Conduct↦Ethics and Laws↦Amendment↦Type
What is it? Why is it important?
Amendments are changes to an Ethics Committee (EC) and if applicable Swissmedic (i.e. risk-category B & C studies) approved study protocol.
Amendments can either be:
- Substantial (SA): where modifications may have a significant impact on the:
- Non-substantial (N-SA): with no expected implications to the study scope (more administrative / formal changes)
SAs require EC and if applicable RA (e.g. Swissmedic, international) approval before implementation.
Exceptions are urgent safety measures needed to protect study participants against any immediate hazard. If required, safety measures such as temporarily halting the study can be implemented without prior approval. Still, EC/RA must be notified as soon as possible.
Non-SAs do not require initial approval before implementation, but are submitted to:
- Swissmedic as soon as possible
- The EC in the annual progress and safety report
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Examples where a substantial protocol amendment might become necessary:
- New scientific evidence becomes available requiring adaptations to the study research question and/or study outcome/endpoint, safety concerns, the statistical study plan
- Data collection is inadequate requiring the collection of additional data and or material (e.g. additional blood samples, questionnaires)
- Participant recruitment is too slow requiring changes or adaptations of study methods, design, procedures (e.g. inclusion of additional study sites, adaptations of inclusion/exclusion criteria, chages to the number of recruited participants)
- The required addition of additional study sites (multi-centre study)
- Fluctuations in study staff requiring changes in responsibilities (e.g. substitution of Site-INV)
- An extension of the required time limit of two years, needed for:
- The submission to the second responsible authority (e.g. to Swissmedic after submission to the Ethics Committee (EC) approaches 2 years ago)
- Inclusion of the first study participant
What do I need to do?
- In the event of a required safety amendment, immediately or as soon as possible:
- Implement preventative safety measures
- Notify the EC and, if applicable, Swissmedic
As a SP-INV:
- Check the Swissmedic and EC homepage to determine whether a planned amendment is a SA or N-SA
- Define reason(s) why you think an amendment is necessary
- If an amendment affects study participants, adapt the Participant Information Sheet (PIS) and the Informed Consent Form (ICF)
- Submit documents to EC (e.g. protocol, PIS, ICF) and, if applicable, to Swissmedic (e.g. protocol)
- Implement changes only after EC/Swissmedic have approved the amendment
- If applicable, ask participants to re-consent by signing the amended ICF
Except for required safety amendments, initiating a protocol amendment should be well thought through, as it can significantly delay the study.
The implementation of a Quality by Design approach during study planning may protect the study from amendments due lack of quality planning.
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In order to take appropriate action in the event of immediate hazard to study participants, make pre-arrangements on how to implement and handle safety measures. The SP-INV can request support from other experts such as the Data Safety Monitoring Board or another responsible person within the organisation. The protocol should identify any individual(s) who accept(s) this responsibility.
Where can I get help?
Your local Research Support Centre↧ can assist you with experienced staff regarding this topic
Basel, Departement Klinische Forschung (DKF), dkf.unibas.ch
Lugano, Clinical Trials Unit (CTU-EOC), ctueoc.ch
Bern, Department of Clinical Research (DCR), dcr.unibe.ch
Geneva, Clinical Research Center (CRC), crc.hug.ch
Lausanne, Clinical Research Center (CRC), chuv.ch
St. Gallen, Clinical Trials Unit (CTU), h-och.ch
Zürich, Clinical Trials Center (CTC), usz.ch
External References
Swissethics – see in particular
- Substantial amendment: YES or NO or "it depends"
Swissmedic – see in particular
- BW101_10_003e_MB Guideline amendments clinical trials
References
ICH GCP R(3) – see in particular articles and Appendix
- Appendix B. Clinical trial protocol and protocol amendment(s)
- Glossary: Definition Protocol amendment
- Art. 1.2.2a IRB / IEC Responsibility
- 1.4.7 Changes to the protocol
- 2.5.5 Reporting of an amendment
- 3.13.3 Managing an immediate hazard
ICH E8(R1) – see in particular guidelines
- 6.1.1 Protocol adherence
Swiss Law
ClinO – see in particular articles
- Art. 29 Modifications (EC)
- Art. 34 Modifications (Swissmedic)
- Art. 55 Modifications (FOPH)
ClinO-MD – see in particular articles
- Art. 15 Modifications (EC)
- Art. 20 Modifications (Swissmedic)
HRO – see in particular article
- Art. 18 Modifications
- Art. 18 Changes