Rights and Protections

Pensacola Research Consultants is dedicated to ensuring that all our volunteers understand their rights and how they are protected during their participation in a clinical trial. All of our investigators reserve the right to take volunteers out of a study if they believe it is not in the best interests for the person to continue in the study. Furthermore, volunteers are able to stop their participation in a clinical trial at any time.
 
Institutional Review Board (IRB) 
An Institutional Review Board functions as both a clinical trials clearinghouse and monitor. In other words, it must give approval before any clinical trial can begin and then keep close tabs on the progress of the research while keeping the safety and well-being of all research participants their top priority.

While the specific make-up of an IRB varies from place to place, it always includes people who are qualified to evaluate new and ongoing clinical trials on the basis of scientific, legal, and ethical merit. Federal regulations require that an IRB include at least five people of diverse occupations and backgrounds. For instance, an IRB could not be made up of five physicians or five nurses. At least one member must have primarily scientific interests, and another member must have primarily non-scientific interests.

In addition, one member must be an institution outsider, not connected by a job or relatives to the institution. To meet these requirements, IRBs usually are made up of a mix of medical specialists, ethicists, and patient advocates.

If the trial you are considering is federally funded or is evaluating a new drug or medical device regulated by the FDA, then it is subject to review by an IRB. However, many institutions also require that all clinical trials conducted there be approved and reviewed by the IRB.

Data Safety Monitoring Boards 
During the initial review process, the IRB will establish how often a study should be monitored at least yearly, but sometimes more frequently. During these review sessions, the IRB examines a progress report provided by the clinical investigator in charge of the project. The report features information about how many people are enrolled in the study and how many have withdrawn; a description of participants' experiences, including benefits and/or adverse effects; and the overall progress to date.

Based on this material, the IRB decides whether or not the project should continue as described in the original research plan, and, if not, what changes need to be made. An IRB can decide to suspend or terminate approval of the clinical trial if the investigator is not following set requirements, or, if the study appears to be causing unexpected serious harm to participants.

Some clinical trials, especially large Phase III clinical trials, which often involve many institutions are monitored more closely and more often by Data Safety Monitoring Boards (DSMB). The DSMB is a group made up of physicians, statisticians, and patient advocates, a majority of whom are not connected with the trial.

Their priority is patient safety, and they review the data periodically (at least annually, but usually more often) with the following two questions in mind:

• Are there any unexpected or severely toxic effects?
• What is the treatment outcome of the trial so far?

DSMBs are required to produce summary reports that provide regular feedback to the IRBs at the institutions involved in the study concerning the cumulative toxicities observed in trial participants.

Statisticians are key members of DSMBs, because typically many statistical tests are used to determine if there are significant differences between the groups involved in the trial. Often it is difficult to tell if a difference that appears significantly early on will be carried through to the end of a trial. Therefore, DSMB members must weigh the current data and the future possibilities very carefully when making decisions.

Physicians and statisticians connected to the trial being monitored may also attend parts of the DSMB meetings, but they are not voting members. Instead, their job is to provide information about the ongoing trial results to the DSMB. In the interests of objectivity, discussion and voting take place in the absence of all professionals connected with the trial.
 
Ending Trials Early: Protecting the Interests of Participants and the Public 
In an ideal world, all clinical trials would run exactly as anticipated from beginning to end. Of course, that's not always the case, and there are often compelling reasons for halting a trial early. If participants are experiencing unexpected and severe side effects, or there is clear evidence that the risks are outweighing the benefits, then the IRB and the Data Safety Monitoring Board will recommend that the trial be stopped early.

In other cases, a trial might be stopped because it is going particularly well. If there is clear evidence early-on that a new treatment or intervention is effective, then the trial may be halted so that it can be made widely available right away.
 
Monitoring Clinical Trials 
The central guardian of participants' safety and welfare in clinical trials that are federally funded (which includes NCI-sponsored trials) is the Office for Human Research Protections (OHRP), a part of the U.S. Department of Health and Human Services). OHRP is responsible for enforcing the Protection of Human Subjects part of the Code of Federal Regulations (Title 45, Part 46). If the trial is evaluating a new drug, medical device or other product that is subject to approval by the U.S. Food and Drug Administration (FDA), then the FDA's Office of Human Affairs is responsible for ensuring that it meets the Code of Federal Regulation.

If the trial falls into both categories, then it is subject to both sets of regulations, which actually are quite similar. Both include guidelines regarding the role of local Institutional Review Boards (IRBs), the formal body in the community charged with overseeing medical research involving people. Understanding the work of IRBs will help you see that there are outside panels of experts monitoring the investigators who conduct clinical trials -- and representing the interests of those who participate.
 
The Approval Process 
Before a proposed research study can start enrolling people, the investigator must submit a detailed application to the IRB.

The IRB carefully reviews the application with the following criteria in mind:

• The risks to participants are minimized as much as possible through sound research design and the use of procedures that are not unnecessarily risky.
• The risks are reasonable in relation to the anticipated benefits and the importance of the knowledge that may result.
• Participants will be selected fairly.
• There is a plan in place for seeking and documenting participants' informed consent. The informed consent document is both legally and ethically sound.
• If necessary, provisions have been made for monitoring the data collected to ensure the safety of participants as the trial progresses.
• Provisions have been made to protect the privacy of participants and the confidentiality of data collected during the study.

Based on these considerations, the IRB either approves or refuses to approve the clinical trial and notifies the investigator and the institution of its decision in writing. In some cases, the IRB may specify certain changes the investigator must make in order to secure approval for the study. If the IRB grants approval, it also must decide how frequently the trial should be reviewed once it is under way.

Usually this is determined according to the degree of risk the trial involves. At the very least, its progress must be reviewed yearly. For certain trials, especially large multi-site Phase III trials, a Data Safety Monitoring Board may be appointed to keep track of the data in order to ensure participants' safety, to ensure that evaluation of interim results are made completely, and to ensure that the results and ethics of the trial are above reproach.
 
The Ongoing Informed Consent Process 
All participants must go through an informed consent process before enrolling in a clinical trial, and this process does not end once the trial begins. Just as researchers are required to submit reports to the IRB, they also are required to keep participants up-to-date on any new information that may impact their decision to remain enrolled in the trial. The monitoring system that is in place ensures that such new information, if there is any, will be available on a regular basis.