EMA Publish Guidelines on Interactive Response Technologies in Clinical Trials
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Over the last 15 years there has been an increasing utilisation of interactive voice response systems (IVRS) utilising telephones. Such systems have been developed further into interactive web based systems (IWRS) utilising the internet. These systems were developed initially to optimise drug availability at sites. However, this has expanded into other areas such as dose titration, unblinding and expiry date updating. This of course may, if not handled appropriately, pose an increased risk to the patient and so IVRS/IWRS is of increasing interest to National Competent Authorities (NCAs).
One specific example is the potential use of IVRS/IWRS to justify the removal of expiry dates from IMP labels. This paper seeks to provide guidance to Member States on what our expectations are of these systems and in particular their use in expiry updating. These positions will form guidance for sponsors and IVRS/IWRS providers.
Sponsors have previously contacted the regulatory agencies with requests to omit the use-by date on study medication in case of IVRS/IWRS use. An advantage of this approach would be avoiding issues related to relabelling of the use-by date on site, which can often cause issues in themselves with poor control of the expiry update labels. However, the request of the sponsors raises concerns for Regulatory Authorities; based on experience, for example GCP inspection findings around IVRS validation and the possibility of dispensing expired study medication to patients.
A White Paper by the ISPE/PDA Expiry Date Task Force produced in 2009, raises an important issue in that many sponsors, due to lack of knowledge, may not be able to use the IVRS/IWRS appropriately (p. 8, 3rd paragraph).
Currently, the information on the use of IVR/IWR systems is limited to the completion of a tick box in the clinical trial authorisation application filled in by the sponsor. Also, the protocol may only provide limited detail on the use of the IVR/IWR.
As IVR/IWR systems are developed to facilitate overall drug management and expanded to assist with dose titration, unblinding and expiry date update, the intent of the paper is to provide guidance to the sponsors and to the IVR/IWR providers in the use of the systems within clinical trials and detail the expectations of the NCA on such systems.
The potential for the revision of Annex 13, when it is next reviewed is also considered.
Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.
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