Responsibility for the safety of the subjects in a clinical trial is
shared between the sponsor, the local site investigators (if different
from the sponsor), the various IRBs that supervise the study, and (in
some cases, if the study involves a marketable drug or device), the
regulatory agency for the country where the drug or device will be sold.
For safety reasons, many clinical trials of drugs are designed to
exclude women of childbearing age, pregnant women, and/or women who
become pregnant during the study. In some cases, the male partners of
these women are also excluded or required to take birth control
measures.
Throughout
the clinical trial, the sponsor is responsible for accurately informing
the local site investigators of the true historical safety record of
the drug, device or other medical treatments to be tested, and of any
potential interactions of the study treatment(s) with already approved
treatments. This allows the local investigators to make an informed
judgment on whether to participate in the study or not. The sponsor is
also responsible for monitoring the results of the study as they come in
from the various sites, as the trial proceeds. In larger clinical
trials, a sponsor will use the services of a
data monitoring committee
(DMC, known in the US as a data safety monitoring board). This
independent group of clinicians and statisticians meets periodically to
review the
unblinded
data the sponsor has received so far. The DMC has the power to
recommend termination of the study based on their review, for example if
the study treatment is causing more deaths than the standard treatment,
or seems to be causing unexpected and study-related serious
adverse events.The sponsor is responsible for collecting
adverse event
reports from all site investigators in the study, and for informing all
the investigators of the sponsor's judgment as to whether these adverse
events were related or not related to the study treatment. This is an
area where sponsors can slant their judgment to favor the study
treatment.
The sponsor and the local site investigators are jointly responsible for writing a site-specific
informed consent
that accurately informs the potential subjects of the true risks and
potential benefits of participating in the study, while at the same time
presenting the material as briefly as possible and in ordinary
language. FDA regulations and ICH guidelines both require "the
information that is given to the subject or the representative shall be
in language understandable to the subject or the representative." If the
participant's native language is not English, the sponsor must
translate the informed consent into the language of the participant.
[59]
Local site investigators
The ethical principle of
primum non nocere
("first, do no harm") guides the trial, and if an investigator believes
the study treatment may be harming subjects in the study, the
investigator can stop participating at any time. On the other hand,
investigators often have a financial interest in recruiting subjects,
and could act unethically to obtain and maintain their participation.
The local investigators are responsible for conducting the study
according to the study protocol, and supervising the study staff
throughout the duration of the study. The local investigator or his/her
study staff are also responsible for ensuring the potential subjects in
the study understand the risks and potential benefits of participating
in the study. In other words, they (or their legally authorized
representatives) must give truly informed consent.
Local investigators are responsible for reviewing all adverse event
reports sent by the sponsor. These adverse event reports contain the
opinion of both the investigator at the site where the adverse event
occurred, and the sponsor, regarding the relationship of the adverse
event to the study treatments. Local investigators also are responsible
for making an independent judgment of these reports, and promptly
informing the local IRB of all serious and study treatment-related
adverse events.
When a local investigator is the sponsor, there may not be formal
adverse event reports, but study staff at all locations are responsible
for informing the coordinating investigator of anything unexpected. The
local investigator is responsible for being truthful to the local IRB in
all communications relating to the study.
Institutional review boards (IRBs)
Approval by an
Institutional Review Board
(IRB), or ethics board, is necessary before all but the most informal
research can begin. In commercial clinical trials, the study protocol is
not approved by an IRB before the sponsor recruits sites to conduct the
trial. However, the study protocol and procedures have been tailored to
fit generic IRB submission requirements. In this case, and where there
is no independent sponsor, each local site investigator submits the
study protocol, the consent(s), the data collection forms, and
supporting documentation to the local IRB. Universities and most
hospitals have in-house IRBs. Other researchers (such as in walk-in
clinics) use independent IRBs.
The IRB scrutinizes the study for both medical safety and protection
of the patients involved in the study, before it allows the researcher
to begin the study. It may require changes in study procedures or in the
explanations given to the patient. A required yearly "continuing
review" report from the investigator updates the IRB on the progress of
the study and any new safety information related to the study.
Regulatory agencies
In the US, the FDA can
audit
the files of local site investigators after they have finished
participating in a study, to see if they were correctly following study
procedures. This audit may be random, or for cause (because the
investigator is suspected of fraudulent data). Avoiding an audit is an
incentive for investigators to follow study procedures.
Alternatively, many American pharmaceutical companies have moved some
clinical trials overseas. Benefits of conducting trials abroad include
lower costs (in some countries) and the ability to run larger trials in
shorter timeframes. Critics have argued that clinical trials performed
outside the U.S. allow companies to avoid many of the FDA’s regulations,
since the FDA audits these trials less frequently than U.S. studies.
For drug applications approved by the FDA in 2008, 0.7 percent of
foreign clinical study sites were audited by the FDA compared to 1.9
percent domestically. Other criticisms of foreign clinical studies,
especially in developing countries, relate to the rights and welfare of
study participants, integrity of study data, and relevance of data to
the U.S. population.
[60][61]
Different countries have different regulatory requirements and
enforcement abilities. An estimated 40% of all clinical trials now take
place in Asia, Eastern Europe, and Central and South America. "There is
no compulsory registration system for clinical trials in these countries
and many do not follow European directives in their operations", says
Jacob Sijtsma of the Netherlands-based WEMOS, an advocacy health
organisation tracking clinical trials in developing countries.
[62]
Beginning in the 1980s, harmonization of clinical trial protocols was
shown as feasible across countries of the European Union. At the same
time, coordination between Europe, Japan and the United States led to a
joint regulatory-industry initiative on international harmonization
named after 1990 as the
International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH)
[63]
Currently, most clinical trial programs follow ICH guidelines, aimed at
"ensuring that good quality, safe and effective medicines are developed
and registered in the most efficient and cost-effective manner. These
activities are pursued in the interest of the consumer and public
health, to prevent unnecessary duplication of clinical trials in humans
and to minimize the use of animal testing without compromising the
regulatory obligations of safety and effectiveness."
[64]