Conduct↦Safety↦Safety Reporting↦Responsibilities
What is it? Why is it important?
Main aim and concern for anyone conducting a study is to guarantee the safety and rights of study participants as well as the quality of the study data.
In order to fulfil safety management responsibilities, the SP-INV and Site-INV must:
- Allocate safety responsibilities in compliance with legal obligations and according to contractual agreement(s)
- Provide staff with safety management SOPs, WIs, and applicable training
- Based on study complexity implement:
- A risk-based QMS with the aim to assess study risks and define preventative measures
- A Data Safety Monitoring Board (DSMB)
- Ensure safety handling and reporting procedures are complied with during study conduct (e.g. as defined in the law, study protocol, safety SOPs, safety management plan)
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EC/RA responsibilities
In the event participant safety becomes jeopardised, the EC may:
- Request from the SP-INV or Site-INV safety relevant information and/or documentation
- Decide to revoke or suspend study authorisation, or make its continuation subject to additional conditions
In the event of safety concerns, the RA (e.g. Swissmedic, FOPH) retains the right to initiate applicable measures. The EC and RA keep each other informed and coordinate their measures.
What do I need to do?
- Know and implement safety reporting laws and guidelines (e.g. HRA, ICH GCP, ISO 14155)
- Delegate safety responsibilities tasks to staff that is adequately qualified and safety trained (e.g. on safety documentation and reporting requirements)
- Assess safety events and evaluate if they require expedited reporting (e.g. within required hours or days)
- Maintain oversight on current and new safety concerns regarding the product under investigation (e.g. IB updates)
- Implement protective measures without delay should that become necessary and notify the EC and RA (e.g. Swissmedic, if applicable)
- Ensure appropriate medical care to participant experiencing safety event(s)
As a SP-INV:
- Ensure safety SOPs and/or WIs remain current
- Inform Site-INVs of new safety concerns (multi-centre studies)
- In the event of an unfavourable shift in the risk-benefit ratio of the study, evaluate necessary steps (e.g. a protocol amendment, preliminary study stop, study termination)
For more information on this topic refer to Quality and Risks in this Study Guide.
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Regardless of reporting deadlines, the Site-INV and SP-INV must first attend to participant safety and well-being.
AEs (both serious and non-serious) are followed until resolution or stabilisation of the event. Participants with ongoing AEs at study termination (including follow-up visits) are followed further up until recovery or stabilisation of the disease
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
Swissmedic – see in particular information sheets
- BW101_10_002e_MB FAQ on clinical trials with medicinal products
- MU680_20_004e_MB Medical devices FAQs Patients
References
ICH GCP E6(R2) – see in particular guidelines
- 1.27 EC responsibility
- 1.31 RA responsibility
- 4.3. Medical care of study subjects
ICH E2A Definition and standards for expedited reporting
ISO 14155:2020 Medical device (access liable to cost) – see in particular sections and annex
- 9.2.5 Safety evaluation and reporting (SP-INV)
- 10.8 Safety reporting (site-INV)
- Annex G EC responsibilities
Swiss Law
HRA – see in particular articles
- Art. 15 Safety and protective measures
- Art. 48 Official measures
ClinO – see in particular articles
- Art. 37 Notification of safety and protective measures
- Art. 39 Documentation of AE
- Art. 40 Documentation and reporting of SAE
- Art. 41 Documentation and reporting of SUSAR
- Art. 42 Documentation and reporting of SAE for in vitro MD
- Art. 43 ASR
- Art. 44 Reporting on the use of radiation sources
ClinO-MD – see in particular articles
- Art. 32 Documentation of AE
- Art. 33 Reporting of SAE
- Art. 34 reporting of safety and protective measures
- Art. 35 ASR
- Art. 39 Reporting on the use of radiation sources
HRO – see in particular articles
- Art. 3 Responsibilities of project leader and sponsor
- Art. 21 SE definition and reporting