Upload
trinhdiep
View
215
Download
0
Embed Size (px)
Citation preview
Research and Development Department North Staffordshire Combined Healthcare h'l:fj NHS Trust
Safety Reporting in the Stroke Oxygen Study
R&D-SOP-SOS-001SOP Reference ,
Final Version 1.1Version Number
19111 February 2010 Effective Date
Review Date 18th February 2012
Author Karen Hampson
Position Research and Development Manager
Amended by Sarah Pountain
Approved by Christine Roffe
Position Chief Investigator/R & D Committee Member
gin April 2010 Approval Date -~~~-~~~-~
SOP Research Template 1.0 Template
Previous
Version
Current
Version
Amended by Amendment
IDate
1.0 Sarah Pountain 19m
1.1 February
2010
Reason for amendment
Update of contact details
R&D-SOP-SOS-001 Page 1 of 21 Final Version 1.1 (19-Feb-10)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare '~l:bj NHS Trust
Contents
Section Description Page
1 Background 4
2 Purpose 4
3 Definitions 4
3.1 Adverse Incident 4
3.2 Adverse Event 4
3.2.1 Adverse Reaction 5
3.2.2 Unexpected Adverse Reaction 5
3.3 Serious Adverse Event (SAE) 5
3.3.1 Serious Adverse Reaction 5
3.3.2 Suspected Unexpected Serious Adverse Reaction (SUSAR) 5
3.4 Urgent Safety Measure (USM) 6
3.5 Abbreviations 6
4 Scope and Responsibilities 6
4.1 Sponsor 6
4.2 Organisation Providing Care 7
4.3 Chief Investigator 7
4.4 Principal Investigator 8
5 Procedures for Reporting Adverse Events, Serious Adverse Events and SUSARs 8
5.1 Adverse Events, Adverse Reactions and any Unexpected Adverse Reactions (excluding 8 Adverse Incidents)
5.2 Serious Adverse Events (SAEs) 9
5.2.1 Serious Adverse Event reporting - All Researchers 9
5.2.2 Serious Adverse Event reporting - Chief Investigator 10
5.3 Suspected Unexpected Serious Adverse Reactions (SUSARs) 10
5.3.1 SUSAR reporting - All Researchers 10
5.3.2 SUSAR reporting - Chief Investigator 11
R&D-SOP-SOS-001 Page 2of21 Final Version 1.1 (19-Feb-10)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare rill:b1 NHS Trust
6 Assessment of Adverse Events 12
6.1 Intensity 12
6.2 Causality 12
6.3 Expectedness 13
7 Procedures for reporting Urgent Safety Measures (USMs) 14
7.1 USM reporting - All Researchers 14
7.2 USM reporting - Chief Investigator 14
8 Safety Reports 15
9 References 15
10 Related SOPs 16
11 Approval signature 16
Appendices
1 Contact details: Chief Investigator, Study Manager, Sponsor 17
2 Summary table of reporting guidelines for researchers 18
3 Flowchart - Reporting of SAEs and SUSARs: Researchers (R&D-FC-SOS-001) 19
4 Flowchart - Reporting of SAEs and SUSARs: Chief Investigator (R&D-FC-SOS-002) 20
5 Annual Safety Report requirements 21
R&D-SOP-SOS-001 Page 3 of21 Final Version 1.1 (19-Feb-1 0)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare 'ct:fj NHS Trust
1 Background
Safety reporting is an essential part of pharmacovigalence and is necessary to comply with the Research Governance
Framework for Health and Social Care 2nd edition (2005) and the Medicines for Human Use (Clinical Trials) Regulations
(2004). It is also an essential part of Good Clinical Practice, described in the ICH Topic E 6 (R1) Guideline for Good
Clinical Practice Step 5.
Stroke is a complex and severe condition which is often accompanied by serious complications which can be Iife
threatening or lead to death, prolonged hospital stay, or long-term disability. In the context of clinical trials these are
termed Serious Adverse Events (SAEs). Trials in acute stroke typically record SAE rates of up to 50% showing how
frequent these may be. SAEs are expected to occur in both actively treated patients and controls in any large stroke trial.
If an SAE is considered as having a 'reasonable' causal relationship with the trial intervention then it is a Serious
Adverse Reaction (SAR). SARs can be expected to occur in any large stroke trial.
However. some events will be uncommon and therefore unexpected. If they can reasonably be attributed to the trial
intervention rather than to the stroke itself then they are called Suspected Unexpected Serious Adverse Reactions
(SUSARs). In the context of the S02S trial a SUSAR is an SAE which is unexpected in patients with acute stroke and
could reasonably be attributed to oxygen supplementation.
Investigators must check for Adverse Events at every patient contact and report any SAE or SUSAR to the Chief
Investigator or deputy within 24 hours of becoming aware of the event. The Chief Investigator or deputy must adjudicate
whether the reported event is a SUSAR or not. It is essential for this SOP to be followed. Failure to report, or failure
to report them in the correct way could put research participants at risk. This is unacceptable and could result in
the trial being terminated at a particular trial site.
2 Purpose
This SOP describes the process for safety reporting during the Stroke Oxygen Study. sponsored by North Staffordshire
Combined Healthcare NHS Trust.
3 Definitions
3.1 Adverse incident
An incident (Clinical, non-clinical and near misses) which occurs and does not fall into the Adverse Event. Serious
Adverse Event or Suspected Unexpected Serious Adverse Reaction categories. Adverse Incidents should be reported to
the relevant NHS trust using local guidelines.
3.2 Adverse Event
Any untoward medical occurrence in a subject to whom a medicinal product has been administered. including
occurrences which are not necessarily caused by or related to that product. If the event was not an untoward medical
occurrence then it is an Adverse Incident and needs to be reported using the local reporting policies.
R&D-SOP-SOS-001 Page 4 of 21 Final Version 1.1 (19-Feb-1 0)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare h'l:bj NHS Trust
3.2.1 Adverse Reaction
Any untoward and unintended response in a subject to an investigational medicinal product which is related to any dose
administered to that subject.
3.2.2 Unexpected Adverse Reaction
An Adverse Reaction, the nature and severity of which is not consistent with the information about the medicinal product
in question (in the case of a product with a marketing authorization this refers to the summary of product characteristics
for that product, in the case of any other investigational medicinal product this refers to the information in the
investigator's brochure relating to the trial in question).
3.3 Serious Adverse Event
Any untoward medical occurrence in a subject to whom a medicinal product has been administered, including
occurrences which are not necessarily caused by or related to that product that:
(a) results in death,
(b) is life-threatening,
(c) requires hospitalisation or prolongation of eXisting hospitalisation,
(d) results in persistent or significant disability or incapacity, or
(e) consists of a congenital anomaly or birth defect
3.3.1 Serious Adverse Reaction
Any untoward and unintended response in a subject to an investigational medicinal product which is related to any dose
administered to that subject; that:
(a) results in death,
(b) is life-threatening,
(c) requires hospitalisation or prolongation of existing hospitalisation,
(d) results in persistent or significant disability or incapacity, or
(e) consists of a congenital anomaly or birth defect
3.3.2 Suspected Unexpected Serious Adverse Reaction (SUSAR):
An Adverse Reaction, the nature and severity of which is not consistent with the information about the medicinal product
in question (in the case of a product with a marketing authorization this refers to the summary of product characteristics
for that product, in the case of any other investigational medicinal product this refers to the information in the
investigator's brochure relating to the trial in question) that:
(a) results in death,
(b) is life-threatening,
(c) requires hospitalisation or prolongation of existing hospitalisation,
(d) results in persistent or significant disability or incapacity, or
(e) consists of a congenital anomaly or birth defect
R&D-SOP-SOS-001 Page 5 of 21 Final Version 1.1 (19-Feb-1 0)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare b'!/:bl NHS Trust
3.4 Urgent Safety Measure (USM)
Any deviation from the approved version of the protocol necessary to ensure the safety of the research participant.
3.5 Abbreviations
SAE Serious Adverse Event
SUSAR Suspected Unexpected Serious Adverse Reaction
USM Urgent Safety Measure
4 Scope and Responsibilities
This SOP is to be used by all personnel involved in the Stoke Oxygen Study.
4.1 Sponsor
• Arrangements are in place to ensure that all Adverse Events possibly related to the investigational medicinal
product are recorded and records maintained, and they are reported to the relevant NHS Trust if necessary.
• Adverse Events are reviewed by a medical assessor, and a summary of Adverse Events is sent to the
appropriate committee for the monitoring of trial safety on a regular basis.
• Arrangements are in place to ensure that specific SAEs (see 5.2.2 for detailS) are reported to the regulatory
authorities and relevant ethics committee within the required timelines and the relevant NHS Trust.
• Arrangements are in place to ensure that SAEs are reviewed by an appropriate committee for the monitoring of
trial safety.
• Arrangements are in place to ensure that SAEs are recorded and records maintained.
• Arrangements are in place to ensure that SUSARs are identified and reported to the regulatory authorities and
relevant ethics committee within the required timelines and the relevant NHS Trust.
• Arrangements are in place to ensure that all investigators are aware of any SUSARs in relation to the
investigational medicinal product.
• Arrangements are in place to ensure that annual safety reports are submitted to the regulatory authorities and
relevant ethics committee within the required timelines.
• Arrangements are in place to ensure the ongoing safety evaluation of the investigational medicinal product
including trend analyses.
R&D-SOP-SOS-001 Page 6 of21 Final Version 1.1 (19-Feb-10)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare 'rl:bj NHS Trust
• Arrangements are in place to ensure that all investigators are made aware of findings which could affect
adversely the safety of the subjects.
• Arrangements are in place to ensure that USMs are reported to the regulatory authorities and relevant ethics
committee within the required timelines.
4.2 Organisation Providing Care
• Ensure that Adverse Events, including SAEs and SUSARs in the context of research are reported to the National
Patient Safety Agency in line with the standard procedures of the organisation; or to the systems for reporting
adverse events in social care.
4.3 Chief Investigator
• All Adverse Events possibly related to the investigational medicinal product are reported to the Sponsor.
• Specific SAEs (see 5.2.2 for details) are reported to the regulatory authorities and relevant ethics committee
within the required timelines and reported immediately to the Sponsor. Arrangements are in place to ensure the
relevant NHS Trust is informed.
• SAEs are reviewed by an appropriate committee for the monitoring of trial safety.
• SAEs are recorded and records maintained.
• SUSARs are identified and reported to the regulatory authorities and relevant ethics committee within the
required timelines and reported immediately to the Sponsor. Arrangements are in place to ensure the relevant
NHS Trust is informed.
• All investigators are aware of any SUSARs in relation to the investigational medicinal product.
• Annual safety reports are submitted to the regulatory authorities and relevant ethics committee within the required
timelines.
• All SAEs are evaluated by the Chief Investigator.
• All investigators are made aware of findings which could affect adversely the safety of the subjects.
• USMs are reported to the regulatory authorities and relevant ethics committee within the required timelines and
the sponsor is alerted immediately. Arrangements are in place to ensure the relevant NHS Trust is informed of
the event.
R&D-SOP-SOS-001 Page 7 of21 Final Version 1.1 (19-Feb-1 0)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare h'l:kj NHS Trust
4.4 Principal Investigator
• Investigators must check for Adverse Events at every patient contact and report any SAE or SUSAR to the Chief
Investigator within 24 hours of becoming aware of the event.
• All non-serious adverse events (excluding Adverse Incidents) are recorded and records maintained.
• All non-serious adverse events (excluding Adverse Incidents) possibly related to the investigational medicinal
product are reported to the Sponsor within 14 days and if necessary the relevant NHS Trust (using local
guidelines).
• All SAEs are recorded and records maintained.
• All investigators are aware of any SUSARs in relation to the investigational medicinal product.
• All investigators are made aware of findings which could affect adversely the safety of the subjects.
5 Procedures for Reporting Adverse Events
5.1 Adverse Events, Adverse Reactions and any Unexpected Adverse Reactions (excluding Adverse
Incidents)
NB If the adverse events, adverse reactions and any unexpected adverse reactions are not classed as serious and are
unrelated or unlikely to be related to the investigational medicinal product the relevant NHS Trust local guidelines should
be consulted and the event should be reported using these guidelines.
If the Adverse Events, Adverse Reactions and any Unexpected Adverse Reactions are not classed as serious and are
possibly related, probably related or definitely related to the investigational medicinal product, or the causality is unknown.
the incident needs to be reported using the following procedure:
1J Complete 'Adverse Event (non-serious) reporting form (R&D-RF-SOS-001), available from the SOS website. The event
should be assessed to determine the intenSity. causality and expected ness using the guidelines set out in sections 6.1
6.3.
2J Send completed form to the Sponsor by fax 01782 441624 within 14 days.
3] The relevant NHS Trust local guidelines should also be consulted and the event should be reported using these
guidelines.
R&D-SOP-SOS-001 Page 8 of 21 Final Version 1.1 (19-Feb-1 0)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare h"l:f1 NHS Trust
A record of all adverse events should be maintained and a copy of the completed 'Adverse Event (non-serious) reporting
form' needs to be placed in the Investigator Site File.
The Sponsor will monitor these events, which will be reviewed by a medical assessor. A summary table of all these
events will be submitted to the trial Data Monitoring and Safety committee for review.
This is outlined in the flow chart 'Reporting of SAEs and SUSARs: Researchers (R&D-FC-SOS-001)' in appendix 3.
5.2 Serious Adverse Events (SAEs)
5.2.1 Serious Adverse Event reporting - All Researchers
NB. If the event is a SUSAR it should be reported following the guidelines in section 5.3.1 (SUSAR Reporting - All
Researchers)
All SAEs should be reported using the following procedure:
1] You must notify the SOS study centre immediately by either telephoning 0300 1230891 (office hours) 07740 372852
(out of hours) 07734 068408 (back up out of hours number); sending a fax to 0300 123 894 (office hours) or sending an
email to [email protected] (Chief Investigator) AND [email protected] (SOS Study
Manager).
2] Report this event using the Serious Adverse Event Notification form (Assessment Form 4) which is available in the
CRF, or on the SOS website. The event should be assessed to determine the intensity, causality and expected ness using
the guidelines set out in sections 6.1 - 6.3. The completed form must be faxed to 0300 1230894 as soon as possible
within 24 hours of becoming aware of the event. Copies of these forms also need to be sent to the Sponsor within 24
hours by faxing to 01782 441624.
3J The relevant NHS Trust local guidelines should also be consulted and the event should be reported using these
guidelines.
A record of all SAEs should be maintained and a copy of the completed Serious Adverse Event Notification form
(Assessment Form 4) form needs to be placed in the Investigator Site File.
This is outlined in the flow chart 'Reporting of SAEs and SUSARs: Researchers (R&D-FC-SOS-001)' in appendix 3.
R&D-SOP-SOS-001 Page 9 of21 Final Version 1.1 (19-Feb-1 0)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare '~/:fj NHS Trust
5.2.2 Serious Adverse Event reporting - Chief Investigator
NB. If the event is a SUSAR it should be reported following the guidelines in section 5.3.2 (SUSAR Reporting - Chief
Investigator).
Is the SAE any of the following:
a) an increase in the rate of occurrence or a qualitative change of an expected serious adverse reaction, which is judged
to be clinically important
b) post-study SUSARs that occur after the patient has completed a trial and are reported by the investigator to the
sponsor
c) a new event, related to the conduct of the trial or the development of the Investigational Medicinal Product, that is likely
to affect the safety of subjects, such as:
a serious adverse event which could be associated with the trial procedures and which could modify the conduct
of the trial (for example a SAE occurring during the run-in period)
a significant hazard to the subject population such as lack of efficacy of an IMP used for the treatment of a life
threatening disease
a major safety finding from a newly completed animal study (such as carcinogenicity).
any anticipated end or temporary halt of a trial for safety reasons where the trial is conducted with the same IMP
by the same sponsor in another country.
(d) the conclusions or recommendations of a data monitoring committee, where relevant for the safety of subjects.
If the answer is yes the European Commission guidance recommends that reports on these occurrences should also be
sent to the main REC according to the same timelines as SUSARs (see 5.3.2 SUSAR Reporting - Chief Investigator).
If the answer is no a copy of the completed form needs to be sent to the Sponsor using the contact details listed in
appendix 1 and the completed Serious Adverse Event Notification form (Assessment Form 4) needs to be placed in the
Trial Master File. The Serious Adverse Event Notification form (Assessment Form 4) also needs to be submitted to the
trial safety committee for review and trend analysis needs to be carried out where appropriate.
This is outlined in the flow chart 'Reporting of SAEs and SUSARs: Chief Investigator (R&D-FC-SOS-002)' in appendix 4.
5.3 Suspected Unexpected Serious Adverse Reactions (SUSARs)
5.3.1 SUSAR reporting - All Researchers
All SUSARS, including post-study SUSARs that occur after the patient has completed a trial, should be reported using the
following procedure:
1] You must notify the SOS study centre immediately by either telephoning 0300 1230891 (office hours) 07740 372852
(out of hours) 07734 068408 (back up out of hours number); sending a fax to 0300 1230894 (office hours) or sending an
R&D-SOP-SOS-001 Page 10 of 21 Final Version 1.1 (19-Feb-10)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare ' ..l:fj NHS Trust
email to [email protected] (Chief Investigator) AND [email protected] (SOS Study
Manager).
2] Report this event using the Serious Adverse Event Notification form (Assessment Form 4) which is available in the
CRF, or on the SOS website. The event should be assessed to determine the intensity, causality and expected ness using
the guidelines set out in sections 6.1 - 6.3. The completed form must be faxed to 0300 123 0894 as soon as possible
within 24 hours of becoming aware of the event. Copies of these forms also need to be sent to the Sponsor within 24
!!2.Yr!. by faxing to 01782 441624.
3] The relevant NHS Trust local guidelines should also be consulted and the event should be reported using these
guidelines.
A record of all SUSARS should be maintained and a copy of the completed Serious Adverse Event Notification form
(Assessment Form 4) form needs to be placed in the Investigator Site File.
This is outlined in the flow chart 'Reporting of SAEs and SUSARs: Researchers (R&D-FC-SOS-001), in appendix 3.
5.3.2 SUSAR reporting - Chief Investigator
The Chief Investigator has to assess all SUSARS: Is the SUSAR fatal or life-threatening?
If the answer is yes the Chief Investigator must notify the following authorities within 7 days:
MHRA
Main Research Ethics Committee
If the answer is no the Chief Investigator must notify the following authorities within 15 days:
MHRA
Main Research Ethics Committee
Reporting to MHRA
Reports can be scanned as PDF documents and [email protected]. clearly stating that the
attachment is a UK clinical trial SUSAR.
Paper UK clinical trial SUSAR reports should be sent to the centralised scanning facility in Gloucester:
MHRA
PO Box 20
Mitcheldean
GL170WQ
R&D-SOP-SOS-001 Page 11 of 21 Final Version 1.1 (19-Feb-1 0)
© North Staffordshire Combined Healthcare NHS Trust
6
Research and Development Department North Staffordshire Combined Healthcare '~l:bj NHS Trust
Reporting to ethics
The Report should be accompanied by the 'Clinical trials of investigational medicinal products safety report to main
research ethics committee' submission form (available from the NRES website:
http://www.nres.npsa.nhs. uk/applicants/after -ethical-review/safetyreports/safety-reports-for -ctimps/#s ubmiss ionofreports)
A copy of the completed form needs to be sent to the Sponsor using the contact details listed in appendix 1 and the
completed Serious Adverse Event Notification form (Assessment Form 4) needs to be placed in the Trial Master File. The
Serious Adverse Event Notification form (Assessment Form 4) also needs to be submitted to the trial safety committee for
review and trend analysis needs to be carried out where appropriate.
This is outlined in the flow chart 'Reporting of SAEs and SUSARs: Chief Investigator (R&D-FC-SOS-002)' in appendix 4.
Assessment of adverse events:
6.1 IntenSity
To assess the intenSity of the Adverse Event the following definitions should be used, along with the investigator's clinical
judgement:
1] Mild
This describes an event that causes minimal discomfort to the patient and/or does not interfere with everyday activities
2] Moderate
This describes an event which is moderately discomforting and/or interferes with normal everyday activities.
3] Severe**
This describes a event which is discomforting and/or prevents normal everyday activities.
**The term severe which describes the intenSity of an adverse event is not the same as an event being classed as
'serious', which is based on patient/event outcome or action criteria. A 'serious' event refers to an event which:
resulted in death,
is life-threatening,
requires hospitalisation or prolongation of existing hospitalisation,
results in persistent or significant disability or incapacity, or
consists of a congenital anomaly or birth defect
6.2 Causality
The relationship between the Adverse Event and the administered investigational medicinal product needs to be
assessed using the investigator's clinical judgement and the definitions listed below. To aid in the causality the
investigator should also refer to the protocol, product information and the investigator brochure.
R&D-SOP-SOS-001 Page 12 of 21 Final Version 1.1 (19-Feb-1 0)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare ,.!f:fj NHS Trust
1] Unrelated
There is no evidence of any causal relationship between the investigational medicinal product and the Adverse Event.
2] Unlikely
There is little evidence to suggest there is a causal relationship between the investigational medicinal product and the
Adverse Event and there is another reasonable explanation which may explain the occurrence of the event for the event
(e.g. the patient's clinical condition, other concomitant treatment).
3] Possibly related*
There is some evidence to suggest a causal between the investigational medicinal product and the Adverse Event and
there is another reasonable explanation which may can explain the occurrence of the event (e.g. the patient's clinical
condition, other concomitant treatment).
4] Probably related*
There is evidence to suggest a causal relationship between the investigational medicinal product and the Adverse Event
and the influence of other factors is unlikely. As such the event is more likely to be related to the investigational medicinal
product.
5] Definitely related*
There is clear evidence to suggest a causal relationship and there are no other possible contributing factors.
6] Unknown
There is insufficient or incomplete evidence to make a clinical judgement of the causal relationship.
*these events are described as adverse reactions
6.3 Expectedness
The relationship between the Adverse Event and the administered investigational medicinal product needs to be
assessed using the investigator's clinical judgement and the definitions listed below to assess if the reaction was
expected or unexpected. To aid in the this the investigator should also refer to the protocol, product information or
investigator brochure.
1] Expected
The nature or severity of the Adverse Reaction is consistent with the applicable product information.
2] Unexpected
The nature or severity of the Adverse Reaction is not consistent with the applicable product information.
R&D-SOP-SOS-001 Page 13 of 21 Final Version 1.1 (19-Feb-10)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare "'/:k1 NHS Trust
7 Procedures for reporting Urgent Safety Measures (USMs)
7.1 USM Reporting - All Researchers
All USMs should be reported using the following procedure:
1] You must notify the SOS study centre immediately by either telephoning 0300 1230891 (office hours) 07740 372852
(out of hours) 07734 068408 (back up out of hours number); sending a fax to 0300 123 894 (office hours) or sending an
email to [email protected] (Chief Investigator) AND [email protected] (SOS Study
Manager) marking the email/fax with 'URGENT SAFETY MEASURE'.
2] Report the USM using the SOS ' Urgent Safety Measure Reporting Form (R&D-RF-SOS-002)' available on the SOS
website ASAP within 24 hours of becoming aware of the event. This form can then be emailed to
[email protected] (Chief Investigator) AND [email protected] (SOS Study Manager) or
faxed to 0300 123 0894 (office hours). Copies of these forms also need to be sent to the Sponsor immediately by
em ailing to [email protected] or faxing to 01782 441624.
3] The relevant NHS Trust local guidelines should also be consulted and the event should be reported using these
guidelines.
7.2 USM Reporting - Chief Investigator
The USM should be reported using the following procedure:
1] The Chief Investigator should phone the Clinical Trial Unit at the MHRA and discuss the issue with a medical assessor
immediately and should phone the main REC and discuss the issue immediately.
2] The Chief Investigator must notify the MHRA and the main research ethics committee, in writing, of the measures taken
and the reason for the measures within 3 days by submitting a substantial amendment. The sUbstantial amendment
should include a covering letter detailing the measures taken, the reason for them and the medical assessor contacted; a
Notification of Amendment form (available from the Eudract website http://eudract.emea.eufopa.eu/document.html#forms); and
supporting documentation. The substantial amendment should be:
Faxed to the Clinical Trials Unit on 020 7084 2443 or
[email protected] marked 'Urgent Safety Measure'
Sent to the main REC marked 'Urgent Safety Measure'
3] The MHRA must also be notified of a Serious Breach, as described in the SOP 'Breach of protocol or GCP (R&D-SOP
SOS-002) within 7 days of the Chief Investigator being made aware of the breach.
R&D-SOP-SOS-001 Page 14 of 21 Final Version 1.1 (19-Feb-1 0)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare 'rl:bj NHS Trust
4] The substantial amendment must also be sent as PDF documents on disk to:
Information Processing Unit,
Area 6,
Medicines and Healthcare products Regulatory Agency,
Market Towers,
1 Nine Elms Lane,
London.
SW85NQ
A copy of the completed report needs to be sent to the Sponsor using the contact details listed in appendix 1 and the
completed report needs to be placed in the Trial Master File. The report also needs to be submitted to the trial safety
committee for review and trend analysis needs to be carried out where appropriate.
8 Safety Reports
The Chief Investigator is responsible for producing Annual Safety reports, These should be provided at yearly intervals
from the date of the original exemption, for trials ongoing on 1 May 2004, or the date of the CT A approval for trials starting
after 1 May. For trials with marketed products, the date is the first marketing authorisation granted in the EU. These
should be sent to the MHRA and main ethics committee. Guidance on what the annual safety report should include can
be found in appendix 5.
NB. For short term trials a safety report should be submitted within 90 days of the end of the trial along with the end of
trial notification.
The Chief Investigator is also responsible for providing reports to the Sponsor on the conclusions or recommendations of
the Data and Safety Monitoring Committee.
9 References
The Medicines for Human Use (Clinical Trials) Regulations 2004
Research Governance Framework for Health and Social Care 2nd edition (2005)
Detailed guidance on the collection, verification and presentation of adverse reaction reports arising from clinical trials on medicinal products for human use (April 2006) http://ec.europa. eu/enterprise/pharmaceuticals/eudralexlvol-1 0121 susar rev2 2006 04 11. pdf
National Research Ethics Service guidance on safety reporting for clinical trials with investigational medicinal products http://www.nres.npsa.nhs.uklapplicants/after-ethical-review/safetyreportslsafetv-reports-for-ctimpsl
MHRA guidance on clinical trial authorisations: Safety reporting - SUSARS and ASRs http://www.mhra.qov.uklHowweregulate/Medicines/Licensingofmedicines/Clinicaltrials/SafetyreportingSUSARSandASRs/index.htm
R&D-SOP-SOS-001 Page 15 of 21 Final Version 1.1 (19-Feb-10)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare 'cl:fj NHS Trust
ICH Topic E 6 (R1) Guideline for Good Clinical Practice Step 5 NOTE FOR GUIDANCE ON GOOD CLINICAL PRACTICE (CPMP/ICH/135/95) http://www.emea.europa.eu/pdfs/human/ich/013595en.pdf
Standard Operating Procedures for Research Ethics Committees in the United Kingdom ('SOPs') v 3.5 May 2008 http://www.nres.npsa.nhs. uklnews-and-publications/pu blications/standard-operating-proced uresl
10 Related SOPs
Serious breach of protocol or GCP (R&D-SOP-SOS-002)
11 Approval signature: Do not use this SOP unless it has been signed below
As a member of the R&D Committee I authorise the use of this SOP.
SOP Reference: R&D-SOP-SOS-001
Version Number: Final version 1.1 (19-Feb-10)
Name Prof. Christine Roffe Position Chief Investigator
ISigned Date C( Cr" f iJ
R&D-SOP-SOS-001 Page 16 of 21 Final Version 1.1 (19-Feb-1 0)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare 'rl:fj NHS Trust
Appendix 1: Contact details
Contact address
Contact email
Contact phone number
Contact fax number
Prof. Christine Roffe - Chief Investigator
SOS Study, Stroke Research Office, North Staffs. Combined Healthcare NHS Trust, Holly Lodge, 62 Queens Road, Stoke-onTrent, ST 4 7LH
0300 1230891 (office hours) 07740 372852 (out of hours) 07734 068408 (back up out of hours number)
0300 1230894 (office hours)
Contact name
Contact address
Contact email
Contact phone number
Dr Sarah Pountain - SOS Study Manager
SOS Study, Stroke Research Office, North Staffs. Combined Healthcare NHS Trust, Holly Lodge, 62 Queens Road, Stokeon-Trent, ST4 7LH
0300 1230891 (office hours) 07740 372852 (out of hours) 07734 068408 (back up out of hours number)
0300 1230894 (office hours)
Contact name Laurie Wrench - Research and Development Manager
I Contact address Research and Development Dept, Academic Suite, Harplands Hospital, Hilton Road, Harpfields, Stoke-on"Trent, ST46TH
i
I Contact email [email protected]
Contact phone number
01782441624 (office hours)
Contact fax number
01782441624 (office hours; same number as phone number)
R&D-SOP-SOS-001 Page 17 of21 Final Version 1.1 (19-Feb-10)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare rifl:bj NHS Trust
Appendix 2: Summary table of reporting guidelines for researchers
EVENT
Adverse Incident
Adverse Event (nonserious) - not related to IMP
Adverse Event (nonserious) - possibly related to IMP
REPORT TO
Relevant NHS Trust using local policies and guidelines
Relevant NHS Trust using local policies and guidelines
Sponsor
Local NHS Trust
TIME FRAME
Consult relevant NHS Trust local policies and guidelines
Consult relevant NHS Trust local policies and guidelines
Within 14 days
Consult relevant NHS Trust local pOlicies and guidelines
FORMS TO USE
Consult relevant NHS Trust local policies and guidelines
Consult relevant NHS Trust local policies and guidelines
Adverse Event (non-serious) reporting form (R&D-RF-SOS001)
Consult relevant NHS Trust local policies and guidelines
!
i
SAE
Chief Investigator, Study Manager and Sponsor
Local NHS Trust
Within 24 hours
Consult relevant NHS Trust local policies and guidelines
Serious Adverse Event Notification form (Assessment Form 4)
Consult relevant NHS Trust local policies and guidelines
SUSAR
Chief Investigator, Study Manager and Sponsor
Local NHS Trust
Within 24 hours
Consult relevant NHS I Trust local policies and I guidelines
Serious Adverse Event Notification form (Assessment Form 4)
IConsutt relevant NHS Trust local policies and guidelines
I
Urgent Safety Measure
, Chief Investigator, Study I Manager and Sponsor
Local NHS Trust
I
Within 24 hours
Consult relevant NHS Trust local policies and guidelines
Urgent Safety Measure (USM) reporting form ( R&D-RF-SOS002)
Consult relevant NHS Trust local policies and guidelines
R&D-SOP-SOS-001 Page 18 of 21 Final Version 1.1 (19-Feb-10)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare '~l:kj NHS Trust
Appendix 3: Flowchart - Reporting of SAEs and SUSARs: Researchers (R&D-FC-SOS-001)
Stroke Oxygen Study Eudract number: 2006-003479-11 Reporting of SAEs and SUSARs: Researchers
Researchers: Is the answer YES to any of the following:
Did the event result in death? Is/was the event life threatening? Did /does the event lead to hospitalization or prolonged hospitalization? Did/does the event result in persistent or significant disability/incapacity? Did/does the event result in congenital anomalylbirth defect/carcinogenesis? Does the investigator consider the event a serious adverse event for other reasons? Is it a SUSAR?
/ This is a SAEISUSAR
1] Inform the SOS study centre immediately 2] Report within 24 hours using the Serious Adverse Event Notification form (assessment form 4) and sending by fax 3] Send copy to sponsor by fax 4] Report to relevant NHS trust using local guide lines 5] Place a copy of form in Investigator site file
This is a non-serious adverse event
Is the non-serious adverse event possibly related, probably related or definitely related to the IMP or is the causality unknown?
1 ] Record this incident using the Adverse Event (non-serious) reporting form 2] Fax form to Sponsor within 14 days 3] Report to relevant NHS trust using local guidelines 4] Place a copy ofform in Investigator site file
1] No further action needs to be taken in relation to the clinical trial 2] Report to relevant NHS trust using local guidelines
R&D-SOP-SOS-001 Page 19 of 21 Final Version 1.1 (19-Feb-1 0)
© North Staffordshire Combined Healthcare NHS Trust
Research and Development Department North Staffordshire Combined Healthcare '~l:bj NHS Trust
Appendix 4: Flowchart - Reporting of SAEs and SUSARs: Chief Investigator (R&D-FC-SOS-002)
Stroke Oxygen Study Eudract number: 2006-003479-11 Reporting ofSAEs and SUSARs: Chief Investigator
ChiefInvestigator: Is the SAE a SUSAR?
Is the SUSAR fatal or Ii fe-threatening?
1] Send the report form and safety report cover letter to the MHRA and the main REC within 7 days 2] Send completed report furm to Sponsor 3] Place a copy of form in Trial Master file 4] Ensure event is reviewed by Trial Safety Committee
1] Send the report furm and safety report cover letter to the MHRA and the main REC within 15 days 2] Send completed report form to Sponsor 3J Place a copy of form in Trial Master file 4] Ensure event is reviewed by Trial Safety Committee
Is the SAE any of the following: a) an increase in the rate ofoccurrence or a qualitative change of an expected serious adverse reaction, which is judged to be clinically important b) post-study SUSARs that occur after the patient has completed a trial and are reported by the investigator to the sponsor c) a new event, related to the conduct of the trial or the development of the IMP, that is likely to affect the safety of subjects, such as:
a serious adverse event which could be associated with the trial procedures and which could modifY the conduct of the trial (for example a SAE occurring during the run-in period) a significant hazard to the subject population such as lack of efficacy ofan IMP used for the treatment ofa life threatening disease a major safety finding from a newly completed animal study (such as carcinogenicity). any anticipated end or temporary halt of a trial for safety reasons where the trial is conducted with the same IMP by the same sponsor in another country.
(d) the conclusions or recommendations ofa data monitoring committee, where relevant for the safety of subj ects.
Report using procedures described for a SUSAR 1] Send completed report form to Sponsor 2] Place a copy of form in Trial Master file 3] Ensure event is reviewed by Trial Safety Committee
R&D-SOP-SOS-001 Page 20 of 21 Final Version 1.1 (19-Feb-10)
© North Staffordshire Combined Healthcare NHS Trust
r.'I:kjNational Patient Safety Agency
National Research Ethics Service Appendix 5: Annual Safety Report requirements
What should the Annual Safety Report (ASR) include? The aim of the Annual Safety Report is to describe concisely all new safety information relevant for one or several clinical trial(s) and to assess the safety of subjects included in these studies. The Annual Safety Report of a clinical trial should have three parts: Part 1: Analysis of the subjects' safety in the concerned clinical trial(s) with an appraisal of its ongoing risk: benefit.
Part 2: A line listing of all suspected serious adverse reactions (including all SUSARs) that occurred in the concerned trial(s), including all serious adverse reactions from third countries.
Part 3: An aggregate summary tabulation of suspected serious adverse reactions that occurred in the concerned trial(s). Full details of what to include in an Annual Safety Report can be found in Section 5.2 of Detailed guidance on the collection, verification and presentation of adverse reaction reports arising from clinical trials on medicinal products for human use - April 2006 European Commission document, http://ec.europa.eu/enterprise/pharmaceuticals/eudralexlvoI10_en.htm
Where to send the Annual Safety Report (ASR)
Annual safety reports should be provided as electronic documents on disk and be sent to: Information ProceSSing Unit, Area 6, Medicines & Healthcare products Regulatory Agency, Market Towers, 1 Nine Elms Lane, Vauxhall, London SW8 5NQ.
Annual safety reports should also be sent to the main REC responsible for a trial of the IMP
Safety reportfarm (eTlMP), version 4.0, April 2007 R&D-SOP-SOS-001 Final Version 1.0 (9-0ct-08)
© North Staffordshire Combined Healthcare NHS Trust
Page 21 of 21