Conduct↦Management↦Amendment↦Protocol
What is it? Why is it important?
A protocol amendment is an implemented change to an approved protocol during study conduct (i.e. approved by Ethics Committee (EC) and if applicable Regulatory Authorities (RA) such as Swissmedic (risk-category B or C) and FOPH.
An amendments can either be:
- Substantial (SA): include changes to the risk-benefit ratio of the study or study conduct. SAs must be approved by EC/RA prior to implementation (i.e. EC requires 30 days deliberation for single centres; 45 days for multicentre studies; Swissmedic requires 30 days deliberation)
- Non-substantial (Non-SA): Include minor aspects such as the coordination of the study (e.g. changes among study nurses regarding delegated tasks). EC is informed through the annual safety report; Swissmedic is notified as soon as possible
Safety amendments do not require pre-approval by EC/RA, as risk-control measures must be implemented to protect study participants. Still, the implementation of safety and protective measures must be reported to EC/RA within 7 days.
What do I need to do?
As a SP-INV:
- Make changes to applicable protocol sections in track-change (i.e. both old and new entries must remain legible)
- Provide a short rational why changes are necessary
- Identify documents, which because of the protocol amendment need an adaptation (e.g. PIS/ICF, CRF).
- Approve the amendment together with potential Site-INV(s) or other involved parties by dating and signing the signature page
- Submit the amended protocol, including other adapted documents, to the EC and if applicable Swissmedic for approval
- File the amended protocol / documents in the ISF to ensure they are available to site staff
- Ensure study staff, Site-INV(s), and other relevant study collaborators (e.g. laboratories, statistician, monitor) are trained on the amendment (i.e. document in a training-log)
More
Document Management:
- Create a “document history” to list all protocol changes
- Following each protocol amendment, update applicable document identifications accordingly (e.g. document release date, document version)
- Sort or save (electronically) protocols according to protocol version and date of the amendment
- Ensure the current and approved protocol / document(s) are accessible to study staff, and that archived protocol / documents are clearly identifiable from current or active ones
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
External Links
Swissethics – see in particular
- Template annual safety report
- Notification of significant and other changes to the EC
References
ICH GCP E6(R2) – see in particular guidelines
- 1.44 Protocol definition
- 1.45 Protocol Amendment definition
- 4.5 Compliance with protocol
- 6 Clinical trial protocol and protocol amendment(s)
ISO 14155:2020 Medical devices (access liable to cost) - see in particular sections
- 6.4 Clinical investigational plan (CIP)
- 7.5.1 Amendments
- 10.5 Informed consent procedure
- 10.6 Compliance with CIP
- Annex A Clinical investigational plan
Swiss Law
ClinO – see in particular articles
- Art. 29, 34, 55. Modifications
HRO – see in particular article
- Art. 18 Modifications