The FDA may propose to terminate an IND during a Phase I study if the FDA finds that which of the following conditions exists?
The FDA has authority to impose clinical holds and terminations on IND studies when subject safety is at risk.
21 CFR 312.44(b)(1): ''The FDA may propose to terminate an IND if it finds that human subjects would be exposed to an unreasonable and significant risk of illness or injury.''
21 CFR 312.42(e): ''If an IND is placed on clinical hold and the deficiencies have not been adequately addressed within 30 days, FDA may terminate the IND.''
Annual reports (A) are required but noncompliance usually results in clinical hold, not immediate termination. IRB approval delays (B) do not trigger termination; the site simply cannot begin. Investigators report safety data to sponsors, not directly to FDA (C).
Thus, the correct answer is D (The FDA issued a clinical hold, and 30 days have elapsed).
21 CFR 312.44(b)(1) (Termination of an IND).
21 CFR 312.42(e) (Clinical hold procedures).
According to ICH GCP, who besides the sponsor should approve the financial aspects of a clinical trial?
ICH E6(R2) 5.6.1: ''The sponsor should ensure agreement from the investigator/institution on the financial aspects of the trial.''
This ensures transparency in compensation, reimbursement, and budget.
An investigator received an updated investigator's brochure from the sponsor; the update did not include changes related to subject safety. Which of the following parties, if any, is the investigator required to notify?
The Investigator's Brochure (IB) is updated by the sponsor to reflect new scientific or clinical information.
ICH E6(R2) 7.3: ''The sponsor should revise the IB as soon as new, significant information becomes available.''
ICH E6(R2) 4.1.5: Requires the investigator to ensure staff are informed, but there is no requirement to notify IRB/IEC unless subject safety, rights, or risk profile is affected.
Since this update contained no changes related to subject safety, the investigator is not obligated to notify IRB/IEC, DSMB, or regulators. The updated IB must simply be filed in the regulatory binder and implemented at the site.
Thus, the correct answer is D (No notification is required).
ICH E6(R2), 7.3 (Updating the Investigator's Brochure).
ICH E6(R2), 4.1.5 (Investigator responsibilities for informing staff).
Which of the following should a clinical investigator include in a submission to an IRB/IEC for a Phase IV drug study?
For IRB/IEC submissions, investigators must disclose subject-related information that may impact voluntariness or fairness of participation.
21 CFR 56.111(a)(3): The IRB must ensure that subject selection is equitable.
21 CFR 50.25(a)(3): Requires disclosure of ''any compensation and/or medical treatments available if injury occurs.''
ICH E6(R2) 4.8.10(n): Informed consent should describe ''any compensation and/or reimbursement to subjects.''
Thus, compensation amounts must be reviewed by IRB/IEC to ensure they are not coercive or excessive. Budgets (A), marketing plans (C), and contracts (D) are administrative and not part of IRB submission requirements.
Correct answer: B (The amount of payments and compensation to subjects).
21 CFR 50.25(a)(3).
ICH E6(R2), 4.8.10(n).
An investigator received an updated informed consent form (ICF) from the sponsor for a study closed to enrollment. Subjects are only in long-term follow-up. The change related to frequent radiation imaging at screening, with no change to drug safety profile. Who must the investigator notify first?
21 CFR 56.109(a): IRBs must review all changes to informed consent before implementation.
ICH E6(R2) 4.8.2: If new information could affect willingness to continue, consent forms must be revised and approved by the IRB.
Even though screening is closed, the IRB/IEC must review the updated form before any subject re-consenting.
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