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ABPI Guidelines for Phase 1 Clinical Trials (PDF

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• added to the files during the trial, to show that<br />

any new in<strong>for</strong>mation is documented as it<br />

becomes available; and<br />

• in the file after the end of the trial.<br />

Quality of documents<br />

Essential and supporting documents:<br />

• should be complete, legible, genuine, traceable<br />

to a specific trial, and readily available to the<br />

sponsor and MHRA upon request;<br />

• should not be altered without permission and<br />

creation of an audit trail, particularly if the<br />

documents are stored on electronic, magnetic,<br />

optical or similar media;<br />

• may be copied or transferred to other media <strong>for</strong><br />

archiving, if the method has been validated to<br />

ensure that in<strong>for</strong>mation will not be lost or altered<br />

and if the copies or transfers are certified <strong>for</strong><br />

accuracy and completeness; and<br />

• should be readily available in printed <strong>for</strong>m, if<br />

stored on media that require processing.<br />

Storage of documents<br />

A specific person, an archivist, should store trial<br />

documents. The archivist should:<br />

• have enough dedicated space that is suitable to<br />

store documents from all current trials on site and<br />

to store documents from all completed trials<br />

either on-site or off-site in a commercial archive;<br />

• have storage facilities that are secure and<br />

adequately protected from fire, flood, pests,<br />

extremes of temperature and humidity, and<br />

unauthorised access;<br />

• in<strong>for</strong>m the sponsor about the arrangements <strong>for</strong><br />

storing documents, and about any changes to the<br />

arrangements; and<br />

• notify the sponsor if the investigator becomes<br />

unable to store trial documents, so that the<br />

sponsor can arrange <strong>for</strong> them to be stored<br />

elsewhere.<br />

Duration of storage<br />

Essential and supporting documents, including the trial<br />

subjects' records, must be archived until at least five<br />

© Association of the British Pharmaceutical Industry 2007<br />

years after the end of the trial. Access to documents<br />

must be restricted to the people with responsibility <strong>for</strong><br />

archiving:<br />

• until at least two years after the last approval of a<br />

marketing application in the EU and until there<br />

are no pending or intended marketing<br />

applications in the EU; or<br />

• until at least two years after stopping the<br />

development of the IMP; or<br />

• <strong>for</strong> a longer period, if required by the MHRA or<br />

the sponsor.<br />

Disposal of documents<br />

The investigator must not destroy any essential<br />

documents without the sponsor's permission. The<br />

reasons should be recorded and the records kept <strong>for</strong><br />

five or more years. Sponsors should in<strong>for</strong>m the<br />

phase 1 unit when the retention period is over.<br />

27. Project management and monitoring<br />

Some sponsors allocate to every phase 1 trial a project<br />

manager, to manage the administrative aspects of the<br />

trial, and a monitor, to carry out the traditional duties<br />

of a monitor. 14 Other sponsors may have one person<br />

do both jobs. The project manager and monitor<br />

should be lifescience graduates or of similar status.<br />

They should be trained in GCP, the relevant aspects of<br />

GMP and monitoring, as appropriate.<br />

<strong>Phase</strong> 1 trials have special features, as follows.<br />

Nowadays, commercial CROs do most phase1 trials. 6<br />

The trials start and usually end on schedule, especially<br />

if the trial subjects are healthy volunteers. Beds, staff<br />

and resources <strong>for</strong> the trial are booked, and subjects set<br />

aside time to take part. So any delay causes problems<br />

and many people are inconvenienced. In a phase 1<br />

trial, many data are collected from few subjects.<br />

Un<strong>for</strong>eseen findings often need protocol amendments<br />

to keep a trial running. And a unit with an MIA (IMP)<br />

may have to manufacture, assemble or import the IMP.<br />

Hence, phase 1 trials need more input from the<br />

sponsor. For example, the project manager and/or<br />

monitor should:<br />

• know the pre-clinical data and be able to deal<br />

with any concerns that the investigators might<br />

have about the risk assessment, by arranging <strong>for</strong><br />

33

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