Role of The Erc
Role of The Erc
Role of The Erc
ETHICS REVIEW
COMMITTEE
Abraham Daniel C. Cruz, MD, MSc, FPSECP
Vice Chair, FEU – NRMF Institutional Ethics Review Committee
Department of Pharmacology
Far Eastern University – Nicanor Reyes Medical Foundation
Objectives
• By the end of this talk, the attendees should be able to:
• Define the responsibilities of the ERC
• List the composition, functions and operations of the ERC
• Describe the procedures of the ERC regarding the review of
research protocols
• Enumerate the relevant records that the ERC retains in the
conduct of its function
CLINICAL RESEARCH
A study undertaken involving a particular person or group of people with the purpose of
increasing knowledge and determining how well treatment or diagnostic test works in a
particular patient population. PATIENT-ORIENTED RESEARCH involves a particular person
or group of people or uses materials from humans. This research can include: studies of
mechanisms of human disease; studies of therapies or interventions for disease; clinical
trials; and studies to develop new technology related to disease. EPIDEMIOLOGICAL AND
BEHAVIORAL STUDIES examine the distribution of disease, the factors that affect health,
and how people make health-related decisions. OUTCOMES AND HEALTH SERVICES
RESEARCH seeks to identify the most effective and most efficient interventions, treatments,
and services.
National Ethical Guidelines for Health Research (2011)
CLINICAL TRIAL
A planned scientific research or study among human volunteers to
determine the effects of treatment or diagnostic test on their safety, efficacy, and
its effect on quality of life. It is also a systematic study on pharmaceutical
products in human subjects (including patients and other volunteers) in order to
discover or verify the effects of and/or identify any adverse reactions to
investigational products, and/or to study the absorption, distribution,
metabolism, and excretion of the products with the object of ascertaining their
efficacy and safety (WHO, Guidelines for Good Clinical Practice for Trials of Pharmaceutical Products).
National Ethical Guidelines for Health Research (2011)
CLINICAL TRIAL
It is also defined as investigative work to evaluate new
drugs, medical devices, biologics, or other interventions to
patients in strictly scientifically controlled settings. Clinical
trials may be designed to assess the safety and efficacy of an
experimental therapy, to assess whether the new intervention
is better than standard therapy, or to compare the efficacy of
two standard or marketed interventions.
National Ethical Guidelines for Health Research (2011)
CLINICAL TRIAL
http://www.who.int/rpc/research_ethics/informed_consent/en/
WAIVER OF INFORMED CONSENT
• Public Benefit or Service Programs Research. The research or demonstration
project is to be conducted by or subject to the approval of state or local
government officials and is designed to study, evaluate or otherwise examine:
• Public benefit or service programs,
• Procedures for obtaining benefits or services under those programs,
• Possible changes in or alternatives to those programs or procedures, or
• Possible changes in methods or levels of payment for benefits or services under those
programs, and
• The research could not practicably be carried out without the waiver or alteration.
WAIVER OF INFORMED CONSENT
• Waiver for Minimal Risk Studies
• The research involves no more than minimal risk to subjects, and
• The waiver or alteration will not adversely affect the rights and welfare of the
subjects, and
• The research could not practicably be carried out without the waiver or alteration, and
• Whenever appropriate, the subjects will be provided with additional pertinent
information after participation
• Unless all four conditions are met, informed consent shall be deemed feasible.
WAIVER OF INFORMED CONSENT
• Emergency Situations. Treatment of individual subjects/patients with an
investigational test article (i.e. investigational drug, biologic product or medical
device) in an emergency situation is allowed by local regulatory authorities.
Obtaining of informed consent shall be deemed feasible unless, before the use of
the test article, both the investigator and a physician who is not otherwise
participating in the clinical investigation certify in writing all of the following:
• The subject is confronted by a life-threatening situation,
• Informed consent cannot be obtained from the subject because of an inability to communicate
with or obtain legally effective consent from the subject,
• Time is not sufficient to obtain consent from the subject's legal representative, and
• There is no available alternative method of approved or generally recognized therapy that
provides equal or greater likelihood of saving the life of the subject.
Retroactive approval for studies
initiated before review and approval
is never granted.
POST-APPROVAL REVIEW
• Study Protocol Amendment
• Continuing Review
• Final Report
• Non-Compliance: Deviation/Violation
• Early Study Termination
• Queries and Complaints
• Serious Adverse Event reports (SAEs) and Suspected Unexpected Serious
Adverse Reactions (SUSARs)
• Site Visit
RECORDS
(ICH GCP 3.4)
IF IT IS NOT WRITTEN,
IT DID NOT HAPPEN.
RECORDS
• Relevant records
• written procedures
• membership lists
• lists of occupations/affiliations of members
• submitted documents
• minutes of meetings
• correspondence
• Retain for a period of at least 3 years after completion of the trial and make
them available upon request from the regulatory authority (ies)
• Provide investigators, sponsors or regulatory authorities with its written
procedures and membership lists
Review Fees (NEGHHR 2017)
Review fees are intended to support the operations of the REC,
training activities, and continuing education of its members. Charging
review fees for other purposes puts the REC in a COI situation, from
which it may not be easy to extricate itself.
Three Important Obligations Placed on the
Research Ethics Committee
1. Research participants; rights must be protected by ensuring that:
a. individuals receive sufficient information which can be easily understood
b. appropriate strategies are in place to protect participants from potential
adverse consequences of the research
Chair and Members deliberate full board study protocols in committee meeting
↓
Secretariat communicates results to PI/Participant
(7 days after full board meeting for full board review; 3 days after review of Primary Reviewers)
SERIOUS ADVERSE EVENTS
REVIEW
SAE Review
• SAE and SUSAR reports are submitted by investigators and sponsors to
comply with ICH GCP.
• SAE - Serious Adverse Event; serious adverse drug reaction (ADR); any
untoward medical occurrence that at any dose:
• results in death,
• is life threatening,
• requires hospitalization or prolongation of existing hospitalization,
• results in persistent or significant disability or incapacity, or
• results in a congenital anomaly or birth defect,
• any other adverse event that, based upon appropriate medical judgment, may
jeopardize the subject’s health and may require medical or surgical intervention to
prevent one of the other outcomes listed in this definition.
SAE Review
• SUSAR - Suspected Unexpected Serious Adverse
Reaction
• serious event; nature and severity is not consistent with
the applicable product information
• Investigator’s Brochure (or its equivalent) for unapproved
investigational product
• Package insert or summary of product characteristics for a
licensed product
SAE Review
• FEU NRMF IERC can suspend or terminate approval of research at
its site when the safety of participants is no longer assured; FEU
NRMF IERC must:
• provide the reasons for its action
• pomptly report such decision to the investigator, the sponsor, the institution
and relevant regulatory authorities.
• FEU-NRMF IERC Vice Chair - head of the SAE Subcommittee
• The SAE Subcommittee
• Vice Chair
• Primary Reviewers of the study protocol with SAE/SUSAR submission
SAE Review
• All onsite SAEs and SUSARs undergo Expedited Review
(unless the SAE subcommittee recommends that the issue
be deliberated on in a full board meeting) in order to hasten
the decision-making, especially when the safety of study
participants are involved