1. WHO Workshop on Assessment of Bioequivalence Data Addis Ababa, 31. August – 3. September Frequent Deficiencies Dr. Henrike Potthast (henrike.potthast@bfarm.de) WHO Workshop on Assessment of Bioequivalence Data, Addis Ababa, 31. August – 3. September 2010

2. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 2 |2 | GCP/GLP Frequent Deficiencies Inspection of bioequivalence studies Critical and major deviations observed during WHO inspections of CROs by WHO inspectors GCP/GLP

3. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 3 |3 | GCP/GLP Frequent Deficiencies Classification of deviations „Critical“ deviation means that this can lead to the conclusion that the study is not of a satisfactory level of compliance with GCP/GLP standards. Several „major“ deviations can lead to the conclusion that the study is not of a satisfactory level of compliance with GCP/GLP standards. „Minor“ deviations need to be addressed in order to sustaine the confidence in the particular CRO. GCP/GLP

4. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 4 |4 | GCP/GLP Frequent Deficiencies Critical deviations Clinical part eg.: No quality assurance system established (eg.: at the time of the study) Consent form not signed by subjects Case report form had been lost GCP/GLP

5. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 5 |5 | GCP/GLP Frequent Deficiencies The ethics committee is not operating and executing its tasks free from bias and from any influence of those who were conducting the trial. Neither the contract nor the protocol describes the responsibility for the design of the protocol Complex language is used in the informed consent forms to be signed by the subjects ("Stevens-Johnson Syndrome", "toxic epidermal necrolysis", "erythema multiforme" angiodema, neuropathy, anaphylaxis, steatosis ). GCP/GLP

6. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 6 |6 | GCP/GLP Frequent Deficiencies No dosing procedure ( eg.: there was no quality assurance system established at the time when the study was done); No record of dosing or not sufficiently detailed (eg.: the dosing form was filled in advance, before dosing: box ticked for Test or Reference); No drug accountability form or inconsistencies (eg.: discrepancies between drug dispensed, dosed and returned). GCP/GLP

7. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 7 |7 | GCP/GLP Frequent Deficiencies The identity of the medicinal product administered to each subject at each period of the trial can not be guaranteed due to insufficient documentation on the dispensing of the product Discrepancy between the protocol, the consent forms and the final report regarding the strength of the test product used GCP/GLP

8. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 8 |8 | GCP/GLP Frequent Deficiencies The batch and the manufacturing date of the test product mentioned in the Certificate of Analysis were different of those indicated on the shipping letter. Lack of shipping letters for the reference products.

9. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 9 |9 | GCP/GLP Frequent Deficiencies Reference product Case: manufacturer. Protocol : Study report:

10. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 10 | GCP/GLP Frequent Deficiencies No certificate of analysis or not sufficiently detailed (eg.: batch size for the test product was not mentioned or less than 100000 units) No record of dispensing or not sufficiently detailed (eg.: - only a typed form prepared in advance to help the staff for the dispensing; - no indication of date of preparation, of the operator, no signature of operator, no mention of double check, no record of line clearance…);

11. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 11 | GCP/GLP Frequent Deficiencies No drug testing was performed on the subjects. Therefore in fact there is no guarantee that the drug abstinence is respected.

12. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 12 | GCP/GLP Frequent Deficiencies

13. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 13 | GCP/GLP Frequent Deficiencies Subject withdrawal due to an adverse event (e.g. vomiting 4 hours post-dose) without any sufficient documentation. The decision was not taken by the investigator until more than 3 h after the event took place and 6 PK blood samples were unnecessarily taken.

14. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 14 | GCP/GLP Frequent Deficiencies Identical ECGs for different Volunteers:

15. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 15 | GCP/GLP Frequent Deficiencies

16. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 16 | GCP/GLP Frequent Deficiencies The composition of the meals versus protocol is not satisfactory as e.g. pizza toppings could be chosen by the volunteers. Consequently the meals are not standardized. Fasting and meals are not controlled during the study days. Records of the timing, duration of meals and amount of food and fluid consumed are missing.

17. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 17 | GCP/GLP Frequent Deficiencies Storage condition of blood samples not monitored. (eg.: temperature records were only kept for one freezer. Proper storage of the samples was therefore not documented. During the inspection the freezer for the blood sample storage did have a temperature drop to give alarm. The system had a red light signal but not the sound signal which should have been also the case according to the laboratory personnel).

18. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 18 | GCP/GLP Frequent Deficiencies The method of calculating AUC values (linear trapezoidal method or other, method of extrapolation to infinity) is not specified in the trial reports and/or incorrect.

19. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 19 | GCP/GLP Frequent Deficiencies

20. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 20 | GCP/GLP Frequent Deficiencies Case: t max. Blood sampling

21. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 21 | GCP/GLP Frequent Deficiencies The justification of the reintegration is not apparent (and not acceptable) and there is no source document to prove that the SOP for manual reintegration is followed (no signature, no date, no comment of authorized person on the chromatograms)

22. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 22 | GCP/GLP Frequent Deficiencies Case: manipulation

23. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 23 | GCP/GLP Frequent Deficiencies Case: remarkable data GCP/GLP

24. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 24 | GCP/GLP Frequent Deficiencies - LOQ: 10 ng/ml, sampling period 96 hours - AUC 0-t : 639 +/- 258 ng.h/ml - AUC inf : 1367 +/- 379 ng.h/ml - C max : 31 +/- 14 ng/ml Analytical method Case: LOQ (1).

25. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 25 | GCP/GLP Frequent Deficiencies Case: LOQ (2). Analytical method

26. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 26 | GCP/GLP Frequent Deficiencies The sample analysis of one subject is coded as “Outlier” (here: concentration much higher than other subjects for this time). The repeat analysis shows a different value but similar to those of other subject at this time. Therefore, the initial result cannot be left as “outlier”. An explanation must be provided (mixed samples?) and SOPs should cover such deviations.

27. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 27 | GCP/GLP Frequent Deficiencies Several data found on chromatograms are not consistent with the final concentration reported by the bio-analytical laboratory but used for calculations Only one QC/batch at each concentration (LQC, MQC, HQC) is processed

28. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 28 | GCP/GLP Frequent Deficiencies Time period of pre-study validation is identical with time period of volunteers’ sample analysis

29. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 29 | GCP/GLP Frequent Deficiencies Bioanalytical part Critical deviations in % (by 2009)

30. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 30 | GCP/GLP Frequent Deficiencies Bioanalytical part Major deviations in % (by 2009)

31. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 31 | GCP/GLP Frequent Deficiencies Use of correction-fluid and overwriting on CRFs and other raw data. Lack of documentation on monitoring and auditing …and more…

32. WHO Workshop on Assessment of Bioequivalence Data 31. August – 3. September 2010, Addis Ababa 32 | GCP/GLP Frequent Deficiencies THANK YOU FOR YOUR ATTENTION