Reporting Unanticipated Problems Including Adverse Events

POLICY

The Principal Investigator is responsible for the accurate documentation, investigation and follow?up and timely reporting of the following:

1. Any adverse event at this site which in the opinion of the principal investigator is both unexpected and related and places subjects or others at risk of harm.
2. Information that indicates a change to the risks or potential benefits of the research. For example:
3. An interim analysis or safety monitoring report indicates that frequency or magnitude of harms or benefits may be different than initially presented to the IRB.
4. A paper is published from another study that shows that the risks or potential benefits of the research may be different than initially presented to the IRB.
5. A breach of confidentiality.
6. Change in FDA labeling or withdrawal from marketing of a drug, device, or biologic used in a research protocol.
7. Change to the protocol taken without prior IRB review to eliminate an apparent immediate hazard to a research participant.
8. Incarceration of a participant in a protocol not approved to enroll prisoners
9. Event that requires prompt reporting to the sponsor.
10. Sponsor imposed suspension.
11. Complaint by a participant when the complaint indicates unexpected risks or cannot be resolved by the research team.
12. Protocol deviation (meaning an accidental or unintentional change to the IRB approved protocol) that harmed participants or others or that indicates participants or others may be at increased risk of harm.
13. Unanticipated adverse device effect.

Key Terms

Adverse Event - Any undesirable and unintended, although not necessarily unexpected, effect of the research occurring in human subjects as a result of (a) the interventions and interactions used in the research; or (b) the collection of identifiable private information under the research.

An unanticipated problem involving risks to participants or others as defined by OHRP include any incident, experience, or outcome that meets all of the following criteria: (a) unexpected (in terms of nature, severity, or frequency) given the research procedures that are described in the protocol-related documents, such as the IRB-approved research protocol and informed consent document and the characteristics of the subject population being studied;  (b) related or possibly related to participation in the research; and (c) suggests that the research places subjects or others at a greater risk of harm (including physical, psychological, economic, or social harm) than was previously known or recognized.

An unanticipated adverse device effect as defined by FDA regulations at 2CFR 812.3(s) – Any serious adverse effect on health or safety or any life-threatening problem or death caused by, or associated with, a device, if that effect, problem, or death was not previously identified in nature, severity, or degree of incidence in the investigational plan or application (including a supplementary plan or application), or any other unanticipated serious problem associated with a device that relates to the rights, safety, or welfare of subjects.

Protocol deviation is an accidental or unintentional change to the IRB approved protocol that harmed participants or others or that indicates participants or others may be at increased risk of harm.

PROCEDURE

Assessment by Principal Investigator - The Principal Investigator must make a judgment about the expectedness of a problem. If the problem is an adverse event, the investigator must make a judgment about the causality of the adverse event with respect to the study intervention. The Principal Investigator must also evaluate whether  protocol / consent form revisions are needed.

Assessment of Expectedness - The Principal Investigator must state whether the problem is expected or unexpected. An unexpected problem is one in which the nature and severity of which is not consistent with information in the relevant source document(s). For an investigational drug, the Investigator Brochure serves as the source document. Reports that add significant information on specificity or severity of a known, already documented serious adverse event constitute unexpected events. For example, a problem more specific or more severe than described in the Investigator’s Brochure would be considered unexpected.

Assessment of Causality – For adverse events the Principal Investigator should evaluate the event and assess causality. The expression ‘reasonable causal relationship’ is meant to convey in general that there are facts (evidence) or arguments to suggest a causal relationship. For purposes of reporting, adverse event reports associated with marketed drugs usually imply causality. The following conditions might help to assess causality:

1. the event has a reasonable temporal relationship to the intervention,
2. the event could not have been produced by the underlying disease states,
3. the event could not have been due to other non-study interventions,
4. the event follows a known pattern of response to the intervention, or
5. the event disappears with cessation of intervention.

Reporting Timeframe

1. Investigators must report the reportable events described above to CPHS via iRIS as follows: All problems involving local deaths, should be reported immediately – within 24 hours after first knowledge by the investigator.
2. All other problems must be reported as soon as possible but not later than 7 calendar days after first knowledge by the investigator.

CPHS Review Process

Upon receipt of reports, IRB staff will review them and determine if the report meets the following criteria: (1) unexpected (2) related and (3) indicates that participants or others are at increased risk of harm.

1. If the report does NOT meet all three criteria, the report is NOT an unanticipated problem involving risks to participants or others, and no further action is taken.
2. If the report meets all three criteria, the report is an unanticipated problem involving risks to participants or others.

IRB staff will evaluate reports that meet the definition of unanticipated problems involving risks to subjects or others to determine if the problems involve more than minimal risk to subjects or others.

Unanticipated problems that involve no more than minimal risk to subjects or others may be reviewed by expedited procedure. IRB staff shall assign it for review by the chair of the subcommittee that initially reviewed the research proposal. If the chair is not available, the IRB staff will assign it to one of the other subcommittee members or another IRB member.

IRB staff will include unanticipated problems involving greater than minimal risks to subjects or others in the agenda for the next full board meeting of the IRB that conducted the initial or previous continuing review of the research. Where possible, IRB staff shall assign it to the chair of the subcommittee that initially reviewed the research. If the chair is not available, IRB staff will assign it to one of the other subcommittee members or another IRB member. The Reviewer and all IRB members have access to all previous information regarding the research project in iRIS.

Outcome of Review: The convened IRB panel considers the following actions:

1. No action;
2. Modification of research protocol;
3. Modification of information disclosed during the consent process;
4. Additional information provided to past subjects;
5. Additional information provided to current subjects (required when such information may relate to subjects’ willingness to continue to take part in the research);
6. Request the outcome of the most recent Data Safety Monitoring review;
7. Requirement that current subjects re-consent to participation;
8. Modification of the continuing review schedule;
9. Monitoring of the research;
10. Monitoring of the consent process;
11. Suspension of the research;
12. Termination of the research;
13. More information sought pending final decision;
14. Referral to appropriate institutional authorities such as legal counsel, Institutional Official
15. Any other actions.

If the IRB requires the Principal Investigator to make more than minor modifications in response to unanticipated problems involving risks to subjects or others, the Principal Investigator’s modifications will be reviewed at the subsequent full board meeting as per policy and procedure Change Requests and Protocol Amendment.

Reporting: After review by the convened IRB, the unanticipated problem involving risks to participants or others is reported to regulatory agencies and institutional officials following policy and procedure on Reporting.

APPLICABLE REGULATIONS

1. 45 CFR 46 Protection of Human Subjects
2. 21 CFR 56 Institutional Review Board
3. OHRP Guidance on Reviewing and Reporting Unanticipated Problems Involving Risks to Subjects or Others and Adverse Events
4. OHRP Guidance on Reporting Incidents to OHRP
5. FDA Information Sheets: Continuing Review After Study Approval

REFERENCE TO OTHER POLICIES

1. Change Request and Protocol Amendment
2. Reporting

ATTACHMENTS

1. Serious Internal Adverse Event Reporting Form
2. Unanticipated Problems Reporting Form
3. Miscellaneous Submission Form
4. Protocol Deviation Submission Form

If you find errors in this document, contact [email protected] 

CPHS HELPLINE   713-500-7943
iRIS HELPLINE    713-500-7960
UTHealth’s Compliance Hotline (1-888-472-9868)

IRB OFFICE HOURS Thursdays from 1 to 4pm, via the Teams Room at this link

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