1 00:00:13,240 --> 00:00:15,140 >> Elizabeth Ness: Hello, my name is Liz Ness. 2 00:00:15,140 --> 00:00:17,260 And I'm the director of the Office of Education 3 00:00:17,260 --> 00:00:20,020 and Compliance in the Center for Cancer Research 4 00:00:20,020 --> 00:00:21,730 at the National Cancer Institute. 5 00:00:22,510 --> 00:00:24,850 Identifying and monitoring adverse events 6 00:00:24,850 --> 00:00:27,950 is critical to protecting research participants 7 00:00:27,950 --> 00:00:29,990 and ensuring data integrity. 8 00:00:29,990 --> 00:00:33,100 Welcome to a four-part series on adverse events. 9 00:00:33,750 --> 00:00:36,620 Part one, will focus on AE definitions. 10 00:00:36,620 --> 00:00:41,030 Part two, will focus on AE assessment and documentation. 11 00:00:41,030 --> 00:00:44,550 Part three, will focus on reporting of adverse events 12 00:00:44,550 --> 00:00:46,460 or investigational new drug 13 00:00:46,460 --> 00:00:49,410 and investigational device exemption studies. 14 00:00:49,410 --> 00:00:51,740 And the final module, part four, 15 00:00:51,740 --> 00:00:54,730 focuses on reportable events to the IRB, 16 00:00:54,730 --> 00:00:57,770 which includes more than just adverse event reporting. 17 00:00:59,840 --> 00:01:01,740 Understanding the various definitions 18 00:01:01,740 --> 00:01:03,600 associated with adverse events 19 00:01:03,600 --> 00:01:06,890 is the first step to understanding adverse events. 20 00:01:06,890 --> 00:01:08,470 At the end of part one, 21 00:01:08,470 --> 00:01:11,490 I hope that you will be able to define the following; 22 00:01:11,490 --> 00:01:14,660 an adverse event; a serious adverse event; 23 00:01:14,660 --> 00:01:18,860 a life-threatening event; an unexpected adverse event; 24 00:01:18,860 --> 00:01:21,450 a suspected adverse reaction; 25 00:01:21,450 --> 00:01:25,190 and finally, an unexpected adverse device effect. 26 00:01:26,900 --> 00:01:29,340 Let's first take a look at a summary definition 27 00:01:29,340 --> 00:01:30,940 of an adverse event. 28 00:01:31,530 --> 00:01:34,420 An adverse event is any unwanted sign, symptom, 29 00:01:34,420 --> 00:01:36,820 or disease that was not seen 30 00:01:36,820 --> 00:01:39,980 before an individual's research participation, 31 00:01:39,980 --> 00:01:42,640 or a worsening of a baseline symptom 32 00:01:42,640 --> 00:01:46,140 regardless of expectedness or relationship to research. 33 00:01:47,510 --> 00:01:51,420 It is important to note that multiple clinical terms 34 00:01:51,420 --> 00:01:54,060 have been used to convey an adverse event 35 00:01:54,060 --> 00:01:57,400 including toxicity, side effect, acute 36 00:01:57,400 --> 00:02:01,580 or late effect, complication, adverse drug reaction. 37 00:02:02,250 --> 00:02:05,270 However, all of the terms you see on this slide 38 00:02:05,270 --> 00:02:09,570 imply that an intervention caused the adverse event. 39 00:02:09,570 --> 00:02:12,410 Which as the previous slide showed, 40 00:02:12,410 --> 00:02:15,060 is not what the definition of an adverse event 41 00:02:15,060 --> 00:02:16,660 is in clinical research. 42 00:02:18,310 --> 00:02:22,150 The purposes of adverse event monitoring or surveillance, 43 00:02:22,150 --> 00:02:25,440 especially for those events related to this study 44 00:02:25,440 --> 00:02:29,000 intervention or procedures include; 45 00:02:29,000 --> 00:02:32,610 identifying events that may have immediate effect 46 00:02:32,610 --> 00:02:36,190 on the safety of our research participants; helps -- 47 00:02:36,190 --> 00:02:39,490 they help to inform our regulators, investigators, 48 00:02:39,490 --> 00:02:42,310 and others of new and important information 49 00:02:42,310 --> 00:02:44,410 about adverse events; 50 00:02:44,410 --> 00:02:48,700 and finally, they provide a summary of adverse experiences 51 00:02:48,700 --> 00:02:50,790 in order to develop the -- 52 00:02:50,790 --> 00:02:54,600 a drug or regimen toxicity profile. 53 00:02:56,930 --> 00:02:59,460 The first slide with the AE definition 54 00:02:59,460 --> 00:03:02,180 is sort of what I refer to as my summary slide. 55 00:03:02,700 --> 00:03:05,100 So, now let's take a look at the evidence 56 00:03:05,100 --> 00:03:07,490 that helps to support that definition. 57 00:03:08,140 --> 00:03:10,630 So, there are various definitions 58 00:03:10,630 --> 00:03:12,500 from different regulators. 59 00:03:12,500 --> 00:03:14,810 The first, the U.S. Department of Health 60 00:03:14,810 --> 00:03:20,500 and Human Services regulations at 45 CFR part 46, 61 00:03:20,500 --> 00:03:24,580 actually does not define or use the term adverse event. 62 00:03:24,580 --> 00:03:27,600 However, the Office for Human Research Protection, 63 00:03:27,600 --> 00:03:28,930 or OHRP, 64 00:03:28,930 --> 00:03:32,200 which provides leadership in the protection 65 00:03:33,190 --> 00:03:38,330 of our research participants and the welfare of them, 66 00:03:39,860 --> 00:03:43,670 they do define adverse event in a guidance document. 67 00:03:43,670 --> 00:03:45,460 In their guidance on reviewing 68 00:03:45,460 --> 00:03:47,790 and reporting unanticipated problems 69 00:03:47,790 --> 00:03:50,390 involving risks to subjects or others, 70 00:03:50,390 --> 00:03:52,080 and adverse events, 71 00:03:52,080 --> 00:03:54,850 the term adverse event is used very broadly. 72 00:03:54,850 --> 00:03:58,390 And includes an event meeting the following definition, 73 00:03:58,390 --> 00:04:02,850 “any untoward or unfavorable medical occurrence 74 00:04:02,850 --> 00:04:04,130 in a human subject, 75 00:04:04,130 --> 00:04:07,190 including any abnormal sign, for example, 76 00:04:07,190 --> 00:04:09,500 an abnormal physical exam or laboratory 77 00:04:09,500 --> 00:04:13,860 finding, symptom, or disease temporally associated 78 00:04:13,860 --> 00:04:16,830 with the subject's participation in the research, 79 00:04:16,830 --> 00:04:18,250 whether or not considered 80 00:04:18,250 --> 00:04:22,830 related to the subject's participation in the research”. 81 00:04:22,830 --> 00:04:26,620 This definition has been modified from the definition 82 00:04:26,620 --> 00:04:28,840 of adverse events in the -- 83 00:04:28,840 --> 00:04:33,420 from the 1996 International Council for Harmonisation, 84 00:04:33,420 --> 00:04:38,720 or ICH E6 Guidelines for Good Clinical Practice. 85 00:04:38,720 --> 00:04:40,440 Which we'll look at shortly. 86 00:04:43,490 --> 00:04:48,150 Under the FDA investigational new drug application regulations 87 00:04:48,150 --> 00:04:53,860 found at 21 CFR part 312, the FDA defines an adverse event 88 00:04:53,860 --> 00:04:56,180 as any untoward medical occurrence 89 00:04:56,180 --> 00:04:59,770 associated with the use of a drug in humans, 90 00:04:59,770 --> 00:05:02,660 whether or not considered drug related. 91 00:05:04,630 --> 00:05:08,640 And finally, the International Council for Harmonisation 92 00:05:08,640 --> 00:05:12,400 of Technical Requirements for Pharmaceuticals for Human 93 00:05:12,400 --> 00:05:15,210 Use Good Clinical Practice Guidelines, 94 00:05:15,210 --> 00:05:19,550 or simply ICH GCP, defines an adverse event 95 00:05:19,550 --> 00:05:21,330 as any untoward medical occurrence 96 00:05:21,330 --> 00:05:23,710 in a research participant administered 97 00:05:23,710 --> 00:05:28,970 a pharmaceutical product and which does not necessarily 98 00:05:28,970 --> 00:05:31,600 have a causal relationship with a treatment. 99 00:05:31,600 --> 00:05:34,060 You can see how this is similar then 100 00:05:34,060 --> 00:05:37,080 to OHRP's guidance definition. 101 00:05:37,080 --> 00:05:41,260 However, please note that at the time of this taping, 102 00:05:41,260 --> 00:05:44,280 there is a draft version of GCP Guidelines, 103 00:05:44,280 --> 00:05:50,140 which provides a slightly varied definition of adverse event. 104 00:05:50,140 --> 00:05:54,460 The draft guidelines, which came out in May of 2023, 105 00:05:54,460 --> 00:05:58,320 defines an adverse event as any unfavorable medical occurrence 106 00:05:58,320 --> 00:05:59,920 in a trial participant. 107 00:06:00,450 --> 00:06:02,690 The adverse event does not necessarily 108 00:06:02,690 --> 00:06:05,250 have a causal relationship with the treatment. 109 00:06:05,250 --> 00:06:08,310 So, it is slightly different, intent the same. 110 00:06:10,220 --> 00:06:12,680 So, let's take a look at a few more definitions 111 00:06:12,680 --> 00:06:14,680 associated with adverse events. 112 00:06:16,870 --> 00:06:18,740 We're going to take a look at serious, 113 00:06:18,740 --> 00:06:22,940 life-threatening, unexpected, SAR, and UADE. 114 00:06:22,940 --> 00:06:25,000 So, a little bit of alphabet soup there. 115 00:06:26,730 --> 00:06:28,510 So, a serious adverse event 116 00:06:28,510 --> 00:06:31,580 is based on the outcome of the adverse event. 117 00:06:31,580 --> 00:06:33,220 It doesn't have anything to do 118 00:06:33,220 --> 00:06:36,360 with how severe the adverse event was. 119 00:06:37,670 --> 00:06:41,540 And this is used to help determine reportability 120 00:06:41,540 --> 00:06:43,020 to our regulators, 121 00:06:43,020 --> 00:06:47,040 whether that's to the IRB or to the FDA. 122 00:06:47,980 --> 00:06:51,380 So, a serious adverse event is an adverse event 123 00:06:51,380 --> 00:06:54,510 that results in any of the following; 124 00:06:55,200 --> 00:06:59,480 a death, life-threatening adverse drug experience; 125 00:06:59,480 --> 00:07:02,780 an inpatient hospitalization or prolongation 126 00:07:02,780 --> 00:07:04,780 of an existing hospitalization; 127 00:07:05,350 --> 00:07:08,520 persistent or significant incapacity 128 00:07:08,520 --> 00:07:11,440 or substantial disruption of the ability 129 00:07:11,440 --> 00:07:13,640 to conduct normal life functions; 130 00:07:14,300 --> 00:07:17,920 a congenital anomaly birth defect; 131 00:07:18,840 --> 00:07:22,610 or an important medical event, 132 00:07:22,610 --> 00:07:25,520 or IME, that may not result in death, 133 00:07:25,520 --> 00:07:28,640 be life-threatening, or require a hospitalization, 134 00:07:29,790 --> 00:07:31,770 but may be considered serious 135 00:07:31,770 --> 00:07:35,260 when based on appropriate medical judgment, 136 00:07:36,040 --> 00:07:38,920 it may jeopardize the patient or the subject 137 00:07:38,920 --> 00:07:42,190 and may require medical or surgical intervention 138 00:07:42,190 --> 00:07:46,470 to prevent one of the outcomes listed in this definition. 139 00:07:46,470 --> 00:07:50,270 An example of that is an allergic bronchospasm 140 00:07:50,270 --> 00:07:52,180 requiring intensive treatment 141 00:07:52,180 --> 00:07:54,690 either in an emergency room or at home. 142 00:07:58,440 --> 00:08:01,300 So, let's take a moment to look at the definitions 143 00:08:01,300 --> 00:08:05,160 that are associated then with the SAE definition. 144 00:08:05,160 --> 00:08:07,220 One of those is life-threatening. 145 00:08:07,990 --> 00:08:10,760 A life-threatening event is an adverse event 146 00:08:10,760 --> 00:08:14,360 or a suspected adverse reaction if, 147 00:08:14,360 --> 00:08:17,840 in the view of either the investigator or the sponsor, 148 00:08:18,380 --> 00:08:23,140 it occurs -- its occurrence places the patient or subject 149 00:08:23,140 --> 00:08:25,560 at immediate risk of death. 150 00:08:25,560 --> 00:08:27,780 It does not include an adverse event 151 00:08:28,320 --> 00:08:31,070 or a suspected adverse reaction that, 152 00:08:31,680 --> 00:08:36,470 had it might been more severe, it might have caused death. 153 00:08:37,480 --> 00:08:39,940 And again, that's an example -- 154 00:08:40,450 --> 00:08:42,960 the example of the allergic bronchospasm 155 00:08:43,480 --> 00:08:45,830 fits this category as well. 156 00:08:48,500 --> 00:08:50,980 So, regulations and guidances 157 00:08:51,730 --> 00:08:55,650 don't really define what an expected event is, 158 00:08:55,650 --> 00:08:59,640 but rather when an event is deemed unexpected. 159 00:09:01,140 --> 00:09:04,640 So, when looking at the FDA definition 160 00:09:04,640 --> 00:09:10,030 under the IND application, when assessing an adverse event 161 00:09:10,030 --> 00:09:13,750 to determine if you need to report this 162 00:09:13,750 --> 00:09:16,370 in what we refer to as an expedited manner, 163 00:09:16,370 --> 00:09:18,640 which we'll talk more about in part three, 164 00:09:19,260 --> 00:09:22,460 an adverse event then would be considered unexpected if; 165 00:09:22,460 --> 00:09:25,200 it wasn't listed in the investigator brochure; 166 00:09:26,160 --> 00:09:30,560 or at the specificity or severity that has been observed; 167 00:09:32,080 --> 00:09:36,860 or if the investigator brochure is not required 168 00:09:36,860 --> 00:09:38,500 or not available, 169 00:09:38,500 --> 00:09:41,650 that it's not consistent with the general risk information 170 00:09:41,650 --> 00:09:45,160 described in the investigational plan, 171 00:09:45,160 --> 00:09:47,230 otherwise known as a protocol, 172 00:09:47,230 --> 00:09:50,560 or elsewhere in the IND application; 173 00:09:51,800 --> 00:09:53,380 if it's mentioned in the IB 174 00:09:53,380 --> 00:09:57,380 as occurring with the drug class or anticipated -- 175 00:09:58,520 --> 00:09:59,830 or it's anticipated 176 00:09:59,830 --> 00:10:03,300 based on pharmacological properties of the drug, 177 00:10:04,220 --> 00:10:06,520 but it may not be specifically mentioned 178 00:10:06,520 --> 00:10:08,450 in the investigator brochure. 179 00:10:10,230 --> 00:10:15,900 So, here are the definitions of -- for OHRP and ICH GCP 180 00:10:16,990 --> 00:10:22,060 for an unexpected adverse event. 181 00:10:22,060 --> 00:10:26,880 So, OHRP guidance defines an AE that's not described 182 00:10:26,880 --> 00:10:29,760 in terms of the nature, severity, or frequency. 183 00:10:30,710 --> 00:10:34,770 Or in GCP definition, it's an adverse reaction, 184 00:10:34,770 --> 00:10:37,940 the nature or severity of which is not consistent 185 00:10:37,940 --> 00:10:40,740 with what is known already about the product, 186 00:10:41,380 --> 00:10:44,710 such as what's found in the investigator brochure 187 00:10:44,710 --> 00:10:46,310 or a package insert. 188 00:10:49,180 --> 00:10:53,150 So, a couple of other FDA definitions to look at. 189 00:10:53,150 --> 00:10:56,770 I had mentioned previously a suspected adverse reaction. 190 00:10:57,300 --> 00:11:01,030 And a SAR, S-A-R, is basically an adverse event 191 00:11:01,030 --> 00:11:05,350 related to the drug being studied on a clinical trial. 192 00:11:05,350 --> 00:11:10,850 FDA's definition is any AE for which there is a reasonable 193 00:11:10,850 --> 00:11:14,550 possibility that the drug caused the adverse event. 194 00:11:15,470 --> 00:11:20,560 And reasonable possibility means there is evidence to suggest 195 00:11:20,560 --> 00:11:25,140 a causal relationship between the drug and the adverse event. 196 00:11:25,140 --> 00:11:30,080 And that bolded and underlined "evidence" is really key. 197 00:11:30,080 --> 00:11:32,930 This can include a single occurrence 198 00:11:32,930 --> 00:11:35,500 of an adverse event that's uncommon 199 00:11:36,160 --> 00:11:40,000 and known to be strongly associated with drug exposure. 200 00:11:40,700 --> 00:11:43,590 Or one or more occurrences of an adverse event 201 00:11:43,590 --> 00:11:46,890 that is not commonly associated with drug exposure, 202 00:11:46,890 --> 00:11:49,710 but is otherwise uncommon in the population 203 00:11:50,270 --> 00:11:52,020 that has been exposed to the drug. 204 00:11:52,540 --> 00:11:56,710 Or finally, an aggregate analysis of specific events 205 00:11:56,710 --> 00:11:58,940 observed in a clinical trial 206 00:11:58,940 --> 00:12:01,370 that indicates those events occur 207 00:12:01,370 --> 00:12:04,510 more frequently in the drug treatment group 208 00:12:04,510 --> 00:12:09,530 than in a concurrent group or a historical control group. 209 00:12:11,780 --> 00:12:14,080 And then finally, in device research, 210 00:12:14,080 --> 00:12:15,600 the FDA regulations 211 00:12:15,600 --> 00:12:18,990 don't specifically define serious or life-threatening. 212 00:12:19,730 --> 00:12:22,290 But understanding these definitions, 213 00:12:22,290 --> 00:12:24,410 as we have already looked at them, 214 00:12:24,410 --> 00:12:27,980 will help you to understand and to know when you have 215 00:12:27,980 --> 00:12:32,790 an unanticipated adverse device effect, or UADE. 216 00:12:33,680 --> 00:12:37,900 This is any serious adverse effect on the health or safety 217 00:12:37,900 --> 00:12:41,310 of any life-threatening problem or death caused by 218 00:12:41,310 --> 00:12:45,180 or associated with a device, if that effect, problem, 219 00:12:45,180 --> 00:12:49,110 or death was not previously identified in nature, 220 00:12:49,110 --> 00:12:52,220 severity, or degree of incidences 221 00:12:52,220 --> 00:12:55,240 in the investigational plan or application. 222 00:12:55,940 --> 00:12:59,420 Or any other unanticipated serious problem 223 00:12:59,420 --> 00:13:02,680 associated with the device that relates to the rights, 224 00:13:02,680 --> 00:13:04,810 safety, or welfare of the subjects. 225 00:13:05,320 --> 00:13:07,800 So, slightly different, 226 00:13:07,800 --> 00:13:11,200 but you see common threads of nature and severity. 227 00:13:13,530 --> 00:13:17,000 So, in closing, adverse event surveillance 228 00:13:17,000 --> 00:13:20,650 helps to ensure the safety of our research participants. 229 00:13:20,650 --> 00:13:24,680 It's critical to understand that the definition of an AE 230 00:13:24,680 --> 00:13:27,830 is regardless of the expectedness or relationship 231 00:13:27,830 --> 00:13:29,660 to the research. 232 00:13:29,660 --> 00:13:32,010 And that there are other definitions 233 00:13:32,010 --> 00:13:36,400 that we have reviewed that will assist you in determining 234 00:13:36,400 --> 00:13:40,860 if and how an adverse event will be reported to sponsors 235 00:13:40,860 --> 00:13:42,840 or other regulatory bodies. 236 00:13:44,800 --> 00:13:46,400 So, let's test your knowledge. 237 00:13:47,110 --> 00:13:49,260 What is the definition of an adverse event? 238 00:13:50,000 --> 00:13:53,820 Is it, A, a known toxicity of the study agent? 239 00:13:53,820 --> 00:13:56,200 B, any untoward sign or symptom 240 00:13:56,200 --> 00:13:58,700 that occurs during the course of a clinical trial? 241 00:13:59,230 --> 00:14:03,210 C, any adverse event which the PI decides to report 242 00:14:03,210 --> 00:14:05,109 during the course of a clinical trial? 243 00:14:05,780 --> 00:14:08,620 Or a side effect caused by the study agent? 244 00:14:09,930 --> 00:14:12,420 And the correct answer is actually B. 245 00:14:13,090 --> 00:14:16,080 Remember, toxicity, side effect, 246 00:14:16,830 --> 00:14:20,100 imply an attribution or a relationship, 247 00:14:20,100 --> 00:14:22,899 which is not part of the definition of an adverse event. 248 00:14:23,410 --> 00:14:28,030 And the PI needs to follow what the definition of an A is -- 249 00:14:28,770 --> 00:14:33,500 AE is not just make that decision on themselves. 250 00:14:34,170 --> 00:14:36,060 And one more test your knowledge. 251 00:14:37,260 --> 00:14:40,600 What type of adverse event is the following scenario? 252 00:14:41,180 --> 00:14:44,730 A research participant slips on an icy sidewalk 253 00:14:44,730 --> 00:14:48,610 and suffers a leg fracture requiring an inpatient surgery. 254 00:14:49,360 --> 00:14:51,750 The investigator says this is not related 255 00:14:51,750 --> 00:14:53,560 to the investigational product. 256 00:14:55,380 --> 00:14:59,330 So, A, it's not an adverse event at all. 257 00:14:59,330 --> 00:15:04,720 B, it's an AE only. C, it's an adverse reaction. 258 00:15:04,720 --> 00:15:10,130 D, it's a serious adverse event. And the correct answer is D. 259 00:15:10,130 --> 00:15:12,960 It is an SAE, or a serious adverse event. 260 00:15:13,820 --> 00:15:17,280 Thank you for listening to part one of Adverse Events.