The Principles of Good Laboratory Practice Applica
The Principles of Good Laboratory Practice Applica
The Principles of Good Laboratory Practice Applica
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3Qualitas, Danworth Lane, Hurstpierpoint, West Sussex BN6 9LN, UK; 4Institute for In
Vitro Science, 21 Firstfield Road, Suite 220, Gaithersburg, MD 20878, USA; 5ECVAM,
Institute for Health and Consumer Protection, European Commission Joint Research Centre,
21020 Ispra (VA), Italy; 6Charles University Faculty of Medicine, Simkova 870, Hradec
Králové, Czech Republic; 7FRAME Alternatives Laboratory, University of Nottingham
Medical School, Queen’s Medical Centre, Nottingham NG7 2UH, UK; 8RCC Cytotest Cell
Research, In den Leppsteinwiessen 19, 64380 Rossdorf, Germany; 9Human and
Environmental Safety Division, The Procter and Gamble Company, Cincinnati, OH, USA;
10ZEBET, BgVV, Diedersdorfer Weg 1, 12277 Berlin, Germany; 11Genetic and In Vitro
Toxicology, Janssen Pharmaceutica, Turnhoutse Weg 30, 2340 Beerse, Belgium
Address for correspondence and reprints: Dr S. Coecke, ECVAM, JRC Institute for Health & Consumer Protec-
tion, 21020 Ispra (VA), Italy.
1ECVAM — European Centre for the Validation of Alternative Methods. 2This document represents the agreed
report of the participants as individual scientists and quality assurance personnel.
540 R. Cooper-Hannan et al.
CONTENTS
PREFACE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 542
1 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 543
6 ACKNOWLEDGEMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 573
7 REFERENCES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 574
PREFACE
This is the report of the thirty-seventh of a series of workshops organised by the European
Centre for the Validation of Alternative Methods (ECVAM). ECVAM’s main goal, as defined
in 1993 by its Scientific Advisory Committee, is to promote the scientific and regulatory
acceptance of alternative methods which are of importance to the biosciences and which
reduce, refine or replace the use of laboratory animals. One of the first priorities set by
ECVAM was the implementation of procedures which would enable it to become well-
informed about the state-of-the-art of non-animal test development and validation, and the
potential for the possible incorporation of alternative tests into regulatory procedures. It was
decided that this would be best achieved by the organisation of ECVAM workshops on specific
topics, at which small groups of invited experts would review the current status of in vitro
tests and their potential uses and make recommendations about the best ways forward (1). In
addition, other topics related to the Three Rs (reduction, refinement, replacement) concept of
alternatives to animal experiments have been considered in several ECVAM workshops.
ECVAM brought together experts in the field of cell culture technology and Good Laboratory
Practice (GLP) to stimulate the use and acceptance of in vitro toxicology data during the human
risk assessment process, at both the European and world levels. The ECVAM workshop on The
Principles of Good Laboratory Practice: Application to In Vitro Toxicology Studies was held in
Angera, Italy, on 6–9 December 1998. The workshop was chaired by Robin Cooper-Hannan
(Qualitas, Hurstpierpoint, UK) and John Harbell (Institute for In Vitro Science, Gaithersburg,
MD, USA), and was attended by cell culture technologists, toxicologists and quality assurance
personnel from industry, academia and government. The aim of the workshop was to discuss
and make recommendations on the application of the OECD Principles of GLP to good quality
cell and tissue culture practices. In addition to reviewing the application of GLP to single-site
and multi-site studies, this document pays specific attention to multi-study in vitro toxicology
trials, including ECVAM’s prevalidation/validation studies which employ blind-coded chemi-
cals. The consensus reached at the workshop was that validation efforts for in vitro toxicology
studies should be carried out under GLP, to facilitate the regulatory acceptance of high quality
validated in vitro tests.
ECVAM Workshop 37: Good Laboratory Practice 543
ted to them. This inquiry resulted in the pro- 1.3 CLAIMING GOOD LABORATORY
duction by the FDA of proposals for GLP reg- PRACTICE COMPLIANCE
ulations in 1976, to provide guidance to test
The requirements of national GLP compli-
facilities for promoting the development of
ance programmes can vary among countries.
quality data. A task force of FDA investiga-
It can be the case that a test facility might
tors was set up to conduct a pilot programme
only be able to claim formal GLP compliance
of inspections. Between 1976 and 1978, the if it is within a compliance programme run
inspectors looked at 98 laboratories (mostly by the relevant national GLP Monitoring
in the USA, but some in Europe) to deter- Authority. It is recommended that a test
mine conformity with the proposed GLP reg- facility should clarify this, as appropriate,
ulations. These investigations showed that with the applicable national GLP Monitoring
the integrity of some studies was open to Authority. Test facilities within a national
question, revealing problems so severe that GLP compliance programme are periodically
studies could not be relied upon for regula- visited by government inspectors who under-
tory decision-making. The conclusion of the take a comprehensive assessment and deter-
FDA’s review of laboratories was that there mine the status of GLP compliance (10).
was an obvious need for improving standards The quality assurance (QA) monitoring of
across industry as a whole. a participating test site in a study, which is
In 1978, the FDA issued the regulations not within a national GLP compliance pro-
specifying the principles of GLP for adequate gramme, might not confer formal GLP com-
safety testing. These regulations became law pliance. If work is conducted in a non-GLP
in the USA in 1979. This established the FDA compliant facility, in support of a GLP study,
as the first government agency to assess labo- consideration should be given to informing
ratory compliance with GLP regulations. In the relevant national GLP Monitoring
1987, the FDA regulations on GLP were Authority. Study reports and trial reports
revised. The FDA’s action stimulated much must clearly identify facilities which do not
interest in the US Environmental Protection adhere to formal GLP, and must address any
Agency (EPA), in other countries and in inter- impact that non-compliance could have had
national organisations such as the OECD. on integrity of the study.
The FDA Principles of GLP provided the
basis for the OECD Principles of GLP pub- 1.4 REGULATORY AND NON-
lished in 1981. These OECD Principles of GLP REGULATORY STUDIES
were set out as an integral part of the OECD
Decision on Mutual Acceptance of Data in the A test facility can conduct both “regulatory
Assessment of Chemicals. The OECD identi- studies”, intended for review by the regulatory
fied three essential elements on which the authorities, and “non-regulatory studies”
mutual acceptance of data can be based, (including test development and fundamental
namely: the application of the OECD Princi- research) which are not intended for submis-
ples of GLP; the establishment of harmonised sion to the regulatory authorities. Where this
national GLP compliance programmes and is the practice in the same GLP area, it will be
guidance for national inspectors in the perfor- necessary for the non-regulatory work to also
mance of inspections and audits; and the use be conducted in compliance with GLP. Essen-
of the OECD Test Guidelines. tially, the main differences between such reg-
Since the OECD Principles of GLP were ulatory and non-regulatory studies is that the
adopted by Member Countries, including the latter can be subject to reduced QA monitor-
European Economic Community (notably via ing and can have fewer specific GLP docu-
Directives 87/18/EEC, 88/320/EEC and mentation requirements.
90/18/EEC), the interpretation of GLP is
essentially the same among OECD Member
Countries (8, 9). After a decade and a half of 2 STUDY ORGANISATION
use, the OECD Member Countries consid-
2.1 SINGLE-SITE STUDIES
ered that there was a need to review and
update the Principles of GLP to account for The original OECD Principles of GLP, issued
scientific and technical progress in the area in 1981, were primarily considered for sin-
of safety testing. This led to the revised gle-site studies (Figure 1). A single-site study
OECD Principles of 1997 (2). is one in which the test facility, the Study
ECVAM Workshop 37: Good Laboratory Practice 545
Director and all study procedures are based Figure 1: Organisation of a single-site
in one location. The Study Director is the study
individual responsible for the overall conduct
of a study. The role of Study Director is of
central importance in GLP (see section on
Study Director’s responsibilities). Each sin- Sponsor
gle-site study, conducted in accordance with
GLP, has one Study Director, one study plan
and one study report.
Sponsor
Management
Quality
assurancea
Study Director
Laboratory 1
aQuality assurance staff will also have communication links with each laboratory.
Dashed lines indicate quality assurance staff involvement.
3.1 TEST FACILITY ORGANISATION terms of GLP. In general, it will be the level of
AND PERSONNEL management which has overall responsibility
for ensuring GLP compliance. The roles of
The Principles of GLP relevant to the test
facility are presented in Table 1A–1C. Test Facility Management, Study Director
and QA manager should each be performed by
3.1.1 Test Facility Management’s different persons, so that there are checks and
responsibilities balances in the overall programme. Test Facil-
ity Management is not the same as the Trial
The Principles of GLP related to Test Facil- Management Team, which has responsibilities
ity Management’s responsibilities are for the overall conduct of a multi-study trial,
shown in Table 1A. and is discussed later in this document.
The primary GLP responsibility of Test
Facility Management is to ensure that a suffi- 3.1.1.1 Study Director
cient number of qualified personnel, and
appropriate facilities, equipment and materi- The Study Director is appointed by Test
als, are available for the timely and proper Facility Management. When appointing a
conduct of studies. The test facility includes Study Director to a study, management
the persons, premises and operational units should be aware of that individual’s current
necessary for the conduct of a study. The test or anticipated workload. The Master Sched-
site is the location(s) at which a phase(s) of a ule, as described below, lists the studies
study is conducted in a multi-site study. It is planned, in progress and completed, and
important to document the name of the per- should be used as a reference when appoint-
son who acts as Test Facility Management, in ing a Study Director.
ECVAM Workshop 37: Good Laboratory Practice 547
Sponsor
Statistics
and should include the lines of reporting and 3.1.1.5 Site plans
communication in the test facility. The chart
Site plans are relevant documents for Test
should identify the main job areas associated
Facility Management, since they can be used
with GLP, and should identify the individu-
to demonstrate that laboratories are well
als who have designated responsibilities with
organised and that there is adequate and
respect to GLP organisation. This includes
the maintenance of lists of individuals who appropriate separation of activities and func-
can be appointed as a Study Director and, tions. Site plans need not be detailed, such as
where appropriate, a list of those individuals in engineering site plans, but they should be
who can be appointed as Principal Investiga- dated and should indicate the main func-
tors. Other positions appropriate for the org- tional areas, such as test item store, formu-
anisation chart are laboratory manager, test lation area and archives. Superseded site
substance controller, Standard Operating plans should be archived.
Procedure (SOP) administrator, archivist
and QA personnel. Superseded organisation 3.1.1.6 Personnel records
charts and superseded lists of designated Test Facility Management must ensure the
Study Directors and Principal Investigators maintenance of a record of the qualifications,
should be retained in the archives. training, experience and job description of
each professional individual with GLP
3.1.1.4 Master Schedule responsibilities. Also, there must be assur-
Reference to the Master Schedule is a useful ance that personnel clearly understand the
means for Test Facility Management to iden- functions they are to perform and, where
tify the allocation of resources. The Master necessary, are provided with training for
Schedule is used to assess the volume of these functions.
work being performed and by which individ- It is usual for the qualifications, together
uals. It also permits an awareness of studies with a brief account of education, employ-
planned, in progress and completed. ment history and experience, to be recorded
The Master Schedule should normally pro- in the form of a curriculum vitae.
vide the following study information: unique Job descriptions will be presented in a
study identification, test system, test item, GLP-compliant manner, if they include job
nature of study, name of Study Director/ title, qualifications and experience necessary
Principal Investigator and start and comple- for the position, reporting relationships and
tion study dates. The inclusion of further an outline of the key objectives of the job
information, such as the date of the issue of position, especially those objectives affecting
the study report and the date of archiving, is GLP. Job descriptions should be signed by
considered appropriate. both employee and manager.
The Master Schedule at the test facility Training is usually documented in the
must show overall dates and the identity of form of an on-going training record listing
the Study Director, whereas a Master Sched- specific tasks which need to be signed off
ule at a test site need only show local dates before an individual can undertake such
and local activities, and the identity of the tasks without direct supervision. Training
relevant Principal Investigator. records are considered to be key GLP docu-
In some test facilities, there is the conduct ments, since they demonstrate those proce-
of both regulatory studies, intended for sub- dures which an individual can undertake.
mission to the regulatory authorities, and One method that can be used by Test Facil-
non-regulatory studies, for example, test ity Management, or the Study Director or
development and fundamental research QA personnel, to determine whether an indi-
studies. Non-regulatory studies can be con- vidual has been trained in a given procedure,
ducted under GLP, but can have a reduced is to check the training record.
amount of QA monitoring and reduced spe- The need for re-training, for example,
cific GLP documentation requirements. after a period of absence or when there have
Where a laboratory has these two types of been procedural and technical revisions,
studies, it is appropriate to identify in the should always be considered.
Master Schedule which are the regulatory Training records should be described in a
studies and which are the non-regulatory Standard Operating Procedure (SOP), which
studies. should address who should have training
ECVAM Workshop 37: Good Laboratory Practice 549
records and who can authorise training The role of Study Director is of fundamen-
records. Training records should be consid- tal importance, and it is the Study Director
ered for all grades of professional staff with who is accountable for ensuring the GLP com-
GLP duties, to at least the level of Study pliance in the conduct of the study and in the
Director. The SOP should describe where the study report. The Study Director is the single
training records are to be located, and should critical point of study control and must
identify that a training record should be for- ensure clear lines of communication between
warded to the archives when an individual the Study Director and study personnel.
no longer has GLP responsibilities. The SOP Before any work on a study is undertaken,
should also outline the documentation for the Study Director should ensure that Test
attendance at courses and conferences. Facility Management have committed ade-
In certain cases, especially for personnel quate resources, that study personnel are ade-
with advanced training, self-education and quately trained, and that the equipment to be
self-certification may be possible. Test Facil- used in the study has been appropriately cali-
ity Management should judge whether and brated and maintained. The Study Director
when this is appropriate. should also ensure that appropriate arrange-
ments have been made for the supply of the test
3.1.1.7 Standard Operating Procedures systems, and test, control and reference items,
It is appropriate for Test Facility Manage- which meet the requirements of the study, and
ment to ensure an individual has been that there are appropriate SOPs for the study.
assigned responsibility for the administra- It is the responsibility of the Study Direc-
tion of the SOP system. Such a role serves tor to approve the study plan, and any
to ensure that SOPs are reviewed at appro- amendments to the study plan, by dated sig-
priate time intervals, that new and revised nature. It is also the Study Director’s respon-
SOPs are authorised and issued in a timely sibility to ensure that copies of the study
manner, that SOPs are appropriately dis- plan, any amendments, and relevant SOPs
tributed, and that a historical file of super- are readily available to personnel, that per-
seded SOPs is maintained. In multi-site sonnel are properly briefed, and that any
studies it might be decided to assign an indi- deviations from the study plan or SOPs are
vidual with SOP responsibilities for ensur- documented and acted upon. The Study
ing the administration and control of Director should ensure that QA personnel
certain SOPs across test sites. SOP admin- have a copy of the study plan, and any
istration of this nature would need to be amendments, in a timely manner and com-
clarified in the study plan. municate effectively with them, as required
during the conduct of the study.
3.1.2 Test Site Management Study Director involvement during the
course of a study should include reviewing pro-
In a multi-site study, Test Site Manage- cedures and data, in order to ensure compli-
ment will have the responsibilities defined ance with the study plan and the SOPs. To
in Table 1A, with the following exceptions: demonstrate the monitoring activities of the
a) the appointment of the Study Director, Study Director, the type and frequency of the
and the replacement of the Study Director, reviews should be documented in the study
if applicable; b) ensuring documented records. The impact of any deviations from the
approval of the study plan by the Study study plan on the quality and integrity of the
Director; c) ensuring that the Study Direc- study should be assessed and appropriate cor-
tor has made the approved study plan avail- rective action should be taken, if necessary.
able to the QA personnel; and d) ensuring The Study Director should acknowledge all
that clear lines of communication exist deviations from SOPs during the conduct of
between the Study Director, Principal the study.
Investigator(s), study personnel and QA The Study Director must sign and date the
personnel.
study report to indicate acceptance of
responsibility for the validity of the data and
3.1.3 Study Director’s responsibilities
that the study report accurately reflects the
The Principles of GLP relevant to the Study work conducted and all the results obtained.
Director’s responsibilities are shown in The Study Director should ensure that all
Table 1B. relevant raw data and records are properly
550 R. Cooper-Hannan et al.
1. Each Test Facility Management should ensure that the Principles of Good Laboratory
Practice are complied with in its test facility.
2. At a minimum it should:
a) ensure that a statement exists which identifies the individual(s) within a test facility
who fulfils the responsibilities of management as defined by these Principles of Good
Laboratory Practice;
b) ensure that a sufficient number of qualified personnel, appropriate facilities, equip-
ment and materials are available for the timely and proper conduct of the study;
c) ensure the maintenance of a record of the qualifications, training, experience and job
description for each professional and technical individual;
d) ensure that personnel clearly understand the functions they are to perform and, where
necessary, provide training for these functions;
e) ensure that appropriate and technically valid Standard Operating Procedures are
established and followed, and approve all original and revised Standard Operating Pro-
cedures;
f) ensure that there is a Quality Assurance programme with designated personnel, and
assure that the Quality Assurance responsibility is being performed in accordance with
these Principles of Good Laboratory Practice;
g) ensure that for each study an individual with the appropriate qualifications, training
and experience is designated by the management as the Study Director before the
study is initiated. Replacement of a Study Director should be done according to estab-
lished procedures, and should be documented;
h) ensure, in the event of a multi-site study, that, if needed, a Principal Investigator is
designated who is appropriately trained, qualified and experienced to supervise the
delegated phase(s) of the study. Replacement of a Principal Investigator should be
done according to established procedures, and should be documented;
i) ensure documented approval of the study plan by the Study Director;
j) ensure that the Study Director has made the approved study plan available to the
Quality Assurance personnel;
k) ensure the maintenance of a historical file of all Standard Operating Procedures;
l) ensure that an individual is identified as responsible for the management of the
archive(s);
m) ensure the maintenance of a master schedule;
n) ensure that test facility supplies meet requirements appropriate to their use in a study;
o) ensure for a multi-site study that clear lines of communication exist between the Study
Director, Principal Investigator(s), the Quality Assurance programme(s) and study
personnel;
p) ensure that test, reference and control items are appropriately characterised;
q) establish procedures to ensure that computerised systems are suitable for their
intended purpose, and are validated, operated and maintained in accordance with
these Principles of Good Laboratory Practice.
3. When a phase(s) of a study is conducted at a test site, test site management (if appointed)
will have the responsibilities as defined above with the following exceptions: 2g, 2i, 2j and
2o.
maintained, to ensure data integrity, and tively carry out the technical phase of the
that upon completion, or termination, of the study in conformance with the study plan,
study, these records are transferred in a applicable SOPs, the Principles of GLP and
timely manner to the archives. the specific technical requirements. It must
be noted that, although a Study Director can
3.1.4 Principal Investigator and study delegate duties to a Principal Investigator,
personnel the Study Director’s responsibilities cannot
be delegated.
3.1.4.1 Principal Investigator
There should not be a need to appoint a
The Principles of GLP related to the Princi- Principal Investigator to work on the study
pal Investigator are shown in Table 1C. at the Study Director’s geographical and
In a multi-site study, it is unreasonable to managerial location.
expect a Study Director to maintain direct The Principal Investigator should indicate
supervision over all test sites. Therefore, it is acceptance of the study plan, and any
appropriate to have a Principal Investigator amendments to the study plan, by dated sig-
appointed at test sites which are remote nature. Management and sponsor dated sig-
from the Study Director. The Principal natures should be provided, as appropriate.
Investigator must be an appropriately quali- In a situation where a Principal Investiga-
fied individual at the test site, who can effec- tor undertakes a specialist activity, the Prin-
1. The Study Director is the single point of study control and has responsibility for the over-
all conduct of the study and for its study report.
2. These responsibilities should include, but not be limited to, the following functions. The
Study Director should:
a) approve the study plan and any amendments to the study plan by dated signature;
b) ensure that the Quality Assurance personnel have a copy of the study plan and any
amendments in a timely manner and communicate effectively with the Quality Assur-
ance personnel as required during the conduct of the study;
c) ensure that study plans and amendments and Standard Operating Procedures are
available to study personnel;
d) ensure that the study plan and the study report for a multi-site study identify and
define the role of any Principal Investigator(s) and any test facilities and test sites
involved in the conduct of the study;
e) ensure that the procedures specified in the study plan are followed, and assess and doc-
ument the impact of any deviations from the study plan on the quality and integrity of
the study, and take appropriate corrective action if necessary; acknowledge deviations
from Standard Operating Procedures during the conduct of the study;
f) ensure that all raw data generated are fully documented and recorded;
g) ensure that computerised systems used in the study have been validated;
h) sign and date the study report to indicate acceptance of responsibility for the validity
of the data and to indicate the extent to which the study complies with these Princi-
ples of Good Laboratory Practice;
i) ensure that after completion (including termination) of the study, the study plan, the
study report, raw data and supporting material are archived.
cipal Investigator can prepare, if necessary, enable the Study Director to write the study
an amendment to the study plan, in consul- report. The Principal Investigator should
tation with the Study Director. However, the include a signed GLP compliance statement
Study Director must be responsible for the confirming compliance with GLP, or indicat-
numbering, approval and issue of all study ing clearly where there were any deviations
plan amendments. All study plan amend- from GLP.
ments should be issued to all recipients of If study documents and/or materials are to
the original study plan. be archived locally, the archiving arrange-
The Principal Investigator is responsible for ments should be confirmed in the contribu-
ensuring that QA personnel are kept informed tory report.
about study activities for which the Principal
Investigator is responsible, so that QA person- 3.1.4.2 Study personnel
nel can plan the inspection schedule. It is also All study personnel involved in the conduct
necessary for the Principal Investigator to of the study must be knowledgeable in the
respond, in a timely manner, to QA reports. aspects of the Principles of GLP which are
On completion of a Principal Investigator’s applicable to their involvement in the study,
study activity, the Principal Investigator and should be sure they are undertaking
should sign and date the contributory report, only duties in which they have been ade-
to confirm that it accurately reflects the work quately trained (Table 1C).
conducted and all the results obtained. Suffi- Study personnel should have ready access
cient commentary should be included to to the study plan and relevant SOPs. It is
The Principal Investigator will ensure that the delegated phases of the study are conducted
in accordance with the applicable Principles of Good Laboratory Practice.
1. All personnel involved in the conduct of the study must be knowledgeable in those parts
of the Principles of Good Laboratory Practice which are applicable to their involvement in
the study.
2. Study personnel will have access to the study plan and appropriate Standard Operating
Procedures applicable to their involvement in the study. It is their responsibility to com-
ply with the instructions given in these documents. Any deviation from these instructions
should be documented and communicated directly to the Study Director, and/or if appro-
priate, the Principal Investigator(s).
3. All study personnel are responsible for recording raw data promptly and accurately and in
compliance with these Principles of Good Laboratory Practice, and are responsible for the
quality of their data.
4. Study personnel should exercise health precautions to minimise risk to themselves and to
ensure the integrity of the study. They should communicate to the appropriate person any
relevant known health or medical condition in order that they can be excluded from oper-
ations that may affect the study.
ECVAM Workshop 37: Good Laboratory Practice 553
their responsibility to comply with the compliance programme, but which is partici-
instructions given in these documents. Any pating in a GLP study, increased QA monitor-
deviations from these instructions should be ing of that laboratory should be considered.
documented and communicated directly to Inspections of facilities, procedures and
the Study Director and/or, if appropriate, to study reports result in QA reports, which are
the Principal Investigator. forwarded to relevant study personnel,
All study personnel are responsible for including the Study Director and Test Facil-
recording raw data promptly and accurately ity Management. QA reports should be seen
and in compliance with GLP, and are respon- as a way of promoting awareness of GLP
sible for the quality of their data. issues. There should be an agreed time-
Study personnel should take the necessary frame for recipients to respond to QA
personal and health precautions to avoid any reports, for example, within 2 weeks. Signif-
contamination of test systems and test items, icant findings should be reported, and
and should take adequate safety precautions responses should be made, as quickly as pos-
when handling materials of known, or sible.
unknown, hazard. QA personnel should prepare and sign a
QA statement for inclusion in the study
3.2 QUALITY ASSURANCE report. The QA statement specifies the
inspections undertaken, their dates, and the
The Principles of GLP specific to QA are pre-
dates when the QA findings were reported.
sented in Table 2. The establishment and
This statement also serves to confirm that
effective operation of a QA programme is a
the study report reflects the raw data. The
requirement of GLP and is one of the princi-
QA statement is usually presented as a
pal means by which study personnel, Man-
stand-alone document, within the study
agement, sponsors and ultimately the
report, to confirm the independence of QA.
regulatory authorities are assured of the
GLP compliance status of studies. The QA
3.3 FACILITIES
function is based on organisational, rather
than scientific, procedures. Therefore, QA The Principles of GLP specific to facilities
does not interfere with the technical and sci- are presented in Table 3. The basic require-
entific conduct of studies. ments for facilities will be dictated by the
Test Facility Management has ultimate types of test systems employed and the types
responsibility for compliance with the Prin- of studies to be performed. Facilities include
ciples of GLP. This includes the appointment all of the buildings, individual room(s) and
and effective organisation of a QA function. equipment provided to maintain the speci-
Persons undertaking QA activities must be fied, controlled environment for the test sys-
independent of the studies inspected, and tem(s). Initial quarantine, diagnosis/
should report to a level of management treatment of disease, maintenance before
where the overall responsibility for GLP and after treatment with the test item, and
resides. In small facilities, it might not be isolation from external disturbances, must
feasible to maintain full-time QA personnel. be provided. External disturbances might
However, Management must appoint at least come in the form of contamination from
one individual to have permanent, albeit other studies/test systems (across species),
part-time, coordination of QA. Management dust from the preparation of test or control
can contract out the QA function, so the QA items for dosing (for example, dose feed
function need not be in-house. preparation, treatment or harvest of individ-
QA inspections include reviews of proce- ual test subjects, environmental sources
dures to assure compliance with the study such as noise, light and bioburden). A test
plan, SOPs and the Principles of GLP. They facility appropriate for one type of test sys-
pay attention to the flow of information and tem might be wholly insufficient for another.
the chain of custody of samples and data GLP was originally developed for facili-
across interfaces. This is particularly relevant ties in terms of rooms or areas (portion of
to multi-site studies, where it is necessary to a room), since those units are appropriate
coordinate QA activities across sites, to ensure for most in vivo studies where test systems
that all critical phases and interfaces are sub- are exposed to room air, so environmental
ject to QA monitoring. In the case of a labora- conditions for maintenance and isolation
tory that is not within a national GLP need to be directed at that level. In con-
554 R. Cooper-Hannan et al.
2.1 General
1. The test facility should have a documented Quality Assurance programme to assure that
studies performed are in compliance with these Principles of Good Laboratory Practice.
3. Such individuals should not be involved in the conduct of the study being assured.
1. The responsibilities of the Quality Assurance personnel include, but are not limited to, the
following functions. They should:
a) maintain copies of all approved study plans and Standard Operating Procedures in use
in the test facility and have access to an up-to-date copy of the Master Schedule;
b) verify that the study plan contains the information required for compliance with these
Principles of Good Laboratory Practice. This verification should be documented;
c) conduct inspections to determine whether all studies are conducted in accordance with
these Principles of Good Laboratory Practice. Inspections should also determine that
study plans and Standard Operating Procedures have been made available to study
personnel and are being followed. Inspections can be of three types as specified by
Quality Assurance programme Standard Operating Procedures: i) study-based inspec-
tions; ii) facility-based inspections; and iii) process-based inspections. Records of such
inspections should be retained;
d) inspect the study reports to confirm that the methods, procedures and observations
are accurately and completely described, and that the reported results accurately and
completely reflect the raw data of the studies;
e) promptly report any inspection results in writing to management and to the Study
Director, and to the Principal Investigator(s) and the respective management, when
applicable;
f) prepare and sign a statement, to be included with the study report, which specifies
types of inspections and their dates, including the phase(s) of the study inspected, and
the dates inspection results were reported to management and the Study Director and
Principal Investigator(s), if applicable. This statement would also serve to confirm that
the study report reflects the raw data.
trast, most in vitro (especially cell and the flasks, tubes or plates in which it is
organ culture) systems are manipulated in grown or treated. Therefore, modifications
vertical laminar flow biological safety cabi- are necessary to the wording of the OECD
nets to protect both the test system and Principles of GLP for facilities conducting
the operator. The test system is main- in vitro studies. The addition of the term
tained within an incubator, which provides “or equipment” in the facilities’ require-
the required environmental conditions. It ments is intended to remedy this situation
is further isolated from other cultures by (Table 3).
ECVAM Workshop 37: Good Laboratory Practice 555
Table 3: Facilities
3.1 General
1. The test facility should be of suitable size, construction and location to meet the
requirements of the study and to minimise disturbance that would interfere with the
validity of the study.
2. The design of the test facility should provide an adequate degree of separation of the
different activities to assure the proper conduct of each study.
1. The test facility should have a sufficient number of rooms, areas or appropriate
equipment (for example, biological safety cabinets) to assure the isolation of test
systems and the isolation of individual projects, involving substances or organisms
known to be or suspected of being, biohazardous.
3. There should be storage rooms or areas as needed for supplies and equipment. Storage
rooms, areas or equipment should be separated from rooms, areas or equipment
housing the test systems and should provide adequate protection against infestation,
contamination, and/or deterioration
2. Storage rooms, areas or storage cabinets for the test, reference and control items
should be separate from rooms, areas, or storage equipment containing the test sys-
tems. They should be adequate to preserve identity, concentration, purity and stability,
and ensure safe storage for hazardous substances.
Table 3: continued
Archive facilities should be provided for the secure storage and retrieval of study plans,
raw data, study reports, samples of test items and specimens. Archive design and archive
conditions should protect contents from untimely deterioration.
Handling and disposal of wastes should be carried out in such a way as not to jeopardise
the integrity of studies. This includes provision for appropriate collection, storage and dis-
posal facilities, and decontamination and transportation procedures.
The handling of test, reference and control in order to introduce a general GLP working
items (7) for an in vitro study is generally practice among all laboratory personnel (for
performed in containment equipment to pro- example, for weighing, labelling and calibra-
tect the items and the operator. The volumes tion).
of sample being prepared are quite small Personnel should not undertake activities
compared to those used in many in vivo stud- within a GLP area unless they have been
ies. Changes to Table 3 focus on the need for trained in the appropriate GLP require-
the absence of contamination and mix-up, ments. The presence of both GLP and non-
and reflect the facilities used for in vitro GLP activities within the same facility
studies and the volumes of material to be requires constant vigilance on the part of
manipulated. Test Facility Management, Study Directors,
There should be adequate storage facilities supervisors and QA personnel, to ensure
for supplies and equipment (for example, continual GLP compliance.
refrigerators, freezers, cryopreservators, The GLP practices in the non-regulatory
ventilated cabinets, storage rooms). Storage studies must not run counter to those for the
facilities should be adequately separated regulatory studies. For example, cell cultures
from the test system and should provide ade- associated with a non-regulatory study
quate protection against infestation, contam- placed in a GLP-compliant incubator must
ination, and/or deterioration. have the same labelling and freedom from
Some facilities work with dedicated GLP adventitious agents as those used for the
and non-GLP areas, while others will con- GLP studies.
duct both regulatory and non-regulatory
studies within a single GLP-compliant area. 3.4 APPARATUS, MATERIAL AND
If a test facility carries out both regulatory REAGENTS
and non-regulatory studies, it is essential The Principles of GLP specific to this area
that the GLP compliance of the regulatory are presented in Table 4. Procedures on how
studies is not compromised by the non-regu- apparatus is inspected, cleaned, maintained
latory studies. and calibrated must conform to the needs of
Management must clearly establish poli- the study plan and SOPs. This conformity
cies and procedures which preclude compro- must be documented as raw data.
mising the GLP compliance of regulatory The apparatus used to maintain test sys-
studies by non-regulatory studies. If a test tem isolation and environment is particu-
facility does have dedicated GLP and non- larly critical for in vitro studies. For
GLP areas, a base level of GLP compliance example, a study plan should specify an
for the complete facility could be established, acceptable temperature range for the incuba-
ECVAM Workshop 37: Good Laboratory Practice 557
tor. The incubator must be able to conform for maintaining and controlling the system.
to that range, and a record of the monitoring The raw data for each computer system
must be maintained. There will usually be should be defined, and the system design
several parameters that should be main- should always provide for the retention of
tained and documented daily (temperature, audit trails, to show all changes to data,
humidity, CO2 concentrations), and others without obscuring the original data. Respon-
which can be assessed and documented peri- sibilities for computer systems must be
odically (cleaning and bioburden). clearly defined before a study begins.
Clearly, the quality of the apparatus must The focus of the acceptance testing effort
meet the expected and established levels of should be on the application(s) being used,
accuracy and precision. The specific require- rather than on the computer system itself.
ments for a certain piece of apparatus (for That is, do the hardware and software
example, frequency of cleaning or calibra- together produce the desired result when
tion) might not be the same in all laborato- challenged by rigorous testing with known
ries or for all assay systems. Management data sets? For example, a spreadsheet might
and the Study Director should establish be prepared to manipulate data in a study.
appropriate requirements. As a minimum The performance of that spreadsheet, for its
requirement, the manufacturer’s specifica- intended purpose, would be tested and docu-
tions should be met. The implementation of mented, rather than an attempt to evaluate
a monitoring/calibration programme is rec- an entire commercial spreadsheet program.
ommended. Any data transfer steps between platforms
The acceptance testing of new, or changed, and any direct data capture functions from
computer systems for data capture, manipu- instrumentation would be included in the
lation and storage is complex, involving both evaluation. In such cases, it will be essential
hardware and software components, and to define precisely the form of the raw data.
should be conducted and documented in a If the raw data are in the form of an elec-
GLP-compliant manner. Before a computer tronic file, electronic signatures and date
system is used for GLP studies, it must be stamps must meet GLP standards, as
demonstrated that it is suitable for its defined by the appropriate regulatory
intended use and that there are procedures authorities.
1. Apparatus, including validated computerised systems, used for the generation, storage
and retrieval of data, and for controlling environmental factors relevant to the study,
should be suitably located and of appropriate design and adequate capacity.
3. Apparatus and materials used in a study should not interfere adversely with the test sys-
tems.
4. Chemicals, reagents and solutions should be labelled to indicate identity (with concentra-
tion if appropriate), expiry date and specific storage instructions. Information concerning
source, preparation date and stability should be available. The expiry date may be
extended on the basis of documented evaluation or analysis.
The requirement that the apparatus and This requirement is similar to documenta-
materials used in a study do not interfere tion of the origin and basic health of an in
with a test system is also critical for in vitro vivo test system.
studies. As study plans, and equipment In vitro test systems are often propagated
maintenance, cleaning and decontamination within test facilities. Both prokaryotic and
procedures (i.e. SOPs) are developed, consid- eukaryotic systems can be expanded and
eration must be given to avoidance of the banked to provide a continuous source of
introduction of chemical residues, tempera- material. Since the study plan will have been
ture fluctuations or other environmental fac- prepared with certain expectations of the
tors which will affect the test system. For test system and specific performance criteria
example, consideration must be given to the for the assay (see section 3.8), the test sys-
effects of bright sunlight on culture media, tem must be maintained in such a way as to
or of incubator vibration on cell culture uni- promote stability over time. Test system
formity. maintenance and propagation should be
The labelling of chemicals, reagents and addressed in the planning of a study (or
solutions, including commercially prepared study type) and documented in sufficient
media and reagent solutions, should be con- detail for the critical elements required to
ducted in such a way as to ensure compliance maintain stability to be included. Records of
with GLP requirements. Revised labelling test system maintenance should also include
should be prepared when appropriate; for all critical elements.
example, supplementation of a medium with Characterisation of the in vitro test system
a labile component could change the expiry is of the utmost importance. The handling of
date. in vitro systems is perhaps more critical than
that of in vivo systems. The following points
3.5 TEST SYSTEMS should be considered.
The Principles of GLP in relation to test sys- 1. Proper conditions should be established
tems are presented in Table 5. Several addi- and maintained for the storage, handling
tions to this table have been made, which are and care of test systems, in order to
directed toward cell/tissue culture systems. ensure the quality of the data. High qual-
These address the needs to authenticate the ity cell and tissue culture practices and
origin of the test system, its freedom from good aseptic techniques, which are an
adventitious agents and its condition upon essential part of in vitro work, should be
arrival. Also, within the facility, the test sys- enforced.
tem must be propagated and maintained in
2. Characterisation of the test system is
order to preserve its biological integrity for
necessary, to ensure that it is what it
its intended application.
claims to be, and any significant changes
Many in vitro test systems are not directly
in the test system should be evaluated.
isolated by the facility from the original
species and tissue of origin, but are cell lines 3. Newly received test systems should be
obtained from other sources. In some cases, controlled for their purity, lack of contam-
the primary isolation might have occurred ination, suitability and identity. Until the
several decades earlier. In other cases, par- test system has met these pre-defined cri-
ticularly with human cells and tissues, the teria, it should not be used in GLP-com-
donor records are not available to the end- pliant studies and should be appropriately
user of the test system. Thus, the agency treated or destroyed. Any future contami-
(cell repository or commercial source) pro- nation or defects which could affect the
viding the test system might be the primary quality of the data should be investigated,
source of data on the species and tissue of and the test system returned to quaran-
origin. It might also provide data on any tine until it is “cleared”. When beginning
tests performed to demonstrate the absence the experimental work in a study, the test
of adventitious agents and the purity system should be free of any contamina-
(species and tissue type) of the test system. It tion or defects, or any conditions which
is essential that the test facility is able to might interfere with the purpose or con-
trace the lineage of the test system to its duct of the study. Test systems that do not
immediate source and to document the han- conform (for example, those with contam-
dling of that system within the test facility. ination, defects) during the course of a
ECVAM Workshop 37: Good Laboratory Practice 559
5.1 Physical/Chemical
1. Apparatus used for the generation of physical/chemical data should be suitably located
and of appropriate design and adequate capacity.
5.2 Biological
1. Proper conditions should be established and maintained for the storage, housing, handling
and care of biological test systems, in order to ensure the quality of the data.
3. The origin (for example, species and tissue), source, arrival condition and
maintenance requirements of the in vitro test system should be documented.
4. Biological test systems should be acclimatised to the test environment for an adequate
period before the first administration/application of the test, reference or control item.
5. All information needed to properly identify the test systems should appear on their hous-
ing or containers. Individual test systems that are to be removed from their housing or
containers during the conduct of the study should bear appropriate identification, wher-
ever possible.
6. During use, housing or containers for test systems should be cleaned and sanitised at
appropriate intervals. Any material that comes into contact with the test system should
be free of contaminants at levels that would interfere with the study. Bedding for animals
should be changed as required by sound husbandry practice. Use of pest control agents
should be documented.
7. Test systems used in field studies should be located so as to avoid interference in the study
from spray drift and from past usage of pesticides.
Recommended additions to the text are in bold and underlined. Recommended deletions are in
italics and underlined.
560 R. Cooper-Hannan et al.
1. Records including test, reference and control item characterisation, date of receipt,
expiry date, and quantities received and used in studies should be maintained.
2. Handling, sampling and storage procedures should be identified in order that the homo-
geneity and stability are assured to the degree that possible contamination or mix-up are
precluded.
3. Storage container(s) should carry identification information, expiry date and specific stor-
age instructions.
6.2 Characterisation
1. Each test, reference and control item should be appropriately identified (for example,
code, Chemical Abstracts Service Registry Number [CAS number], name, biological para-
meters).
2. For each study, the identity, including batch number, purity, composition, concentrations
or other characteristics to appropriately define each batch of the test, reference or con-
trol items should be known.
3. In cases where the test, reference or control item is supplied by the sponsor, there
should be a mechanism, developed in cooperation between the sponsor and the test facil-
ity, to verify the identity of the test item subject to the study, as appropriate.
4. The stability of test, reference and control items under storage and test conditions
should be known for all studies.
5. If the test, reference or control item is administered or applied in a vehicle, the homo-
geneity, concentration and stability of the test item in that vehicle should be determined,
as appropriate. For test items used in field studies (for example, tank mixes), these may
be determined through separate laboratory experiments.
6. A sample from each batch should be retained for analytical purposes for all studies except
short-term studies.
Recommended additions to the text are in bold and underlined. Recommended deletions are in
italics and underlined.
be responsible for characterisation and for provide some information directly to the
providing the laboratory with sufficient laboratory if there is a particular hazard
information to handle the test and refer- which must be addressed. Safety instruc-
ence items appropriately. Laboratory safety tions (for example, material safety data
is also an issue when testing coded materi- sheets) may be sent to the laboratory safety
als. It is common practice for the sponsor to officer or another appropriate agency (for
562 R. Cooper-Hannan et al.
example, a poisons control centre) in a SOPs which are the primary reference for
sealed envelope which is opened only in the the study. In multi-site studies, it may be
case of an emergency (spill or exposure). It helpful for the lead laboratory to provide
is important that the supplier of the blind study SOPs to the other laboratories. This
coded materials takes on these responsibil- reduces the workload and helps to assure
ities and provides sufficient information to greater uniformity in procedures among the
help ensure that the handling of the test participating laboratories.
items under code does not affect the out-
come of the study. 3.8 PERFORMANCE OF THE STUDY
This section includes discussion on the study
3.7 STANDARD OPERATING
plan and performance of a study. The Princi-
PROCEDURES
ples of GLP specific to this area are pre-
The Principles of GLP specific to SOPs are sented in Table 8.
presented in Table 7. SOPs are the written
body of procedures that govern the proce- 3.8.1 Controls and acceptance criteria
dural aspects of the GLP-compliant labora-
One of the major additions to the Principles
tory. They should address all the categories
of GLP proposed by the workshop is the con-
listed in Table 7. Collectively, they should set
cept of assay acceptance criteria for end-
the standards by which the test facility oper-
points (Table 8).
ates, reflecting the expectations of Test
The responses of a test system to control
Facility Management, the Study Director,
items usually provides the basis for deter-
and QA.
mining the acceptability of an assay. In
The procedure for preparing, distributing
some assays, both negative and positive
and maintaining SOPs should be addressed
control items are used to determine accep-
in an SOP. This SOP should describe SOP
tance. In other assays, only positive control
format, including section headings and sec-
responses are used. The observed positive
tion numbering, in order to promote consis-
control response is compared to historical
tency. SOPs can be written by a variety of
values for the assay to determine whether
authors, reflecting the expertise of many
or not the response falls within the prede-
individuals within the organisation. In
fined limits given in the study plan’s accep-
turn, the SOPs should be reviewed and ulti-
tance criteria. The range of acceptable
mately approved by the appropriate signa-
values is generally derived as a function of
tory.
the historical mean and standard deviation
SOPs are controlled to ensure that only
for the controls. They must also address
current authorised SOPs are available.
the required precision of the assay. Ideally,
Given that they are controlled documents, it
each endpoint in an assay should be
is appropriate for every SOP page to have the
addressed by a positive control and have an
SOP identifier and version number. Manage-
acceptable range of values. The perfor-
ment should ensure that a responsible indi-
mance of the controls also allows compari-
vidual has been assigned, such as an SOP
son of an assay’s performance in different
administrator, who is accountable for ensur-
laboratories and over time.
ing that SOPs are current, authorised,
appropriately distributed, and reviewed on a
3.8.2 Study preparation
regular basis.
A copy of each superseded or withdrawn Before the commencement of a study, it can
SOP should be maintained in a designated be useful for the Study Director to have a
archive. In this manner, when reconstruct- pre-study meeting to discuss the proposed
ing studies, the SOPs which were current at study plan. Such a meeting should clarify
the time of a study can be referenced. communications throughout the study. The
If common SOPs are to be issued to all lab- establishment of open, two-way communica-
oratories in a multi-site study, it is necessary tion between the Study Director and study
to establish, before beginning the study, how personnel is essential to the proper control of
SOPs are to be authorised, issued and even- a study. In addition to a discussion of the
tually archived. Where there are differences study plan, such a meeting can include prac-
between a study plan and SOPs, it should be tical demonstrations of applicable tech-
clarified whether it is the study plan or the niques.
ECVAM Workshop 37: Good Laboratory Practice 563
7.1 A test facility should have written Standard Operating Procedures approved by Test Facil-
ity Management that are intended to ensure the quality and integrity of the data generated
by that test facility. Revisions to Standard Operating Procedures should be approved by
Test Facility Management.
7.2 Each separate test facility unit or area should have immediately available current Standard
Operating Procedures relevant to the activities being performed therein. Published text
books, analytical methods, articles and manuals may be used as supplements to these Stan-
dard Operating Procedures.
7.3 Deviations from Standard Operating Procedures related to the study should be docu-
mented, and should be acknowledged by the Study Director and Principal Investigator(s),
as applicable.
7.4 Standard Operating Procedures should be available for, but not be limited to, the following
categories of test facility activities. The details given under each heading are to be consid-
ered as illustrative examples.
Recommended additions to the text are in bold and underlined. Recommended deletions are in
italics and underlined.
564 R. Cooper-Hannan et al.
1. For each study, a written plan should exist prior to the initiation of the study. The study
plan should be approved by dated signature of the Study Director and verified for GLP com-
pliance by Quality Assurance personnel as specified in Table 2. The study plan should also
be approved by the Test Facility Management and the sponsor, if required by national reg-
ulation or legislation in the country where the study is being performed.
2. a) Amendments to the study plan should be justified and approved by dated signature
of the Study Director and maintained with the study plan.
b) Deviations from the study plan should be described, explained, acknowledged and
dated in a timely fashion by the Study Director and/or Principal Investigator(s) and
maintained with the study raw data.
The study plan should contain, but not be limited to, the following information.
1. Identification of the study, the test item(s), reference item(s), negative control item(s),
and positive control item(s):
a) a descriptive title;
b) a statement which reveals the nature and purpose of the study;
c) identification of the test item(s) by code or name (IUPAC; CAS number, biological para-
meters, etc.);
d) the reference item(s) to be used (if applicable);
e) negative control item(s);
f) positive control item(s).
3. Dates:
a) the date of approval of the study plan by signature of the Study Director. The date of
approval of the study plan by signature of the test facility management and sponsor if
required by national regulation or legislation in the country where the study is being
performed;
b) the proposed experimental starting and completion dates.
4. Test methods.
Reference to the OECD Test Guideline or other test guideline or method to be used.
Table 8: continued
6. Records.
A list of records to be retained, including their location.
1. A unique identification should be given to each study. All items concerning this study
should carry this identification. Specimens from the study should be identified to confirm
their origin. Such identification should enable traceability, as appropriate for the speci-
men and study.
3. All data generated during the conduct of the study should be recorded directly, promptly,
accurately and legibly by the individual entering the data. These entries should be signed
or initialled and dated.
4. Any change in the raw data should be made so as not to obscure the previous entry, should
indicate the reason for change, and should be dated and signed or initialled by the indi-
vidual making the change.
5. Data generated as a direct computer input should be identified at the time of data input
by the individual(s) responsible for direct data entries. Computerised system design
should always provide for the retention of full audit trails to show all changes to the data
without obscuring the original data. It should be possible to associate all changes to data
with the persons having made those changes, for example, by use of timed and dated (elec-
tronic) signatures. Reason for changes should be given.
the raw data to be obtained, the manipula- bered, indicate the reason for the change,
tions of the raw data to produce the study and include the dated signature of the Study
endpoint values, the interpretation scheme Director and, if applicable, those of the Prin-
for endpoints, and the acceptance criteria for cipal Investigators and Test Facility Man-
the study. The study plan must be written in agement. All amendments should be
such a way as to preclude misinterpretation distributed to all recipients of the original
by the study personnel. This requirement is study plan.
particularly important when more than one
laboratory will use the same study plan. 3.8.5 Notes to file
In a multi-site study, the study plan
A note to file provides a means of recording
should include the name and address of the
study information, such as a study plan devi-
Principal Investigator, the location of the
ation. Notes to file can be initiated by any
test site(s), the study-part(s) performed, the
study personnel, but should be acknowl-
methods and statistical parameters used, the
edged by the Study Director, who should
location where the documentation relating to
approve any corrective action and decide
the part for which the Principal Investigator
upon the recipients of notes to file. Sequen-
is responsible is archived, the GLP regula-
tial numbering of notes to file assists study
tions followed (according to national require-
control. Significant deviations from the
ments), and any time schedules necessary for
study plan might be best documented as
the conduct of the study. A study plan
study plan amendments.
amendment will be necessary if a new Prin-
cipal Investigator and new test site become
3.8.6 Raw data
involved in the study. The study plan should
include procedures for the recording of study Study personnel must have a clear under-
data to ensure consistency of data recording standing of what constitutes raw data. The
at all of the sites in a multi-site study, and to definition of raw data (see Appendix 1) must
meet the requirements of data management. be documented.
In addition to the study plan which identi- Raw data records should enable the recon-
fies the records to be retained or archived, it struction of the study. They should also be
is also appropriate to address at which loca- able to explain who did what, when, by what
tions archived records will be kept. means, why and where. To do so, data must
The study plan becomes an authorised be generated completely, accurately, legibly
document when it is signed by the Study and promptly. Entries should be signed or
Director, Test Facility Management and the initialled and dated. Corrections should be
sponsor, if applicable. The study plan should made without obscuring the original entry.
be distributed to study personnel and QA Corrections should also be dated and signed,
personnel, who need to be informed of stud- and the reason for the correction should be
ies so that QA inspections can be planned. given. Raw data not only involve study-spe-
Obtaining signatures in a multi-site study cific documentation (performance of a
can be a lengthy process. It might be accept- study), but also the more general records
able, subject to written procedures, for fac- concerning apparatus, material and
similied signatures to be used in order to reagents, and handling of test, control and
allow the study plan and amendments to be reference items and of test systems. During a
issued in a timely manner. study, raw data should be maintained in safe
A study plan is distinct from the trial plan, storage areas prior to transfer to archives for
which is specific to multi-study trials and is long-term secure retention.
discussed later.
3.8.7 Quality control
3.8.4 Study plan amendments
The conduct of the study should include
If a change to the original study plan is pro- quality control (QC) steps, undertaken by
posed, a study plan amendment should be study personnel, as described in SOPs. QC
issued before the change occurs. An amend- steps should be undertaken when there is a
ment may also be issued as a result of unex- need for verification, especially at a data
pected occurrences during a study, which interface. For example, manual entry of raw
will require significant action. Study plan data should be checked by another study
amendments should be sequentially num- member. If the data being checked are criti-
ECVAM Workshop 37: Good Laboratory Practice 567
cal, i.e. one error in the data could affect sented in the study report, which is a distinct
study integrity, all such data should be con- and separate record of QA study monitoring.
sidered for checking. If the data being The Study Director should authorise and
checked are non-critical, consideration can sign any subsequent corrections and/or addi-
be given to checking samples of data (for tions to the study report.
example, a sample from each analytical
batch). 3.10 STORAGE AND RETENTION OF
RECORDS AND MATERIALS
3.8.8 Confidentiality issues
The principles of GLP specific to records are
In multi-site studies, it should be ensured presented in Table 10.
in advance that confidentiality issues will On completion of a study, the Study Direc-
not impede the flow of information between tor is responsible for ensuring that all study
institutions. It may be appropriate for data are transferred in a timely manner to
study personnel to sign confidentiality the archives, as described in the study
statements. report. If study data are archived at several
locations, it should be remembered that, if
3.9 REPORTING OF STUDY RESULTS the study is subject to regulatory audit, it
could be necessary, at short notice, for all
The Principles of GLP specific to the report-
study data to be transferred to one location
ing of study results are presented in Table 9.
for the audit.
The OECD Principles of GLP employ the
Once archived, the responsibility for the
term “final report”. In the current docu-
safe keeping of study data passes from the
ment, “study report” is used instead of final
Study Director to Test Facility Manage-
report, in order to keep study report distinct
ment, which has responsibility for ensuring
from the trial report, i.e. the report of a
that there are designated personnel respon-
multi-study prevalidation and validation
sible for the archives, and that the archives
trial (see section 4.4).
are secure areas with the contents indexed
Study reports should be prepared in a
in an orderly manner. The duration of
timely manner. The Study Director should
archiving should be in accordance with reg-
sign and date the study report to indicate
ulatory requirements or as specified by
acceptance of responsibility for the validity
Test Facility Management.
of the data and that the study report accu-
rately reflects work conducted and all the
results obtained. The study report for a
4 MULTI-STUDY TRIALS
multi-site study should identify and define
the role of any Principal Investigators and
4.1 TRIAL MANAGEMENT TEAM
test sites involved in the conduct of the
study. The sponsor of a multi-study trial appoints
The study report should include a GLP a Trial Management Team to have respon-
compliance statement, which is a formal sibility for overseeing the organisation,
record to confirm that the study was con- conduct and reporting of the trial (6, 15).
ducted and reported in accordance with The Trial Management Team does not have
GLP, clearly identifying, as appropriate, immediate responsibility for ensuring GLP
where the study deviated from GLP. The compliance, since it is Test Facility Man-
GLP compliance statement is signed and agement which has direct GLP responsibil-
dated by the Study Director and should ity. However, there are some Principles of
address, in particular, the GLP status of any GLP which can be usefully applied to the
test sites not within a national GLP compli- Trial Management Team. For example, the
ance programme. trial plan should identify the key responsi-
In a multi-site study, it might be appropri- bilities of specific members of the Trial
ate for the Principal Investigator to include a Management Team, including that of the
signed GLP compliance statement in the chairperson and Trial Coordinator. It
contributory report that is forwarded to the might be appropriate to designate an indi-
Study Director. vidual in the Trial Management Team to
The GLP compliance statement should not coordinate GLP compliance issues; how-
be confused with the QA statement, also pre- ever, the responsibility for GLP at a test
568 R. Cooper-Hannan et al.
9.1 General
1. A study report should be prepared for each study. In the case of short-term studies, a
standardised study report accompanied by a study-specific extension may be prepared.
2. Reports of Principal Investigators or scientists involved in the study should be signed and
dated by them.
3. The study report should be signed and dated by the Study Director to indicate acceptance
of responsibility for the validity of the data. The extent of compliance with these Princi-
ples of Good Laboratory Practice should be indicated.
The study report should include, but not be limited to, the following information.
1. Identification of the study, the test item(s), reference item(s) and control items:
a) a descriptive title;
b) identification of the test items by code or name (IUPAC, CAS number, biological para-
meters, etc.);
c) identification of the reference and control items, by name;
d) characterisation of the test item including purity, stability and homogeneity.
3. Dates.
Experimental starting and completion dates.
Table 9: continued
6. Results:
a) a summary of results;
b) all information and data required by the study plan;
c) a presentation of the results, including calculations, determinations of statistical sig-
nificance (if appropriate) and historical control data;
d) an evaluation and discussion of the results and, where appropriate, conclusions.
7. Storage: The location(s) where the study plan, samples of test, reference and control
items, specimens, raw data and the study report are to be stored.
facility remains with Test Facility Manage- on a need-to-know basis. Any changes to the
ment. Some of the required responsibilities trial plan should result in a trial plan amend-
of the Trial Management Team are illus- ment, in the same manner that any changes
trated in Figure 4 (6, 13). The Trial Man- to a study plan result in a study plan amend-
agement Team is responsible for the ment. Trial plan amendments must be num-
selection of participating laboratories, but bered, sequentially, and should be issued to
not for the appointment of Study Directors, all the original recipients of the trial plan.
who are appointed by Test Facility Man-
agement. 4.3 TRIAL COORDINATOR’S
RESPONSIBILITIES
4.2 TRIAL PLAN
The name and location of the Trial Coordi-
The trial plan outlines the trial goals and nator should be identified in each of the indi-
proposed time-scales, and identifies the stud- vidual study plans as the person responsible
ies, all the participating facilities and the for coordinating the supply and analysis of
names of Test Facility Management, Study test, reference and control items and the
Directors and Principal Investigators. Where coordination and preparation of the trial
there is no formal Study Director or Princi- report. It should be clarified whether the
pal Investigator, as might be the case for Trial Coordinator has direct access to the
facilities undertaking test item supply, data test item coding.
management and statistics, the person
The Trial Coordinator’s responsibilities
responsible for the technical conduct of the
include:
work should be identified.
The trial plan should include: a) the iden- 1. Responsibility for the coordination and
tity of the Trial Coordinator; b) SOP admin- communication network for test, refer-
istration, if common SOPs are to be used ence and control item supply and analy-
across studies; c) arrangements for QA mon- sis, data management and statistics for
itoring of study activities, including any pre- all the studies in a multi-study trial.
trial inspections; and d) the identity of
2. Ensuring that document and data flow
archiving locations.
between facilities are recorded.
The trial plan must be signed by at least
the chairperson of the Trial Management 3. Ensuring that QA monitoring is being
Team. The final trial plan should be identi- undertaken in accordance with the trial
fied as final, be fully authorised, and issued plan.
570 R. Cooper-Hannan et al.
10.1 The following should be retained in the archives for the period specified by the appro-
priate authorities:
a) the study plan, raw data, samples of test, reference and control items, specimens
and the study report of each study;
b) records of all inspections performed by the Quality Assurance programme, as well as
Master Schedules;
c) records of qualifications, training, experience and job descriptions of personnel;
d) records and reports of the maintenance and calibration of apparatus;
e) validation documentation for computerised systems;
f) the historical file of all Standard Operating Procedures;
g) environmental monitoring records.
In the absence of a required retention period, the final disposition of any study materials
should be documented. When samples of test, reference and control items and specimens are
disposed of before the expiry of the required retention period for any reason, this should be
justified and documented. Samples of test, reference and control items and specimens
should be retained only as long as the quality of the preparation permits evaluation.
10.2 Material retained in the archives should be indexed in order to facilitate orderly storage
and retrieval.
10.3 Only personnel authorised by management should have access to the archives. Move-
ment of material in and out of the archives should be properly recorded.
10.4 If a test facility or an archive-contracting facility goes out of business and has no legal
successor, the archive should be transferred to the archives of the sponsor(s) of the
study(s).
4. Assessing and documenting the impact of 8. Ensuring that the trial documentation is
any amendments and/or deviations from properly archived.
the trial plan and study plans on the qual-
ity and integrity of the multi-study trial. 4.4 TRIAL REPORT
5. Ensuring that the individual study The trial report summarises the trial goals,
reports are forwarded, in a timely man- procedures, results and conclusions of a multi-
ner, for data and statistical analysis. study trial. This represents the whole multi-
study trial, including archiving and, as such,
6. Preparing the trial report, which can be
will cover several study reports, as well as
allocated to a Study Director or an inde-
reports for test item supply, data management
pendent person.
and statistics. The preparation of the trial
7. Ensuring that the trial report is an accu- report is outlined in Figure 5. The Trial Coor-
rate reflection of the overall multi-study dinator oversees the preparation of the trial
trial. The Trial Coordinator signs and report. The Trial Coordinator might also be
dates the final trial report to confirm that responsible for preparation of the scientific
the trial report is an accurate account of conclusions. Signatories to the trial report
the multi-study trial. include the Trial Coordinator, the chairperson
ECVAM Workshop 37: Good Laboratory Practice 571
Sponsor
Finances
Contracts
Tests/Laboratories Chemicals
Selection of tests Control of quality of in Data
Identification of vivo data Planning of data
laboratories Selection of chemicals structure
Identification of lead Coding Data handling
laboratories
Distribution Data analysis
Approval of Standard
Operating Procedures Safety
of the Trial Management Team, the statisti- ing matters of GLP compliance. A QA state-
cian, and the Study Directors. Although the ment could be included in the trial report, in
Study Directors may not be involved with the order to identify what QA monitoring was
preparation of the trial report, their signa- done and to confirm whether or not the trial
tures confirm that the trial report is an accu- report is an accurate reflection of the study
rate reflection of study events. The trial report data.
should contain a statement, signed by the
Trial Coordinator, commenting on the accu- 4.5 QUALITY ASSURANCE OF MULTI-
racy and completeness of the trial report and STUDY TRIALS
identifying any significant issues which could Multi-study trials can involve independent
have affected the integrity of the trial, includ- facilities which are not formally GLP-compli-
572 R. Cooper-Hannan et al.
Sponsor
Quality assurancea
Trial Coordinator
Inspections and Overall trial report
audits
ant, such as facilities for test item analyses. GLP, describes a quality system con-
However, the QA monitoring of such facili- cerned with the organisation and the
ties is advised, to assure compliance with the conditions under which regulatory
relevant principles of GLP. Also, this pre- studies are planned, performed, moni-
sents the opportunity for QA personnel to tored, recorded, archived and reported.
monitor data exchange between facilities. Undertaking studies in compliance
QA reports should be forwarded to the rele- with GLP demonstrates to the regula-
vant facilities and also to the Trial Coordina- tory authorities that studies were
tor. In addition, the production of summary undertaken in a manner which pro-
and periodic QA reports, that would be issued motes confidence in the data and
to the Trial Management Team and sponsor reporting.
should be considered. QA review of the trial
report is appropriate, to provide independent 5.2 GOOD LABORATORY PRACTICE
assurance that the trial report is an accurate COMPLIANCE
reflection of the study reports and also the
2. A test facility might only be able to claim
trial data and trial chemical reports.
formal GLP compliance if it is within a
compliance programme run by the rele-
vant national GLP monitoring author-
5 CONCLUSIONS AND
ity. The QA monitoring of a facility not
RECOMMENDATIONS
within a compliance programme, does
not confer GLP compliance. Study
5.1 GOOD LABORATORY PRACTICE
reports and trial reports must clearly
PROMOTES CONFIDENCE IN THE
identify facilities which did not adhere to
DATA
formal GLP and address any impact this
1. The primary GLP reference for this might have had on study or trial
workshop, the OECD Principles of integrity.
ECVAM Workshop 37: Good Laboratory Practice 573
3. If a test facility has designated GLP- an assay among laboratories and over
compliant areas and non-GLP areas, it is time.
essential that GLP compliance in the
GLP areas is not compromised by the 5.4 QUALITY ASSURANCE
non-GLP areas. Maintenance of GLP
8. The principles of GLP include the
and non-GLP areas in the same facility
requirement for QA monitoring by per-
requires constant vigilance to ensure
sonnel independent of the procedures
compliance of the GLP areas. being inspected. QA is based on organi-
4. A test facility might conduct both “regu- sational rather than scientific proce-
latory studies”, intended for review by dures. Therefore, QA does not interfere
the regulatory authorities, and “non- with the technical and scientific conduct
regulatory” studies, which are not of studies.
intended for submission to the regula-
tory authorities. Where this is the prac- 5.5 VALIDATION AND MULTI-STUDY
tice in the same GLP area, it will be TRIALS
necessary for the non-regulatory work to 9. The validation of in vitro tests is under-
also be conducted in compliance with taken as multi-study trials, consisting of
GLP. Essentially, the main differences a number of separate studies, with each
between such regulatory and non-regu- study, having its own study plan and
latory studies are that the latter may be Study Director. Each study within a for-
subject to reduced QA monitoring and mal validation multi-study trial, is con-
have a reduced amount of specific GLP ducted and reported without knowledge
documentation requirements. of the test item randomisation code.
5.3 STUDY CONDUCT 10. Multi-study trials are overseen by a
Trial Management Team which is
5. The management of single-site and responsible for the selection of partici-
multi-site studies, including the key pating facilities. However, it is the Test
roles of Study Director and Principal Facility Managements of the participat-
Investigator, as described in the OECD ing laboratories who have responsibility
Principles of GLP, are considered rele- for the GLP compliance of facilities,
vant to the conduct of in vitro studies. including the appointment of Study
6. To ensure the applicability of GLP to in Directors.
vitro studies, some additions are neces- 11. A trial plan serves to outline the multi-
sary to the OECD Principles of GLP, study trial and includes trial goals and
most notably with respect to: a) defini- time-scales, and identifies participating
tion of test system facilities, with special facilities and key personnel. The trial
reference to handling and storage of test plan becomes a formal document when it
items; b) characterisation and care of is signed by the chairperson of the Trial
test systems; c) the required use of posi- Management Team, and the Trial Coor-
tive and negative control items; and d) dinator.
acceptance criteria.
12. The Trial Coordinator undertakes a
7. The concept of acceptance criteria is one pivotal role in ensuring compliance of
of the major additions to the Principles the multi-study trial with the trial plan,
of GLP proposed by the workshop. The including preparation of the trial
responses of a test system to control report.
items usually provides the basis for
determining the acceptability of an
assay. The observed control response is 6 ACKNOWLEDGEMENTS
compared to historical values for the
assay, to determine whether or not the The authors would like to thank Dr Melanie
response falls within predefined limits Scheiwiller (Novartis, Pharma AG, Switzer-
given in the study plan acceptance crite- land) and Mr Mike Burrows (Guy’s Drug
ria. The performance of the controls also Research Unit, Quintiles, London, UK) for
allows comparison of the performance of commenting on the draft report.
574 R. Cooper-Hannan et al.
8 Appendix 1
Terminology
These terms are based on the terms con- ical health and environmental safety
tained in the OECD Principles of Good Lab- study.
oratory Practice. Recommended additions
Test Facility. The persons, premises and
are in bold and underlined.
operational unit(s) that are necessary for
conducting the non-clinical health and
Good Laboratory Practice
environmental safety study. For multi-site
Good Laboratory Practice (GLP). A studies (studies conducted at more than
quality system concerned with the organisa- one site), the test facility comprises the site
tional process and the conditions under at which the Study Director is located and
which non-clinical health and environmental all individual test sites, which individually
safety studies are planned, performed, moni- or collectively can be considered to be test
tored, recorded, archived and reported. facilities.
Test Facility Management. The persons
Terms concerning the organisation of a test
who have the authority and formal responsi-
facility
bility for the organisation and functioning of
Master Schedule. A compilation of infor- the test facility according to these Principles
mation to assist in the assessment of work- of Good Laboratory Practice.
load and for the tracking of studies at a test
Test Site. A location at which a phase of a
facility.
study is conducted.
Principal Investigator. An individual
Test Site Management (if appointed). The
who, for a multi-site study, acts on behalf of
person responsible for ensuring that the
the Study Director and has defined responsi-
phase of the study, for which he/she is
bilities for delegated phases of the study. The
responsible, are conducted according to these
Study Director’s responsibility for the over-
Principles of Good Laboratory Practice.
all conduct of the study cannot be delegated
to the Principal Investigator; this includes
Terms concerning the study
approval of the study plan and its amend-
ments, approval of the study report, and Acceptance Criteria. The basis for
ensuring that all applicable Principles of determining the acceptability of an
Good Laboratory Practice are followed. assay according to pre-defined perfor-
mance parameters.
Quality Assurance Programme. A
defined system, including personnel, which Experimental Completion Date. The last
is independent of study conduct and is date on which data are collected from the
designed to assure Test Facility Manage- study.
ment of compliance with these principles of
Experimental Starting Date. The date on
Good Laboratory Practice.
which the first study-specific data are col-
Sponsor. An entity which commissions, lected.
supports and/or submits a non-clinical
Good Laboratory Practice Compliance
health and environmental safety study.
Statement. A formal record, signed and
Standard Operating Procedures dated by the Study Director, to indicate
(SOPs). Documented procedures which acceptance of responsibility for the validity
describe how to perform tests or activities of the data and to indicate the extent to
normally not specified in detail in study which the study complies with Good Labora-
plans or test guidelines. tory Practice.
Study Director. The individual responsi- Non-clinical Health and Environmen-
ble for the overall conduct of the non-clin- tal Safety Study. Henceforth referred to
576 R. Cooper-Hannan et al.
Trial Coordinator. The individual who Trial Plan. A document which outlines
coordinates the overall conduct and the goals, design, participants and pro-
reporting of a multi-study trial. posed time-scales of the multi-study
trial.
Trial Management Team. The persons
who have responsibility for overseeing Trial Report. The document which sum-
the organisation, conduct and report- marises the goals, procedures, results
ing of a multi-study trial. and conclusions of a multi-study trial.