Basic↦Quality and Risk↦Risk-Based QMS Responsibilities↦Sponsor-Investigator
What is it? Why is it important?
The Sponsor-Investigator (SP-INV) is legally responsible to ensure the safety of study participants, the quality of study data, and the traceability of study results.
In order to safeguard these aims, a risk-based Quality Management System (QMS), including Quality Assurance (QA) and Quality Control (QC) procedures must be in place.
A risk-based approach includes to:
- Identify risks based on critical study processes (e.g. data management, documentation, informed consent process, safety reporting, quality assurance)
- Define roles and responsibilities
- Evaluate and prioritise risks (e.g. frequency and impact)
- Define risk control measures (e.g. accept, tolerate, reduce, eliminate risks)
- Communicate risk control measures to those affected by such activities
- Periodically review risk control measures to ascertain they remain effective and relevant
- Report risk event(s) and the adaptation of risk control measures needed to prevent reoccurrence
Risks should be included in an overall evaluation of the study in order to decide whether the study can be implemented as planned.
What do I need to do?
As a SP-INV:
- Define how to set-up a risk-based QMS for your study. Focus on the safety of study participants and the quality of study data (e.g. include QA and QC procedures)
- If applicable, consider regional or local QMS requirements (e.g. multi-centre studies)
- Select applicable experts able to contribute to the identification of potential study risks (e.g. study staff, statistician, quality manager)
- Define potential study risks including potential control-measures
- Document the risk management of your study in a Risk Assessment Form (RAF)
Study aim, design should be tailored based on the information needed to answer your study question. The complexity of your study (e.g. design, target group) will have a significant effect on potential inherent risks, and the required QMS needed to control these risks. Activities above requirements will only negatively burden staff, timeline, budget, and increase the occurrence of risks
More
As a SP-INV you can delegate QMS responsibilities to:
- A CRO or CTU, with a contract defining delegated tasks and responsibilities
- Study staff, with delegated tasks and responsibilities documented on a delegation-log
Still, ultimate responsibilities remain with the SP-INV, who ensures the qualification and training of the study staff including the competency of any potential partners.
Where can I get help?
Your local CTU↧ can support you with experienced staff regarding this topic
Basel, Departement Klinische Forschung, CTU, dkf.unibas.ch
Lugano, Clinical Trials Unit, CTU-EOC, www.ctueoc.ch
Bern, Clinical Trials Unit, CTU, www.ctu.unibe.ch
Geneva, Clinical Research Center, CRC, crc.hug.ch
Lausanne, Clinical Research Center, CRC, www.chuv.ch
St. Gallen, Clinical Trials Unit, CTU, www.kssg.ch
Zürich, Clinical Trials Center, CTC, www.usz.ch
References
ICH GCP E6(R2) – see in particular guideline
- 1.54 Sponsor-Investigator
- 4. Investigator
- 5. Sponsor
- 5.0 Quality management
ISO 31000 – (access liable to costs) see in particular section
- Risk management: Principles and guidelines
Swiss Law
ClinO – see in particular article
- Art. 2 Definitions
Documents