Was betrifft es? Warum ist das wichtig?

Risk Control-Measures are decisions taken by the SP-INV based on risk evaluation and prioritisation including respective actions taken, such as to:

  • Accept a risk: no measures required
  • Tolerate a risk: no measures taken as long as risk remains within a predefined limit
  • Reduce a risk: mitigation measures taken
  • Prevent a risk: measures taken to avoid risk occurrence all together

 

If the decision is to tolerate a risk, any deviation from predefined tolerance limits should trigger a re-evaluation and potential implementation of new mitigating measures.

Ideally, risk control-measures target the root cause of a risk. Knowing the cause of a risk can prevent or reduce the likelihood of its occurrence.

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Example

In a blinded vaccine study, placebo & vaccine vials are identical only distinguishable through an 8 digit identifier placed on the vial.

 

Risk: mix-up of placebo and vaccine vials which will threaten study outcome and endanger the safety of study participants (e.g. unwanted side effects are falsely attributed to the treatment intervention)

 

Risk Control-Measures: the study SP-INV recognises the risk and proposes measures to mitigate risk occurrence.

  • RCM 1: placebo and vaccine vials are stored in separate sections of the fridge or in 2 separate fridges
  • RCM 2: consensus between vial identifier list (placebo or vaccine) and the 8-digit identifier on the retrieved vial are checked and confirmed based on a 4-eye/double-check principle (e.g. 2 persons agree and confirm the correct vial identifier)

Was muss ich befolgen?

As a SP-INV you are responsible to define risk control-measures according to risks defined in your study. 

 

For each risk:

  • Decide whether you want to accept, tolerate, reduce or prevent a risk altogether
  • Depending on how you decide to manage a risk, define applicable control-measures. Consult relevant experts for support (e.g. study staff, quality manager, lab personnel)
  • Plan control-measures proportionate to the expected significant impact of a potential risk (e.g. impact on the primary- or secondary study endpoint(s))
  • Implement and test the efficacy of your control-measures and make appropriate adaptations
  • Document risk control-measures in the Risk-Assessment-Form (RAF) of the study, and ensure all study staff is trained on its implementation

 

As a SP-INV implement a risk-based QMS tailored to the risk management of your study. This includes the potential ongoing update of the RAF during study conduct.  

 

Mehr

A RCM can be a single measure or a combination of different measures, with the involvement of different staff members, even departments (e.g. surgery, study staff, laboratory).

 

Examples of risk control-measures:

  • Study protocol: use an appropriate study design by abstaining from over the top-designs which increases complexity and risk occurrence. Avoid unnecessary data collection that challenges available resources (e.g. study staff, infrastructure, budget)
  • Study Documents: provide guidelines for study relevant procedures such as data collection, informed consent, handling of IMP/IMD (e.g. SOPs, WIs)
  • Staff trainings: ensure study staff is trained on the risk-based QMS of your study (e.g. risk management)
  • Monitoring: follow-up on implemented risk control-measures during study conduct and the potential for novel risk occurrence(s). Consider quality assurance and quality control aspects.
  • Infrastructure & functionality: adapt eCRF to be user friendly, provide required specialised analytical material, ensure appropriate premises are available

Wo kann ich Hilfe anfordern?

Your local CTU can support you with experienced staff regarding this topic

References

ICH GCP E6(R2) – see in particular guidelines

  • 5.0 Quality management
  • 5.0.4 Risk control

ISO 31000 (access liable to costs) – see in particular section

  • Risk management: Principles and guidelines

Documents

Abkürzungen
  • CTU – Clinical Trials Unit
  • eCRF – electronic Case Report Form
  • ICH GCP – International Council for Harmonisation Good Clinical Practice
  • IMP/IMD – Investigational Medicinal Product / Investigational Medical Device
  • ISO – International Organization for Standardization
  • QMS – Quality Management System
  • RAF – Risk Assessment Form
  • RCM – Risk Control Measures
  • SOP –Standard Operating Procedures
  • SP-INV – Sponsor-Investigator
  • WI – Working Instructions
Development ↦ Quality and Risk ↦ Study Risk Management ↦ Risk Control Measures
Study
Basic

Provides some background knowledge and basic definitions

Basic Protocol
Basic Statistics
Basic Monitoring
Basic Drug or Device
Concept

Starts with a study idea

Ends after having assessed and evaluated study feasibility

Concept Protocol
Concept Statistics
Concept Drug or Device
Development

Starts with confidence that the study is feasible

Ends after having received ethics and regulatory approval

Development Protocol
Development Statistics
Development Drug or Device
Set-Up

Starts with ethics and regulatory approval

Ends after successful study initiation

Set-Up Protocol
Set-Up Ethics and Laws
Set-Up Statistics
Set-Up Quality and Risk
Set-Up Drug or Device
Conduct

Starts with participant recruitment

Ends after the last participant has completed the last study visit

Conduct Protocol
Conduct Statistics
Conduct Drug or Device
Completion

Starts with last study visit completed

Ends after study publication and archiving

Completion Protocol
Completion Statistics
Completion Drug or Device
Current Path (click to copy): Development ↦ Quality and Risk ↦ Study Risk Management ↦ Risk Control Measures

Please note: the Easy-GCS tool is currently under construction.