Blog — Clinical Pathways

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Document Retention Investigator Warning Letter

02/01/2022

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A recent US Food And Drug Administration (FDA) investigator warning letter focused on record retention. According to FDA regulations, site records must be retained for at least two years after a marketing application is approved or two years after the study is closed (21 CFR 312.62(c)).

Remote Data Collection in Clinical Trials Draft Guidance

01/25/2022

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The US Food and Drug Administration (FDA) released a draft guidance “Digital Health Technologies for Remote Data Acquisition in Clinical Investigations” for public comment in December 2021. The draft guidance provides best practices for how digital health technologies (DHT) can be used to collect and support endpoint data and what information is needed in an investigational new drug application (IND) or an investigational device exemption (IDE) application that uses DHT. DHT is a “system that uses computing platforms, connectivity, software, and/or sensors, for healthcare and related uses.”

FDA Issues Draft Guidance on Signature Waiver for Form FDA 1572

6/08/2021

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The US Food and Drug Administration (FDA) issued a draft information sheet guidance “Frequently Asked Questions Statement of Investigator (Form FDA 1572)” as an update to the same titled guidance document from 2010. It provides clarification on when a waiver can be requested when an investigator outside the US cannot or will not sign a Form 1572. The purpose of the Form FDA 1572 is to collect applicable information from the investigators and sub-investigators at clinical research sites to verify they have the appropriate experience and background to conduct the clinical trial. Signing the 1572 is an agreement to conduct the clinical trial according to the applicable FDA regulations while protecting the safety and rights of the study participants and the quality of the data.

Is Your Study High Quality? Investigator Warning Letter Issued

2/16/2021

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During the pandemic, onsite FDA inspections were temporarily suspended starting in March 2020 and restarted late summer. Our blog “FDA Resumes Domestic Inspections” describes the risk-based approach to remote assessments during that time period. This in part explains the long interval since the last warning letter. The first new warning letter after inspections resumed was issued to an investigator.