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What is the line between CRO and sponsor responsibilities, and the difference between the delegation of the tasks and delegation of the responsibilities?
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According to ICH-GCP related to the CRO; 5.2.1 The sponsor may transfer all or a portion of duties and functions associated with its own to the Contract Research Organizations. However, the ultimate responsibility of the quality and accuracy of research data always belongs to the sponsor. Contract Research Organization has to apply quality control and quality assurance system 5.2.2 Any task or function transferred or taken over from the Contract Research Organizations has to be specified in writing. 5.2.3 The responsibility of any task or function specially not transferred or taken over from the Contract Research Organizations belongs to the sponsor 5.2.4 Refers made to the sponsor in the user guide, to the extent of task or function transferred or taken over from the Contract Research Organizations also does include the Contract Research. Written definitions can be seen. According to the perspective of authority, no matter from where the sponsors have received service, what kind of agreements were made, all final responsibility regarding the reliability of the quality of work and of data belongs to the sponsor. As a result, the sponsor has to be sure of the quality of service received and having required experience and knowledge of the duties, that are transferred from SAK. For this reason, many sponsors have created criteria to work with CRO who have these competencies. Some of these criteria are; experience from similar projects of the CRO experience with similar sponsors of the CRO For how much years the CRO is working in this area organization structure of CRO training and experience of staff with clinical research experience and infrastructure of High level managers Are Quality systems applied (customer, employee satisfaction, etc.) Basic training programs Are Emergency action plans made? Supervision and hiding conditions of Working documents Compliance and information with local regulations Audit and accreditation Software used Research has shown that after the implementation of the above-mentioned selection criteria, the sponsors make their decisions according to priorities given below. Having the capability to apply Problem detection and analysis process (problem-solving processes to be defined, recovery plans, etc. ..) Compliance with Project-specific practices Team chemistry integration (work ethics, a general approach, etc. ..) Experience of CRO(relevant experience with projects, contribution of the leading team to the project etc. ..) Capacity of CRO(geographic coverage, etc. ..) Making a contract with the CRO: The sponsor after primarily determining needs of its own research has to make a contract with the CRO for the transfer of tasks related to these services. This contract has also to contain; Legal issues such as contract work directive, the service time, time of payment, amount, etc (obligations, insurance, termination, choice of law, privacy, bad management etc.). Working directive (services to be taken from outside must be explained with all details.) For example; the scope of work responsible personnel timing payment schedule, phases, cost / budget
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the desired formats for reports list of CRO that will be used data base, etc.. risk sharing protocols special requirements for work etc. CRO Responsibilities: CRO training programs should be created for new joining Organizations If services should be taken from outside, assessment process should be available. CRO training programs should be created for service taken from People/ organizations from outside. it should have appropriate personnel, infrastructure and facilities to meet the requirements of the project. It should have the necessary software to monitors and measure Project management and performance. It should be made sure that the insurance made by the sponsor is appropriate. The application file provided by the sponsor should be careful reviewed and compliance must be ensured. It should be made sure that Medicines process is managed well (place and conditions of the place where drugs are being manufactured, in which conditions they are stored, how the distribution is made, shelf life, tags, etc.). For Protocol or research brochure revision, process must be defined. If there is transfer of the task, it must be well documented. Routine quality control of the system must be created. It must be made sure that the SOP which the sponsor wants to be applied are the recent revisions. Tel/ fax numbers given by the sponsor necessary for the security alert,/ fax numbers should be tested. CRO by third parties (e.g. specialist Biostatistics, medical monitors, etc. ..) should have data management system to make active data transfer / review easier. CRO must continuously develop their own technological capabilities. CRO are required to issue and follow-up compulsory working documentation. For this process they should have a system for archiving
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