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Tipologie di Audit e loro caratteristiche. Riunione sottogruppo GCP-GIQAR 21 Marzo 2006. Francesca Bucchi. PROCEDURES. 1 - Preparing for the Audit 2 - Conducting the Audit 3 - Reporting the Audit 15 working days Draft Report Issued 15 working days
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Tipologie di Audit e loro caratteristiche Riunione sottogruppo GCP-GIQAR 21 Marzo 2006 Francesca Bucchi
PROCEDURES 1- Preparing for the Audit 2 - Conducting the Audit 3 - Reporting the Audit 15 working days Draft Report Issued 15 working days Responses Provided Responses Reviewed/Accepted Final Report Issued
Responsibilities • Lead Auditor: Will facilitate organising, conducting and reporting of the audit. He/she will lead the audit activities and will prepare the audit report • PSA (Project Specific Auditor) In line with Line Management is responsible for: - Development of the audit programme - Being the focal point of contact with the clinical teams for audits - Ensuring that auditors conducting audits are aware of project related audit issues
Responsibilities (cont’d) • Process Owner: He/she is responsible for Harmonisation of all operational activities of the process, including its development and improvement
What are Global Systems Audits? A systems audit is a review of the organisation, procedures and documentation related to a selected system, or an examination of a process or group of processes that result in an end product.
Why a “systems” approach? • All work is process driven and the systems approach focuses on auditing the process • It can act as key fact finding tool for process improvement • It can provide an evaluation of interfaces within Sponsor, and between Sponsor and preferred providers • It can assess of cross-functional consistency in a global organisation
Some of the key areas for which a systems approach would be adopted include: • Process Management and Training • Trial Management • Monitoring • Data Management • Safety Management • Investigational Product (IP) Management • Archiving of Essential Documents • Computerised systems
How are they performed? Systems audits may consist of visit-based audits covering a number of locations or desk-based from the CQA offices. The audits may be conducted as a combination of documentation review, questionnaires and/or Interview
Audit Procedure Preparation • Assign Audit Team • Identify Audit Sponsor (global/local) • Define scope of the audit • Define audit references and standards • Develop audit plan & tools (e.g. audit method questionnaires, checklists, agenda) • Identify audit sample • Notification – early enough to ensure that personnel involved are available • Request for documentation
Audit Procedure (cont’d) Conducting the Audit • Audit may involve visits to one or moreSponsor sites or may be conducted via telephone discussions and review of documents only • Duration – between 2 and 4 days per site • Balance between discussions, review of documents and review of facilities • Discussions – encouraging staff to explain their daily work, understanding the issue & root cause • Focus is not on the individual • Review of documents – e.g. procedures, training records, CVs, job descriptions, documents related to the system audited • Review of facilities – e.g. archive
Audit Procedure (cont’d) Reporting and Follow-up • Initial feedback at the end of the audit • Draft audit report issued to Audit Sponsor for responding • Final report includes responses and actions • Audit Sponsor responsible for follow-up audit findings
ABC HOSPITAL Investigator Site Audits
Why Investigator Sites? • Obligation to ensure that studies are conducted to the relevant national and international laws • Obligation to ensure that studies are conducted to GCP • Assurance that the company and investigator sites would stand up to a regulatory inspection
Investigator Site Audits • Which studies? • regulatory submission status • priorityof the project in R&D portfolio • pivotalstatus of study • Which centres? • 1 - 15%
Investigator Site Audits • Selection of investigator sites is based on: • Recruitment • Site workload • Site with new investigator, monitoring staff or using new systems • Coordinating investigator sites • Requests from study teams/compliance concerns (“For cause”)
Investigator Site Audits How are they performed? • Examination of 3 basic aspects • Nature of the investigator’s conduct of the study • Theinteractionbetween the monitor and the investigator • Patient source datathat supports entries on the CRF • In 2 steps • At monitor’s office • At study site
What happens at the investigator site? • Introductions • Objectives • Audit procedure • Investigator interview • Role of staff OPENING MEETING TOUR OF STUDY RELATED FACILITIES / EQUIPMENT INVESTIGATOR FILE AUDIT SOURCE DATA VERIFICATION • Verbal feedback - key audit observations • Clarify any outstanding issues • Auditor notes investigator’s comments • Thank site staff DRUG STORAGE/DISPENSING ACCOUNTABILITY EXIT MEETING
Scope of Document Audits The document audits refer but are not limited to: • High Level Documents (HLDs) (integrated summary of data across studies for a particular section of a regulatory submission) • Investigator’s Brochures (IBs) • Clinical Study Protocols (CSPs) • Clinical Study Reports (CSRs) The quality of the document is assessed for internal consistency and against appropriate source documents, further to GCP and applicable regulatory requirements
How are they performed? • Review against relevant clinical SOPs, guidelines, templates, etc. • Check for completeness and logic • A review of the text for accuracy and consistency • A review against the source
SCOPE • It is limited to the information in the clinical study database and the supporting documentation for the process from database set up to clean file • The audit of one database is divided into blocks and may be staged over time
PROCEDURE • Audit Structure It will be conducted in 3 blocks: • To verify presence and approval of a selection of DM documentation for the study • To verify data with clean data status from data entry site • To verify data that have completed central validation and to verify selected DM documentation
PROCEDURE • Electronic Data Capture For studies using Web Based Data Capture the procedure will be adjusted by omitting the verification of clean data from blocks 2 and 3
Audit of Clinical Research Organisations and Clinical Laboratories
This audit covers but is not limited to: • Clinical Research Organisations (CROs) • Academic Research Organisations • Site Management Organisations • Collaborative Research Groups • Clinical Laboratories (Labs) • Other external provides of services such as IVRS, e-clinical technologies, etc. • Clinical Pharmacology Units (CPUs)
SCOPE OF THE AUDIT It may be one of 3 types: • Initial assessment audit of capabilities before work is transferred to the CRO/Lab • Follow-up of assessment of ongoing activities • For-cause audit where specific problems have been highlighted