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MANAGEMENT OF PROTOCOL AND GCP DEVIATIONS AND VIOLATIONS
ACCORD SOP CR010 v3.0 (Effective 30 May 2016) TRAINING SLIDES
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DEFINITIONS DEVIATION: Any change, divergence, or departure from the study design, procedures defined in the protocol or GCP that does not significantly affect a subjects rights, safety, or well-being, or study outcomes VIOLATION: A deviation that may potentially significantly impact the completeness, accuracy, and/or reliability of the study data or that may significantly affect a subject’s rights, safety, or well-being
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WHAT HAS CHANGED? Responsibilities ACCORD e-mail Deviation Log
Violation Form Trending Retention of records New responsibilities in ACCORD only New ACCORD for reporting Updates to Log and Form Review of data by ACCORD Where are records retained?
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RESPONSIBILITIES PI/research team responsibilities not changed
ACCORD QA; Reviewing, logging, tracking and trending deviations/violations ACCORD Senior Clinical Trials Monitor; Awareness of study specific trends and/or significant findings Discuss/address with Investigator s to Research Governance will forward to this All communication now with ACCORD QA team
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PROTOCOL DEVIATION LOG
(CR010-T01 v2.0) REC No. Event No. Code Sign/Date PI informed Actions complete Review/receipt of log REPORTING TIMELINES HAVE NOT CHANGED (Every 3 months or as per protocol) Replaces R&D No. Allows ACCORD to track deviations (not applicable for studies already started) ACCORD internal use only To evidence timely PI awareness To evidence actions complete To evidence oversight from PI/ACCORD
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VIOLATION FORM (CR010-F01 v2.0) REC No. and PI Code Conclusion
Sign/Date Assessment Actions complete Receipt of form Violation No. REPORTING TIMELINES HAVE NOT CHANGED (within 3 days of becoming aware) In line with Deviation Log ACCORD internal use only Justify why participant to remain/withdraw (e.g. why no actual impact) To evidence who is making assessment To evidence actions complete To evidence who is making conclusion ACCORD internal use only
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To Senior Management Team/Senior Clinical Trials Monitor (ACCORD)
TRENDING ACCORD QA will review/report on deviations/violations Quarterly Study trends Global trends ACCORD Senior Clinical Trials Monitor will address study specific trends and/or significant findings with research team To Senior Management Team/Senior Clinical Trials Monitor (ACCORD)
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RETENTION OF LOG/FORMS
Original records (essential documents) stored in the Investigator Site File (ISF) by the PI, with; Any communication regarding resolution of corrective/preventative action Copies retained in the Trial Master File (TMF) or Sponsor File, with;
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CONTACTS & REFERENCES Please address any questions to;
(QA Manager) (QA Coordinator) SOP CR010 and examples of completed Deviation Logs/Violations Forms are available on the ACCORD website
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