UNANTICIPATED PROBLEMS - Research Affairs
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|Loma Linda University Shared services |
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|Research Affairs |
|UNANTICIPATED PROBLEMS |
|Supplement |
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|Version |
|E (r1) |
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A & B without DMC ( Unanticipated Problems
IRB itself Performs AE Oversight
(if With Federal Funding – add shaded boxes)
|BY Whom | |WHAT KIND |WHEN |
| |TO Whom |(AE or ADR) | |
|Investigator * |IRB |1 |Within 5 working days |
| | |SERIOUS |of investigator awareness |
| | |RELATED |(OHRP guidance: |
| | |that are |Dated 01-15-07 |
| | |UNEXPECTED |V.(2) ) |
| | |and | |
| | |that suggest the study risks are greater than | |
| | |previously recognized | |
| | | | |
| | | | |
| | |5 |Within 10 working days |
| | |NOT SERIOUS |of investigator awareness |
| | |RELATED |(OHRP guidance: |
| | |that are |Dated 01-15-07 |
| | |UNEXPECTED |V.(2) ) |
| | |and | |
| | |that suggest the study risks are greater than | |
| | |previously recognized | |
|IRB |Institutional |1, 5 |Within 10 working days |
| |Official |RELATED |of notice to IRB |
| | |that are |(not regulatory- this |
| | |UNEXPECTED |allows time for I/O to consider |
| | |and |before reporting to OHRP) |
| | |that suggest the study risks are greater than | |
| | |previously recognized | |
|Institutional |OHRP | |Within one month of notice to IRB |
|Official |and | |(OHRP Guidance) |
| |Funding | | |
| |Agency | | |
C. with DMC –Unanticipated Problems
Study with LLU-Appointed DSMB
(if With Federal Funding – add shaded boxes)
|BY Whom |TO Whom |WHAT KIND |WHEN |
| | |(AE or ADR) | |
| |DMC |1, 5 |Within 5 working days |
| | |RELATED |of investigator awareness |
|Investigator | |and | |
| | |UNEXPECTED | |
| | |and | |
| | |that suggest the study risks are greater | |
| | |than previously recognized |OHRP guidance: |
| | | |Dated 01-15-07 |
| | | |§V.(2) |
| |IRB |1 | |
| | |SERIOUS | |
| | |RELATED | |
| | |and | |
| | |UNEXPECTED | |
| | |and | |
| | |that suggest the study risks are greater | |
| | |than previously recognized | |
|DMC | |1, 5 | |
| | |RELATED |Within 5 working days |
| | |and |of DMC awareness |
| | |UNEXPECTED |institutional requirement (1) |
| | |and | |
| | |that suggest the study risks are greater | |
| | |than previously recognized | |
|IRB |Institutional | |Within 10 working days |
| |Official | |institutionally required report timing; |
| | | |allows time for I/O to consider before |
| | | |reporting to OHRP |
|Institutional |OHRP | | |
|Official |and | |Within one month of notice to IRB |
| |Funding Agency | |(OHRP Guidance dated 01-15-07) |
NOTE: This matrix is for studies that are not within FDA regulations for an IND (Investigational New Drug) or
an IDE (Investigational Device Exemption).
D & E ( Unanticipated Problems
AE Oversight provided by non-LLU entity
(NON-FDA Study)
(if With Federal Funding – add shaded boxes)
|BY Whom |TO Whom |WHAT KIND |WHEN |
| | |(AE or ADR) | |
| |Sponsor |As Required by |As Required by protocol, |
| | |protocol, |grant, or contract |
|Investigator | |grant, or contract | |
| | | | |
| | | | |
| |IRB | |Within 5 working days |
| | |1 |of investigator awareness |
| | |SERIOUS |OHRP guidance: |
| | |RELATED |Dated 01-15-07 |
| | |that are |§ V.(2) |
| | |UNEXPECTED | |
| | |and | |
| | |that suggest the study risks are greater | |
| | |than previously recognized | |
| | |5 |Within 10 working days |
| | |NOT SERIOUS |of investigator awareness |
| | |RELATED |OHRP guidance: |
| | |that are |Dated 01-15-07 |
| | |UNEXPECTED |§ V.(2) |
| | |and | |
| | |that suggest the study risks are greater | |
| | |than previously recognized | |
|IRB |Institutional |1, 5 |Within 10 working days of notice to |
| |Official |RELATED |IRB |
| | |and |(allows time for I/O to consider |
| | |UNEXPECTED |before reporting to OHRP) |
| | |that suggest study risks are greater than | |
| | |previously recognized | |
|Institutional |OHRP | |Within one month of notice to IRB |
|Official |and | |(OHRP Guidance) |
| |Funding Agency * | | |
* On a multi-center study, although AE’s are reported to an external oversight body such as COG, regulations still place responsibility on LLU to assure reporting to OHRP of Unanticipated Problems that occur at our site..
When LLU PI is a Sponsor-Investigator
G & K – Drug or Device Trial: FDA-ICH
with LLU Appointed DMC
Unanticipated Problems
(that are not AE’s)
(if With Federal Funding – add shaded boxes)
|BY Whom |TO Whom |WHAT KIND |WHEN |
| | |(AE or ADR) | |
|Sponsor-Investigator |DMC |1 |Within 5 working days* |
| | |SERIOUS |of investigator awareness |
| | |RELATED |(not regulatory ) |
| | |and | |
| | |UNEXPECTED | |
| | |that suggest study risks are greater | |
| | |than previously recognized | |
| |IRB | | |
| | |5 |Within 10 days |
| | |NOT SERIOUS |of investigator awareness |
| | |RELATED |(OHRP guidance: |
| | |and |Dated 01-15-07 |
| | |UNEXPECTED |§ V.(2) ) |
| | |that suggest study risks are greater | |
| | |than previously recognized | |
|DMC |IRB |1, 5 |Within 5 working days* |
| | |RELATED |of DMC receipt |
| | |and |(not regulatory) |
| | |UNEXPECTED | |
| | |that suggest study risks | |
| | |are greater than | |
| | |previously recognized | |
|IRB |Institutional | |Within 10 working days |
| |Official | |of IRB receipt |
| | | |(not regulatory) |
| | | | |
| | | |(21 CFR 56.108 “prompt”)** |
|Institutional | | |Within one month of notice to IRB |
|Official |FDA | |(OHRP Guidance) |
| | | | |
| | | |(21 CFR 56.108 “prompt”) |
| |OHRP and | | |
| |Funding Agency | | |
* 1 week investigator to DSMB + 1 week DSMB to IRB = 2 weeks, which meets 2 week OHRP guidance for reporting of non-AE UP’s to IRB; + 10 days IRB to I/0 = 24 days, leaving 7 more to report to OHRP within recommended one month. This does not comply strictly with OHRP guidance for investigator to notify IRB about a serious UP within 5 days, but neither does the guidance mention prior reporting to an internal DMC.
** Extract from 21 CFR 56.108: In order to fulfill the requirements of these regulations, each IRB shall:
“b) Follow written procedures for ensuring prompt reporting to the IRB, appropriate institutional officials, and the Food and Drug Administration of: (1) Any unanticipated problems involving risks to human subjects or others;
H, I, L, M - ( Unanticipated Problems
Device or Drug Trial: FDA-ICH ,
AE Oversight provided by non-LLU entity
(if With Federal Funding – add shaded boxes)
|BY Whom |TO Whom |WHAT KIND |WHEN |
| | |(AE or ADR) | |
|Investigator |Sponsor |As required, by protocol, grant, or | |
| | |contract |As required, by protocol, grant, or |
| | | |contract |
| |IRB |1 |Within 5 working days |
| | |SERIOUS |of investigator awareness |
| | |RELATED |(OHRP guidance: |
| | |and |Dated 01-15-07 |
| | |UNEXPECTED |§ V.(2) ) |
| | |and | |
| | |that suggest study risks are greater than | |
| | |previously recognized | |
| | |1, 5 |Within 10 working days |
| | |RELATED |of investigator awareness |
| | |and |(OHRP guidance: |
| | |UNEXPECTED |Dated 01-15-07 |
| | |and |V.(2) ) |
| | |that suggest study risks are greater than | |
| | |previously recognized | |
|IRB |Institutional |1, 5 |Within 10 days from |
| |Official |RELATED |IRB receipt |
| | |and |(not regulatory)(1) |
| | |UNEXPECTED | |
| | |and | |
| | |that suggest study risks are greater than | |
| | |previously recognized | |
|Institutional | | |Within one month of notice to IRB |
|Official |FDA(2) | |(OHRP Guidance) |
| |OHRP and | | |
| |Funding Agency | | |
(1) Sets-up correct report timing to IRB, I/O, FDA, and Funding Agency, per Guidance
(2) Reporting of (non-AE) unanticipated problems to the FDA, is specified in 21 CFR 56.108.
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