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A very good detailed presentation on ICH GCP.

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Page 1: ICH GCP

Overview of

ICH GCP

Syed Sarfaraz Uddin

e-mail: [email protected]

Page 2: ICH GCP

What is ICH?

ICH is a joint initiative involving both the regulators and the industry as equal partners in the scientific and technical discussions of the testing procedures which are required to ensure and assess the safety, quality and efficacy of medicines.

Page 3: ICH GCP

How did it evolve?

The need to harmonize Public disasters, serious fraud and

abuse of human rights. Trials of War criminals-Nuremberg

code 1949 Thalidomide- Declaration of Helsinki

1964 Belmont report 1978( Ethical Principles and

guidelines for the protection of human subjects of research)-Tuskegee syphilis study

Page 4: ICH GCP

History

1962 US FDA IND Guidelines

1964 Declaration of Helsinki

1968 Committee on Safety of Medicines, uk

1978 GCP, US FDA

1991 GCP, Europe

1996 ICH GCP

1997 ICH GCP Guideline

Page 5: ICH GCP

When did it begin?

Ist conf. in 1990 in Brussels

3 regions participated

Representatives from

Industry

Academia

Ministry of health

Page 6: ICH GCP

ICH parties

6 parties EU EFPIA European federation of pharmaceutical industries’

associations

MHLW Ministry of health, Labor and welfare, Japan

JPMA Japan Pharmaceuticals manufacturers Association

US FDA PhRMA Observers : WHO, TPP(canada) International federation of Pharmaceutical

manufacturer’s association

Page 7: ICH GCP

Key objective

To discuss and define the minimum standards for the development and registration of investigational products

Page 8: ICH GCP

The result?

Many guidelines made

Most important- ICH GCP guidelines Evolved in several steps Consolidated guideline ICH E6 Sept

1997

Page 9: ICH GCP

ICH Guidelines: examples

Efficacy: clinical trials etc

Safety: pharmacovigilance, adverse drug reaction

reporting Quality:

raw materials, impurities, residual solvents etc Multidisciplinary:

common technical document, electronic submission, coding systems

Page 10: ICH GCP

The ICH Story

Who: Regulatory authorities and research-based industry of the EU, US and Japan; WHO, EFTA and Canada observers

Why: Reduce unnecessary duplication and thereby contribute to the efficiency of drug development and registration for new pharmaceuticals

How: Through the development of science-based, international guidelines and standards

Page 11: ICH GCP

What is GCP?

A standard for the design, conduct, performance, monitoring ,auditing, recording, analyses and reporting of clinical trials that provide assurance that the data and the reported results are credible, accurate and that the rights, integrity and confidentiality of trial subjects are protected.

Page 12: ICH GCP

Why is it needed?

To ensure the rights, safety and well being of the trial subjects are protected

Ensure the credibility of clinical trial data

Page 13: ICH GCP

The ICH GCP guideline

Provide a unified standard for the EU, Japan and USA regions to facilitate mutual acceptance of clinical trial data

by the regulatory authorities in these regions.

?The need No acceptance of foreign clinical data Regional variation in reg guidelines Escalating costs Extended time for registration ICH region covers 85% of Pharm. sales

Page 14: ICH GCP

ICH GCP guideline

8 sections

Page 15: ICH GCP

ICH GCP guideline

1. Glossary

Common language for investigators/sponsors/ethics committees

2.Principles of Good Clinical Practice

13 tenets of ICH GCP

3.Requirements for IRB/IEC

Roles responsibilities and composition

Page 16: ICH GCP

ICH GCP guideline

4.Responsibilities of the investigator

5.Responsibilities of the sponsor

6.Requirements for clinical trial protocol and protocol amendments

7.Responsibility of the sponsor in the development of investigator’s brochure.

8.Essential documents

Page 17: ICH GCP

Principles of ICH GCP

Ethical conduct as per Declaration of Helsinki GCP Regulatory Requirements Risk- Benefit Primary concern- Subject

Page 18: ICH GCP

Principles of ICH GCP Supportive data

Protocol Scientifically sound, clear, detailed

Ethical Clearance Study to be conducted in compliance

to the protocol which has received EC approval

Page 19: ICH GCP

Principles of ICH GCP

Subject Care Medical decisions responsibility of

qualified physician Qualified staff By education, training, experience in

their area of responsibility Informed Consent

Page 20: ICH GCP

Principles of ICH GCP

Clinical Trial data Recorded, handled and stored to

enable accurate reporting, interpretation and verification

Confidentiality

Page 21: ICH GCP

Principles of ICH GCP

Investigational Product Manufactured, handled and stored as

per GMP

Used as per the protocol

Page 22: ICH GCP

Principles of ICH GCP

Quality Assurance

Systems and procedures to ensure the Quality of every aspect of the trial

Page 23: ICH GCP

Concerns about ICH

Industry driven agenda or public health oriented approach

Public health implications- inability to achieve standards and withdrawal of essential drugs

Misdirecting national priorities

Page 24: ICH GCP

ICH vs. non-ICH

ICH: 17 countries 15% world population 82% drug production 90% drug sales 95% R&D New Chemical Entities Chronic & lifestyle

diseases Strong DRAs $$$$$

“non-ICH”: 176 countries 85% world population 18% drug production 10% drug sales 5% R&D Mainly generics Life-threatening diseases

Weak DRAs $

Page 25: ICH GCP

Indian GCP guidelines

Released in Dec 2001(Developed by CDCSO and endorsed by DCGI)

In general, in line with ICH GCP

Has Revised Schedule Y (Jan 2005) addressed discrepancies?

Page 26: ICH GCP

Issues in Developing Countries

The informed consent process Economic Vulnerability Patient doctor relationship Education level

Page 27: ICH GCP

ROLE OF GCP ?ROLE OF GCP ?

Good clinical practice (gcp) is an international ethical & scientific standard for conducting clinical trials that involve the participation of human subjects

Compliance with this standard provides public assurance that the rights, safety & well-being of trial subjects are protected, which is consistent with the principles outlined in the declaration of helsinki

GCP also ensures the credibility of clinical trial data.

Page 28: ICH GCP

INTERNATIONAL ETHICAL INTERNATIONAL ETHICAL STANDARDSSTANDARDS

Professional standards for the protection of human subjects in

research did not exist till late 1940’s.

Nuremberg tribunal held in 1945 and 1946 that “voluntary

consent of the human subject is absolutely essential”

The Declaration of Helsinki outlines 12 principles by which

physicians must conduct research in therapeutic & non-

therapeutic interventions.

Page 29: ICH GCP

Fundamental Ethical Principles Guiding Protection Of Human Subjects In Biomedical ResearchFundamental Ethical Principles Guiding Protection Of Human Subjects In Biomedical Research

RESPECT FOR PERSONS: Acknowledges the dignity & autonomy of individuals. This principle requires that subjects give their informed consent prior to participating in research.

BENEFICENCE: Obligates researchers to treat subjects fairly.

• JUSTICEJUSTICE: requires the equitable : requires the equitable selection of subjects in light of selection of subjects in light of research setting & research research setting & research purposes.purposes.

Page 30: ICH GCP

PRINCIPLES BEHIND GCPPRINCIPLES BEHIND GCP

Before initiating any clinical trial, ANTICIPATED RISKS should be weighed against EXPECTED BENEFITS for the trial subject & society

• The RIGHTS, SAFETY & WELL BEING of trial subjects The RIGHTS, SAFETY & WELL BEING of trial subjects are the most important considerations & should prevail are the most important considerations & should prevail over the interests of science & society.over the interests of science & society.

• The entire study procedure should be The entire study procedure should be scientifically sound & detailed in a trial scientifically sound & detailed in a trial protocol. This protocol should receive a protocol. This protocol should receive a prior APPROVAL FROM AN prior APPROVAL FROM AN INDEPENDENT ETHICS COMMITTEE.INDEPENDENT ETHICS COMMITTEE.

Page 31: ICH GCP

ETHICAL REVIEW SHOULD DEFINE JUSTIFIABLE BOUNDARIES BETWEEN THE RIGHTS OF THE SUBJECT AND THE BENEFITS THAT MIGHT ACCRUE TO SOCIETY THROUGH SCIENTIFIC INFORMATION DEVELOPED IN

CLINICAL TRIALS.

Regulations have been established internationally, to ensure ethical & scientific conduct of trials

Regulations have been established internationally, to ensure ethical & scientific conduct of trials

Page 32: ICH GCP

GOALS OF INTERNATIONAL HARMONIZATION OF REGULATORY REQUIREMENTS

GOALS OF INTERNATIONAL HARMONIZATION OF REGULATORY REQUIREMENTS

SAFEGUARD PUBLIC HEALTH ASSURE CONSUMER PROTECTION STANDARDS FACILITATE AVAILABILITY OF SAFE AND

EFFECTIVE PRODUCTS ELIMINATE INCONSISTENT STANDARDS

INTERNATIONALLY FACILITATE MUTUAL ACCEPTANCE OF DATA

FROM CLINICAL TRIALS

Page 33: ICH GCP

STAKEHOLDERS & THEIR RELATIONSHIPS

SUBJECTSUBJECT

REGULATORY REGULATORY AUTHORITYAUTHORITY

SPONSORSPONSORETHICSETHICS

COMMITTEECOMMITTEEINVESTIGATOR

Page 34: ICH GCP

ROLE OF ETHICS COMMITTEESROLE OF ETHICS COMMITTEES

Play a vital role in protecting human subjects in clinical trials.

They review trial protocols to ensure that…. informed consents are obtained from the subjects subjects are not exposed to unreasonable risks

Establishment of EC’s has become a cornerstone of protection of human subjects in clinical research

Page 35: ICH GCP

Protection of Human SubjectsPrior To Study Start

The investigator must request ethics approval for: Protocol Informed Consent Form/Advertisements/Other

Information Protocol amendment and /or Informed Consent

Amendments All sites at which patient activity will occur

Page 36: ICH GCP

Protection of Human Subjects During the study

The investigator must request ethics approval for any change in the research activity

The investigator must submit progress reports to the IRB as required

The subject must be informed of any new information which might affect their decision to continue participation in the trial

Page 37: ICH GCP

RESPONSIBILITIES OF THE INVESTIGATORRESPONSIBILITIES OF THE INVESTIGATOR

Conduct the research in accordance with the protocol and Good Clinical Practice (GCP)

Protect the rights, safety, and welfare Protect the rights, safety, and welfare of the subjectsof the subjects

Report all adverse events (serious Report all adverse events (serious and non-serious)and non-serious)

Retain study documents and Retain study documents and medical recordsmedical records

Control the distribution and use of Control the distribution and use of the study medicationthe study medication

Page 38: ICH GCP

RESPONSIBILITIES OF THE SPONSORRESPONSIBILITIES OF THE SPONSOR The sponsor is responsible for

implementing and maintaining quality assurance of data generated in compliance with the protocol

Sponsor is responsible for securing agreement from all involved parties to ensure direct access to all sites, source data & reports for the purpose of monitoring & auditing by regulatory authorities

Agreements made by the sponsor with the investigator should be in writing

Page 39: ICH GCP

MEDICAL CARE OF TRIAL SUBJECTSMEDICAL CARE OF TRIAL SUBJECTS

During and following a subject’s participation in a trial, the investigator & institution should ensure that adequate medical care is provided to deal with adverse events related to the trial

The investigator should inform the subject’s primary physician about the trial & the subject’s participation

Page 40: ICH GCP

Protection of Human SubjectsInformed Consent

Must be signed and dated by the subject prior to study start

Language understandable to the subject Subject Information Sheet approved by the

Ethics Committee The Consent Form must contain the

elements required by GCP Subject must be given a copy

Page 41: ICH GCP

Study DocumentationBefore the study starts

IRB approval letter Members of IRB and their

qualifications/affiliation Normal ranges of clinical laboratory

Page 42: ICH GCP

Study DocumentationDuring the study

The investigator must keep: Source documents

Medical records (including access to computer records)

Laboratory reports ECGs, X-rays, etc. Any other medical records, reports or notes

(hospital admissions and discharges) A subject identification list Copies of all study related documentation

Page 43: ICH GCP

Medical Records

In particular, they should contain notes on: Sufficient information to support subject eligibility This should be well documented (signed and dated) Subject’s participation in the study Dates of visits Procedures, investigations done Observations, diagnoses Medications taken (including study medication) Adverse events / SAE’s Completion or withdrawal (reason) from the study

Page 44: ICH GCP

Study DocumentationAfter the study

The sponsor needs from the investigator:

Final drug accountability records All used and unused supplies and medication All required documents completed

Page 45: ICH GCP

The trial subjects should be explained the correct use of the investigational product and compliance to these instructions should be checked periodically

Investigator should maintain records of the delivery of the product, the inventory, use by each subject as per protocol

INVESTIGATIONAL INVESTIGATIONAL PRODUCTPRODUCT

Page 46: ICH GCP

MONITORINGMONITORING

The rights & well-being of human subjects are protected

The reported data are accurate, complete & verifiable from source documents

The conduct of the trial is in compliance with approved protocol & with applicable regulatory requirements

• THE PURPOSES OF MONITORING ARE TO THE PURPOSES OF MONITORING ARE TO VERIFY THAT…VERIFY THAT…

Page 47: ICH GCP

Questions?

Page 48: ICH GCP