Who is responsible for drug accountability in clinical trials?

Drug Accountability of the Investigation Medication begins from the selection of location for its storage. Issues with drug accountability are major and the majority of warning letters from regulators are a result of this. Major delays are faced by sites for non-conformity and it often leads to non-acceptance of trial data. Drug accountability is of utmost importance and it is the clinical investigator who remains responsible for the entire process taking place at the clinical site. If the supplies are controlled substances then more attention shall be needed from the Investigator in terms of its storage and disposition. IRT systems allow in streamlining such processes by keeping a single source of data and hence the process of Drug Accountability tracking becomes easier.

It is the complexity surrounding the paper-based systems that makes them more prone to errors. Drug accountability shall be maintained at sponsor level and site level. The Investigational medication documented as shipped should reconcile with the documentation of used and unused. The Drug Accountability at site begins once an investigational drug reaches the site. Records need to be maintained and staffs need to confirm that the contents that have been shipped match its previous record. The authorized person needs to put his signature with date after thorough verification. Once these have been completed, the investigational drug needs to be stored securely maintaining the standards specified in the protocol. Entire details need to be updated in the drug accountability log and with the commencement of trials; drug dispensing records are to be updated in writing in multiple documents. Site shall maintain all the data of the drugs right from drug dispensing to final disposition. Paper-based drug accountability never ends with the end of study, discrepancies in accountability logs need to be resolved, and its copies are to be returned with the original shipment records. The sponsor should receive the reconciled log along with the returned investigational drugs. Any discrepancy in drug accountability not only violates the regulations but also points the integrity of the study and public health.

Utilizing electronic medium for data collection and tracking helps in mitigating the challenges associated with data accountability. When data associated with a trial gets centralized, then the visibility gets doubly enhanced and a single accountable system improves the process of reporting. This entire method eases regulatory compliance achievement process and accountability audit issues get resolved immediately. As the use of the IRT system increases the pace, end-of-study documents are prepared in no time using the single system as the source.

mIRT has a special feature to track Drug Accountability where the reconciliation of the supplies that are used, lost, damaged and returned shall be captured which enables the system to calculate the compliance of the drug automatically.

With the current advancements, as the world is moving ahead and accepting technology, there is an increased level of visibility in the supply chain for both the regulators and sponsors.

1. Trends, charts, and maps. US National Library of Medicine. clinicaltrials.gov/ct2/resources/trends. Published July 2019. Accessed July 25, 2019. [Google Scholar]

2. US Food and Drug Administration. CFR – Code of Federal Regulations Title 21. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm. Updated September 19, 2019. Accessed July 18, 2019. [Google Scholar]

3. International Conference on Harmonisation Good Clinical Practice. Good Clinical Practice Network. ichgcp.net/. Accessed July 18, 2019. [Google Scholar]

4. Form 1572. US Food and Drug Administration. www.fda.gov/media/71816/download. Accessed July 25, 2019. [Google Scholar]

5. Warning letters. US Food and Drug Administration. www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/warning-letters. Accessed July 25, 2019.

6. Responsibilities of sponsors and investigators. Selecting investigators and monitors. 21 CFR §312.53. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=312.53. Updated September 19, 2019. Accessed July 25, 2019.

7. Responsibilities of sponsors. Selecting investigators and monitors. 21 CFR §812.43. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=812.43. Updated September 19, 2019. Accessed July 25, 2019.

8. ICH Good Clinical Practice Guideline. In: Eckstein S, ed. Manual for Research Ethics Committees 6th ed. Cambridge, UK: Cambridge University Press; 2003. [Google Scholar]

9. Investigator responsibilities – protecting the rights, safety, and welfare of study subjects. Guidance for industry. US Food and Drug Administration. www.fda.gov/regulatory-information/search-fda-guidance-documents/investigator-responsibilities-protecting-rights-safety-and-welfare-study-subjects. Published October 2009. Updated April 12, 2019. Accessed October 12, 2019. [Google Scholar]

10. Kefauver-Harris amendments revolutionized drug development. US Food and Drug Administration. www.fda.gov/consumers/consumer-updates/kefauver-harris-amendments-revolutionized-drug-development. Accessed October 12, 2019.

11. Kim JH, Scialli AR. Thalidomide: the tragedy of birth defects and the effective treatment of disease. Toxicol Sci. 2011. July;122(1):1-6. doi:  10.1093/toxsci/kfr088. [PubMed] [CrossRef] [Google Scholar]

12. Protection of human subjects. 21 CFR §50. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=50. Updated September 19, 2019. Accessed October 12, 2019.

13. Institutional review boards. 21 CFR §56. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=56. Updated September 19, 2019. Accessed October 12, 2019.

14. Investigator recordkeeping and record retention. 21 CFR §312.62. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=312.62. Updated September 19, 2019. Accessed October 12, 2019.

15. Investigator reports. 21 CFR §312.64. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=312.64. Updated September 19, 2019. Accessed October 12, 2019.

16. Reports. 21 CFR §812.150. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=812.150. Updated September 19, 2019. Accessed October 12, 2019.

17. Financial disclosure by clinical investigators. 21 CFR §54. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=54. Updated September 19, 2019. Accessed October 12, 2019.

18. Specific responsibilities of investigators. 21 CFR §812.110. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=812.110. Updated September 19, 2019. Accessed October 12, 2019.

19. Inspection of investigator's records and reports. 21 CFR §312.68. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=312.68. Updated September 19, 2019. Accessed October 12, 2019.

20. Inspections. 21 CFR §812.145. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=812.145. Updated September 19, 2019. Accessed October 12, 2019.

21. FDA Form 483 frequently asked questions. US Food and Drug Administration. www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/inspection-references/fda-form-483-frequently-asked-questions. Accessed February 13, 2020.

22. Disqualification of a clinical investigator. 21 CFR §312.70. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=312.70. Updated September 19, 2019. Accessed October 12, 2019.

23. Disqualification of a clinical investigator. 21 CFR §812.119. US Food and Drug Administration. www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=812.119. Updated September 19, 2019. Accessed October 12, 2019.

24. FDA debarment list (drug product applications). US Food and Drug Administration. www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/fda-debarment-list-drug-product-applications. Updated December 20, 2019. Accessed February 13, 2020. [Google Scholar]

25. Mathews AW. FDA panel urges prominent warning label for antibiotic. The Wall Street Journal. May 19, 2006. www.wsj.com/articles/SB114799677462757266. Accessed February 13, 2020. [Google Scholar]

26. Ross DB. The FDA and the case of Ketek. N Engl J Med. 2007. Apr 19;356(16):1601-1604. doi:  10.1056/NEJMp078032. [PubMed] [CrossRef] [Google Scholar]


Page 2

Summary of Investigator Requirements and Responsibilities

CategoryRequirements and Responsibilities
Principal investigator•Anyone qualified by training to run the trial; a physician or dentist must be listed as a subinvestigator if the principal investigator is not a physician
•Hire and train qualified individuals to run the trial
Subject safety•Protect subjects from harm
•Keep track of drugs and distribute only as specified in the protocol
•Obtain informed consent
•Ensure IRB approval
•Keep careful records and maintain them for as long as the protocol dictates or at least 2 years
Reports•Progress, safety, financial, and a final report to the study sponsor
•Adverse events; serious adverse events must be reported immediately
•Update financial disclosures if any circumstances change during the study
Form 1572•Strictly adhere to the protocol
•Directly supervise the study and take responsibility for study staff
•Inform subjects of experimental nature of the drug products
•Report adverse events and stay updated on the investigational brochure
•Maintain records
•Ensure IRB compliance
FDA inspections•Ensure all records are complete and easily accessible by FDA
•Send a written response within 15 business days if any violations are found
How to avoid violations•Read all communications from the IRB
•Hire experienced staff and verify their credentials
•Train staff regularly
•Check for conflicts of interest/financial disclosures regularly
•Write efficient protocols or reduce inefficiencies or confusing portions of the protocol
•Keep regulatory binders up to date and conduct continuing reviews
•Meet with the team regularly
•Conduct several dry runs to ensure the study will run smoothly
•Regularly check data processes