1 00:00:17,817 --> 00:00:19,586 >> Alissa Mun: Hello. My name is Alissa Mun, 2 00:00:19,652 --> 00:00:21,354 and I'm in the Clinical Center, 3 00:00:21,421 --> 00:00:23,723 Office of Research Support and Compliance, 4 00:00:23,790 --> 00:00:26,493 Clinical Research Quality Management section. 5 00:00:26,559 --> 00:00:29,662 And today I'm going to introduce good clinical practices 6 00:00:29,729 --> 00:00:34,501 that are known as GCP or ICHE6(r2). 7 00:00:34,567 --> 00:00:36,136 The goals of today's session 8 00:00:36,202 --> 00:00:39,005 are understanding core elements of GCP -- 9 00:00:39,072 --> 00:00:41,374 I'll provide you a historical background, 10 00:00:41,441 --> 00:00:45,178 and then the core principles of ICHE6(r2). 11 00:00:45,245 --> 00:00:47,514 You'll be able to recognize who is involved 12 00:00:47,580 --> 00:00:49,249 in good clinical practices, 13 00:00:49,315 --> 00:00:51,718 and finally, how you implement GCP 14 00:00:51,785 --> 00:00:53,386 in your clinical research study. 15 00:00:54,754 --> 00:00:57,590 There are three critical principles 16 00:00:57,657 --> 00:00:59,626 that are universally recognized 17 00:00:59,692 --> 00:01:01,728 when we think about good clinical practices, 18 00:01:01,795 --> 00:01:04,631 and that is safety, ethics, and quality. 19 00:01:04,697 --> 00:01:06,132 When we think about safety, 20 00:01:06,199 --> 00:01:07,634 it's to protect the rights, safety, 21 00:01:07,700 --> 00:01:11,137 and welfare of human subjects participating in research. 22 00:01:11,204 --> 00:01:13,807 And in ethics, it's to provide ethical standards 23 00:01:13,873 --> 00:01:16,576 and guidelines for the conduct of the research. 24 00:01:16,643 --> 00:01:20,246 And then finally, the quality of data that is being collected, 25 00:01:20,313 --> 00:01:24,284 and this also helps in promoting reproducibility of trial data. 26 00:01:25,051 --> 00:01:27,754 Now, we did not come up with GCP on our own, 27 00:01:27,821 --> 00:01:30,490 and there were significant historical events 28 00:01:30,557 --> 00:01:33,760 which were the foundation of what is known today as GCP. 29 00:01:35,895 --> 00:01:38,565 In the 1940s, there was the Nuremberg Code, 30 00:01:39,065 --> 00:01:41,768 which was a direct result of the atrocities 31 00:01:41,835 --> 00:01:43,870 inflicted in the concentration camps 32 00:01:43,937 --> 00:01:46,539 of unethical human experimentations. 33 00:01:47,040 --> 00:01:48,241 The Nuremberg Code 34 00:01:48,308 --> 00:01:52,245 focuses on human rights of research subjects, 35 00:01:52,312 --> 00:01:55,315 and those three elements are voluntary participation, 36 00:01:55,815 --> 00:01:58,384 informed consent, and minimization of risk. 37 00:01:59,786 --> 00:02:03,189 In the 1964, there was the Declaration of Helsinki, 38 00:02:03,256 --> 00:02:06,793 and this with the main principle to set ethical principles 39 00:02:06,860 --> 00:02:10,196 developed from the medical community from the WMA 40 00:02:10,263 --> 00:02:12,665 that are known as the World Medical Association. 41 00:02:13,299 --> 00:02:16,269 It is widely known as the cornerstone document 42 00:02:16,336 --> 00:02:18,571 of human research and ethics. 43 00:02:18,638 --> 00:02:21,608 They focus on the respective persons, 44 00:02:22,208 --> 00:02:24,944 the protection of subjects' health and rights, 45 00:02:25,011 --> 00:02:26,145 and when we think about this, 46 00:02:26,212 --> 00:02:28,915 we also want to ensure pre-clinical data. 47 00:02:29,415 --> 00:02:32,352 And this was a result of the thalidomide trials 48 00:02:32,418 --> 00:02:35,121 where pregnant women were provided thalidomide 49 00:02:35,188 --> 00:02:38,157 and resulted in severe birth defects or deaths. 50 00:02:39,292 --> 00:02:40,994 There's also this special protection 51 00:02:41,060 --> 00:02:42,996 now of the vulnerable populations, 52 00:02:43,930 --> 00:02:47,400 the adults with the incapacity to consent, 53 00:02:47,467 --> 00:02:50,203 or we think -- we think about the minors. 54 00:02:50,270 --> 00:02:53,206 And this required a legally authorized representative 55 00:02:53,273 --> 00:02:54,908 to consent for these individuals. 56 00:02:54,974 --> 00:03:00,146 In 1979, there was the Belmont Report, 57 00:03:00,213 --> 00:03:03,182 and there are three main elements in the Belmont Report 58 00:03:03,249 --> 00:03:06,085 that talk about respective persons with the informed 59 00:03:06,152 --> 00:03:08,855 consent and protection of vulnerable populations, 60 00:03:09,422 --> 00:03:12,025 beneficence, which means do no harm, 61 00:03:12,091 --> 00:03:13,860 better known in the medical community, 62 00:03:13,927 --> 00:03:15,094 and then justice, 63 00:03:15,161 --> 00:03:17,764 which is the fairness in selection of subjects. 64 00:03:17,830 --> 00:03:21,868 The Belmont Report was a result of the Tuskegee trials, 65 00:03:21,935 --> 00:03:23,536 and I highly recommend that -- 66 00:03:24,370 --> 00:03:26,873 considering reading the Nuremberg trials, 67 00:03:26,940 --> 00:03:28,107 the thalidomide trial, 68 00:03:28,174 --> 00:03:30,076 and Tuskegee trials to learn more on 69 00:03:30,143 --> 00:03:32,979 how clinical research has evolved over time. 70 00:03:34,113 --> 00:03:36,182 From these documents, a lot of countries 71 00:03:36,249 --> 00:03:39,519 then began to create multiple different guidelines, 72 00:03:39,586 --> 00:03:41,788 and it became problematic in the industry. 73 00:03:42,355 --> 00:03:45,491 And thus, the International Conference of Harmonization 74 00:03:45,558 --> 00:03:49,662 was created to look at standardization 75 00:03:49,729 --> 00:03:51,431 of good clinical practices. 76 00:03:53,399 --> 00:03:57,070 So today we have the ICHE6(r2), 77 00:03:57,136 --> 00:04:00,239 which is the International Conference on Harmonization 78 00:04:00,306 --> 00:04:03,710 of Good Clinical Practices. What this does -- what it was -- 79 00:04:03,776 --> 00:04:06,212 it brought together regulatory authorities 80 00:04:06,279 --> 00:04:09,616 and the pharmaceutical industries to discuss scientific 81 00:04:09,682 --> 00:04:12,518 and technical aspects of drug registration 82 00:04:12,585 --> 00:04:15,922 and how to formalize the conduct of research. 83 00:04:17,056 --> 00:04:19,258 ICH has gradually evolved over time, 84 00:04:19,892 --> 00:04:23,696 and by responding to the increasing global development 85 00:04:23,763 --> 00:04:25,698 of drugs within the world, 86 00:04:25,765 --> 00:04:29,335 as well as the technological advancements that we have today. 87 00:04:30,236 --> 00:04:33,806 ICHE6(r2) is focused on the ethical 88 00:04:33,873 --> 00:04:36,843 and scientific quality standards for designing, 89 00:04:36,909 --> 00:04:38,778 conducting, recording, 90 00:04:38,845 --> 00:04:42,048 and reporting of trials that involve human subjects. 91 00:04:44,083 --> 00:04:47,320 So, who has adopted ICHE6(r2)? 92 00:04:47,387 --> 00:04:49,188 Hundreds of countries have adopted this, 93 00:04:49,255 --> 00:04:51,691 and it is widely accepted and expected 94 00:04:51,758 --> 00:04:54,193 in all research involving human subjects. 95 00:04:55,495 --> 00:04:59,632 But there are 13 core principles of ICHE6(r2), 96 00:04:59,699 --> 00:05:01,768 and I'll go through each one of them now. 97 00:05:02,802 --> 00:05:05,304 There's the ethical conduct of research, 98 00:05:05,371 --> 00:05:07,407 ensuring that it is in accordance 99 00:05:07,473 --> 00:05:09,075 with the Declaration of Helsinki, 100 00:05:09,142 --> 00:05:11,044 as mentioned before, 101 00:05:11,110 --> 00:05:14,180 that the benefit justifies the risk of the patients, 102 00:05:14,747 --> 00:05:17,383 and that the rights, safety, and well-being of subjects 103 00:05:17,450 --> 00:05:20,420 prevails over all the interest of science. 104 00:05:21,120 --> 00:05:24,157 And then when we think about the protocol in and of itself, 105 00:05:24,223 --> 00:05:26,526 we want to ensure that non-clinical 106 00:05:26,592 --> 00:05:29,128 and clinical information support the trial 107 00:05:29,195 --> 00:05:31,230 that you will plan on conducting 108 00:05:31,297 --> 00:05:35,068 and that it is in compliance with scientifically sound data. 109 00:05:35,134 --> 00:05:36,402 And that should be, again, 110 00:05:36,469 --> 00:05:38,204 detailed in your research protocol. 111 00:05:40,339 --> 00:05:43,776 There are major responsibilities when it comes to GCP, 112 00:05:43,843 --> 00:05:46,312 and those are, of course, within your IRB 113 00:05:46,379 --> 00:05:47,947 or your ethics committee, 114 00:05:48,014 --> 00:05:50,383 and there must be approval from these committees 115 00:05:50,450 --> 00:05:52,819 prior to the initiation of your research. 116 00:05:53,720 --> 00:05:56,155 You want to ensure that the individuals 117 00:05:56,222 --> 00:05:59,092 that are providing medical care or decisions 118 00:05:59,158 --> 00:06:01,994 are done by a qualified physician or dentist 119 00:06:02,595 --> 00:06:07,834 and that any individual that is involved in clinical research 120 00:06:07,900 --> 00:06:10,670 and are delegated to perform specific tasks 121 00:06:11,270 --> 00:06:14,073 are qualified either by education, training, 122 00:06:14,140 --> 00:06:15,742 and/or experience. 123 00:06:16,876 --> 00:06:18,845 And of course, you have informed consent, 124 00:06:18,911 --> 00:06:21,748 that informed consent is provided to all subjects 125 00:06:21,814 --> 00:06:23,616 and that they are provided freely 126 00:06:23,683 --> 00:06:25,418 to make their own decision 127 00:06:25,485 --> 00:06:27,320 and there's no coercion involved. 128 00:06:28,354 --> 00:06:30,256 You have your, of course, your data, 129 00:06:30,323 --> 00:06:31,457 and they want to ensure 130 00:06:31,524 --> 00:06:34,761 that the data is accurately recording, reporting, 131 00:06:34,827 --> 00:06:38,931 and handling verification and storage of that data, 132 00:06:39,632 --> 00:06:41,901 and to ensure that there are special protections 133 00:06:41,968 --> 00:06:44,937 involved for the confidentiality of those records. 134 00:06:47,707 --> 00:06:49,041 In your research study, 135 00:06:49,108 --> 00:06:51,110 you will have your investigational products, 136 00:06:51,177 --> 00:06:54,714 and you want to ensure that they conform to the current good 137 00:06:54,781 --> 00:06:57,784 manufacturing practices that are used in your protocol. 138 00:06:58,551 --> 00:07:01,921 And finally, quality control and quality insurance. 139 00:07:01,988 --> 00:07:03,856 You want to ensure that these are in place 140 00:07:03,923 --> 00:07:05,992 for the systems that you have to ensure 141 00:07:06,058 --> 00:07:08,795 the quality of all aspects of your trial. 142 00:07:09,328 --> 00:07:15,468 That includes electronic systems as well as standards of SOPs 143 00:07:16,736 --> 00:07:18,337 or manuals of operations. 144 00:07:20,473 --> 00:07:22,809 So where does GCP apply? 145 00:07:23,342 --> 00:07:26,045 This really applies anywhere that clinical trial data 146 00:07:26,112 --> 00:07:28,581 is being conducted, collected, or assessed. 147 00:07:29,115 --> 00:07:32,318 That is your research site, any laboratory, 148 00:07:32,385 --> 00:07:34,420 your pharmacy where they are maintaining 149 00:07:34,487 --> 00:07:36,455 your investigational product, 150 00:07:36,522 --> 00:07:39,826 imaging centers, CROs, the sponsors, 151 00:07:39,892 --> 00:07:42,061 and your other oversight committees. 152 00:07:44,697 --> 00:07:46,732 So now that we know where it applies, 153 00:07:46,799 --> 00:07:50,203 but who then is responsible for good clinical practice? 154 00:07:50,736 --> 00:07:52,672 That is, of course, the sponsors, 155 00:07:52,738 --> 00:07:53,906 and on a site level, 156 00:07:53,973 --> 00:07:56,609 the ultimate responsibility is of -- 157 00:07:56,676 --> 00:08:00,613 from the clinical investigators or principal investigators. 158 00:08:00,680 --> 00:08:03,249 They are the ones that are solely responsible 159 00:08:03,316 --> 00:08:05,218 for the conduct of research. 160 00:08:05,284 --> 00:08:07,220 You also have your research staff, 161 00:08:07,286 --> 00:08:10,056 which could be research nurses or data managers, 162 00:08:11,123 --> 00:08:15,661 your CRAs, or protocol monitors, any medical monitor. 163 00:08:15,728 --> 00:08:19,098 The research subjects themselves are also responsible for GCP, 164 00:08:19,165 --> 00:08:21,000 and then any regulatory authority. 165 00:08:23,402 --> 00:08:25,705 So in summary, protection of the rights 166 00:08:25,771 --> 00:08:28,140 and safety and welfare of participants 167 00:08:28,207 --> 00:08:30,276 are extremely important, and finally, 168 00:08:30,343 --> 00:08:33,112 to ensure the protection of their confidentiality. 169 00:08:34,413 --> 00:08:36,482 This, again, follows the three main things 170 00:08:36,549 --> 00:08:37,783 that I spoke of earlier, 171 00:08:37,850 --> 00:08:40,019 which is the safety, ethics, and quality. 172 00:08:41,454 --> 00:08:43,856 You want to ensure that there is informed consent process 173 00:08:43,923 --> 00:08:47,460 for all participants and that the data is secured in a -- 174 00:08:47,526 --> 00:08:49,195 in a secure location. 175 00:08:49,262 --> 00:08:51,998 What that means is if there are paper records, 176 00:08:52,064 --> 00:08:54,300 they should be in a double locked location, 177 00:08:54,834 --> 00:08:57,737 and if it is electronic, that they are stored, 178 00:08:57,803 --> 00:09:00,006 password protected with limited access. 179 00:09:00,973 --> 00:09:03,943 You want to ensure you follow your approved protocol 180 00:09:04,010 --> 00:09:05,878 where you treat it like a contract. 181 00:09:05,945 --> 00:09:08,881 This is your agreement not only to yourself as the -- 182 00:09:08,948 --> 00:09:11,217 as the principal investigator, 183 00:09:12,018 --> 00:09:15,388 but also to the IRB as well as your research participants. 184 00:09:16,289 --> 00:09:17,924 You also want to ensure research staff 185 00:09:17,990 --> 00:09:19,992 are appropriately trained and qualified. 186 00:09:20,526 --> 00:09:24,063 How you do this is you maintain a delegation of authority log 187 00:09:24,130 --> 00:09:27,166 which details each individual's responsibilities 188 00:09:27,233 --> 00:09:28,601 and what they have been delegated 189 00:09:28,668 --> 00:09:31,971 by the clinical investigator or the principal investigator. 190 00:09:32,805 --> 00:09:35,441 You can also develop manual of operations 191 00:09:35,508 --> 00:09:40,513 or standard of operations in order to convey consistency. 192 00:09:42,815 --> 00:09:45,885 There's also the quality of data that you want to ensure accurate 193 00:09:45,952 --> 00:09:49,455 source documentation of your research data. 194 00:09:50,389 --> 00:09:52,158 This also means -- you will hear this 195 00:09:52,224 --> 00:09:54,961 consistently when people talk about GCP -- 196 00:09:55,027 --> 00:09:57,663 that if it's not documented, it didn't happen. 197 00:09:58,531 --> 00:10:00,433 And lastly, the investigational product 198 00:10:00,499 --> 00:10:03,302 should be manufactured in accordance to GMP. 199 00:10:07,173 --> 00:10:10,343 So now that we've gone through the presentation, 200 00:10:10,843 --> 00:10:14,947 just a few questions to get a sense of your understanding. 201 00:10:15,915 --> 00:10:17,516 So, what are the three core elements 202 00:10:17,583 --> 00:10:19,185 of good clinical practice? 203 00:10:20,653 --> 00:10:22,922 That is the safety, ethics, and quality. 204 00:10:25,324 --> 00:10:27,693 What is considered the cornerstone document 205 00:10:27,760 --> 00:10:29,362 of ethical human research? 206 00:10:31,263 --> 00:10:33,032 That's the Declaration of Helsinki. 207 00:10:35,167 --> 00:10:37,603 And lastly, who is ultimately responsible 208 00:10:37,670 --> 00:10:40,039 for good clinical practice at a site? 209 00:10:41,607 --> 00:10:43,809 And that would be your clinical investigator 210 00:10:43,876 --> 00:10:45,444 and principal investigator. 211 00:10:46,345 --> 00:10:48,414 I hope you were able to learn some of the core elements 212 00:10:48,481 --> 00:10:52,351 of good clinical practice, ICHE6(r2), 213 00:10:52,418 --> 00:10:54,220 and thank you so much for listening.