pro FDA Clears 1st Product Derived From Amniotic Fluid To Enter COVID-19 Trial By www.rttnews.com Published On :: Tue, 05 May 2020 13:21:37 GMT Organicell Regenerative Medicine Inc. (BPSR.OB) has received FDA clearance to initiate a phase I/II multi-center clinical trial of Organicell Flow in patients diagnosed with moderate to severe acute respiratory syndrome (SARS) due to COVID-19 infection. Full Article
pro Six Ways New Federal Health IT Rules Improve Both Care and Public Health By feedproxy.google.com Published On :: Fri, 17 Apr 2020 09:26:15 -0400 The federal government in March released a pair of long-awaited rules that will give patients greater access to their health data and improve the flow of information across care settings. Full Article
pro Policy Changes Could Bolster Prescription Drug Monitoring Programs By feedproxy.google.com Published On :: Thu, 23 Apr 2020 07:00:00 -0400 High rates of opioid prescribing have contributed to the current U.S. opioid epidemic and the steady increase in overdose deaths across the country. Prescribers wrote an all-time high of 255 million opioid prescriptions in 2012, and though that rate has since declined. Full Article
pro Care Coordination Strategies for Patients Can Improve Substance Use Disorder Outcomes By feedproxy.google.com Published On :: Thu, 23 Apr 2020 14:17:00 -0400 Care coordination is considered a hallmark of patient-centered treatment and has been shown to improve health outcomes and patient satisfaction as well as reduce costs. Defined as organizing patient care activities and sharing information among all participants concerned with an individual’s treatment plan in order to achieve safer and more effective results, care coordination is increasingly... Full Article
pro Some Indicators of Public Health in Philadelphia Had Improved Before COVID-19 By feedproxy.google.com Published On :: Tue, 28 Apr 2020 09:57:00 -0400 The spread of COVID-19 is placing unprecedented strain on Philadelphia’s hospitals, public health systems, and residents. Although the full effects of the emergency have yet to be realized, newly released data from 2018 and 2019 provides insight on the state of public health in the city before the pandemic. Full Article
pro Pew Urges Congress to Promote Patient Matching in Electronic Health Records to Address COVID-19 By feedproxy.google.com Published On :: Mon, 04 May 2020 13:32:47 -0400 The Pew Charitable Trusts sent a letter May 4 to the leaders of the Senate and House of Representatives urging them to support improved patient matching in electronic health records to help combat the COVID-19 pandemic. Full Article
pro The Promise Of Precision Neuroscience And Launch Of Arkuda Therapeutics By feedproxy.google.com Published On :: Thu, 14 Nov 2019 11:29:38 +0000 Neuroscience has had a tough run of news lately. With Amgen deprioritizing neuro this year, Pfizer doing the same last year, and others like BMS, GSK, and AZ cutting back on CNS a few years earlier, it would seem dark The post The Promise Of Precision Neuroscience And Launch Of Arkuda Therapeutics appeared first on LifeSciVC. Full Article Portfolio news Rare Diseases Science & Medicine Translational research
pro The Balancing Act: Taking A Systematic Approach To Hard Decisions In Times Of Rapid Change By feedproxy.google.com Published On :: Mon, 30 Mar 2020 10:49:04 +0000 This blog was written by Ankit Mahadevia, CEO of Spero Therapeutics, as part of the From The Trenches feature of LifeSciVC. If CEOs have empowered their teams effectively, they have three roles during times of rapid change: Motivator in chief The post The Balancing Act: Taking A Systematic Approach To Hard Decisions In Times Of Rapid Change appeared first on LifeSciVC. Full Article Corporate Culture From The Trenches Leadership
pro Marketing Age-Related Nutrition Products By feedproxy.google.com Published On :: Tue, 06 Feb 2018 15:32:00 GMT Baby Boomers, Gen X and Millennials are key consumer target groups for marketers, with three different sets of needs and buying propensities; it’s important that brands define their unique selling propositions. Full Article
pro AHPA Recommends Regulatory Improvements in Comments Submitted to CFSAN By feedproxy.google.com Published On :: Tue, 06 Feb 2018 16:30:00 GMT The American Herbal Products Association submitted nearly 100 pages of comments to the Food and Drug Administration Center for Food Safety and Applied Nutrition identifying ways to improve regulations, guidance documents and enforcement practices to better protect public health. Full Article
pro Probi's Largest Clinical Trial Confirms the Immune Enhancing Impact of Probi Defendum® By feedproxy.google.com Published On :: Tue, 06 Feb 2018 17:01:00 GMT Probi's largest clinical trial ever, focused on probiotic immune health, has recently been completed. Full Article
pro OmniActive Expands Gingever Range and Showcases New Prototypes at Engredea 2018 By feedproxy.google.com Published On :: Tue, 06 Feb 2018 17:43:00 GMT At Engredea 2018 in March in Anaheim, CA, OmniActive will be highlighting the latest addition to its ginger ingredient range, Gingever 10% powder, expanding its application to tablets, capsules and beverages. Full Article
pro The Health Care Practitioner Channel: Connecting Industry and Medical Professionals By feedproxy.google.com Published On :: Wed, 07 Feb 2018 14:57:00 GMT Selling directly to health care practitioners, supplement companies can foster open dialogue about their products; but, every regulation applies to products in this channel, too. Full Article
pro New Study with Wellmune Shows Promise for Intestinal Barrier Function Improvements By feedproxy.google.com Published On :: Wed, 07 Feb 2018 19:37:00 GMT A study demonstrated Wellmune® may protect intestinal barrier function in adults when faced with stress. Full Article
pro Orienteering World Champion Signs up to Promote Lacprodan® HYDRO.365 By feedproxy.google.com Published On :: Wed, 07 Feb 2018 20:15:00 GMT Another leading athlete has joined Arla Foods Ingredients’ growing number of brand ambassadors for Lacprodan® HYDRO.365. Full Article
pro Valensa's Parry Organic Spirulina, Chlorella, Microalgae Earn Non-GMO Project Butterfly By feedproxy.google.com Published On :: Wed, 07 Feb 2018 22:50:00 GMT Valensa International announced Non-GMO Project has been awarded to Valensa’s Organic Spirulina, Chlorella and Microalgae products. Full Article
pro Emport LLC New Training Resources for Professional Kitchens By feedproxy.google.com Published On :: Thu, 08 Feb 2018 22:58:00 GMT Emport LLC is pleased to introduce new training programs and materials to augment its food safety and allergen control portfolio. Full Article
pro Ingredient Manufacturer Announces Non-GMO Project Verified Caffeine Ingredient By feedproxy.google.com Published On :: Thu, 08 Feb 2018 23:32:00 GMT Applied Food Sciences, Inc. (AFS) takes the next step in demonstrating complete transparency by getting four of its core ingredients Non-GMO Project Verified. Full Article
pro National Institutes of Health Announces NIAGEN® Shows Improved Cognitive and Physical Function By feedproxy.google.com Published On :: Fri, 09 Feb 2018 15:39:00 GMT ChromaDex Corp. announced NIAGEN® nicotinamide riboside prevented neurological damage and improved cognitive and physical function in a new mouse model of Alzheimer’s disease. Full Article
pro Supplement Company CEO Arrested, Faces Possible Probation Revocation By feedproxy.google.com Published On :: Fri, 09 Feb 2018 21:23:00 GMT The chief executive of a supplement company under investigation by FDA could go to prison for allegedly violating the terms of his supervised release following a criminal conviction in 2014. Full Article
pro Endurance, Energy and Cognitive Prowess Drive Sports Performance By feedproxy.google.com Published On :: Wed, 14 Feb 2018 15:17:00 GMT The best sports nutrition formulas designed to improve performance draw from a pool of ingredients researched for benefits to energy production, cognitive function and endurance both in general and specifically concerning muscles. Full Article
pro Immunity products: "This is the world's biggest ever advertising campaign, bar none" By www.nutraingredients.com Published On :: Tue, 05 May 2020 10:30:00 +0100 It is "inconceivable" that immunity will not remain high on the list of health priorities when this pandemic ends and now is the time to create more "convincing experiences" to ensure trial turns into adoption, according to food and drink research and branding experts. Full Article Markets and Trends
pro Mice study: Faecal virus transplant shows promise in combating obesity and diabetes By www.nutraingredients.com Published On :: Wed, 06 May 2020 11:01:00 +0100 Obese mice with unhealthy lifestyles gain significantly less weight and avoid type 2 diabetes when they receive bacteriophages from the faeces of a lean mouse, according to a new University of Copenhagen study. Full Article Research
pro APEC Steps Up Promotion of Cross-Border Privacy Rules By www.apec.org Published On :: Thu, 12 Sep 2019 11:08:00 +0800 APEC economies, data privacy regulators, and other stakeholders are exploring ways to bolster the Cross-Border Privacy Rules (CBPR) system. Full Article
pro Promoting Universal Health Coverage: Sharing a Prosperous and Healthy Future By www.apec.org Published On :: Tue, 24 Sep 2019 21:10:00 +0800 Leaders from around the world gathered at the United Nations General Assembly in New York on 23 September for the first-ever United Nations High-Level Meeting (UNHLM) on Universal Health Coverage (UHC): Moving Together to Build a Healthier World. Full Article
pro Malaysia to Lead APEC in 2020 in Fostering Shared Prosperity By www.apec.org Published On :: Mon, 25 Nov 2019 15:58:00 +0800 Media Registration is Open for the APEC Informal Senior Officials’ Meeting Full Article
pro Technology Opens Doors, say Winners of APEC Digital Prosperity Award By www.apec.org Published On :: Tue, 10 Dec 2019 13:38:00 +0800 A duo of innovative programmers from Malaysia are the winners of the 2019 APEC Digital Prosperity Award, announced on the sidelines of the APEC Informal Senior Officials’ Meeting in Langkawi. Full Article
pro Towards Shared Prosperity: Malaysia Begins Host Year in Putrajaya By www.apec.org Published On :: Mon, 13 Jan 2020 11:07:00 +0800 Media registration is open for the First APEC Senior Officials’ Meeting (SOM1) and related meetings in Putrajaya, Malaysia from 3 February to 22 February 2020. Full Article
pro Promoting Trade in Medical Goods Will Save Lives By www.apec.org Published On :: Tue, 28 Apr 2020 15:24:00 +0800 Medical supplies and personal protective products are facing barriers worldwide Full Article
pro RE: Sort It Out by participating in the RAPS Tagging Project By connect.raps.org Published On :: Wed, 06 May 2020 09:44:05 -0400 From : Communities>>Regulatory Open ForumHi everyone, I just finished it, and it is a really simple task! Go ahead! Thanks Anna --------------------------------- Anna Alonzi MD Sr. Regulatory Associate Newtown PA United States --------------------------------- Full Article Discussion
pro RE: Cell banks for cell culture process development By connect.raps.org Published On :: Wed, 06 May 2020 13:23:29 -0400 From : Communities>>Regulatory Open ForumThe short answer is "yes" provided that the development cell bank was the source for the GMP bank and is comparable in terms of performance. However, the devil is in details and you need to evaluate "comparability" carefully between the development bank and the GMP bank with respect to the characterization data you plan to use for, e.g., to support GMP bank for production, etc. Two ICH guidance documents are useful to look at, Q7 Table 1 and Q5D. The US FDA generally follows ICH guidance but EMA [More] Full Article Discussion
pro RE: Extending Product Shelf-Life By connect.raps.org Published On :: Wed, 06 May 2020 14:56:31 -0400 From : Communities>>Regulatory Open ForumYes, exactly i asked same Full Article Discussion
pro RE: Sort It Out by participating in the RAPS Tagging Project By connect.raps.org Published On :: Thu, 07 May 2020 09:00:51 -0400 From : Communities>>Regulatory Open ForumThank you all for participating in our Tagging Project! We're glad to hear you enjoyed it. All volunteers were entered into a drawing for a $50 Amazon gift card. See a video of the drawing attached. I'm happy to announce that the winner is ... @Jonathan Amaya-Hodges ! Thanks again to all who participated. If you're interested in more volunteer opportunities, see our full list here . ------------------------------ Danielle Fezell Manager, Chapter & Volunteer Relations, RAPS Rockville MD United [More] Files Attached DocumentRE: Sort It Out by participating in the RAPS Tagging Project Full Article Discussion
pro RE: Sort It Out by participating in the RAPS Tagging Project By connect.raps.org Published On :: Thu, 07 May 2020 09:25:53 -0400 From : Communities>>Regulatory Open ForumThank you RAPS, what a pleasant surprise! I appreciate the opportunity to contribute to the project! Now, if only Amazon had any toilet paper in stock... ------------------------------ Jonathan Amaya-Hodges Associate Director, Regulatory Affairs CMC Combination Products and Medical Devices Cambridge MA United States ------------------------------ Full Article Discussion
pro Online sale of unapproved combinations of Minoxidil as topical solution By connect.raps.org Published On :: Thu, 07 May 2020 23:07:00 -0400 From : Communities>>Regulatory Open ForumHello, I can see many unapproved combinations of Minoxidil as topical solution like minoxidil+ Azelaic Acid; Minoxidil + Finasteride; Minoxdil+ niacin+retinol+caffeine that are available online for sale in US but these drug products are not approved by FDA as visble from USFDA website. Can anyone explain that is there any mechanism or guideline to allows to sell such unapproved drug products online in US and also in EU? Or is this totally illegal practice? Thanks Ankur RAC Full Article Discussion
pro RE: Online sale of unapproved combinations of Minoxidil as topical solution By connect.raps.org Published On :: Fri, 08 May 2020 04:15:00 -0400 From : Communities>>Regulatory Open ForumHi, Ankur - Some may be "legal," others not. It's a big industry, and it is fair to be cynical. Combination products for sale that have not been approved-as the combination-by FDA are just that, unapproved drugs. I assume you checked for the approval status in FDA's "Orange Book" (https://www.accessdata.fda.gov/scripts/cder/ob/index.cfm). Even if both active pharmaceutical ingredients in a 2-drug mixture were approved separately on their own, it does not mean the combined product is approved for [More] Full Article Discussion
pro RE: Online sale of unapproved combinations of Minoxidil as topical solution By connect.raps.org Published On :: Fri, 08 May 2020 08:16:03 -0400 From : Communities>>Regulatory Open ForumThese are all unapproved new drugs. Many people who have very limited knowledge of our OTC drug system, assume that if it is sold OTC, it is a monographed drug and they can change the formulation. They do not know that there are two types of OTC drugs allowed-compliance with a monograph or NDA. Minoxidil is one and chlorhexidine antiseptic wash is another. ------------------------------ David Steinberg,FRAPS President Steinberg & Associates, Inc. Pompton Plains NJ USA 609-902-8860 -------------- [More] Full Article Discussion
pro RE: Online sale of unapproved combinations of Minoxidil as topical solution By connect.raps.org Published On :: Fri, 08 May 2020 08:38:05 -0400 From : Communities>>Regulatory Open ForumThe only possible way I can see any of these products being legally marketed in the US without going the OTC NDA route would be if the ingredients other than Minoxidil are considered "inactive" and have some purpose (other than their active ingredient purposes) in the formulation. That said, this might work for the last combination in your listing because all of these can and are often used in OTC products as inactive ingredients with understood and current reasons for existing in a formulation [More] Full Article Discussion
pro Drug Component Quality (OTC vs Combination Product) By connect.raps.org Published On :: Fri, 08 May 2020 09:02:59 -0400 From : Communities>>Regulatory Open ForumThis message was posted by a user wishing to remain anonymous For device-lead drug combination products, is there any difference in the quality (grade) of API used compared to a pure drug product? The cGMP guidance for combination products does not seem to specify, and since drug claims cannot be made on device-lead drug combination products, it was not clear what quality of drug is required. Thank you! Full Article Discussion
pro RE: Drug Component Quality (OTC vs Combination Product) By connect.raps.org Published On :: Fri, 08 May 2020 13:53:12 -0400 From : Communities>>Regulatory Open ForumI doubt FDA would have any willingness to change the requirements or expectations for a drug product based on whether it is in a strictly drug product versus in a combination product. The fact also that there is not a published allowance for this is further evidence that FDA expects that the drug will meet the requirements as expected for drug products without providing any allowed changes or classes of changes. Remember, FDA expects that drug products meet specific requirements. Things like [More] Full Article Discussion
pro RE: Online sale of unapproved combinations of Minoxidil as topical solution By connect.raps.org Published On :: Sat, 09 May 2020 10:49:42 -0400 From : Communities>>Regulatory Open ForumThese types of products and combinations you mention are all unapproved drugs and unapproved combinations. Unless the specific combination is approved or listed in an OTC monograph, it is a new drug and requires a NDA to market it. Minoxidil is a Rx to OTC switch product so it requires a NDA or ANDA to market this drug in the US, even as a OTC drug. Thus any combination with minoxidil is a new drug. In the past the FDA has also specifically stated that combining different types of products (drug [More] Full Article Discussion
pro Movie Quotes for QA Professionals By polarisconsultants.blogspot.com Published On :: Tue, 26 Apr 2016 14:24:00 +0000 What if your favorite movie quotes were written for QA professionals? Would they be as memorable? We think so, but we’ll let you decide.In the fall of 2015, the internet was rife with tweets sporting the hashtag #ScienceMovieQuotes. Creative scientists repurposed their favorite movie quotes, gleefully infusing them with nerdy humor for the entertainment of their colleagues. Such a great idea was just asking to be stolen. And who are we to resist the siren call of piracy? So here’s our best attempt at making #QAmovieQuotes go viral.*“I’m gonna schedule an audit… he can’t refuse.” - Vendor Oversight Manager at Corleone Clinical “Batches? We don’t need to see no stinking batches!” - Said no GMP auditor ever.Auditee: “You want candor?” Auditor:” I want the proof.” Auditee: “You can’t access the proof!” (Not even A Few Good Men can view electronic source documents at some sites.)"Contemporaneous. You keep using that word.I do not think it means what you think it means." - Inigo Montoya, CCRP“I’ve always depended on the kindness of trainers.” Oh no. Who let Blanche talk to the Inspectors? “I love the smell of Wite-Out in the morning.” - Compliance Auditor, Fraud Division“Get busy complyin’ or get busy tryin’.” (Motivational poster at Shawshank Consulting)“Fecal transplants happen.” “Audits are like a box of chocolates…” [Sorry.] “That’s all right. He can call me ‘Sour’ if he wants to. I don’t mind.” Not every audit is like a trip to Magic Kingdom. Jr. Auditor: “How do you know it’s a glitch?” Sr. Auditor: “It looks like one.” It’s not witchcraft; it’s experience – the holy grail of the QA industry.“Of all the org charts in all the sites in all the world, you had to look into mine.” Qualification records are amiss at Casablanca Research Institute.And amiss is still amiss. [Again, sorry.] “What we’ve got here is a failure to refrigerate” Dr. Luke’s Hand might be Cool, but his Investigational Product isn’t. (Is the study drug supposed to be the Color of Money?) …And because the rhymes were just too good, we couldn’t resist…“What we’ve got here is a failure to investigate.” “What we’ve got here is a failure to remediate.” CAPA fail, Newman StyleIf you’re feeling creative, here are the American Film Institute’s 100 greatest movie quotes of all time. Please share your humor! (Fair warning – we took all the good ones.)By Laurie Meehan________________________________________________* Thanks to Robyn Barnes of MasterControl for this fun idea.Photo creditsBrando: User:Aggiorna / CC BY-SA-3.0, changes madeBadge: User:Dandvsp / Wikipedia Commons / CC BY-SA-3.0Nicholson: User:Nikita~commonswiki / CC BY-SA-2.5, changes madeShawn: Sam Felder / CC BY-SA-2.5, changes madeLeigh: Trailer Screenshot, A Streetcar Names Desire,1951, Public domainFreeman: User:FRZ / CC BY-SA-2.5, changes madeAladdin Chocolates: Hans Lindqvist, 2009, Public domainFlower: Walt Disney, Bambi, 1942, Public DomainDoune Castle: Keith Salveson / CC BY-SA-2.0Bogart: Trailer Screenshot, Casablanca,1942, Public domainNewman: Warner Bros. Entertainment, Cool Hand Luke, 1967, Public Domain Full Article Movie Quotes QA Quality Assurance
pro Avoiding Protocol Deviations By polarisconsultants.blogspot.com Published On :: Tue, 11 Oct 2016 07:06:00 +0000 Year in and year out, protocol deviations are the most common FDA Site Inspection finding. Why does this keep happening?If you’ve seen FDA’s Inspectional Observation Summaries, you know that in 2015 the most frequently cited violation in clinical research by far was “failure to conduct research in accordance with the investigational plan.” Do you know this finding also topped the list the year before that? And the year before that? In fact, deviating from the protocol has been the most common observation every year for the last decade.Why does this keep happening?The Nature of ProtocolsThis will come as a surprise to no one: not all protocols are well written. Important procedures can be hidden in the most obscure places. Charts depicting Time and Events Schedules are famous for carrying dozens of footnotes that appear nowhere else in the protocol, yet convey important study procedures. For instance, a pre-dosing column may include a footnote that provides a timeframe for performing a physical exam; a post-dosing footnote might specify the interval at which vitals must be taken. Failing to follow study procedures compromises subject safety and data integrity; FDA won’t care whether the procedures were in big bold italics or 7-point font.This, too, may come as no surprise, but not all protocols are error-free. Information in charts may not match the narrative. Procedures in Section A may conflict with procedures in Section B. When the FDA investigator spots an inconsistency, you’ll be asked which of the two conflicting procedures you followed and why. If you performed procedure A only because you didn’t even notice there was a B, it will be clear you didn’t read the protocol as thoroughly as you needed to. The FDA investigator may become concerned that your study execution differed from the sponsor’s intention. This is not a concern you want to trigger.For these reasons, it’s imperative that study staff read and understand the protocol. Study team members need to ask questions about anything they’re unsure of, seek clarification on protocol inconsistencies, and get responses that satisfy before starting the study. A PowerPoint overview is not sufficient training.One more irksome attribute of protocols that can make them difficult to follow -- they change. While most study sites allocate time and resources for initial protocol training, many lack a plan for training staff on protocol amendments. A disproportionate number of protocol deviations occur in amended procedures, and it’s often because staff members have been insufficiently trained on them. (And when you do train on protocol amendments, don’t forget to document it.)Deviation TemptationA protocol is not a suggestion; PIs cannot substitute their own judgment for prescribed procedures, no matter how well-intentioned the departure. The protocol for a psoriasis study might call for the PI to perform a series of punch biopsies, very invasive procedures. After the first biopsy, an empathetic PI might be tempted to skip a second if he observes the plaque is clearing up; the drug is working. But this would be a protocol deviation. The protocol for another study might preclude the use of a particular drug, even though the drug is routinely used throughout the practice to treat a symptom that a study participant is exhibiting. But the study protocol trumps standard of care; prescribing the drug would be a protocol deviation.A PI who feels she must deviate from the protocol for some reason must obtain prior approval, since failure to follow the protocol can jeopardize the reliability of the study data, if not subject rights and safety.Deviations HappenSo you’ve thoroughly read the protocol, you’ve asked your questions and received the necessary clarifications, you’ve trained your staff on the protocol and its amendments, and you do your best to follow them.Despite all your preparation and vigilance, protocol deviations happen. They just do. And when they do, here are two don'ts.(1) Don’t panic.(2) Don’t let an FDA investigator find them first.Take the time to fully document any protocol deviations. Be sure to record why they happened, how they were corrected, and what was submitted to the IRB.[Note: IRBs have different requirements about what types of protocol deviations should be communicated. Out-of-window visits are common and are frequently considered too minor to report. But nothing’s black and white. If the missed visit resulted in missed doses, that would probably change the calculus. The PI needs to determine whether to notify the IRB, and if no submission is thought necessary, it’s a good idea to document why not.]_______________________________________________________________A version of this article originally appeared in InSite, the Journal of the Society for Clinical Research Sites. Full Article BIMO deviations FDA Inspectional observations protocol time and event schedules
pro Anticipating Tensions Between Clinical Care and Study Protocol By polarisconsultants.blogspot.com Published On :: Tue, 19 Sep 2017 11:57:00 +0000 Protocol trumps practice. This principle seems clear enough, but complying with it is not always as straight-forward as it sounds. Years of practicing medicine has reinforced the way a physician responds to medical situations. But do these responses run counter to the investigational plan? Can a site’s commitment to standard of care affect its ability to meet enrollment targets?There’s a lot to consider.What’s Your Standard of Care?When deciding whether or not to conduct a particular study, a PI needs to verify that the protocol is aligned with practice norms. For example, an early phase trial might exclude a medication that is part of a practice’s routine therapy. Is the study placebo-controlled? Does it feature a specific comparator drug? Will it include a washout period? Any of these elements could present enrollment challenges or preclude a site from accepting a study at all. Responsible sites want to make thoughtful decisions about study suitability; they want to provide realistic enrollment estimates. Sponsors want this too, and can help sites do both these things by providing them a sufficient level of detail about protocol procedures as early as possible.The Road to Deviations is Often Paved with Good IntentionsTherapeutic misconception – a well-documented phenomenon in clinical research – occurs when a study participant “fails to appreciate the distinction between the imperatives of clinical research and of ordinary treatment.”* Study participants are not alone in this. Researchers blur the distinction themselves when they conduct procedures that are consistent with clinical care but deviate from the protocol. This may be particularly true for PIs who recruit participants from their own practices. An endocrinologist might ordinarily reduce dosage for a particularly diminutive patient. A pulmonologist would often skip a scheduled chest x-ray she felt wasn’t needed to avoid exposing her patient to unnecessary radiation. An orthopedic surgeon may decide his patient needs more recovery time than usual before attempting her first walk. In a clinical care setting, these decisions are sound, made in an individual patient’s best interest. In a clinical trial, if they differ from the investigational plan and haven’t been approved by the Sponsor, they’re protocol deviations.**It May be Par for the Course, But It's Still an AESpecialists who have experience treating particular conditions are also familiar with the complications that ordinarily accompany them. A nephrologist, for instance, knows that a patient with end-stage renal disease frequently experiences bloat from a buildup of fluid between dialysis sessions. Though useful for a doctor treating patients, this knowledge can actually work against a doctor running a trial. How? A PI may fail to report a stomach ache as an AE because it’s so typical, so expected. “Bloat is common for renal patients. If I recorded every GI incident, I’d be recording AEs all day.” At its surface, this PI’s argument sounds reasonable, but what if the study drug itself is contributing to the participant’s discomfort? In order to assess the drug’s gastrointestinal effect, the PI must document the frequency and severity of all GI events.Lab values that are either above or below normal range are also prime candidates for AE underreporting. “Of course the participant’s liver enzyme is high – we’re testing a cholesterol drug.”The Importance of Study OversightAny GCP course worth its registration fee will discuss the distinction between standard of care and the study protocol. In practice, the distinction is not always as obvious as training sessions might suggest. This is where well-trained CRAs come in. As site monitors, CRAs are in a position to catch deviations that result from lapses into standard of care. Reading through progress notes, a monitor can ensure that any untoward medical event has been reported as an Adverse Event. They can verify that procedures conducted by the PI and site staff are compliant with the protocol. Then, by reviewing which types of data must be collected and emphasizing the importance of following certain protocol procedures, monitors can take the opportunity to re-educate study personnel and help them avoid these common pitfalls. _______________________________________________________________________* Lidz CW, Appelbaum PS (2002) The therapeutic misconception: problems and solutions. Med Care 40: V55-V63.**Andrew Snyder of the HealthEast Care System wrote a thoughtful piece describing the compatibilities that do exist between clinical care and clinical research. His arguments provide a useful counterpoint to the issues we’re raising here. https://firstclinical.com/journal/2017/1707_Research_vs_Care.pdfA version of this article originally appeared in InSite, the Journal of the Society for Clinical Research Sites. Full Article adverse events clinical research clinical trials protocol protocol deviations standard of care
pro FDA approval delayed for Sanofi Genzyme’s next blockbuster By www.bizjournals.com Published On :: Fri, 28 Oct 2016 11:11:53 +0000 Editor's note: This story was originally published Friday morning, and has been updated to reflect the FDA's decision regarding the drug later that day. A U.S. approval decision for a major drug planned to be marketed by Cambridge-based Sanofi Genzyme that had been expected last Friday has been delayed due to “deficiencies” found during a manufacturing site inspection in France. In its third quarter report, released Friday morning, French drugmaker Sanofi (NYSE: SNY) disclosed that “manufacturing… Full Article
pro FDA approves MenQuadfiTM, the latest innovation in meningococcal (MenACWY) vaccination By www.news.sanofi.us Published On :: Fri, 24 Apr 2020 08:00:00 -0400 Latest innovation in quadrivalent meningococcal vaccination designed for use in persons 2 years of age and older in the U.S. Full Article
pro Sanofi and Regeneron provide update on U.S. Phase 2/3 adaptive-designed trial in hospitalized COVID-19 patients By www.news.sanofi.us Published On :: Mon, 27 Apr 2020 06:58:00 -0400 • Independent Data Monitoring Committee recommended continuing ongoing Phase 3 trial only in the more advanced “critical” group with Kevzara higher-dose versus placebo and discontinuing less advanced “severe” group Full Article
pro Phase 3 trial of Libtayo® (cemiplimab) as monotherapy for first-line advanced non-small cell lung cancer stopped early due to highly significant improvement in overall survival By www.news.sanofi.us Published On :: Mon, 27 Apr 2020 08:40:00 -0400 - Libtayo decreased the risk of death by 32.4% compared to chemotherapy Full Article
pro Non-innovator biologicals in India: regulatory context and areas for improvement By www.gabionline.net Published On :: Mon, 04 May 2020 08:14:37 +0000 There are major regulatory lapses in the manufacturing of similar biologics in India. The use of scientific audits could strengthen the regulatory system and improve the provision of high quality biosimilars in the country, according to a recent opinion piece [1] by Dr GR Soni, which was published in GaBI Journal. Full Article
pro FDA approves Proventil and Daraprim generics By www.gabionline.net Published On :: Fri, 08 May 2020 08:26:22 +0000 The US Food and Drug Administration (FDA) has approved the first generic version of a commonly used inhaler, marketed as Proventil, and the anti-parasitic Daraprim, which has previously been the subject of a price gouging scandal. Full Article