Careers in Clinical Research

May 21, 2008

FDA website gets a facelift

Filed under: FDA Regulation — clinnovo @ 9:41 pm


Now we all did visit the FDA website and felt it was a bit out-of-fashion. FDA has listened to us and have come up with new look website, check it out at www.fda.gov.

One thing : The new look is only for the first page, rest of the FDA site is exactly like you saw many many years back….

May 20, 2008

CDISC ADaM standard

Filed under: ADaM, CDISC, FDA Regulation — clinnovo @ 9:26 pm

ADaM is a CDISC standard to submit analysis data to FDA. Key is to understand that ADaM is a SDTM model for providing analysis data, programs and data definitions. The principles of ADaM is aimed at providing  a clear and unambiguous  communicationof the content, source and  quality of the datasets submitted in support of  the statistical analysis performed by the 
sponsor. This in turn would support the machine-readable  description for the JANUS data repository. 

Analysis datasets

Analysis datasets are datasets created to support specific analyses.

  • Each dataset is provided as a SAS Transport (XPORT) file. 
  • Programs should be provided as both ASCII text and PDF files and should include sufficient documentation to allow a reviewer to understand the submitted programs. 

Programs

Programs are scripts used with selected software to produce reported analyses based on these datasets.

Analysis-level Metadata

  • ANALYSIS NAME –A unique identifier for this analysis. May include a table number or other sponsor- specific reference. 
  • DOCUMENTATION –A text description documenting the analysis performed.
  • REASON –The reason for performing this analysis. Examples may include Pre-specified, Data-driven, Exploratory, and Regulatory Request. 
  • DATASET –the name of the analysis dataset used should be linked to the analysis dataset used for this analysis. In most cases, this will be a single dataset. If multiple datasets are used, they should all be listed here. 
  • PROGRAM –Analysis programs using the DATASET above as input can be described or included here.
The complete ADaM specification can be found at : http://www.cdisc.org/models/adam/V2.0/index.html

May 19, 2008

define.xml and SDTM

Filed under: CDER, CDISC, FDA Regulation — clinnovo @ 10:03 pm

Define.xml is the document which specifies the standard for providing Case Report Tabulations Data Definitions in an XML format for submission to regulatory authorities (e.g., FDA). 

The XML schema used to define the expected structure for these XML files is based on an extension to the CDISC Operational Data Model (ODM).
In the picture below the key aspects are highlighted with the red text, basically it is a listing of data items that a sponsor will transmit to FDA along with the regulatory application.

Each data set if furthered detailed with what data items are sent and their nature (ex: Derived or from a CRF page)

You can find the DTD definition and stylesheets to transform define.xml on CDISC website : http://www.cdisc.org/models/def/v1.0/index.html

May 13, 2008

FDA regulations on eClinical trials

Filed under: FDA Regulation — clinnovo @ 4:00 pm

The following general guidelines are proposed by FDA in reference in Computerized systems in clinical trials, the complete document is available at http://www.fda.gov/ora/compliance_ref/bimo/ffinalcct.htm

A. Each study protocol should identify at which steps a computerized system will be used to create, modify, maintain, archive, retrieve, or transmit data.

Comment : This means that the study protocol has to receive input from the data manager. Most of the companies include these steps as SOPs so that they can be referenced in the study protocol.
B. For each study, documentation should identify what software and, if known, what hardware is to be used in computerized systems that create, modify, maintain, archive, retrieve, or transmit data. This documentation should be retained as part of study records.
Comment : This level of detail is not mandatory, and is often missed out in most study protocols.

C. Source documents should be retained to enable a reconstruction and evaluation of the trial.

Comment : This requirement is fulfilled via a Audit trial so that FDA/ independent audits can be performed.
D. When original observations are entered directly into a computerized system, the electronic record is the source document.

Comment : The specific condition where this rule will not apply is for lab data, the source data is obtained electronically from the lab. The data is then batch loaded into the CDM system, still the source data is the lab data.
E. The design of a computerized system should ensure that all applicable regulatory requirements for recordkeeping and record retention in clinical trials are met with the same degree of confidence as is provided with paper systems.
Comment : 21 CFR Part 11 and ER/ES are two common regulatory requirements. The “degree of confidence” is set via a validation process for each CDM system.

F. Clinical investigators should retain either the original or a certified copy of all source documents sent to a sponsor or contract research organization, including query resolution correspondence.

Comment : Though this sounds simple, it is complicated for investigators to maintain a source data archive.
G. Any change to a record required to be maintained should not obscure the original information. The record should clearly indicate that a change was made and clearly provide a means to locate and read the prior information.

Comment : All updates on source data will include a reason for change, data and time of change, person initiating the change, data value before change and data value after change. Sometimes the change in data may require sign-off by a study manager.
H. Changes to data that are stored on electronic media will always require an audit trail, in accordance with 21 CFR 11.10(e). Documentation should include who made the changes, when, and why they were made.

Comment : Refer to above
I. The FDA may inspect all records that are intended to support submissions to the Agency, regardless of how they were created or maintained.

Comment : Refer to above
J. Data should be retrievable in such a fashion that all information regarding each individual subject in a study is attributable to that subject.

Comment : Refer to above

K. Computerized systems should be designed: (1) So that all requirements assigned to these systems in a study protocol are satisfied (e.g., data are recorded in metric units, requirements that the study be blinded); and, (2) to preclude errors in data creation, modification, maintenance, archiving, retrieval, or transmission.

Comment : Refer to above
L. Security measures should be in place to prevent unauthorized access to the data and to the computerized system.
Comment : Refer to above

March 20, 2008

Drug Safety and Pharmacovigilance

Filed under: CDER, drug safety, EMEA, FDA Regulation, pharmacovigilance — clinnovo @ 3:10 pm

The ground truth of how pharmaceutical industry has evolved over the past decade is the large surge in increased specialization and sophistication. In this series we will focus on specialist careers in pharmaceutical industry, lets start with pharmacovigilance.

No medicine which is effective is 100% safe, but the adverse/side effects of a drug have to be weighed against the benefits of the drug. For example a drug treating terminal disease like cancer can have some adverse effects like vomiting and hair loss, but still it would be approved given the gravity of disease it is used to treat. Drug safety function focuses on measurement, prediction, reporting and evaluating safety signals. There are several roles in this domain namely :

  • Drug safety physician
  • Safety specialist
  • Safety informatics expert
  • Safety information expert

If you are good at either synthesising medical information/research finding or have great analytical capabilities to drill down into complex safety data this area of specialization is very suitable and lucrative for you.

March 17, 2008

Why SAS ?

Filed under: Analytics, CFR part 11, FDA Regulation, SAS — clinnovo @ 12:07 pm

Recently we were looking for some SAS experts to work for clients in US, UK and Singapore, the response as always was huge (200+ resumes), for some of those that looked outstanding we had a telephone interview with only one question : Why SAS ?, unfortunately only 2 candidates knew why SAS was relevant in clincial research.

If you know why SAS please feel free to let us know using the comments option below

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