Professional Documents
Culture Documents
Tina RossCruz
Abstract
Research disasters have been noted for years. In the early years, the reasons for these
disasters was that there were no regulations governing the protection of human beings;
and there were no guidelines for safety and efficacy of a new medication or treatment
prior to the use in humans. Now regulations and guidelines are in effect for the
protection of human subjects. These guidelines and regulations also protect the
researchers. These regulations have enabled the researchers to further scientific
knowledge of diseases and the etiology, along with the bioavailability, toxicology, and
pharmacology of the new medication or treatment. Even with all of these regulations
and guidelines, still researchers perform unethical research on human subjects. This
could be attributed to several factors: One is the financial gain; second, is the need to be
the best; and third, the professional and academic pressure put on the researchers.
Although there are these pressures, the research subject should still be aware of the
research at hand and the qualifications of the researchers.
Clinical Research Past and Present
Imagine living in the early twentieth century and suffering from chronic headaches. A
physician suggests trying something different, a medication not approved by the Food
and Drug Administration (FDA) for chronic headaches. The medication is taken at the
physician’s request and the result is death. This kind of preclinical research actually did
happen and still does today. There are regulations today that govern clinical research in
humans because of this type of disregard for human life. These regulations enable
healthcare providers to enhance scientific development and to minimize risks involved
with participation in a clinical research trial.
The need for current and accurate information concerning the proper conduct of clinical
research has never been greater than it is today. Researchers are aware of the
vulnerability of the data supporting research trials today; this is why properly conducted
randomized clinical trials have profound effects on the advancement of medicine.
Research involving human patients can be performed in unethical manners. More
importantly, if it is not conducted under stringent standards there is a potential for
criminal deviations. That is why there is a need for the potential research subject to
select ethical sites to ensure their regard for safety and moral conduct.
History of Clinical Research
In the year 1780, Benjamin Franklin said, (Shryock1947)
“The rapid true science now makes occasion, my regretting sometimes that I was born
so soon. It is impossible to imagine the height to which maybe carried, in a thousand
years, the power of man over matter all diseases maybe prevented or cured, not even
expecting even that of old age, and our lives lengthened at pleasure beyond the
antidiluvium standard.”
The history of medical science in the United States falls into four epochs; the first era
began early in the 18th century and ended approximately in 1820. The second era falls
in the year 1820 and ended around 1860; the third era started in 1860 and ended
around 1895. Finally, the last era began in 1895 and has proceeded to the present era.
During this time, American medicine surpassed a long persisting colonial status and
emerged on a level of cultural independence.
Physicians have for years attempted to understand diseases, to use the knowledge to
cure and relieve suffering in the ill. There is a sense of the term “experimentation” in
which it would be true to say that physicians have been experimenting on their patients
since a time beyond memory, record or knowledge. From earliest times when a patient
presented with unusual symptoms or a condition that failed to response to usual
treatment, doctors have experimented with new therapies. “This approach to medical
knowledge, trying out new treatments and procedures and then carefully observing the
results, was the dominant method in Western medical science until well into the present
century” (Schafer, Vol. 307, P 719724). Therapies were not based on observational
studies but on the authority of tradition. For instance, take the great cough medicine;
people were sold the recipe of whiskey, honey, and lemon to quiet the cough. Recipes
similar to these were sold to the public without any evidence of safety and efficacy. The
products that were noneffective; most of them were 99% water. In the words of Oliver
Wendell Holmes, M.D., “If all of these patent medications were thrown into the ocean it
would be good for the population, but bad for the fish in the ocean” (Parasandola, 1999).
“The history of medicine is abundantly endowed with therapies that were widely used
and then were shown ineffective or deadly” (Passamani, 1991). For instance, radiation
therapy was used on patients between 1940 and 1968 for the treatment of acne. The
radiation treatment was found later to lead to a high incidence of thyroid cancer in the
treated patients.
The thalidomide disaster was another treatment found to be toxic. Thalidomide was
used in pregnant women for morning sickness in the early 1950’s. This led to birth
defects in hundreds of babies. Because of the birth defects in infants, the drug was
banned from use in the United States. In 1906 a law was passed to set standards for
drug purity and quality through the United States Pharmacopoeia and the National
Formulary; however, there still was not a law regulating the safety profile of drugs at this
time.
Disasters of Clinical Research
“Research was not as it is today” (Code of Federal Regulations, 1999). For instance, a
study that was performed in 1937 involved the death of 107 Americans, most of whom
were children. The deaths occurred after taking Elixir Sulfanilamide, a medicine used to
treat bacterial infections. The drug Sulfanilamide itself was safe, but the solvent
dethylene glycol added made the elixir deadly. The incident received major media
coverage, which led to the 1938 Food, Drug and Cosmetic Act. “The most important
outcome of the disaster was that new drugs had to be tested and proven safe before
marketing” (Parascandola, 1999).
Another disaster of medical research occurred during World War II. The public views
doctors as some of the most respected and intelligent individuals in our society. So how
can doctors be transformed from healers into systematic killers? Human beings, who
put their utmost trust in physicians, were exposed to unthinkable research. “Nazi doctors
conducted research that was not only unethical in nature, but they did not add anything
of significance to medical knowledge” (Scott, 1998). The Nazi researchers exposed a
number of prisoners to freezing conditions and experimented with various methods of
reviving the prisoners. These doctors also had prisoners involved in the drinking of
seawater to determine how long pilots could survive once drifting in the ocean. (Moreno,
1997) The doctors involved in the unthinkable research projects were able to maintain
some sense that they were not murderers, because they were able to hide behind the
idea that they were doctors. These experiments that were done on prisoners led to
regulations for human research. “The trials of these doctors raised issues that were
problematic. Prosecutors realized the lack of internationally recognized medical ethics
by which the Nazi doctors could be judged” (Moreno, 1997). The “Nuremburg Code” was
created for the ability to judge physicians and researchers who do unethical research on
human beings. This code was adopted to enable the classifying of rules that would
govern the participation of human beings in all medical research worlds wide.
The Declaration of Helsinki was adopted in 1964 by the World Medical Association to
aid in the guidance of ethics in human research. These are principles (Appendix A) that
are to be followed by physicians and others involved in human research. Of these
principles, one states, “It is the duty of the physician to promote and safeguard the
health of the people. The physicians’ knowledge and conscience are dedicated to the
fulfillment of this duty” (World Medical Association, 1964).
In 1966, the Surgeon General announced a policy to govern human subjects
participating in research supported by Public Health Service grants. This policy required
institutions receiving Public Health Service support to create an Institutional Review
Board to oversee research involving human subjects and require that researchers obtain
informed consent from subjects. With this policy in effect since 1966, the following
disaster leaves questions on how the Public Health Service could not follow the policy
themselves.
In 1972, Jean Heller of the Associated Press broke the story of the Tuskegee Trials.
“The United States Public Health Service had been conducting a study on the effects of
untreated syphilis in black men in Tuskegee, Alabama for 40 years” (Jones, 1981).
Syphilis is a disease that can end in death if left untreated. In the latter stages of
syphilis, it affects the brain and impairs one’s mental faculties. These men were not told
that they had syphilis. Instead, they were told they had “bad blood”. These men thought
they were being treated for their bad blood. However in reality they were being studied
to see how syphilis affected them. Once this story broke, an investigation was launched
against the United States Public Health Service. The investigation uncovered that there
never was a protocol created to be followed for this trial. The tragedy of this trial was,
not only did men die at the hands of these unethical physicians, but they also lost the
ability for selfcare and independence. When this study took place there was an
approved treatment available for syphilis that would have saved the lives of these men.
This type of research brought forth even more strict guidelines for the protection of
human subjects in research.
The Code of Federal Regulations is an important part of clinical research today. These
regulations guide all researchers involved in clinical research. Section 50.20 states, “No
investigator may involve a human being as a subject in research covered by those
regulations unless the investigator has obtained the legally effective informed consent of
the subject or subject’s legal authorized representative. An investigator shall seek such
consent only under circumstances that provide the prospective subject or the
representative sufficient opportunity to consider whether or not to participate and that
minimize the possibility of coercion or undue influence” (Code of Federal Regulations).
For example, if a patient is approached to participate in a clinical trial, they are to be
given enough time and information to decide if that is what they want to participate in
the trial. An investigator or an associate with the research site must inform the subject
that they can take the informed consent home and talk it over with their family, or
research the information without feeling pressured to participate in the trial.
The section 50.25 gives the information on the elements of the informed consent
(Appendix B). This section in the Code of Federal Regulations must be present in every
informed consent prior to an Institutional Review Board approval of the consent for the
subjects to read.
Clinical Research Today
“Research today is referred to as medical experimentation, and involves the designing of
procedures that systematically manipulates subjects and the use of controls for gaining
knowledge” (Schafer, 1982 p 719724). Properly performed randomized clinical trials are
essential to the medical world of today. There are many advantages to randomized
clinical trial. Randomized clinical trials are necessary for valid assessment of therapeutic
efficacy. Secondly, they remain the most reliable method for evaluating the efficacy of
therapies. Thirdly, they are important in the advancement of medical knowledge. Clinical
research today is the scientific study of new medications, treatments, or devices in
human subjects.
“Professionals who conduct research typically have advance degrees, such as M.D.’s,
Ph.D.’s. These professionals work in research centers, universities, or for
pharmaceutical companies” (Dunkin, 2000). “What these professionals have in common
is inquiring minds; they have the patience to probe into the mechanics of diseases and
the desire to help their fellow man” (Dunkin, 2000).
Researchers work together to better understand a disease and the process it takes on
within a subject’s body and why a disease may affect a certain population. However, for
advancements to occur basic research and clinical research are necessary.
The clinical research phase begins after scientific research has been done on animals.
The findings in the animal studies must have shown that the results are promising to be
able to conduct research in humans. The research that is done on animals gives
important information on toxicology, pharmacology, and bioavailability of the new
medication or treatment. Once scientists have all of the information on these animal
studies, scientists present the data to another group of scientists to start the clinical
phase.
The second group of scientists complies all of the data from the animal studies and
begin writing a protocol for the clinical research phase. A clinical trial is a research study
that sets out to answer specific questions about a new treatment or medication. These
trials are used to determine whether a new treatment or medication is safe and effective
for use in humans. A protocol serves as the basic criteria for all clinical trials. Protocols
consist of several steps (Appendix C). It is imperative that these protocols have all of the
steps included for the FDA to approve that the clinical trial is acceptable for human
subjects.
Prior to the research trial beginning the pharmaceutical company has to present the
protocol and expected outcomes to the FDA for approval. There are times where the
FDA will turn down the protocol and the scientists must start all over with a new protocol
and outcomes. The FDA has also been known to add specific tests to be performed in a
protocol due to previous information on the chemical background of the drug. If this
happens, then the pharmaceutical company will do what is called an amendment to the
protocol to include what the FDA has requested.
The IRB must approve the protocol, informed consent, amendment and the investigator
to prior to the start of the clinical trial. The IRB can request that certain information be
put in the informed consent for subjects to read. The informed consent must be written
on an eighth grade level; this is to ensure that the information provided in the informed
consent can be understood by the lay subjects.
There are four phases of clinical research. Phase I is the initial introduction of an
investigational new medication in humans. Phase I studies are typically closely
monitored and may be conducted in patients or normal healthy volunteers. The Phase I
studies are designed to determine the metabolism and pharmacologic actions of the
drug in humans. Phase II include controlled clinical studies conducted to evaluate the
effectiveness of the drug for a particular indication or indications in patients with the
disease or condition under study and to determine the common shortterm side effects
and risks associated with the new drug. Phase III studies are expanded controlled and
uncontrolled trials. They are performed after preliminary evidence suggesting
effectiveness of the drug has been obtained. These studies are conducted to gather
additional information about the effectiveness and safety that is needed to evaluate the
overall benefit to risk relationship of the drug. This phase can take years to complete
and is done on patients with a certain disease. Phase IV is completed after the FDA has
given approval for “post marketing”. The post marketing phase reflects the FDA’s
approval of the drug or drugs in question. This phase is used specifically for testing
efficacy of one approved drug to another with the same indication. This type of research
is commonly referred to as a head to head comparison.
The FDA conducts audits at clinical research sites based on for cause audits or on
regular audits. The chart below shows the total audits that have been conducted by the
FDA to date along with the findings of these audits.
NAI = No action indicated
VAI = Voluntary action indicated
OAI = Official action indicated
Based on the chart it should be noted that the official action indicated means that the
site must respond to the findings in writing to the FDA within a specific time period. If a
site does not respond to the FDA’s findings, the site can be shut down from conducting
research any further. There are many sites that receive a voluntary action indicated.
This usually means that the site did not follow the protocol as it was written. The FDA
requires that the site responds to the findings, however, the FDA does not stop the site
from conducting research if they do not respond. With the no action indicated the FDA
has found no deviations from the protocol. This finding is not usually the case in audits
performed by the FDA.
Ethics in Clinical Research
The financial stakes are high in modern pharmaceutical research, and there is concern
that researchers maybe tempted to commit fraud for personal financial gain. The
problems with fraud in clinical research are brought to the attention of the public and
many people have a negative perception about clinical research. The reason for this
negative perception is caused by the deception that researchers have committed on
behalf of their greed.
“Scientists have traditionally assumed that research fraud is a rare event, believing that
peer review and replication of experiments uncover most attempts at deception”
(Parascandola, 1999). A well known case of deception happening has been
documented, and was noted as happening in California in the late 1990’s. A physician
was asking his staff and family members to donate their biological samples for falsifying
research subjects. The investigator actually was taking samples from his employees and
family, storing the samples in a refrigerator at his office. The physician was entering
ghost patients into the studies and using the samples from the employees and family
members for visits that required lab samples to be collected. It was not until a staff
member turned the physician in to the FDA that he was caught for falsifying data on
several clinical trials. It was noted that this physician had been committing fraud for over
two years. He was given a federal prison term and a hefty fine for the falsifying of data.
Another trial that is recently noted for deception is the one in which Jesse Gelsinger
participated in for a disease that he had since he was born. Jesse was an eighteen
yearold with a terrible disease called OTC deficiency. This disease interfered with
Jesse’s liver being able to metabolize ammonia. There is a fatal form of this disease;
however, Jesse did not have the fatal form. Jesse was able to manage the disease with
medications. Jesse took 32 pills a day by mouth to manage the disease. Jesse was a
somewhat normal teenager with a terrible disease; until Jesse stopped taking the
medication and ended up very sick and in a coma. Jesse did recover from the coma and
went on to graduate high school like most teenagers.
Then Jesse learned about a clinical trial being done in Philadelphia for the disease. The
trial was looking for a cure of the fatal type of this disease that strikes babies. The
clinical trial which involved gene therapy was a hope in the future for the babies in
Jesses’ eyes. Jesse flew to Philadelphia to inquire about the study and to see if he
qualified to participate in the trial. Jesse underwent the screening process for the study.
This process is done to ensure that subject is a good a candidate and qualify for
participating in the trial. Jesse was informed by the researchers that he did meet the
inclusion criteria to be enrolled into the clinical trial. Jesse was scheduled to return for
the treatment phase of the research trial in the near future.
Jesse stated to a friend before the treatment, “The worst thing that could happen to me
is that I die; however, it is for the babies” (Helms, 2000). At the treatment visit Jesse had
labs collected along with other study specific procedures to ensure that he still met the
criteria for participating. Jesse did in one respect qualify; however, he had a high blood
level of ammonia. Jesse’s level was 90 mmol. This level was exclusionary for the
treatment phase of the research trial. In order to be able to participate in the trial, the
subject could have a level up to 75 mmol of ammonia and still qualify. The researchers
at the site blatantly ignored the protocol specifics. Not only did the researchers ignore
the elevated ammonia level, the researchers skipped the order in which the assigned
treatment should have been given. The researchers did not follow the protocol as
written. The results of the ignorance, human error, or sloppiness on behalf of these
researchers resulted in the death of Jesse.
Risks are involved in all types of clinical research. “There maybe side effects or adverse
reactions to medications or treatments. The treatment may not be effective for the
research subject. The protocol may require a lot of the research subjects’ time for trips
to the study site, treatments, hospital stays, or complex dosage requirements” (National
Institute of Health, 2007).
The risks that are involved in participating in a clinical research trial are put into the
informed consent for the potential subjects to read. This information gives in detail the
possible side effects with the medication or treatment being studied. The informed
consent also gives detailed information about the possible side effects not yet known
with the medication or treatment being studied. The information about every possible
side effect that has been reported in previous studies is also stated in the informed
consent. This information is essential for the protection of the potential research subject
that has been asked to participate in the clinical trial.
With all the information included in the informed consent, the subjects have the right to
decline participation in the clinical trial if they wish. Along with the risks involved in the
research, the benefits are also included in the informed consent.
“In many cases the patient himself is intended to benefit directly from the experiment.
That is part of its purpose, but not the study’s whole purpose” (Schafer, 1982, p 719
724). For example, by agreeing to participate in an experiment, a patient may gain
access to a new and promising medication or treatment that is being tried in a limited
way. “Alternatively, or additionally, the patient may benefit indirectly by receiving
especially careful attention and care from an elite group of highly trained specialist”
(Schafer, 1982, p 719724).
Subjects who agree to participate in a clinical trial will be able to take an active role in
their healthcare. Subjects may have the benefit of putting their disease in remission
through clinical research and subjects will be helping others by contributing to medical
research.
Another benefit is if a subject is unable to afford uptodate medical care, the subject is
able to receive medical care and medications or treatments at no cost. Research can be
helpful for more expensive diagnostic procedures that need to be done to find the
medical problem that the subject maybe having. The other side to this is the subject may
have something serious going on medically and will have the capability to find out the
medical condition. Another, benefit to the subject is they maybe paid for participating in
a clinical trial. With this in mind the subjects who have no insurance coverage and
cannot afford to take off from work for the necessary medical care, maybe given a
stipend to help with the financial burdens of missing work.
Without medical research there would be no cures today. Take the treatment for polio; a
research trial provided the information for the prevention of polio. Many research trials in
the past have given the knowledge for today’s medicine.
Ethical Research Sites
How does a subject know if a site is an ethical research site? Is the research site
reputable? A subject who is contemplating participation in a clinical trial can look for
standards in a research site. A subject can ask questions, such as how long has the
research site been doing clinical trials? Most reputable sites have been doing clinical
research for more than two years.
The subject can ask if the employees are familiar with the regulations and the protection
of human beings participating in a clinical trial. Research coordinators who are well
versed in research will inform the subject of the Nuremberg Code, Code of Federal
Regulations, and the Declaration of Helsinki. The site has the obligation to read these
regulations to the subject. The regulations have been put into effect for the protection of
the subject considering participation in a research trial.
The subject can ask if the research coordinator is certified in research. Research sites
are requiring that the coordinators get certified by the Association of Clinical Research
Professionals (ACRP). Pharmaceutical companies also look for this certification when
considering a site to conduct a protocol.
The certification is a test asking questions of the coordinator regarding the FDA
regulations, good clinical practices, Code of Federal Regulations, and basic knowledge
of performing research on subjects. This certification is currently the only means of
knowing that the coordinator is knowledgeable in clinical research. The ACRP requires
recertification every two years with the coordinator having to complete 24 hours of
continuing education hours.
Since the requirement of coordinators to be certified in clinical research, the ACRP has
created a certification test for potential investigators. Even though there is a test for the
investigators to take it is not mandatory for an investigator to take this test. With this in
mind if there was an increase in expected accountability on the investigators, this would
solve a lot of the problems with investigators not doing research for the advancement of
medicine and knowledge of disease, but for the greed of the money. This certification
may also help in detouring physicians from performing unethical research.
A subject should always be aware of the actions of the research staff. If the subject feels
uneasy about the research site, the subject should ask to see the credentials of the
research staff. This would include the physicians’ degrees and certifications along with
the site staff. More than likely if a subject is at a reputable research site the subject will
feel comfortable in the surrounding. The subject should always remember that withdraw
from a study is allowed without any prejudice toward the subject. With all of this
information a potential research subject should be able to judge a site’s capabilities and
ethics.
References
Byar, M.D., David P., et al “Randomized Clinical Trials.” The New England Journal of
Medicine. Vol 295 No.2 (1976): p 7480
Code of Federal Regulations. Illinois: TAP 1999
Helms, Robert. “No Charges Filed: The Manslaughter of Jesse Gilsinger” March 2000.
Retrieved November 10, 2000, from http://www.geocities.com
Jones, J. Bad Blood: The Tuskegee Syphilis Experiment: A tragedy of race and
medicine. NY: The Free Press, 1981
Moreno, Jonathan D. “The Dilemmas of Experimenting on People” July 1997. Retrieved
November 10, 2000, from http://www.techreview.com/articles/july97/Moreno.html>
National Institute of Health “Understanding Clinical Trials” Retrieved December
12,2006,from http://www.clinicaltrials.gov
Parasandola Ph.D., Mark. “The History of Medical Research in the United States”
Journal of Clinical Research Practice 1:1 (1999): 720
Parascandola, Ph.D., Mark. “Investigator Fraud in Clinical Research” Mar/Apr 1999.
Retrieved December 12, 2006, from http://www.researchpractice.com
Passamini, M.D., Eugene. “Clinical Trials are they Ethical? The New England Journal of
Medicine. Vol 324 No. 22 (1991) : 15891592
Scott, Stephen. “Nazi Experimentation” April 1998. Retrieved December 14, 2006, from
http://www2kenyon.edu
Shyrock, R.: American Medical Research Past and Present. NY: The Common Wealth
Fund, 1947
World Medical Association “The Declaration of Helsinki” June 1964, Retrieved
December 14, 2006, from http://www.wma.net
Appendix A
DECLATATION OF HELSINKI
Recommendations Guiding Physicians in Biomedical Research Involving Human
Subjects:
It is the mission of the physician to safeguard the health of the people. His or her
knowledge and conscience are dedicated to the fulfillment of this mission.
1. Biomedical research involving human subjects must conform to generally accepted
scientific principles and should be based on adequately preformed laboratory and
animal experimentation and on a thorough knowledge of the scientific literature.
2. The design and performance of each experimental procedure involving human
subject should be clearly formulated in an experimental protocol which should be
transmitted for consideration, comment and guidance to a specially appointed
committee independent of the investigator and the sponsor provided that this
independent committee is in conformity with the laws and regulations of the country in
which the research experiment is performed.
3. Biomedical research involving human subjects should be conducted only by
scientifically qualified persons and under the supervision of a clinically competent
medical person. The responsibility for the human subject must always rest with a
medically qualified person and never rest on the subject of the research, even though
the subject has given his or her consent.
4. Biomedical research involving human subjects cannot legitimately be carried out
unless the importance of the objective is in proportion to the inherent risk to the subject.
5. Every biomedical research project involving human subjects should be preceded by
careful assessment of predictable risks in comparison with foreseeable benefits to the
subject or to others. Concern for the interests of the subject must always prevail over the
interests of science and society.
6. The right of the research subject to safeguard his or her integrity must always be
respected. Every precaution should be taken to respect the privacy of the subject and to
minimize the impact of the study on the subject’s physical and mental integrity and on
the personality of the subject.
7. Physicians should abstain from engaging in research projects involving human
subjects unless they are satisfied that the hazards involved are believed to be
predictable. Physicians should cease any investigation if the hazards are found to
outweigh the potential benefits.
8. In publication of the results of his or her research, the physician is obliged to preserve
the accuracy of the results. Reports of experimentation not in accordance with the
principles laid down in this Declaration should not be accepted for publication.
9. In any research on human beings, each potential subject must be adequately
informed of the aims, methods, anticipated benefits and potential hazards of the study
and the discomfort that it may entail. He or she should be informed that he or she is at
liberty to abstain from participation in the study and that he or she is free to withdraw his
or her consent to participation at any time. The physician should then obtain the
subject’s freelygiven informed consent, preferably in writing.
10. When obtaining informed consent for the research project the physician should be
particularly cautious if the subject is in a dependent relationship to him or her or may
consent under duress. In that case the informed consent should be obtained by a
physician who is not engaged in the investigation and who is completely independent of
this official relationship.
11. In case of legal incompetence, informed consent should be obtained from the legal
guardian in accordance with national legislation. Where physical or mental incapacity
makes it impossible to obtain informed consent, or when the subject is a minor,
permission from the responsible relative replaces that of the subject in accordance with
national legislation. Whenever the minor child is in fact able to give consent, the minor’s
consent must be obtained in addition to the consent of the minor’s legal guardian.
12. The research protocol should always contain a statement of the ethical
considerations involved and should indicate that the principles enunciated in the present
Declaration are complied with.
Appendix B
CONTENTS OF INFORMED CONSENT
1. A statement that the study involves research, an explanation of the purposes of the
research and the expected duration of the subject’s participation, a description of the
procedures to be followed, and identification of any procedures which are experimental.
2. A description of any reasonably foreseeable risks or discomforts to the subject.
3. A description of any benefits to the subject or to others which may reasonably be
expected from the research.
4. A disclosure of appropriate alternative procedures or courses of treatment, if any, that
might be advantageous to the subject.
5. A statement describing the extent, if any, to which confidentiality of records identifying
the subject will be maintained and that notes the possibility that the Food and Drug
Administration may inspect the records.
6. For research involving more than minimal risk, an explanation as to whether any
compensation and an explanation as to whether any medical treatments are available if
injury occurs and, if so, what they consist of, or where further information may be
obtained.
7. An explanation of whom to contact for answers to pertinent questions about the
research and research subjects’ rights, and whom to contact in the event of a research
related injury to the subject.
8. A statement that participation is voluntary, that refusal to participate will involve no
penalty or loss of benefits to which the subject is otherwise entitled, and that the subject
may discontinue participation at any time without penalty or loss of benefits to which the
subject is otherwise entitled.
9. A statement that the particular treatment or procedure may involve risks to the subject
(or to the embryo or fetus, if the subject is or may become pregnant) which are currently
unforeseeable.
10. Anticipated circumstances under which the subject’s participation may be terminated
by the investigator without regard to the subject’s consent.
11. Any additional costs to the subject that may result from participation in the research.
12. The consequences of a subject’s decision to withdraw from the research and
procedures for early termination of participation by the subject.
13. A statement that significant new findings developed during the source of the
research which may relate to the subject’s willingness to continue participation with be
provided to the subject.
14. The approximate number of subjects involved in the study.
Appendix C
CONTENTS OF PROTOCOLS
Purpose, Allocation, Masking, Control, Assignment, and Endpoint.
Purpose—reason for the protocol
• Treatment: protocol designed to evaluate one or more interventions for treating a
disease, syndrome, or condition.
• Prevention: protocol designed to assess one or more interventions aimed at preventing
the development of a specific disease or health condition.
• Diagnosis: protocol designed to evaluate one or more interventions aimed at
identifying a disease or health condition.
• Educational/Counseling/Training: protocol designed to assess one or more
interventions in an educational, counseling, or training environment.
Allocation—participant selection
• Randomized Controlled Trial: participants are assigned to intervention groups by
chance.
• Nonrandomized Trial: participants are expressly assigned to intervention groups.
Masking—knowledge of intervention assignments
• Open: no masking is used. All involved know the identity of the intervention
assignment.
• Single Blind: participants are unaware of the intervention assignment; investigators are
aware.
• Double Blind: both participants and investigators are unaware of the intervention
assignment.
Control—nature of the intervention control
• Placebo: participants may receive only placebo throughout the course of the protocol.
• Active: participants may receive some form of treatment (e.g., standard treatment) in
place of the intervention under investigation.
• Uncontrolled: no controls are used.
• Historical: the control consists of results from past studies.
• Dose Comparison: participants may receive one of several doses of the intervention.
Assignment—intervention assignments
• Single Group: all participants receive the same intervention throughout the protocol.
• Parallel: participants receive an intervention throughout the protocol.
• Crossover: participants may receive different interventions sequentially during the
protocol.
• Factorial: participants may receive no intervention, some intervention, or multiple
interventions simultaneously.
• Expanded Access: includes treatment IND protocols.
Endpoint—overall outcome that the protocol is designed to evaluate. Select one.
• Safety: show if the drug is safe under conditions of proposed use.
• Efficacy: measure of an intervention's influence on a disease or health condition.
• Safety/Efficacy (as described above).
• Bioequivalence: scientific basis for comparing generic and brand name drugs.
• Bioavailability: rate and extent to which a drug is absorbed or otherwise available to
the treatment site in the body.
• Pharmacokinetics: the action of a drug in the body over a period of time including the
process of absorption, distribution and localization in tissue, biotransformation, and
excretion of the compound.
• Pharmacodynamics: action of drugs in living systems.
• Pharmacokinetics/dynamics (as described above).
Outcomes—specific measurements or observations used to measure the effect of
experimental variables in a study
• Primary Outcomes Definition: The specific measure that will be used to determine the
effect of the intervention(s). The description should include the time at which the
measure will be taken. Examples: Effectiveness of olanzapine, as measured by the
Children's Psychiatric Rating Scale
• Secondary Outcomes Definition: Other measures that will be used to evaluate the
intervention and that are specified in the protocol. The description should include the
time at which the measures will be taken. Examples: Aberrant Behavior Checklist;
Clinical Global Impressions
Glossary
Adverse Drug Reaction – In the preapproval clinical experience with a new medicinal
product or its new usages, particularly as the therapeutic dose(s) may not be
established, all noxious, and unintended responses to a medicinal product related to any
dose should be considered adverse drug reactions. The phrase “responses to a
medicinal product” means that a causal relationship between a medicinal product and
an adverse event is at least a reasonable possibility, i.e., the relationship cannot be
ruled out.
Adverse Event – An AE is any untoward medical occurrence in a patient or clinical
investigation. An AE can therefore be any unfavorable and unintended sign (including
abnormal laboratory findings), symptoms, or disease temporally associated with the use
of the medicinal product.
Approval – The affirmative decision of the IRB that the clinical trial has been reviewed
and may be conducted at the institution site within the constraints set forth by the IRB,
the institution, good clinical practice (GCP), and the applicable regulatory requirements.
Blinding/Masking – A procedure in which one or more parties to the trial are kept
unaware of the treatment assignment(s). Single blinding usually refers to the subject(s)
being unaware, and double blinding usually refers to the subject(s), investigator(s),
monitor and in some cases data analyst being unaware of the treatment assignment(s).
Case Report Form A printed, optical, or electronic document designed to record all of
the protocol required information to be reported to the sponsor on each trial.
Clinical Trial/Study – Any investigation in human subjects intended to discover or verify
the clinical, pharmacological, and/or pharmacodynamic effects of an investigation
product(s), and/or to study absorption, distribution, metabolism, and excretion of an
investigational product(s) with the object of ascertaining its safety and/or efficacy.
Comparator – An investigational or marketed product (i.e., active control), or placebo
used as a reference in a clinical trial.
Compliance – Adherence to all the trial related requirements, good clinical practices
(GCP) requirements, and applicable regulatory requirements.
Confidentiality – Prevention of disclosure to other than authorized individuals of a
sponsor’s proprietary information or of a subject’s identity.
Good Clinical Practice – A standard for the design, conduct, performance, monitoring,
auditing, recording, analysis, and reporting of clinical trials that provides assurance that
the data and reported results are credible and accurate, and that the rights, integrity,
and confidentiality of trial subjects are protected.
Informed Consent – A process by which a subject voluntarily confirms his or her
willingness to participate in a particular trial, after having been informed of all aspects of
the trial that are relevant to the subject’s decision to participate. Informed consent
documented by means of a written, signed, and dated informed consent form.
Institution – Any public or private entity or agency or medical or dental facility where
clinical trials are conducted.
Institutional Review Board (IRB) – An independent body constituted of medical,
scientific, and nonscientific members, whose responsibility is to ensure the protection of
the rights, safety, and wellbeing of human subjects involved in a trial by, among other
things, reviewing, approving and providing continuing review of the clinical trials. This
group also approves amendments to protocols, the methods and materials to be used in
obtaining and documenting informed consent of the trial subjects.
Investigator – A person responsible for the conduct of the clinical trial at a trial site. If a
trial is conducted by a team of individuals at a trial site, the investigator is the
responsible leader of the team.
Protocol – A document that describes the objective(s), design, methodology, statistical
considerations, and organization of a trial. The protocol usually also gives the
background and rationale for the trial, but these could be provided in other protocol
referenced documents.
Protocol Amendment – A written description of the change(s) to a protocol. It can also
be done to make formal clarification of a protocol.
Randomization – The process of assigning trial subjects to treatment or control groups
using an element of chance to determine the assignments in order to reduce bias.
Sponsor – An individual, company, institution, or organization that takes the
responsibility for the initiation, management, and/or financing of a clinical trial.
Subject/Trial Subject – An individual who participates in a clinical trial, either as a
recipient of the investigational product(s) or as a control.
Trial Site – The location(s) where trial related activities are actually conducted.