Compliance with Good Clinical Practice in oncology registration trials in Japan

A descriptive research: Exclusion from submitted clinical data package in the review process of new drug approval due to GCP violation in Japan

Introduction

In Japan, the PMDA conducted inspections based on GCP in the review process of the submission of NDAs or sNDAs. In this descriptive study, we examined in detail the contents of exclusion data from submitted clinical data package subjects in the results of GCP inspections in Japan for NDAs or sNDAs.

Methods

For NDAs or sNDAs approved in Japan between January 2007 and December 2017, we gathered information about the PMDA's conclusion from review reports, concerning the results of the GCP on-site inspection.

Results

For 1193 NDAs and sNDAs approved in Japan between 2007 and 2017, there were 37 cases in 33 applications of non-compliance with GCP, including 1 by the sponsor and 32 at the clinical trial site. Of the 32 applications at the clinical trial site, 9 cases were categorized as “General findings” and 28 as “Findings for individual subjects.” Of the 9 “General findings” cases, problems related to the IRB were most common (44.4%), while faulty record keeping was the most common (60.7%, 95% confidence interval 42.6%–78.9%) problem in the 27 “Findings for individual subjects” cases. Violations of GCP were mostly found in 2007 and 2009, but few were found after 2013.

Conclusion

In this study, we revealed that record keeping was the most common reason for exclusion from the analysis data of subjects in the results of GCP inspections. It is necessary to be careful in maintaining medical records, especially when conducting clinical trials without using electronic medical records.

Surveillance of protocol deviations in Japanese oncology registration trials: a single institute experience

Background The contents and requirements of study protocols vary depending upon each clinical registration trial. This study aims to describe details of protocol deviations in Japanese oncology registration trials. Methods We reviewed deviation reports that were discussed by the Institutional Review Board between 2010 and 2015. Results A total of 499 clinical trials were performed, from which 967 deviations were reported. In the initial 3 years, 445 deviations occurred in 535 ongoing trials, while 522 deviations occurred in 876 trials in the subsequent 3 years. The frequency of deviations related to visit, examination, treatment, and others was 189 (19.5%), 446 (46.1%), 275 (28.4%), and 57 (5.9%), respectively. Serious deviations were common at the time of registration of trials and during treatment. The deviations were attributable to the institution (n = 520), subject (n = 93), sponsor (n = 28), schedule management (n = 162), disease condition (n = 95), and others (n = 69). Conclusion This study showed the number and detail responsible factors of protocol deviations. Our findings support to distinguish between the measures to reduce the serious deviations and to reduce the overall number of deviations.