Question: ArrayIf the situation described in the plan as "definitely relevant", "possibly relevant", or "unable to determine" is relevant, it will be considered as the PV of the CRO, Do you need to confirm with the applicant that 'possibly unrelated' situations are also relevant, and that meeting SUSAR standards also requires rapid reporting? @ @ According to Article 33 of China's Good Clinical Practice for Drug Trials, the applicant entrusts a contract research organization (CRO) When carrying out work, it is necessary to clarify the specific tasks entrusted and the corresponding standard operating procedures. Therefore, it is recommended that CRO communicate fully with the sponsor before the project is launched, reach an agreement on the criteria for correlation judgment and SUSAR reporting, and implement this standard uniformly in the research project. If there are exceptions, it is necessary to communicate fully with the applicant and researcher in a timely manner, and keep records of the relevant communication and discussion results as well as judgment criteria. There are currently different standards in the industry regarding whether 'possibly unrelated' should correspond to 'relevant'. For example, according to Clinical Trial Regulation (EU) No.536/2014 Q&A, if researchers use WHO's causal relationship classification, it may be considered irrelevant. According to the CDE's "Common Issues in Rapid Reporting of Safety Data during Drug Clinical Trials (Version 1.0)", Q9 mentions that causal relationships are "unable to be evaluated" or "unknown", which are not standardized, but cannot exclude correlations and require rapid reporting according to SUSAR. It is recommended that applicants establish internal procedures based on compliance and scientific considerations to standardize the evaluation criteria for causal relationships. Reference: Clinical Trial Regulation (EU) No.536/2014 Q&A, May 2022 Quick Report on Safety Data during Drug Clinical Trials FAQ (Version 1.0)
Answer:
根据中国《药物临床试验质量管理规范》第三十三条,申办者委托合同研究组织(CRO)开展工作时,应明确委托的具体工作以及相应的标准操作规程。因此建议CRO在项目开展前和申办者进行充分沟通,对关联性判断和SUSAR报告标准达成一致,并在研究项目中按此标准统一执行。如有例外需要及时与申办者和研究者充分沟通,并对相关沟通和讨论结果以及判断标准做好记录。
“可能无关”是否应该对应到“有关”,目前业内存在不同标准。例如,根据Clinical Trial Regulation (EU) No.536/2014 Q&A,如果研究者使用WHO的因果关系分类,可能无关可以认为是无关。根据CDE发布的《药物临床试验期间安全性数据快速报告常见问题(1.0版)》,Q9提到因果关系为“无法评价”或“未知”表述不规范,但均无法除外相关性,需要按照SUSAR快速报告。建议申办者基于合规性和科学性的考量,建立内部规程,规范因果关系的评价标准。
参考:Clinical Trial Regulation (EU) No.536/2014 Q&A, May 2022
药物临床试验期间安全性数据快速报告常见问答(1.0版)