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Eldin RammellParticipantZone – Regulatory
Relevant Communications
Eldin RammellParticipantRemember that a DSUR is not a trial-specific document (unless you only have 1 clinical trial in development). For this reason, many sponsors do not file the DSUR (or PSUR) in the TMF but rather file it in the Pharmacovigilance system. However, the TMF will hold any trial-specific notifications related to the DSUR e.g. notification to Ethics Committee.
Eldin RammellParticipantHi Manuela,
Can you clarify what it is you’d like advice or recommendations on. Are you asking about the long-term archiving of electronic files with Iron Mountain? Or are you asking about whether emails should be archived as a PST file?
Eldin RammellParticipantIs there an artifact in the model that captures agreements or financial information? If so, I guess that would be the most likely place.
Eldin RammellParticipantHi Mariz,
Different inspectors will have their own preferences but usually they require direct access to the system. I recommend getting this clarified before the inspection actually happens ie. in your pre-inspection communications.
Kind regards,
Eldin.
Eldin RammellParticipantHi Mariz,
You could try the HSRAA online course:
HSRAA is a not-for-profit.
Kind regards
EldinDecember 23, 2020 at 1:05 pm in reply to: Statement of Investigator for non-US Clinical Trial Sites #3911
Eldin RammellParticipantHi Maria
I would say it meets this definition: A regulatory statement from the investigator (required by certain health authorities).
Kind regards
EldinDecember 22, 2020 at 8:37 pm in reply to: Statement of Investigator for non-US Clinical Trial Sites #3909
Eldin RammellParticipantThe “purpose/description” column is usually the best indicator of filing location.
Eldin RammellParticipantHi Rebecca,
Then I suspect you are not downloading the correct file. The main TMF Reference Model has 249 artifacts whereas the Real-world study index has only 131. The index can be downloaded from the main Resources page (look under the “TMF Tools section) and a direct link to the index is HERE.
Kind regards,
Eldin.
Eldin RammellParticipantHi Vicki,
Do you have a reference for a specific regulatory requirement for a Data Management Plan or wording in a regulation that makes it very clear this is an expectation? If so, it would be good to get this added as a reference. Thanks.
Eldin.
Eldin RammellParticipantIs there a regulation that describes in detail what content must be in a CV? Conversely, is there a regulation that identifies content that should not be included? A CV should demonstrate qualifications and experience. Other than this, I’m not aware of other specific regulatory guidance. Any “restrictions” that I’ve seen (eg a 1-page CV) have been sponsor requirements.
Inclusion of other sponsors on a CV may be a confidentiality issue for those sponsors but I don’t think this is a regulatory issue (perhaps a legal one if they’re under a confidentiality agreement!).
Eldin RammellParticipantHi Jane Marie,
I’m not sure if the query is looking for how to ensure the long-term archiving/retention of emails for x years, or whether it is simply how emails should be filed/integrated into the TMF. Archiving means actions taken to ensure the long-term safety, security and integrity of records so not sure how this would necessarily be different for emails, other than maybe different file formats. Only reason I’m asking is that the question is posted in the “archiving” forum.
Having said that, just to let you know that there is a TMF Reference Model sub-team looking specifically at best practice for the management of electronic mail, including the long-term preservation of email records. Shouldn’t be too long before they have something available for us!
Eldin RammellParticipantHi Dee,
Where I’ve seen some differences is between filing of submissions versus approvals. Often, the full submission is filed in the regulatory system but only the documentary evidence of approval is filed in the TMF. It is essential the TMF Index identified which system both documents are filed in.
Eldin.
Eldin RammellParticipantThis is an individual sponsor decision but my inclination would be to avoid updating a TMF structure specifically for COVID-19. This is certainly a significant risk currently but I’m not seeing a justification for classifying the documents in a different way to how they would ordinarily be classified. If you need a means of quickly identifying all COVID-19 related documents for a study, you can use a naming convention and/or search capabilities to achieve this. Letters to a site that concern action you’ve taken with regards to COVID-19 should be processed and filed in the same way as for any other site communication. Whilst this is an extraordinary situation, we do not create filing exceptions for any other clinical trial risks.
Eldin RammellParticipantIn my experience, this is typically not part of the TMF. It is part of the Quality Management System / Audit files.
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