Development↦Quality and Risk↦Risk Communication↦Strategy
What is it? Why is it important?
The risk strategy of a study provides guidance on how to manage study risks. Persons involved in risk management activities or affected by risk control-measures should:
- Receive ongoing information to its effectiveness including potential adaptations
- Provide ongoing relevant feedback to the risk management team and/or SP-INV
This will
- Facilitate risk reviews
- Insure continual improvement
- Enable to learn from experience (e.g. lessons learned)
- Promote transparency and support to the risk-based QMS of the study
Communication can include regular updates between SP-INV, Site-INV and study staff during team meetings, newsletter from SP-INV, ongoing study trainings.
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Example of an established risk management process: Safety reporting at a study site.
Required process: All SAEs must be reported to SP-INV within 24 hours.
Risk management prior to study conduct
- Risk identification: SAE reporting is not done or not within required timeline (24 hr.)
- Risk evaluation: is likely to occur and will have serious impact on participant safety
- Risk prioritisation: High priority due to safety risks for study participants
Implemented risk control-measures
- Required SAE reporting procedures are described in a SOP or WI
- Two monitoring visits will be conducted during study conduct in order to assess SAE reporting procedures
Riskdocumentation and communication
- The Site-INV documents any SAE non-compliance in a study deviation log
- Applicable study staff is trained on applicable SOPs and/or WIs regarding SAE reporting procedures
QC and monitoring visit during study conduct
- Monitoring findings: reporting timeline to SP-INV was delayed in 2 instances
- Root cause analysis: reporting responsibilities were unclear
Implemented risk control-measures and risk communication
- Reporting responsibilities are delegated by the Site.-INV to one key staff member (e.g. documented on the site delegation-log)
- Staff is trained on adapted safety reporting measures
What do I need to do?
As a SP-INV and based on the risk prevention strategy of your study:
- Maintain oversight regarding any delegated tasks and/or functions in order to ensure compliance with the risk-based QMS of the study
- Collect feedback from study staff in order to ensure ongoing effectiveness of risk control-measures
- Train study staff and communicate potential adaptations to risk control-measures
- Document all risk related activities, including any evaluation or rational for implemented/ adapted risk control-measures in the Risk Assessment Form (RAF) of your study
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Risk communication should be a 2-way street
- As a SP-INV implement 2-way communication channels with:
- As a Site-INV provide ongoing relevant feedback to the SP-INV and site staff
- Schedule team meetings to ensure information flow
- Clearly define responsibilities within implemented risk control procedures
- Discuss and define problem-solving strategies
- In order to reach all potential stakeholders, applicable information can be documented in a newsletter
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 guidelines
- 5.0 for Quality management
- 5.0.5 Risk communication
- 5.2.2 Addendum: Sponsor oversight
ISO 9001:2015 (access liable to costs) – see in particular section
- Quality Management Systems