WHOPIR Lambda 5-9june2023
WHOPIR Lambda 5-9june2023
WHOPIR Lambda 5-9june2023
3111 – WWW.WHO.INT
General section
Lambda Therapeutic Research Ltd., located at Lambda House, Plot No. 38, Survey No.
388, Ahmedabad, Gujarat, India, is a registered clinical research organization. It holds a
valid registration certificate in Form CT-09 by CDSCO (HQ), Delhi, under the New
Drugs and Clinical Trial Rules, 2019. The certificate allows Lambda Therapeutic
Research Ltd. to operate as a Bioavailability/Bioequivalence study center with a clinical
facility comprising 360 beds and a Bioanalytical facility. Furthermore, on 14th
September 2020, CDSCO approved the firm's request to increase the bed capacity from
360 to 376.
The CRO maintained up-to-date organizational charts that listed key positions and
responsible individuals. These charts were authorized by the managing director, and
regularly reviewed.
The CRO had a Master Service Agreement in place with sponsors. The agreement with
the sponsor was provided and reviewed. Within the agreement, specific provisions and
timelines were defined for the retention of investigational medical products (IMP),
documentation, and biological samples.
Each employee had a job description outlining their responsibilities. Random verification
confirmed that the job descriptions were signed and dated by the respective staff
members.
A list of signatures of the authorized personnel performing tasks during each study was
available and randomly verified.
Management made sure that appropriate and technically valid Standard Operating
Procedures (SOPs) were implemented and followed. They also ensured that a well-
organized historical file of all SOPs was maintained.
The CRO's official working hours were from 9:30 AM to 6:20 PM, six days a week, apart
from every second Saturday, which was designated as a non-working day.
2. Computer systems
A list of software and computer systems used in the studies was submitted.
The CRO maintained a software inventory for GxP computerized systems, following the
guidelines outlined in the Computer System Validation SOP. Generally, the systems in
use were validated, and any changes made to these validated systems underwent a
thorough review process that assessed associated risks and impacts. For handling changes
in systems, processes, infrastructure, and IT systems, the activities were defined in SOP
for Change Control. All change requests were reviewed and approved by the QA team or
other designees, as applicable. The validation team was responsible for conducting
validation activities. In case of any identified gaps during periodic assessment, hardware
upgrades, or other changes that could affect the software's validated state, revalidation of
the software was performed. Periodic Review of computerized system was carried as per
the applicable SOP.
The organization utilized multiple servers of different makes and models for their storage
area network. These servers had an adequate storage capacity, allowing them to handle
large volumes of data. The servers were integrated to manage data generated by various
applications.
Regular backups of all generated data were scheduled according to the frequency and
process outlined in SOP for Backup and Restoration of Electronic Data. An annual
restoration process was conducted, and the last restoration documentation from 2022 was
requested and reviewed. A yearly restoration plan was provided, and once finalized, the
process was initiated. Documentation for verifying the content of folders was available
and reviewed. Random checks were performed by the respective departments to ensure
the content was intact and readable.
Lambda had a procedure in place for data archival after project completion. A flowchart
was provided to illustrate the backup architecture and data archival routes. According to
the archival diagram, the data was transferred to the respective storage appliance that was
automatically synchronized with the cloud. Once stored in the cloud, the archivist
responsible for the procedure notified the IT department to delete the source data on the
Lambda Therapeutic Research Ltd, Ahmedabad - CRO 5-9 June 2023
--------------------------------------------------------------------------------------------------------------------------------------------
This inspection report is the property of the WHO
Contact: [email protected]
Page 6 of 28
20, AVENUE APPIA – CH-1211 GENEVA 27 – SWITZERLAND – TEL CENTRAL +41 22 791 2111 – FAX CENTRAL +41 22 791 3111 – WWW.WHO.INT
The software programs utilized for essential tasks were mandated to undergo validation
to ensure their suitability for the intended purpose. Qualification and/or validation
certificates were obtained under the user's supervision. Randomly selected systems’
qualification/validation documentation was reviewed.
Networks, including the full client/server architecture and interfaces such as laboratory
information management systems, were designed, qualified, managed, and controlled. A
basic diagram was provided and approved on 21 Sep 2022.
Data entry procedures, including data validation methodology (proofreading, double data
entry, etc.) were generally designed to prevent errors. The data entry process was
specified in the applicable procedures.
3. Quality management
Lambda had established manuals, policies, and master quality documents to implement
their quality system. They utilized an electronic SOP Management System. The SOPs
were collaboratively authored by department representatives, reviewed by department
leads/designees and Quality Assurance, and authorized by a designated Management
Representative.
Lambda Therapeutic Research Ltd, Ahmedabad - CRO 5-9 June 2023
--------------------------------------------------------------------------------------------------------------------------------------------
This inspection report is the property of the WHO
Contact: [email protected]
Page 7 of 28
20, AVENUE APPIA – CH-1211 GENEVA 27 – SWITZERLAND – TEL CENTRAL +41 22 791 2111 – FAX CENTRAL +41 22 791 3111 – WWW.WHO.INT
Lambda aligned their SOPs and systems with sponsor requirements to ensure the
collaboration, especially when project sponsors mandated specific SOPs or systems. The
electronic SOP Management System served as a storage facility for SOPs, but the
overview of SOPs, including revision schedules and reviews, was managed outside of the
system. Once the review process was completed, the initiator uploaded the SOP into the
system for approval and signatures. After approval, the responsible person downloaded
the new SOP into the training folder, and another responsible person handled the upload
into the e-Training system. The e-training matrix enabled the applicable staff to access
the approved SOP, read and understand it, and electronically sign it within the system. A
presentation was provided to demonstrate the QMS software system during the
inspection.
Lambda provided a Quality Manual. The Quality Manual outlined Lambda's Quality
Policy, organizational structure, and advocated quality systems for their daily operations.
It offered an overview of Lambda's objectives, business areas, and served as a guide for
quality management of processes and systems within the organization.
QA personnel were not directly involved in trial-related activities. Both in process and
retrospective verification of study data was done and recorded in the respective QA-
statement for each study.
An in-house audit was conducted following the respective SOP. The inspection team
requested the audit report for March 2023, but the CRO declined to share it due to internal
procedures. However, communication evidence related to the audit was available and
reviewed.
The company implemented audit trail reviews as per specific SOPs. Additionally, the SOP
for Good Documentation Practice provided general instructions for performing an audit trail
review. Each SOP provided guidance on which data should be reviewed, how the audit trail
should present data and any modifications, and which changes were considered acceptable in
routine system use. The respective checklists accompanied the SOPs to document the audit
trail review process and its outcomes. Adequate training on the SOPs was provided to the
relevant personnel.
4. Archive facilities
The facility was inspected during the previous inspection and found adequate.
Document access and return records were maintained, following the specified time period
outlined in the respective SOP and the contract between the sponsor and the CRO. The
contract also included provisions for financing the archiving process. The trial-related
documentation was successfully retrieved and traced during the inspection, verifying the
effectiveness of the archiving procedures.
5. Premises
During the inspection, a tour of the clinical facility was conducted on Day 3.
Ground Floor
• Screening & Check-in area
• Clinical Pharmacy (with 3 dispensing rooms)
• President Office
• Human Resources Development
• Finance & Purchase
• Library
• Archives
First Floor
• Clinical facility - divided in two wings (Wing 1A & 1B) of 90 beds each.
• ICU
• Sample Separation
• Quality Assurance-Early Phase
• Business Development & Project Management
• Clinical Data Management
• Report Group (Report compilation)
• Biostatistics & Programming
• Regulatory Affairs
• Engineering Services
• Management Representative Office
• Directors' office
Second Floor
• Clinical Facility - divided into two wings (Wing 2A & 2B) of 90 beds each.
• ICU
• Sample Separation
• Pathology Laboratory
• Bioanalytical-Protein Biosimilars.
• Information Technology
• Information and technology Quality Assurance-(IT-QA)
• Protocol Writing
• Medical Imaging
• Service, Calibration and Validation
• Regulatory and Compliance
Third Floor
• Bioanalytical Laboratory
• Bioanalytical-Protein Biosimilars
• Clinical facility (Phase-I)
• Training hall
• Archives
• Regulatory and Compliance
Fourth Floor
• Clinical Trial Management Operations
• Clinical Trial Management (Medical Services)
• Quality Assurance-Late Phase
• Medical Imaging
• Report Group (Report writing)
• Training Hall
The facilities were kept clean and had adequate lighting, ventilation, and environmental
control at the time of inspection. Floors, walls, and working bench surfaces were easy to
clean and decontaminate.
Clinical trials were carried out under conditions that ensured adequate safety for the
subjects. The site selected was appropriate to the potential risk involved. The
Lambda Therapeutic Research Ltd, Ahmedabad - CRO 5-9 June 2023
--------------------------------------------------------------------------------------------------------------------------------------------
This inspection report is the property of the WHO
Contact: [email protected]
Page 10 of 28
20, AVENUE APPIA – CH-1211 GENEVA 27 – SWITZERLAND – TEL CENTRAL +41 22 791 2111 – FAX CENTRAL +41 22 791 3111 – WWW.WHO.INT
departmental divisions within the facility were designed to facilitate smooth and one-way
movement of people and materials. To control personnel access, magnetic locking
mechanisms were installed at the entrance doors of different sections or departments.
Employees were provided with Access/I-Card based on their specific requirements,
ensuring that only authorized individuals could enter or exit the departments (through an
electronic access control system). Emergency evacuation measures were implemented,
and all entries and exits from the facility were recorded for documentation purposes for
critical areas such as the pharmacy and freezer room.
The CRO had sufficient space to accommodate the personnel and activities required to
perform the studies. The trial site had adequate facilities, including laboratories and
equipment.
Laboratory premises were designed to suit the operations that were carried out in them.
Sufficient space was provided to avoid mix-ups, contamination, and cross-contamination.
Adequate storage space was available for samples, standards, solvents, reagents, and
records.
Laboratory premises were designed to provide protection to all employees and authorized
external personnel, including inspectors, by ensuring their safety while handling or
working in the presence of chemicals and biological samples.
Safety data sheets were available in an electronic folder to staff before testing was carried
out. Staff working in the laboratory was familiar with and knowledgeable about the
material safety data sheets for the chemicals and solvents they were handling. Selective
Staff (25 of them) was trained to use the firefighting equipment, including fire
extinguishers. Staff was instructed to wear laboratory coats or other protective clothing,
including eye protection. Highly toxic and/or genotoxic samples were handled in a safety
cabinet to avoid the risk of contamination. All containers of chemicals were fully labelled
and included prominent warnings whenever appropriate.
Adequate insulation and spark-proofing were provided for electrical wiring and
equipment, including refrigerators. Rules on the safe handling of cylinders of compressed
gases were observed, and the staff was familiar with the relevant colour identification
codes. Staff was aware of the need to avoid working alone in the laboratory. First-aid
materials were provided, and the staff was instructed in first-aid techniques, and
emergency care.
were handled under fume-hoods or air extractors, and safety and eye showers were
available in the laboratory.
Premises had suitable systems in place to dispose waste, treat fumes and protect the
environment in conformance with local or national regulations. Backup generator and
UPS room were well maintained.
6. Personnel
A sufficient and qualified team of medical, paramedical, technical, and clerical staff was
available to support the trial and effectively respond to foreseeable emergencies. The
number of members of staff counted to about 800 at the time of inspection. At all trial
stages, including at night, there were qualified and trained personnel to ensure that the
subject's rights, safety, and well-being were safeguarded and to care for the subjects in
emergencies. In specific activities, contract workers were employed to complement the
team's capabilities.
Training records at Lambda were kept in both hard copy and electronic formats using a
software. The specific guidelines for training were outlined in SOP for Training and SOP
for Contractual Staff Training, specifying the details and frequency of training. The
training sessions were conducted by department heads within their own departments,
across departments, or with the help of external experts.
To ensure accuracy, random samples of current curricula vitae and training records were
reviewed for both full-time employees and contract workers involved in trial activities.
Clinical section
7. Clinical phase
The clinical phase of the studies was performed on the premises of the CRO.
Systems were in place in the accommodation facilities so that subjects could alert CRO
staff in case of need.
Lambda Therapeutic Research Ltd, Ahmedabad - CRO 5-9 June 2023
--------------------------------------------------------------------------------------------------------------------------------------------
This inspection report is the property of the WHO
Contact: [email protected]
Page 12 of 28
20, AVENUE APPIA – CH-1211 GENEVA 27 – SWITZERLAND – TEL CENTRAL +41 22 791 2111 – FAX CENTRAL +41 22 791 3111 – WWW.WHO.INT
Facilities for changing and storing clothes and for washing and toilet purposes were
clean, well-ordered, easily accessible, and appropriate for the number of users. Lockable
toilets were equipped with alarm bells, and doors were designed to ensure they could be
opened from the outside should a medical emergency occur. A separate area was
designated for female volunteers.
A radiologist consultant was contracted since 1 Aug 2017, to review and assess X-ray
records performed at the in-house X-ray facility in the screening area. The government of
India's Atomic Energy Regulatory Board issued a registration certificate for the operation
of medical diagnostic X-ray equipment on 13 Aug 2020, which was valid until August
2025.
Provisions were made for the urgent transportation of subjects to the hospital.
The equipment used was calibrated at predefined intervals. The adequate function and
performance of emergency-use equipment (e.g., defibrillators) were verified at
appropriate intervals.
8. Clinical laboratory
An inhouse accredited internal clinical laboratory was utilized to analyze samples during
the clinical trial. The laboratory's accreditation certificates, including those from bodies
like NABL and CAP, were available in the respective Trial Master File (TMF). The TMF
also contained the laboratory's normal ranges for various tests.
As specified in the study protocol, the laboratory conducted hematological tests, urine
analysis, and other specified tests. To ensure traceability and sample integrity, sample
Lambda Therapeutic Research Ltd, Ahmedabad - CRO 5-9 June 2023
--------------------------------------------------------------------------------------------------------------------------------------------
This inspection report is the property of the WHO
Contact: [email protected]
Page 13 of 28
20, AVENUE APPIA – CH-1211 GENEVA 27 – SWITZERLAND – TEL CENTRAL +41 22 791 2111 – FAX CENTRAL +41 22 791 3111 – WWW.WHO.INT
labeling, receipt, storage, and chain of custody processes were implemented using the
laboratory's LIMS system.
The TMF contained the list of analytical methods employed by the laboratory, along with
the dated laboratory normal ranges and accreditation certificates. The current and signed
curricula vitae of the Head of the Clinical Laboratory was also reviewed.
Individual reports for each subject were generated by the laboratory and included in the
eCRFs. The laboratory archived the source or raw data for all performed tests in
electronic or paper formats.
To ensure data integrity, the laboratory employed adequately validated systems for
sample analysis. In most cases, the results were transferred to the LIMS system
automatically.
9. Ethics
Trials underwent approval by an independent ethics committee (IEC) prior to
commencing any study. The committee's independence from the sponsor, investigator,
and CRO was verified through the member list. The approval letter contained detailed
discussions, recommendations, and decisions from the IEC meetings. Adequate time was
given to the IEC for reviewing protocols, informed consent forms (ICFs), and related
documentation.
An insurance policy, covering the study period of RH093, was reviewed and available.
When applicable, the TMF contained the license to import the drug issued by the local
authority (CDSCO).
Informed consent was given by the subject and documented in writing before starting any
trial-related activities. The information was clear: participation was voluntary, and the
subject had the right to withdraw from the study on their initiative at any time without
giving a reason. The reasons for withdrawal from the study were included in the study
records.
The information about insurance and other procedures for compensation or treatment
should the subject be injured or disabled by participating in the trial or during was
available through the Insurance policy.
The volunteers or subjects were allowed to discuss their concerns regarding potential side
effects or reactions from using the investigational products before participating in the trial
with a physician.
The certificate of translation and back translation of the informed consent were reviewed.
10.Monitoring
The studies were monitored by monitors who were either employed or represented by the
sponsor. The monitors ensured that the study adhered to the protocol, GCP, GLP, and
relevant ethical and regulatory requirements. They verified the correct completion of
Case Report Forms (CRFs) and the accuracy of collected data.
A monitoring visit log was included in the Trial Master File (TMF), documenting the
recommendations and observations shared with the site in a timely manner. The monitors
covered specific periods as determined by the sponsor.
Pre-study, post-study, and regular monitoring visits were conducted according to the
sponsor's schedule. After each site visit, the monitor prepared a written report and
communicated any issues to the CRO and sponsor to enable corrective action in timely
manner, if possible, even during the ongoing study. These communications and any
corrective actions taken were documented.
11.Investigators
The principal investigator (PI) was responsible for the clinical conduct of the study,
including clinical aspects of study design, administration of the products under
investigation, contacts with local authorities and the ethics committee, and signing of the
protocol and the final study report.
The pharmacy had separate storage rooms for IMPs and retained samples in stability
chambers or refrigerators (if applicable). The dispensing areas were completely isolated
from the rest of the pharmacy, following hygienic provisions. This was achieved by
implementing a changing area and a separator before entering the facility, which was
equipped with a LAF (Laminar Air Flow) bench. Pharmaceutical products were stored in
accordance with the specified conditions mentioned in the official product information
provided by the sponsor. The monitoring of these storage conditions was conducted using
the a digital temperature monitoring system, which was installed in 2021. The data from
this monitoring period was successfully retrieved and reviewed.
The shipment was monitored throughout the transportation process. The shipment
documentation and communication between the CRO and sponsor were reviewed
specifically for study RH093.
Randomization was carried out following the SOP for Randomization schedule
management. This SOP governed the generation, review, and release of all randomization
schedules used to allocate treatments to subjects in clinical studies conducted by Lambda,
whether internally or externally. The same SOP also applied to the random selection of
subject chromatograms for submission purposes. Records pertaining to randomization,
including the randomization list and seed, were duly maintained.
Labels were generated using the respective software system. The IPs were appropriately
labelled. The compliance of all labels with the randomization list was verified after
printing and before labelling the containers. The barcoded labels were securely attached
to the containers to prevent information loss when the lids were removed.
Dispensing and packaging procedures were performed in accordance with the SOP for
Handling of IMPs.
The surface on which the product was handled was thoroughly cleaned before bringing
bottles of the product into the area. Any product containers (full or empty, labelling
materials, contaminants, dirt, and debris) were removed from the area. A second person
verified that the surface area/line was clear and clean before bringing in and opening
containers of the product. The IMPs were handled with appropriate utensils. Tablets were
distributed into each container in accordance with the randomization list for the reference
or the test product as appropriate. The two products, i.e., Test & Reference, were handled
at different times. This also applied to the labelled containers. Every step was recorded
sequentially in detail in the software system. The surface upon which the product was
handled, and its surroundings were cleared and cleaned immediately before and after
initiating the dispensing of the following product, also in the same study.
The empty containers were labelled separately for the test and the reference
investigational products. They remained segregated in a secure area under lock and key to
avoid the risk of any potential mix-ups until the dispensing stage.
The documentation for the destruction IMPs related to study RH093 was available. It
included communication with the sponsor and confirmation from the service provider,
dated 20 Aug 2021, following the expiry of products as per the agreement with the
sponsor.
Dosing was conducted following SOP for administering the IMP to participants. The
investigator and a qualified staff member, specifically assigned in writing, supervised the
dosing process. Prior to dosing, the barcode on the volunteers' ID card and the IMP
container were checked against the label. The exact time of dosing was then documented
on the designated page of eCRF using the time register software system. To ensure the
intake of the IP, a mouth check was performed. This involved examining under the
tongue, under the lips, in the corners of the mouth, and between the gums and cheeks.
The software system provided an alert for this activity. Immediately after dosing, the
actual time of administration and any other required information for each participant were
automatically recorded. These details were captured in the respective individual eCRF or
as deemed appropriate.
After dosing, the pharmacist and another designated person verified the reconciliation of
the investigational product. The records of this verification were maintained in the TMF.
Samples of the product in its original container were retained for a minimum of one year
after the expiry date of the most recent product. This retention period was defined and
explained in the respective SOP and was outlined in the contract between the sponsor and
the CRO. Additionally, any dispensed products that were not administered were also kept
for further reference.
As part of the inspection process, a random selection of e-CRFs from the study was
reviewed. For this review, e-CRFs were selected from two specific studies, namely Study
RH093 and Study CV018. All instances of protocol deviations and discontinued subjects,
along with their AEs and subsequent follow-ups, were included in the review.
The CRO has introduced a new procedure for establishing a predetermined range of
acceptable laboratory values, considering various factors such as population and regional
differences. This list has been incorporated into the protocol and investigators were now
using these values to assess the laboratory results of volunteers. However, this practice
did not apply to the studies conducted before 2019. Therefore, the values for study
RH093 were assessed at the discretion of the investigators and a note was included in the
TMF on 16 May 2018. This note explained the approach taken in evaluating the
laboratory reports for volunteers enrolled in WHO submission studies, prior to the
initiation of the study.
At the time of study RH093, there was no logbook available to document the usage of the
ECG instrument. However, a new procedure has been introduced to address this issue and
now includes the recording of ECG machine usage.
In study RH093, a binder was used to compile the medical screen record. This included
the ICFs, screening ECG records, and X-ray reports (if applicable). Other source data
related to the study protocol was directly entered into the eCRF. This included
information such as inclusion and exclusion criteria, laboratory reports, vital signs, meal
intake, dose administration, IMP handling, blood collection, biological sample
processing, screening and post-study physical examinations, adverse events, and
concomitant medication.
The eCRF was designed to include the scheduled time for blood collection and dosing
administration, with the ability to populate the actual time in the system. Any deviations
from the study protocol were documented in the respective system.
Potential subjects were required to provide informed consent not only for their
participation in the research portion of the study but also for any screening procedures
necessary to determine their eligibility. The clinical trial protocol outlined specific
criteria for subject selection, including both inclusion and exclusion criteria, as well as
the screening procedures to be followed.
Timing, duration, and amount of food and fluids consumed were recorded in the eCRF.
Before samples were obtained from ambulatory subjects, they were asked about their
food and drink consumption. An inhouse dietitian with appropriate qualifications,
training, and experience designed standardized meals.
First-aid equipment and appropriate rescue medication were available in the ICU and
ready for emergency use at the study site. Any treatment given to a subject was
documented and included in the CRF and the supporting documentation in the ICU.
The CRO had adverse event registration and reporting sections, as well as consumption
of concomitant medication as part of the eCRF.
Bioanalytical section
The inspection primarily focused on two studies, namely, RH093 and CV018, along with
their associated validation projects. Additionally, spot checks were conducted for study
NT014. The following records and activities were investigated during the inspection:
- Source documentation and raw data pertaining to the validation of bioanalytical
methods.
- Analysis of subject plasma samples, as well as the corresponding electronic data.
- Audit trails associated with electronic data capture and handling specifically
related to the bioequivalence (BE) studies.
- Examination of results from calibration standards (CCs), quality control samples
(QCs), and subject plasma samples in analytical runs. This included a review of
chromatograms generated during these analytical runs.
- Assessment of the preparation process for analyte stock solutions, calibration
standards, QCs, internal standards, and reagents.
These aspects were thoroughly examined to ensure compliance and reliability in the
respective studies and validation projects.
Furthermore, chromatograms and their integration, the absence of signals in the blank
samples, and the absence of any unexplained interruptions in the injected sequences were
verified. The reason for the study sample repeat analyses and all instrument failures was
reviewed. The provisions and the documentation of the ISRs were confirmed. The
documentation and justification for the reinjection of the analytical runs were verified and
compared to the provisions.
For a review of the study documentation, the inspection team received adequate support
from well-informed and transparent personnel. The inspectors had access to electronic
copies of electronic raw data associated with the inspected studies and method
validations.
As part of the method validation following the respective SOP, a run was conducted to
determine the batch size for analysis. For study RH093, a batch of 150 QCs along with
the respective CCs was used. Similarly, for study CV018, a batch of 190 QCs and CCs
was employed. This batch size was selected to be comparable in length to the batches
expected to be used for actual analysis.
The sample processing was documented in the respective forms. A note to file was also
provided to record any unexpected activity during sample processing, when applicable.
Data to support the stability of the samples under the stated conditions and period of
storage was available before the start of the studies, except for the long-term stability,
which was performed before the issuance of the study reports.
The review of the entire method validation included precision and accuracy testing
(P&A), sensitivity, selectivity, matrix effect, calibration curve, autosampler carry-over,
dilution integrity, stability (including freeze-thaw stability, stock solution stability and
reference standard storage stability), haemolytic effect, recovery, and reinjection
Lambda Therapeutic Research Ltd, Ahmedabad - CRO 5-9 June 2023
--------------------------------------------------------------------------------------------------------------------------------------------
This inspection report is the property of the WHO
Contact: [email protected]
Page 21 of 28
20, AVENUE APPIA – CH-1211 GENEVA 27 – SWITZERLAND – TEL CENTRAL +41 22 791 2111 – FAX CENTRAL +41 22 791 3111 – WWW.WHO.INT
Each analytical run included calibration curve (CC) standards, QC samples interspersed
throughout the run, and subject samples, were all processed simultaneously. The exact
sequence of processing was defined and documented. All samples collected from a given
subject during all trial periods were analysed in the same run. The acceptance criteria for
the analytical runs were confirmed by a review of the analytes’ retention time, the accuracy
of calibration standard and quality control samples, peak integration, and IS peak areas, as
per the applicable SOPs. A system suitability and a stabilization test were done prior to the
start of runs on each day.
Of the first 1000 samples, 10% were used to run Incurred Sample Reanalysis (ISR), and of
the subsequent samples, 5% were used for ISR purpose. The samples were selected with a
concentration around Cmax and in the elimination phase. The acceptance criteria were
clearly defined in the respective SOP.
The system audit trail review was carried out at the time of the studies in the scope of the
inspection, and adequate training was provided to the responsible personnel.
To ensure accurate identification and traceability, the labels for collected samples were
systematically generated using the respective software system. This automated process
helped eliminate the possibility of human errors, thus improving the accuracy of sample
Lambda Therapeutic Research Ltd, Ahmedabad - CRO 5-9 June 2023
--------------------------------------------------------------------------------------------------------------------------------------------
This inspection report is the property of the WHO
Contact: [email protected]
Page 22 of 28
20, AVENUE APPIA – CH-1211 GENEVA 27 – SWITZERLAND – TEL CENTRAL +41 22 791 2111 – FAX CENTRAL +41 22 791 3111 – WWW.WHO.INT
Throughout the storage period and transportation, all storage conditions, including freezer
temperature, were controlled, monitored, and recorded. Digital temperature monitoring
systems were utilized for this purpose.
A software system was used in creating and maintaining detailed records for each sample.
These records contained important information such as sample ID numbers, storage
locations, timestamps for storage and retrieval, and relevant metadata. Such comprehensive
records provided an overview of the sample inventory, simplifying the tracking of
necessary information. When samples were stored, the software system diligently recorded
key details like the storage location, date, and time. This thorough documentation created
a complete audit trail, enabling precise tracking of sample movement and storage history.
The recorded details were essential for maintaining sample integrity, complying with
regulations, and supporting quality control procedures. To prevent any compromise,
samples were duplicated in aliquots, shipped, and stored separately.
As per SOP for Storage of biological samples and solutions in the freezer/refrigerator, the
study samples, QC samples, and pooled matrix were discarded.
The criteria for acceptance and exclusion of CC standards and QC samples, as well as batch
acceptance, were clearly defined in the applicable SOP. The source data for all the
analytical runs contained all information about the original first evaluation of runs
(containing all calibration samples) when the analysis was repeated. The calibration range
was adequately truncated. Internal standard variations were trended and used as part of the
verifications of result validity.
Full audit trails were always activated on all analytical instruments before, during, and after
the method validation and the studies of interest.
All original analytical raw data (e.g., calculations, chromatograms, and their associated
audit trails) were documented in a manner that ensured traceability concerning the sample
number, equipment used, date and time of analysis, and the name(s) of the technician(s).
All audit trail files were retained (e.g., results table audit trail, project audit trail, and
instrument audit trail).
Lambda Therapeutic Research Ltd, Ahmedabad - CRO 5-9 June 2023
--------------------------------------------------------------------------------------------------------------------------------------------
This inspection report is the property of the WHO
Contact: [email protected]
Page 23 of 28
20, AVENUE APPIA – CH-1211 GENEVA 27 – SWITZERLAND – TEL CENTRAL +41 22 791 2111 – FAX CENTRAL +41 22 791 3111 – WWW.WHO.INT
Each data point was traceable to a specific sample, including sample number, time of
collection of the sample, time of centrifugation, time when the sample was placed in the
freezer, and time of sample analysis, to be able to determine whether any aberrant results
might have been caused by sample mishandling.
Within the Bioanalytical department on the 3rd floor, the following dedicated sections
were established to conduct various laboratory activities
• Instrumentation room
• Sample processing laboratories
• Freezer rooms
• Balance rooms
• Chemical store
• General store
• Wash area
• Documentation room
• Wet/Dry ice storage room
• Utility room
• Office area
The general principles of Good Laboratory Practice were followed during the
bioanalytical part of BE studies, with an established appropriate QA system.
The storage of samples in deep freezers and reference standards in refrigerators within
the Bioanalytical department was well-managed. These storage units were appropriately
qualified, calibrated, and maintained. An alarm system was integrated with the digital
thermometer. The temperature monitoring system had the capability to send SMS and
email notifications to the designated custodians responsible for facility maintenance. To
ensure its reliability, the automatic alarm system underwent testing during the inspection
to verify its proper functionality. The daily monitoring and alarm checks were diligently
documented.
the inspection. Proper consideration was given to the transfer of samples to equivalent
storage units during maintenance and repair activities.
Balances, other measuring devices, and equipment and instruments used during the
conduct of a trial were periodically calibrated and verified before use to be fit for their
intended purpose.
The operation, use, calibration, checks, and preventive maintenance of equipment were
described in the respective SOPs. Records were maintained in accordance with applicable
requirements. These activities were verified by random review of the equipment used in
study-related activities. Equipment and its components were labelled with the respective
ID number, date of calibration, and date of next calibration. The equipment usage was
adequately documented in the analytical sheets, as well as the respective logbooks for the
instrument usage. The use of columns was recorded in the logbook for the usage of
columns.
The respective software systems processed the study data and generated an Excel file that
could be utilized in PK database for pharmacokinetic (PK) analysis. This streamlined
process avoided manual data handling and enhanced the efficiency.
The statistical model for the primary bioequivalence (BE) analysis was outlined in the
protocol, with input from the biostatistician. The methods used for conducting
pharmacokinetic and statistical calculations, including the software and scripts utilized,
were specified in the study protocol.
22.Study report
The process of study report writing was verified during the inspection. Procedures were
established to ensure the quality and integrity of the study report. No discrepancies were
identified between the results stated in the report and the original (raw) data.
The study report included a report on the bioanalytical part of the trial, including a
description of the bioanalytical method used and a report on the validation of this
method. The Principal Investigator approved the clinical study reports before data
transfer to the statistical department. The responsible staff and management also
approved the bioanalytical reports. Monitoring and audit reports were available before the
release of the final study report.
Miscellaneous
Samples taken N/A
Assessment of the CRO Master File was submitted and reviewed.
CRO master file
Annexes attached N/A
Based on the areas inspected, the people met, and the documents reviewed and
considering the findings of the inspection, including the observations listed in the
Inspection Report, as well as the corrective actions taken and planned, the studies were
considered to have been conducted at an acceptable level of compliance with WHO
GCP/GLP/BE guidelines at Lambda Therapeutic Research Ltd., located at Lambda
House, Plot No.38, , Survey No. 388, S.G. Highway, Gota, Ahmedabad - 382 481,
Gujarat; India.
All the non-compliances observed during the inspection that were listed in the complete
report as well as those reflected in the WHOPIR were addressed by the CRO, to a
satisfactory level, prior to the publication of the WHOPIR.
This WHOPIR will remain valid for three years, provided that the outcome of any
inspection conducted during this period is positive.
2. Good clinical laboratory practice (GCLP), WHO on behalf of the Special Programme for
Research and Training in Tropical Diseases. Geneva, 2009
Short name: WHO GCLP
3. Guidelines for good clinical practice for trials on pharmaceutical products. WHO Technical
Report Series, No. 850, 1995 (pp. 97–137).
Short name: WHO GCP
4. Handbook – Good Laboratory Practice (GLP): quality practices for regulated non-clinical
research and development – Annex I: The OECD Principles on GLP, 2nd ed., 2009. Short
name: OECD GLP
5. Standards and operational guidance for ethics review of health-related research with human
participants. Guidance Document. Geneva, World Health Organization, 2011.
Short name: WHO Ethics Committee Guidance
6. Guidelines for the preparation of a contract research organization master file, WHO Expert
Committee on Specifications for Pharmaceutical Preparations. Forty-fourth Report.
Geneva, World Health Organization, 2010 (WHO Technical Report Series, No. 957),
Annex 7.
Short name: WHO CROMF Guidelines or TRS No. 957, Annex 7
8. Glove use information leaflet, Patient Safety, Save lives clean your hands. Geneva, World
Health Organization, 2009 (revised).
Short name: Glove use information leaflet
11. Guideline on data integrity. WHO Expert Committee on Specifications for Pharmaceutical
Preparations. Fifty-fifth Report. Geneva, World Health Organization, 2021 (WHO
Technical Report Series, No. 1033), Annex 4.
Short name: WHO TRS 1033, Annex 4
13. Bioanalytical Method Validation and Study Sample Analysis M10, ICH Harmonised
Guideline, Final version, Adopted on 24 May 2022
Short name: ICH M10