CREDE GCP Beginner Webinar Lecture Notes 2023
CREDE GCP Beginner Webinar Lecture Notes 2023
CREDE GCP Beginner Webinar Lecture Notes 2023
Sections 1 - 4
Section 1: Clinical Research, Phases and Role Players
GCP therefore applies to any person involved in the research process, whether you are the
one working directly with the participant, or just with their samples, or just with their data and
analysis, and everything in between.
What makes a clinical trial different and why is this distinction important?
We’ll discuss this during the webinar (here’s a clue: what is an “intervention”?).
You are an investigator on a clinical trial with a potential new medication for resistant
tuberculosis (MDR TB). You are personally convinced that this new medication is effective.
Perhaps unconsciously, you select participants with less severe disease and a better chance
of survival to go into the experimental arm of the trial, and others with a worse prognosis into
the control arm.
Your colleague sees a participant at a follow-up visit who was allocated to the experimental
arm. The participant complains of a mild headache. Knowing that the new medication has
previously been reported to cause terrible headaches, your colleague interprets and records
the symptom as severe, or very bad.
Another participant, knowing that she has been allocated to the control arm, thinks that the
nausea she gets after taking her pills is unimportant, and keeps it to herself.
AT THIS POINT THE SPONSOR APPLIES FOR REGISTRATION FOR THE PRODUCT TO
BE USED NON- EXPERIMENTALLY e.g. prescribed in clinical practice
All pharmaceutical medicines or vaccines on the market need to undergo a version of this
process. This may take years and is a very expensive pathway.
What is the success rate i.e. of every 10 products that enter phase 1 trials, how many end up
successfully on the market?
The SPONSOR sets up the study, pays for it, appoints the researcher, writes the protocol,
oversees the process, and provides the study infrastructure e.g. database.
The RESEARCH TEAM, led by the Principal Investigator (PI), conducts the study.
MONITORS and AUDITORS a re appointed by the sponsor to link the sponsor and the
research team and to monitor the conduct of the research by the research team.
An ETHICS COMMITTEE represents the interests of the research participants and oversees
the rights, safety and well-being of participants by approving and monitoring research
activities and documentation.
SAHPRA appoints INSPECTORS to check compliance by the research team and sponsor,
to the protocol and GCP guidelines.
COMMUNITY ADVISORY BOARDS represent the community and advise the research team
on community issues, opinions and preferences.
“All study material is the copyright of CREDE (Pty) Ltd and may not be
reproduced or used without written permission”
Finally, we’ll end the subsection by summarizing how GCP came about.
The Nuremberg Code was published in 1947 after the Nuremberg war trials.
Nazi physicians were put on trial after the second world war for medical experiments that
were performed on prisoners in the concentration camps.
The Nuremberg Code was an attempt to prevent these atrocities from recurring and contains
10 items, amongst which the importance of informed consent, the right to withdraw, and
consideration of risk versus benefit.
This link to a NEJM article contains the 10 items and some more detail:
Fifty Years Later: The Significance of the Nuremberg Code
Scenario 1:
A clinical trial is planned in participants with tuberculosis (TB) with a new combination of
drugs.
Scenario 2:
A simple non-interventional study is planned by a psychology Masters’ student, who is also a
teacher’s assistant on some undergraduate courses. She will administer a questionnaire to a
sample of university students recording negative life experiences over the previous year.
Thalidomide was a drug used in the 1950’s and 1960’s for nausea in pregnancy. However,
even though the drug was used extensively for many years, there were very little data for it’s
safety (certainly nothing like phase 1 to 4 that we have these days) and no testing in
pregnant women. It turns out that Thalidomide in early pregnancy causes serious birth
defects like underdeveloped limbs.
Here’s an excellent article and video from the New York Times:
The Death and Afterlife of Thalidomide
The Thalidomide disaster was a catalyst for the Declaration of Helsinki - one of our
cornerstone documents.
We have provided you with your copy of the Declaration of Helsinki as part of the resources.
Please read through the principles before the webinar.
The trial ends with a favourable outcome result - the new medication works well. For the 2
years that participants in the experimental arm were on the new fancy medication, they did
very well and their disease was well controlled. They did have some mild and moderate
adverse events (side effects) though.
However, the trial is now over, so the sponsor thanks them and refers them back to their old
clinic to go back onto their old medication they used before.
The Tuskegee syphilis study was a study conducted on poor, black American males with
syphilis from 1932 to 1972 who lived in the small town of Tuskegee in the USA. They were
all already infected with the sexually transmitted disease syphilis.
At the start of the study no treatment for syphilis existed, and the plan was to follow the
participants over their lifetimes to observe the natural history of the disease over time.
Without treatment syphilis worsens over many years, causing debilitating symptoms like
neurological damage, dementia and early death.
Here’s the thing though: a treatment, in the form of penicillin, became available in the 1940s
- but these participants were never given the opportunity to receive that treatment.
In fact, the treatment was actively concealed from them so that the study could continue into
the effects of syphilis - and so that autopsies could later be performed on their bodies. So for
decades they continued to be followed up with their disease as part of the study, while they
could actually have been cured.
When the study was exposed in a headline article in the New York Times, there was an
uproar in the USA. A commission was set up to lay the foundation for legislation and
measures to prevent such incidents.
Here’s a useful video and interview with the journalist who exposed the study in 1972:
The unknowns about the Tuskegee syphilis study
The Belmont Report is well-known for its 3 ethical principles for clinical research:
1. Respect for persons (autonomy or agency) which requires researchers to respect
and protect the rights and decision-making capacity of participants.
2. Beneficence means that everything we do is in the best interests of the participant.
Non-malificence means we minimize and manage the risks. So we maximize benefits
and minimize risks.
3. Justice - the fair and equal distribution of benefits and risks. The communities or
individuals that take on the risk should be the ones benefiting from the research.
As part of your resource package, you have your own copy of ICH GCP (Topic E6).
These are the typical steps in the life cycle of a study or clinical trial:
1. Formulate the research question
2. Prepare a summary proposal
3. Find funding and put together the team
4. Write the protocol
5. Seek approval
6. Conduct the study & collect data
7. Analyse the data
8. Prepare the study report
During the conduct of the study, a number of processes follow each other (the typical steps
to any research study):
1. Recruitment (the process of identifying and approaching potential participants)
2. Informed consent
3. Screening (the process of determining whether a potential participant is eligible
according to inclusion and exclusion criteria in the protocol) and enrolment
(participant now becomes part of the study)
4. Conduct of the study and data collection
5. Close-out (the last visit on the last participant) and data analysis
6. Compile a study report
a) In order to avoid doing unnecessary consenting, you ask the sister-in-charge, who is a
friend of yours, if you can page through the clinical records in her office, so that you only
have to approach the women who are HIV negative for the full informed consent
b) After the introductory talk, one of the women comes to you in private. She says she just
wants to check that she understands. “I’m HIV positive” she says, “does this mean I can’t
take part?”. You confirm her understanding.
“All study material is the copyright of CREDE (Pty) Ltd and may not be
reproduced or used without written permission”
SA GCP section 5 and ICH GCP section 4 discusses the responsibilities of the
Investigator. In this section we will list those responsibilities, and look at some of them in
more detail. In particular, we will be dealing with:
● Delegation and supervision by the Principal Investigator (PI)
● Good Documentation Practice (GDP)
● Accountability of the Investigational Product (IP)
Please refer to:
● SA GCP section 5 (the equivalent is section 4 in ICH GCP)
● Case scenarios and questions within the notes below
The responsibilities of the investigator listed in SA GCP and ICH GCP include:
● Demonstrating that adequate qualifications and agreements are in place
● Providing adequate resources for the study to be conducted
● Medical care of clinical trial participants
● Informed consent
● Care and accountability of the Investigational Product
● Compliance with the protocol and with monitoring and auditing
● Data management and good documentation practice
● Safety reporting
● Providing progress reports and disseminating study results
Some terminology:
When I ask you who is the “investigator”, who do you think of?
What is the difference between the PI, a sub-investigator, site investigator, investigator, and
co-investigator?
Supervision: “…individual or party to whom the investigator delegates trial-related duties and
functions …”
Delegation: “…should ensure this individual or party is qualified to perform those trial-related
duties and functions and should implement procedures to ensure the integrity of the trial-related
duties and functions performed and any data generated.”
Not only does the PI need to be involved, we need to be able to demonstrate to a sponsor,
monitor, auditor, inspector and ethics committee that adequate delegation and supervision has
taken place.
During the webinar, we will look at something called the Delegation of Authority Log.
If you are the PI, before you sign someone onto your log, what would you like to know about
that person?
GCP refers to 3 competencies:
● Education - if you need a qualification to fulfil your role
● Training - protocol training, GCP training, protocol on SOPs etc.
● Experience - relevant to your role and the area of study
Traditionally, the types of skills that the PI and everyone on the team need to have, are divided into:
● Technical skills - skills and techniques
● Humanistic skills - how we work with people, our manner with participants and team
members, ethics etc.
What documentation and evidence can we provide to demonstrate each of these competencies
and skills?
“Original documents, data, and records (e.g. hospital records, clinical and office charts,
laboratory notes memoranda, subjects’ diaries or evaluation checklists, pharmacy dispensing
records, recorded data from automated instruments, copies or transcriptions certified after
verification as being accurate copies… “
SA GCP: Glossary,p.70/ ICH GCP 1.52
Here’s a quick way of thinking about what source is: “the first place where we record data or
information.”
We’ll look at some more examples of source data and source documentation during the
webinar, and the difference between source documents and a Case Report Form (CRF).
Definition of CRF: “A printed, optical, or electronic document designed to record all the protocol
required information to be reported to the sponsor on each trial participant”.
SA GCP Glossary,p.66/ ICH GCP 1.11
GCP has some guidance on how we work with our source documentation, the so-called ALCOA
CCEA principles.
A - Attributable: we are able to link an entry in the source to a person (who made the entry)
We also need to think about the correct procedure for correcting our errors, things like the
format of dates, and other best practices. More about this on the webinar.
“All study material is the copyright of CREDE (Pty) Ltd and may not be
reproduced or used without written permission”
Continuing with the discussion of the responsibilities of the investigator, this section examines 2
of those that are very important:
● Informed consent (IC)
● Safety reporting and adverse events
Please refer to:
● Lecture notes below
● SA GCP sections 2.5, 5.9
Informed Consent
Informed consent (IC) is a core responsibility of the research team.
Even if you're not the one taking the actual consent, whatever your role you do fulfil, must be
covered by consent in some way.
Here are some things to consider about informed consent in clinical research:
● It is never implicit (in other words just implied) - it is explicit and obvious
● It is not just verbal - it is always written
An audit trail is essential when it comes to IC - both the actual signed document, but also good
notes in the source documentation around the process.
Scenario 1: you are taking consent from a 16yr old potential participant. Her mother
accompanies her to the site. Who signs the consent? What is assent?
Scenario 2: your adult participant speaks Xhosa at home. Your printer is broken, so you couldn’t
print the Xhosa consent forms. But you have the English version, and that’s ok because
everyone speaks some English, don't they?
Scenario 3: Your participant is 8 years old. Her parents aren’t around any more, and she’s
grown up in the household of her grandma. Can grandma sign consent?
Scenario 4: your participant can’t read or write. What do we do now?
Scenario 5: your potential participant walks into the consent session and says to you: “whatever,
you don’t need to talk to me, as long as I get my money by the end of the visit today I’m happy,
where do I sign?”
Scenario 6: Your adult participant has TB and needs life-saving treatment. You inform her that
she has a choice not to take part, but do point out to her that the local clinic is under-staffed and
doesn’t have medication in stock, and so she would probably not get proper treatment there.
T- Time spent by the participant on site e.g. a short hour long visit versus the entire day
I- Inconvenience s uffered by a participant e.g. consider the difference between a simple
questionnaire and an invasive procedure
E- Expenses e.g. transport money, money for food
For clinical trials in SA, SAHPRA has a guideline for the minimum amount that should be given
to participants per study visit.
Do you know what that amount is?
Safety reporting
In clinical trials, reporting of adverse events becomes critically important.
Why? Well, obviously for the health safety of our participant, but also because this becomes
important data on the safety profile of our intervention, doesn’t it?
The sponsor and the PI (and therefore the entire research team) need to put systems in place to
detect, manage and report adverse events.
Untoward: “unintended and unfavourable” (we didn’t set out for this to happen and it’s not a nice
thing)
Medical occurrence: any health related event e.g. symptom, physical sign, abnormal lab result
Causal relationship: one thing causes another, i.e. the AE is caused by the intervention
What do we need to do differently for SAEs than non-serious AEs? (hint: what is “expedited
reporting” and what is an SAE report?)
According to SA GCP, we need to report the SAE urgently, at least within the time frame
specified in the protocol (which is often in the vicinity of 1 day).
Some SAEs are even more special, and we call them “SUSARs”
What does SUSAR stand for?
“All study material is the copyright of CREDE (Pty) Ltd and may not be
reproduced or used without written permission”