Conduct↦Quality and Risk↦Regulatory Inspections↦Conduct
What is it? Why is it important?
A regulatory inspection is a systematic and independent examination conducted by Regulatory Authorities (RA) (e.g. Swissmedic, international).
Its purpose is to determine whether a study is conducted according to:
- The Ethics Committee (EC), and if applicable Swissmedic, approved study protocol
- Applicable regulatory requirements (e.g. Swiss Law, FOPH, international)
- Applicable guidelines (ICH GCP, ISO 14155, Biobanking)
- Study quality processes (e.g. SOPs. WIs)
- Ethical principles
The conduct of an inspection follows standarised procedures (e.g. Swissmedic GCP inspection):
- Pre-Inspection: inspectors send an announcement letter to the SP-INV, and request documents for review. Inspectors define the inspection plan (e.g. purpose, scope)
- During the inspection: inspectors present the inspection agenda/plan, and proceed to check study documents, perform staff interviews, and a facility tour. Due to a shift in priority, inspectors may decide to adjust the agenda during the inspection. The inspection ends with a closing meeting, where inspection findings are presented
- Post-Inspection: inspectors forward the signed inspection report, assess and approve the CAPA plan of the SP-INV
More
Inspectors can target any establishment involved in the planning and implementation of a study (e.g. the SP-INV, CRO’s, participating study sites, partners).
Based on certain conditions, international RAs may conduct inspections in Switzerland. Foreign inspectors can only access documents related to the scope of the inspection.
What do I need to do?
Prior to an upcoming inspection.....
As a SP-INV:
- Notify the Site-INV about the upcoming inspection, by providing the site with the inspection agenda (e.g. purpose and scope)
- Ensure SP-INV documents are current and complete (e.g. filed in the TMF)
- Initiate inspection pre-trainings, covering roles, responsibilities, dos and don’ts, and how to answer inspectors
As a Site-INV:
- Ensure site documents prove that the study is implemented according to required quality processes (e.g. SOP, WI)
- Notify study team and ensure documentation shows that the study staff is trained on study responsibilities and quality processes
- Ensure study site documents are current, complete, filed (e.g. ISF), and readily available during the inspection
Post Inspection:
- Inspectors issue an inspection report describing findings and obligations
- The study SP-INV provides a written inspection response. The response describes CAPAs, including timeline until when findings are resolved
- Inspectors review and approve the response rapport, or may request additional adaptations, which must be resubmitted for approval
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- Any findings identified during the inspection are documented in an official report issued by RA (e.g. Swissmedic)
- Findings are categorised according to level of compliance towards RA requirements (e.g. minor , major-, and critical findings according to EMA`s grading of inspection findings)
- In the event of critical findings, the RA might decide to put participant recruitment on hold, or define further sanctions that must be resolved prior to study continuation
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
References
ICH GCP E6(R3) – see in particular guidelines
- Glossary: Inspection, Regulatory Authorities
- 2.3.5 Inspection permission
- 3.10 Quality management
- 3.16.4 Record access
ISO 9001 (access liable to costs) – see in particular section
- QMS Requirements
EMA - see in particular document on
- Procedures for reporting of GCP inspections requested by the committee for Medical Products for Human Use (CHMP)
- Appendix 5: Grading of inspection findings
Swiss Law
ClinO – see in particular articles
- Art. 46 Swissmedic inspections
- Art. 58 FOPH inspections