Senior Resident Department of Clinical Pharmacology, Seth GSMC and KEM Hospital, Donde Marg, Parel, Mumbai, INDIA.
Assistant Professor, Department of Clinical Pharmacology, Seth GSMC and KEM Hospital, Donde Marg, Parel, Mumbai, INDIA.
Indian J Med Ethics. 2022 Apr-Jun;VII(2):108-113. doi: 10.20529/IJME.2021.094.
The present audit was carried out with the objective of evaluating warning letters (WLs) issued to trial sponsors, clinical investigators and institutional review boards (IRBs) by the United States Food and Drug Administration during a six-year period and compare it with two similar earlier audits. WLs were reviewed and classified as per stakeholders and further categorised as per predefined violation themes. The chi-square test was performed for trend analysis of WLs. A total of 62 WLs were issued to the three stakeholders. The maximum number of WLs were issued to the clinical investigators (36/62, 58.06%), followed by sponsors (19/62, 30.64%), and least to the IRBs (7/62, 11.29%). Among sponsors, lack of standard operating procedures for the monitoring, receipt, evaluation and reporting of post-marketing adverse drug events was the most common violation theme (8/19, 42.1%). Among clinical investigators, deviation from investigational plan was the most common violation theme (31/36, 86.11%.). For IRBs, inadequate documentation was the most common violation theme (6/7, 85.71%). We saw an overall reduction in the number of WLs issued to the stakeholders. Thus, we identified multiple areas on which each stakeholder should work for improvement.
本次审核旨在评估美国食品和药物管理局在六年期间向试验赞助商、临床研究者和机构审查委员会 (IRB) 发布的警告信 (WL),并将其与之前的两次类似审核进行比较。对 WL 进行了审查和分类,根据利益相关者进行分类,并根据预先定义的违规主题进一步进行分类。采用卡方检验对 WL 进行趋势分析。共向三个利益相关者发布了 62 份 WL。向临床研究者发布的 WL 数量最多 (36/62,58.06%),其次是赞助商 (19/62,30.64%),IRB 最少 (7/62,11.29%)。在赞助商中,最常见的违规主题是缺乏监测、接收、评估和报告上市后药物不良反应的标准操作程序 (8/19,42.1%)。在临床研究者中,最常见的违规主题是偏离研究计划 (31/36,86.11%)。对于 IRB,最常见的违规主题是文件不足 (6/7,85.71%)。我们看到向利益相关者发布的 WL 数量总体减少。因此,我们确定了每个利益相关者应该改进的多个领域。