Conduct↦Protocol↦Protocol Amendment↦Procedures
What is it? Why is it important?
A protocol amendment is necessary if (a) change(s) is/are made in an Ethics Committee (EC), and if applicable Swissmedic (i.e. risk-category B and C) approved protocol.
Amendments are either substantial (SA) or non-substantial (Non-SA). SAs potentially impacting participant safety (risk-benefit ratio) and rights, or the reliability of study results, and require approval prior to implementation.
Reasons for a protocol amendment may include:
- New scientific evidence requiring an adaptation of study aim, statistical study plan
- Missing variables requiring the collection of additional data and/or biological material
- Slow participant recruitment (e.g. inclusion of additional study sites, adaptations of study inclusion/exclusion criteria)
- Staff fluctuations and change in responsibility (e.g. substitution of Site-INV)
Example of SAs that require Swissmedic approval may include:
- Adaptation regarding the investigational product, such as changes in IMP administration route (oral, intravenous), dosage form (tablet, cream), administered dose (200 or 500 mg / tablet)
- New preclinical/clinical data or new manufacturing procedures potentially affecting product safety (i.e. study risk-benefit ratio)
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Safety amendments do not require pre-approval by EC/RA, as risk-control measures must be implemented in order to protect study participants (i.e. implementation of safety and protective measures)
What do I need to do?
As a SP-INV:
- Apart from the protocol, identify documents that need to be adapted due to the amendment (e.g. PIS/ICF, CRF).
- Make changes to applicable protocol sections / documents in track-change (i.e. both old and new entries must remain legible)
- Ensure amended documents comply with document identification guidelines
- Provide a short rational why changes are necessary
- Approve (sign and date) the amendment together with applicable partners (e.g. Site-INV, statistician)
- 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 partners (e.g. laboratories, monitor) are trained on the amendment (i.e. document in training-log)
Note:
- Adaptations to participant documents (e.g. PIS, ICF) may require that participants re-consent to the study
- A shift in the study`s risk-benefit ratio may require an update of the insurance policy
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A protocol amendment can only be implemented while the study is still ongoing. An amendment is no longer possible after the last patient has had his or her last study visit.
Document Management:
- Create a “document history” to list all protocol changes
- For each amendment ensure to comply with document identification guidelines (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
- Ensure 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 – in particular see
- 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 - see in particular sections (access liable to cost)
- 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. Changes
ClinO-MD – See in particular articles
- Art. 15 Modifications
- Art. 20 Modifications
HRO – see in particular article
- Art. 18. Changes