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Fundamentals
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gold standard of clinical trials
controlled randomized, double blind
Nuremburg Code 1946
principles for medical research on human subjects
Kefauver Harris Amendment
drug manufactures required to prove to FDA the effectiveness, new safety standards
Declaration of Helsinki
basis of good clinical practices used today
goal of IRB
protect humans
Belmont report
respect for persons, beneficence, justice
respect for persons example
informed consent
beneficence example
risk/benefit analysis - important for IRB approval
justice example
equitable selection of participants
belmont report laws
title 21 Code of federal regulation
current regulations three provisions
definition of drug, definition of new drug, criteria new drugs needs to meet to gain marketing approval
basic concepts of compliance
laws, regulation, guidance (non binding, interpretations)
ICH GCP means
international conference of harmonization good clinical practice
ICH GCP principles
overarching ethical and scientific expectations
CFR means
citations for federal regulations
non-clinical testing
variety of testing to support use in humans
toxicology and FDA
testing must be performed in two species before it can be submitted to FDA
good laboratory practice 7 basic areas
organization, testing facility, facility operation, article characterization, non clinical protocol, records, equipment design
GLP inspections
surveillance/routine, directed (from complaints or questionable data)
investigational new drug application (IND)
drug sponsor alerts FDA of intention to start clinical trials
IND characteristics
request of exemption from federal statute, product of successful preclinical development
IND broad areas
animal pharmacology/toxicology, manufacturing, clinical protocol and investigator info
IND response timeline
FDA has 30 days to respond or sponsor may begin
treatment protocol/IND phase availability
phase 3, can be as early as phase 2
protocol seven elements
objectives, investigator info, patient criteria, dose and duration exposure, study design, observations/measurements, clinical procedure
clinical hold phase
1 (dangerous, unqualified), 2-3 (deficient protocol)
phase 1
20-100 volunteers, pharmacokinetic and pharmacodynamic, initial safety estimate, days to week
phase 2
100-500 volunteers, dosing requirements, study efficacy, more frequently observed side effects, week to months
phase 3
1000-5000 volunteers, pivotal study, long term efficacy and safety, year or longer
drug discovery and development
discovery > preclinical > (IND) > clinical trials > (NDA) > FDA review > scale up manufacturing > post market

NDA objectives
safety and efficacy, drug insert, prove adequate methods, show benefit outweigh risk
NDA adequate product
quality, stability, strength, purity
NDA sections
12- summary, chemistry, clinical data, statistics, case report, FDA356h
NDA clinical data section
most important, complex, largest
NDA expedited options
fast track, breakthrough therapy, accelerated approval
NDA fast track
meet an unmet need or show superior results over current drug for serious illness
NDA breakthrough
show superior promise over current market and effect on clinical endpoint
advisory committees
core members appointed by FDA, 2 experts on drug (can’t vote), no FDA or gov employees
validity of data dependent on
power of the study, need 95% CI
study design objectives
superiority, equivalence, non-inferiority
common study designs
dose escalation, crossover, parallel group, dose range, uncontrolled
common control groups
placebo, dose comparison, no treatment, active, historical
who’s in trouble if study goes wrong
investigator, NOT sponsor
IRB primary objective 21 CFR 56
safeguards rights, safety, and well being of all trial participants
IRB members
min 5, diverse, one with expertise, one lay person (attorney/advocate), one not affiliated
vulnerable participants
prisoners, pregnant women, children, handicapped/disabled, economically/educationally disadvantaged, students, non english speakers
research deviation
no changes without approval from IRB unless eliminates an immediate hazard
Consent lasts from
first interaction to the very last, even after study closes
informed consent (21 CFR 50) describes
foreseeable risks, benefit to participant and others, alternative procedures or treatment, maintain confidentiality, any compensation
consent process
discussion, review, concerns, time, signatures, re-consenting when necessary
physician need consent for
perform surgery, chemo/radiation, blood transfusion, insert surgical device, experimental medication/device/manner
goal of clinical research
good and clean data that can be analyzed to change the standard of care
who is the only one able to exempt a participant from certain criteria
medical monitor
is the medical monitor exemption FDA approved
no, will be flagged in an audit
compensation is
any perception of financial gain
sponsor role
oversight and monitor, set up info needed to conduct study, select investigators, reports and quality assurance
CRO
contract research organization, helps sponsor
monitor role
verify all info, communicate between sponsor and investigators
investigator role
directly responsible for conduct, assemble team, adhere to GCP, budget, consent
What is 1572
contract between physician and FDA to use most current protocol w/o deviation from their patients
study coordinator role
gate keeper of data and records, IRB communication
FDA mission
safety, efficacy, and security of human and veterinary drugs, biological products a medical devices
FDA type I error
risk of approving a drug that is not safe and people are harmed
FDA type II error
delays/prevents approval of a drug that saves lives
how FDA monitors
on site inspections and data audits
consumer safety officer (CSO)
FDA investigator (CI), check signatures and documentations, protocol procedures
Form FDA 482
note of inspection, given to PI and IRB chairperson
Form FDA 483
any significant observations during inspections, 15 days to respond
establishment inspection report (EIR)
no action needed, voluntary action, official action