ICH E8 8.2.12 and the use of “or”.

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    • #4531
      Sally Quinn

      In ICH E8 8.2.12 (and 8.3.7) (Medical/Laboratory/Technical procedures/tests) is has:
      -Certification or
      -Accreditation or
      -Established quality control and/or external quality assessment or
      -other validation (where required)

      Typically, when “or” is used in this fashion it means any of the 4 options is fine and that you do not need all 4. In the TMF Ref Model, 08.01.01 (Accreditation),08.01.02 (Lab Validation),08.01.07 (Head of Facility CV) and 08.01.08 (Standardization Methods) are all listed as “Core”(except for CV) and as “dependent on type of study”. This has led to some confusion, especially from the labs when asked for these types of documents. My interpretation of 8.2.12 (E8) would be that as long as you have one of the 4 listed options, you do not need the other 3. Since most labs used by the sponsor are accredited, they would not have to provide Lab Validation docs or standardization methods. At least, this is what the labs are telling us. Would you agree that only one of the 4 is required? Also, can you clarify what “dependent on type of study” means? I assume it means studies that use labs for any protocol testing. Plus, there is that pesky “where required”. Is this country specific? Thanks again!

    • #4541
      Fran Ross

      Unfortunately, there’s no one answer. One trial can have more than one type of lab (central, country-specific, site, etc.), necessitating different types of “credentialing” records.

      Collect the type of records that qualify the lab for that particular trial, and don’t worry about the ones that don’t apply.

      As oft repeated at GCP conference last week (MHRA, FDA and Health Canada) – one size does not fit all.

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