Oh dear! I didn't see any of these responses until now! I think my notifications weren't working. I had been wondering this whole time "why didn't anyone respond..." haha. I am so sorry! It may be too late, but here are the answers:
The PI's involvement with the Human Subjects is ZERO. Just a data provider. Pull the records from the chart and send them off to the sponsor. That's about it. Well, to be fair, also do the admin work of getting the contract signed.
My apologies for poor wording. When I said, once "after all the interventions are completed, all the data and documents would be immediately sent back to the pharmaceutical company," I mean that the PI also reviews all the data and may conduct her own (or duplicate) the analysis, but essentially the data are sent directly to the sponsor.
No, the PI will NOT sign a 1572. She believes none are necessary or relevant for her.
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Tamiko Eto
Research Compliance and IRB Manager
Milpitas CA
United States
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Original Message:
Sent: 16-Feb-2020 08:30
From: Julie Omohundro
Subject: How Pharmaceutical Clinical Trials work
I deleted my first response, and also much of this response, when I remembered that Tamiko had posted here once previously, also about "conflicts of interest," but never responded to any of the questions that were posed by members of the forum in their effort to give her informed responses. So I think I will say no more until Tamiko has had a chance to clarify:
What is the PI's involvement with the HUMAN SUBJECTS in terms of assessing and managing any safety issues?
When you say that, once "after all the interventions are completed, all the data and documents would be immediately sent back to the pharmaceutical company," do you mean that the PI gets and reviews all the data first, or that the data are sent directly to the sponsor? (Sent "back" implies the sponsor had it first and then sent it to the PI, who would now send it back.)
Will the PI sign a 1572?
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Julie Omohundro, ex-RAC (US, GS), still an MBA
Principal Consultant
Class Three, LLC
Mebane, North Carolina, USA
919-544-3366 (T)
434-964-1614 (C)
julie@class3devices.com
Original Message:
Sent: 16-Feb-2020 07:31
From: Shy Shorer
Subject: How Pharmaceutical Clinical Trials work
What you describe (with one major difference) is pretty normal. The company hires the PI/site to conduct the study and pays accordingly. This is how most phase I units functions. Of course, there is nothing to prevent the PI to negotiate more involvement if they so wish. In academic environment publication rights might be important and something to be negotiated - although in the setting of a phase I it would not be surprising if the company will want to delay any publications.
The IRB is not concerned about the results of the study. It is concerned about the risk/benefit ratio to participants. As long as they interactions with the participants is complete and all safety issues are addressed prior to closure of the study with the IRB it should not be a problem.
However, if the PI holds the IND it is a completely different ball game, as the PI is completely responsible to the entire life cycle of the protocol and is the one who need to report the results back to the FDA, as well as all other Sponsor obligations.
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Shy Shorer MD, MBA, EJD
Director, Office of Sponsor and Regulatory Oversight
Center for Cancer Research
National Cancer Institute
Original Message:
Sent: 14-Feb-2020 16:54
From: Tamiko Eto
Subject: How Pharmaceutical Clinical Trials work
Coming from a predominantly education-centered research institution, we don't see many drug studies. Occasionally we do, but we outsource them to commercial IRBs.
That said, I do have a general question about Phase 1 drug studies (or any phase):
Is it typical for a pharmaceutical company to pay university hospital PIs and/or large research institution PIs to recruit, consent, and administer their investigational drugs and collect biospecimens, but NOT actually have these PIs play any additional role in the study?
For example, after all the interventions are completed, all the data and documents would be immediately sent back to the pharmaceutical company for analysis and the research institution is then complete with the project and closes out their study with their IRB with no further involvement.
This is new to me but seems to be a bit of a conflict because:
1) There are no findings to present to the IRB in the closure/final report.
2) Why wouldn't the pharmaceutical company just use their own internal docs to run the trial?
3) If our PI is the one holding the IND, does this cause some concern?
Are there any other considerations I should be aware of?
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Tamiko
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