Research Ethics in Child Psychiatry: Introduction and Historical Perspectives

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BEFORE YOU START YOUR STUDY:
INTRODUCTION TO RESEARCH
ETHICS IN CHILD PSYCHIATRY
A. J. Allen, MD, PhD
Sr. Med. Fellow, Bioethics & Peds
Capabilities
Eli Lilly and Company
E-learning series
AACAP
A. J. Allen/Allenaj@Lilly.com/Dec. 11, 2013
Disclosure
No medications will be discussed during this
presentation.
Disclaimer
The opinions expressed are those of the presenter
and in no way reflect an official opinion of Eli Lilly
and Company.
Overview
Short history for context
The Belmont Report and basic principles
Other research ethics sources
US regulations for the protection of human subjects
Subpart D: Children
Other subparts
Investigator responsibilities
Resources
Partial History of Shame
1940s: Nazi “medical experiments”
Occurred in spite of pre-Nazi German laws
Resulted in the US drafted Nuremberg Code
1966: Henry Beecher’s NEJM article identifying
22 instances of published human subject
research involving unethical practices
Willowbrook State School study exposing severely
mentally disabled children and adolescents to hepatitis
virus
1972: 40 year Tuskegee syphilis study revealed
Partial History of Shame (continued)
Sept. 16, 1999: Jesse Gelsinger, an 18 year old
healthy volunteer, dies in gene therapy
experiment at U. Penn
Inadequate preclinical research in advance
Lead researcher had financial ties to gene therapy
company that were not disclosed to study subjects
Study team violated approved protocol procedures
intended to protect subjects
SUPPORT Trial
IRB reviewed and approved double-blind,
randomized trial involving pre-term infants
Investigating outcomes (including death and
blindness) of different levels of oxygen saturation
The two oxygen saturation levels were at the extremes of the
range normally used in practice at the time
Controversy erupted over whether the informed
consent document adequately described the risk of
the trial, including the possibility of death and
blindness
SUPPORT Trial (continued)
August 28, 2013 Federal hearing involving NIH, FDA
and OHRP
Resource page:
http://www.hhs.gov/ohrp/newsroom/rfc/Public%20Meeting
%20August%2028,%202013/aug28public.html
Presentations:
https://www.youtube.com/playlist?list=PLrl7E8KABz1Gc_ndt
9grGg8O_jE5G1RNC&feature=edit_ok
Two parent presentations:
https://www.youtube.com/watch?v=n1USAH0PMu0&list=PLrl
7E8KABz1Gc_ndt9grGg8O_jE5G1RNC&index=22
https://www.youtube.com/watch?v=mzLubIgWGP8&list=PLrl7
E8KABz1Gc_ndt9grGg8O_jE5G1RNC&index=23
SUPPORT Trial (continued 2)
August 28, 2013 Federal hearing involving NIH, FDA
and OHRP
Presentations (continued):
https://www.youtube.com/playlist?list=PLrl7E8KABz1Gc_ndt
9grGg8O_jE5G1RNC&feature=edit_ok
Neonatologist and grand parent presentation:
https://www.youtube.com/watch?v=SmWJnOp1QaU&list=PLrl7E
8KABz1Gc_ndt9grGg8O_jE5G1RNC&index=10
Nice summary presentation:
https://www.youtube.com/watch?v=1Hunhqfz8C4&list=PLrl7E8
KABz1Gc_ndt9grGg8O_jE5G1RNC&index=28
Belmont Report
Product of National Commission for the
Protection of Human Subjects of Biomedical
and Behavioral Research (est. 1974)
Response of Congress to the Tuskegee revelations
Discussions by commission members turned into report
by commission staff
Outgrowth of 4 day meeting at Smithsonian
Institution’s Belmont Conference Center in
February, 1976
Belmont Report 2
Final version published: April 18, 1979
Statement of basic ethical principles and guidelines
that should assist in resolving the ethical problems
that surround the conduct of research with human
subjects
http://www.hhs.gov/ohrp/humansubjects/guidance
/belmont.html
Belmont Report TOC
Boundaries between practice and research
Basic ethical principles
Respect for persons
Beneficence (implicitly includes nonmaleficence)
Justice
Applications
Informed consent
Assessment of risk and benefits
Selection of subjects
Declaration of Helsinki
Product of the assembly of the World Medical
Association (WMA)
Triggered by Nazi “experiments”
Produced by medical organization (physicians)
First adopted in 1964
Amended 
6
 7 
times (most recently in 
2008
 October, 2013
) and
clarifying notes added twice
Has been a source of controversy at times in a
number of areas
http://www.wma.net/en/30publications/10policies/
b3/
Declaration of Helsinki (continued)
2013 version – reorganized as 37 statements in 12
sections
Preamble
General principles
Risks, burdens and benefits
Vulnerable groups and individuals
Scientific requirements and research protocols
Research ethics committees
Privacy and confidentiality
Informed consent
Use of placebo
Post-trial provisions
Research registration and publication and dissemination
Unproven interventions in clinical practice
International Committee on
Harmonization (ICH)
Guidance documents are products of agreements
between FDA, EMA, PMDA, PhRMA, EFPIA, JPMA
Biopharmaceutical oriented guidance
ICH E6 covers Good Clinical Practices (GCPs)
http://www.ich.org/fileadmin/Public_Web_Site/ICH_Produc
ts/Guidelines/Efficacy/E6_R1/Step4/E6_R1__Guideline.pdf
Includes ethics and protection of human subjects
Responsibilities sections:
IRB/IEC (section 3)
Investigators (section 4)
Sponsors (section 5)
FDA requires foreign studies comply with ICH E6
16
International Committee on
Harmonization (ICH, continued)
Ethics also included in other guidance documents as
well
Example, E11: Clinical Investigations of Medicinal Products in
the Pediatric Population
http://www.ich.org/fileadmin/Public_Web_Site/ICH_Products/
Guidelines/Efficacy/E11/Step4/E11_Guideline.pdf
Section 2.6 deals with “Ethical Issues in Pediatric Studies”
17
CIOMS International Ethical Guidelines for
Biomedical Research Involving Human Subjects
CIOMS = Council for International Organizations
of Medical Sciences
Collaboration with WHO
Document produced by panel of international
experts in bioethics
http://www.cioms.ch/publications/layout_guide2002.pdf
First issued in 1993
Revised in 2002
21 comprehensive guidelines
CIOMS International Ethical Guidelines for
Biomedical Research Involving Human Subjects 2
Document produced by panel of international
experts in bioethics (continued)
Longer than Declaration of Helsinki
Addressed vulnerable groups 10+ years before DoH
Specifically addresses research involving children (DoH still
does not)
Sampling of Various Countries Ethics
Regulations, Guidelines, Codes, etc.
Council of Europe Guide for Research Ethics
Committee Members:
http://www.coe.int/t/dg3/healthbioethic/source/INF(2011)_e
n.pdf
Indian Council of Medical Research Ethical
Guidelines for Biomedical Research on Human
Participants:
http://icmr.nic.in/ethical_guidelines.pdf
Nigerian National Code of Health Research Ethics:
http://www.nhrec.net/nhrec/National_Code_for_Health_Res
earch_Ethics_v2.0.pdf
Global Challenges
President’s Commission for the Study of Bioethics
Issues (PCSBI):  
www.bioethics.gov
“Rules, standards, and practices vary greatly around
the globe”…(but)…
Almost all international codes and national laws and
regulations…seem to promote the basic principles of:
Respect for persons
Beneficence
Justice
21
PCSBI: Research Across Borders, 2011
Global Challenges (continued)
Almost all international codes and national laws and
regulations…agree specifically about certain
fundamental requirements, such as:
Minimizing risk
Obtaining informed consent
Requiring independent review of research.
22
PCSBI: Research Across Borders, 2011
Respect for Persons (Autonomy)
(USA)
Beneficence &
Non-maleficence
(Germany)
Justice
(India or China)
US Regulations Protecting Human Subjects
Involved in Research
Regulations developed based on recommendations
of the National Commission for the Protection of
Human Subjects of Biomedical and Behavioral
Research (“THE” National Commission, est. 1974)
Established as a result of Tuskegee syphilis study disclosures
OHRP regulations (perspective of agencies funding
human subjects research): 45CFR46
FDA regulations (perspective of agency regulating
drug and device development research involving
human subjects): 21CFR50
Often referred to as “The Common Rule”
US Regulations Protecting Human Subjects
Involved in Research (continued)
“Common Rule” regulations govern:
Composition, functioning, roles and responsibilities of
institutional review boards (IRBs)
Informed consent (and assent)
There is a proposal to add investigator responsibilities (see
later slides)
IRBs and informed consent are the primary tools for
protecting human subjects
Important to recognize these are not the only tools (e.g. data
safety monitoring boards, DSMBs, and FDA’s GCP regulations
regarding responsibilities of investigators and sponsors)
US Regulations Protecting Human Subjects
Involved in Research (continued 2)
45CFR46 (OHRP) Subparts
Subpart A:  Basic HHS Policy for Protection of Human
Research Subjects
Subpart B:  Additional Protections for Pregnant Women,
Human Fetuses and Neonates Involved in Research
Subpart C:  Additional Protections Pertaining to Biomedical
and Behavioral Research Involving Prisoners as Subjects
Subpart D:  Additional Protections for Children Involved as
Subjects in Research
Subpart E:  Registration of Institutional Review Boards
US Regulations Protecting Human Subjects
Involved in Research (continued 3)
21CFR50 (FDA) Subparts
Subpart A:  General Provisions
Subpart B:  Informed Consent of Human Subjects
Subpart C:  Reserved
Subpart D:  Additional Safeguards for Children in Clinical
Investigations
Subpart E:  Does not exist
Other FDA regulations cover registration of IRBs,
good clinical practices, data safety monitoring
boards, etc.
US Regulations: 45CFR46 (OHRP) and
21CFR50 (FDA), subpart D – Re: Children
46.404/50.51 Clinical investigations not involving
greater than minimal risk
46.405/50.52 Clinical investigations involving
greater than minimal risk but presenting the
prospect of direct benefit to individual subjects
46.406/50.53 Clinical investigations involving
greater than minimal risk and no prospect of direct
benefit to individual subjects, but likely to yield
generalizable knowledge about the subjects'
disorder or condition.  The risk represents a minor
increase over minimal risk
US Regulations: 45CFR46 (OHRP) and
21CFR50 (FDA), subpart D (continued)
46.407/50.54 Clinical investigations not otherwise
approvable that present an opportunity to
understand, prevent, or alleviate a serious problem
affecting the health or welfare of children
46.408/50.55 Requirements for permission by
parents or guardians and for assent by children.
46.409/50.56 Wards
What is “classic” component analysis?
What is “classic” component analysis?
A clinical investigation may include more than one
intervention or procedure.
Each intervention or procedure must be evaluated
separately to determine whether it does or does not hold
out the prospect of direct benefit to the enrolled child.
This “classic” approach is consistent with the recommendations of
the National Commission (1978) and the resulting regulations.
Interventions or procedures that hold out the prospect of
direct benefit should be considered under 21 CFR 50.52.
Interventions or procedures that 
do not
 hold out the
prospect of direct benefit should be considered under 21
CFR 50.51 or 50.53 (but not 50.52).
30
Investigator Responsibilities
FDA already addresses in GCP regulations
SACHRP proposed in March, 2013 that OHRP
regulations also address:
http://www.hhs.gov/ohrp/sachrp/commsec/attachmentc-
sec.letter19.pdf
Not official yet, requires a notice of proposed rule
making and public comment period
New 46.104 Responsibilities of Investigators.
13 requirements (e.g., ensuring staff qualifications and training,
IRB review, obtaining informed consent, etc.)
New 46.105 Qualification Standards for Investigators.
2 requirements (e.g., education, training and experience)
Investigator Responsibilities (continued)
SACHRP proposed in March, 2013 that OHRP
regulations also address (continued):
http://www.hhs.gov/ohrp/sachrp/commsec/attachmentc-
sec.letter19.pdf
New 46.106 Investigator Records, Reports and
Documentation.
5 requirements (e.g., how long to retain records)
Overview - Conclusion
Short history for context
The Belmont Report and basic principles
Other research ethics sources
US regulations for the protection of human subjects
Subpart D: Children
Other subparts
Investigator responsibilities
Resources (after question slide)
undefined
ALLENAJ@LILLY.COM
Questions?
OHRP Resources
These resources apply to all Federal departments
and agencies that follow the “Common Rule”
OHRP regulations page:
http://www.hhs.gov/ohrp/humansubjects/index.html
OHRP policy and guidance page:
http://www.hhs.gov/ohrp/policy/index.html
OHRP vulnerable populations page (includes
children):
http://www.hhs.gov/ohrp/policy/populations/index.html
FDA Resources
FDA Clinical Trials and Human Subject Protection
Page:
http://www.fda.gov/ScienceResearch/SpecialTopics/Running
ClinicalTrials/default.htm
FDA protection of human subjects and GCP
regulations page:
http://www.fda.gov/ScienceResearch/SpecialTopics/Running
ClinicalTrials/ucm155713.htm#FDARegulations
FDA pediatrics page:
http://www.fda.gov/scienceresearch/specialtopics/pediatricth
erapeuticsresearch/default.htm
CITI Training
Collaborative Institutional Training Initiative (CITI)
Run out of Univ. of Miami
Research ethics training courses
Used by many institutions and IRBs in the US and
internationally
CME available
https://www.citiprogram.org/
PRIM&R
Public Responsibility In Medicine & Research
(PRIM&R)
Professional organization composed of investigators,
research staff, IRB members, human research
protection professionals, others
Promotes highest ethical standards in research
Holds regional and national training conferences
International outreach programs
http://www.primr.org/
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This presentation provides an introduction to research ethics in child psychiatry, emphasizing the importance of ethical considerations in conducting studies involving children. It highlights key ethical principles, historical events shaping research ethics, and examples of past unethical practices. The content covers disclosure of conflicts of interest, responsible investigator conduct, and regulatory frameworks for protecting human subjects in research.

  • Research Ethics
  • Child Psychiatry
  • Historical Perspectives
  • Ethical Principles
  • Investigator Conduct

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  1. BEFORE YOU START YOUR STUDY: INTRODUCTION TO RESEARCH ETHICS IN CHILD PSYCHIATRY

  2. Disclosures of Potential Conflicts Source Research Funding Advisor/ Consultant Employee Books, Intellectual Property In-kind Services (example, travel) Stock or Equity Honorarium or expenses for this presentatio n or meeting Speakers Bureau Lilly X X X SACHRP X (SGE) X

  3. Disclosure No medications will be discussed during this presentation.

  4. Disclaimer The opinions expressed are those of the presenter and in no way reflect an official opinion of Eli Lilly and Company.

  5. Overview Short history for context The Belmont Report and basic principles Other research ethics sources US regulations for the protection of human subjects Subpart D: Children Other subparts Investigator responsibilities Resources

  6. Partial History of Shame 1940s: Nazi medical experiments Occurred in spite of pre-Nazi German laws Resulted in the US drafted Nuremberg Code 1966: Henry Beecher s NEJM article identifying 22 instances of published human subject research involving unethical practices Willowbrook State School study exposing severely mentally disabled children and adolescents to hepatitis virus 1972: 40 year Tuskegee syphilis study revealed

  7. Partial History of Shame (continued) Sept. 16, 1999: Jesse Gelsinger, an 18 year old healthy volunteer, dies in gene therapy experiment at U. Penn Inadequate preclinical research in advance Lead researcher had financial ties to gene therapy company that were not disclosed to study subjects Study team violated approved protocol procedures intended to protect subjects

  8. SUPPORT Trial IRB reviewed and approved double-blind, randomized trial involving pre-term infants Investigating outcomes (including death and blindness) of different levels of oxygen saturation The two oxygen saturation levels were at the extremes of the range normally used in practice at the time Controversy erupted over whether the informed consent document adequately described the risk of the trial, including the possibility of death and blindness

  9. SUPPORT Trial (continued) August 28, 2013 Federal hearing involving NIH, FDA and OHRP Resource page: http://www.hhs.gov/ohrp/newsroom/rfc/Public%20Meeting %20August%2028,%202013/aug28public.html Presentations: https://www.youtube.com/playlist?list=PLrl7E8KABz1Gc_ndt 9grGg8O_jE5G1RNC&feature=edit_ok Two parent presentations: https://www.youtube.com/watch?v=n1USAH0PMu0&list=PLrl 7E8KABz1Gc_ndt9grGg8O_jE5G1RNC&index=22 https://www.youtube.com/watch?v=mzLubIgWGP8&list=PLrl7 E8KABz1Gc_ndt9grGg8O_jE5G1RNC&index=23

  10. SUPPORT Trial (continued 2) August 28, 2013 Federal hearing involving NIH, FDA and OHRP Presentations (continued): https://www.youtube.com/playlist?list=PLrl7E8KABz1Gc_ndt 9grGg8O_jE5G1RNC&feature=edit_ok Neonatologist and grand parent presentation: https://www.youtube.com/watch?v=SmWJnOp1QaU&list=PLrl7E 8KABz1Gc_ndt9grGg8O_jE5G1RNC&index=10 Nice summary presentation: https://www.youtube.com/watch?v=1Hunhqfz8C4&list=PLrl7E8 KABz1Gc_ndt9grGg8O_jE5G1RNC&index=28

  11. Belmont Report Product of National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research (est. 1974) Response of Congress to the Tuskegee revelations Discussions by commission members turned into report by commission staff Outgrowth of 4 day meeting at Smithsonian Institution s Belmont Conference Center in February, 1976

  12. Belmont Report 2 Final version published: April 18, 1979 Statement of basic ethical principles and guidelines that should assist in resolving the ethical problems that surround the conduct of research with human subjects http://www.hhs.gov/ohrp/humansubjects/guidance /belmont.html

  13. Belmont Report TOC Boundaries between practice and research Basic ethical principles Respect for persons Beneficence (implicitly includes nonmaleficence) Justice Applications Informed consent Assessment of risk and benefits Selection of subjects

  14. Declaration of Helsinki Product of the assembly of the World Medical Association (WMA) Triggered by Nazi experiments Produced by medical organization (physicians) First adopted in 1964 Amended 6 7 times (most recently in 2008 October, 2013) and clarifying notes added twice Has been a source of controversy at times in a number of areas http://www.wma.net/en/30publications/10policies/ b3/

  15. Declaration of Helsinki (continued) 2013 version reorganized as 37 statements in 12 sections Preamble General principles Risks, burdens and benefits Vulnerable groups and individuals Scientific requirements and research protocols Research ethics committees Privacy and confidentiality Informed consent Use of placebo Post-trial provisions Research registration and publication and dissemination Unproven interventions in clinical practice

  16. International Committee on Harmonization (ICH) Guidance documents are products of agreements between FDA, EMA, PMDA, PhRMA, EFPIA, JPMA Biopharmaceutical oriented guidance ICH E6 covers Good Clinical Practices (GCPs) http://www.ich.org/fileadmin/Public_Web_Site/ICH_Produc ts/Guidelines/Efficacy/E6_R1/Step4/E6_R1__Guideline.pdf Includes ethics and protection of human subjects Responsibilities sections: IRB/IEC (section 3) Investigators (section 4) Sponsors (section 5) FDA requires foreign studies comply with ICH E6 16

  17. International Committee on Harmonization (ICH, continued) Ethics also included in other guidance documents as well Example, E11: Clinical Investigations of Medicinal Products in the Pediatric Population http://www.ich.org/fileadmin/Public_Web_Site/ICH_Products/ Guidelines/Efficacy/E11/Step4/E11_Guideline.pdf Section 2.6 deals with Ethical Issues in Pediatric Studies 17

  18. CIOMS International Ethical Guidelines for Biomedical Research Involving Human Subjects CIOMS = Council for International Organizations of Medical Sciences Collaboration with WHO Document produced by panel of international experts in bioethics http://www.cioms.ch/publications/layout_guide2002.pdf First issued in 1993 Revised in 2002 21 comprehensive guidelines

  19. CIOMS International Ethical Guidelines for Biomedical Research Involving Human Subjects 2 Document produced by panel of international experts in bioethics (continued) Longer than Declaration of Helsinki Addressed vulnerable groups 10+ years before DoH Specifically addresses research involving children (DoH still does not)

  20. Sampling of Various Countries Ethics Regulations, Guidelines, Codes, etc. Council of Europe Guide for Research Ethics Committee Members: http://www.coe.int/t/dg3/healthbioethic/source/INF(2011)_e n.pdf Indian Council of Medical Research Ethical Guidelines for Biomedical Research on Human Participants: http://icmr.nic.in/ethical_guidelines.pdf Nigerian National Code of Health Research Ethics: http://www.nhrec.net/nhrec/National_Code_for_Health_Res earch_Ethics_v2.0.pdf

  21. Global Challenges President s Commission for the Study of Bioethics Issues (PCSBI): www.bioethics.gov Rules, standards, and practices vary greatly around the globe (but) Almost all international codes and national laws and regulations seem to promote the basic principles of: Respect for persons Beneficence Justice PCSBI: Research Across Borders, 2011 21

  22. Global Challenges (continued) Almost all international codes and national laws and regulations agree specifically about certain fundamental requirements, such as: Minimizing risk Obtaining informed consent Requiring independent review of research. PCSBI: Research Across Borders, 2011 22

  23. Equal Principles, But Variable Emphasis Based On History, Philosophy, Politics, Culture, etc.? Respect for Persons (Autonomy) (USA) Beneficence & Non-maleficence (Germany) Justice (India or China)

  24. US Regulations Protecting Human Subjects Involved in Research Regulations developed based on recommendations of the National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research ( THE National Commission, est. 1974) Established as a result of Tuskegee syphilis study disclosures OHRP regulations (perspective of agencies funding human subjects research): 45CFR46 FDA regulations (perspective of agency regulating drug and device development research involving human subjects): 21CFR50 Often referred to as The Common Rule

  25. US Regulations Protecting Human Subjects Involved in Research (continued) Common Rule regulations govern: Composition, functioning, roles and responsibilities of institutional review boards (IRBs) Informed consent (and assent) There is a proposal to add investigator responsibilities (see later slides) IRBs and informed consent are the primary tools for protecting human subjects Important to recognize these are not the only tools (e.g. data safety monitoring boards, DSMBs, and FDA s GCP regulations regarding responsibilities of investigators and sponsors)

  26. US Regulations Protecting Human Subjects Involved in Research (continued 2) 45CFR46 (OHRP) Subparts Subpart A: Basic HHS Policy for Protection of Human Research Subjects Subpart B: Additional Protections for Pregnant Women, Human Fetuses and Neonates Involved in Research Subpart C: Additional Protections Pertaining to Biomedical and Behavioral Research Involving Prisoners as Subjects Subpart D: Additional Protections for Children Involved as Subjects in Research Subpart E: Registration of Institutional Review Boards

  27. US Regulations Protecting Human Subjects Involved in Research (continued 3) 21CFR50 (FDA) Subparts Subpart A: General Provisions Subpart B: Informed Consent of Human Subjects Subpart C: Reserved Subpart D: Additional Safeguards for Children in Clinical Investigations Subpart E: Does not exist Other FDA regulations cover registration of IRBs, good clinical practices, data safety monitoring boards, etc.

  28. US Regulations: 45CFR46 (OHRP) and 21CFR50 (FDA), subpart D Re: Children 46.404/50.51 Clinical investigations not involving greater than minimal risk 46.405/50.52 Clinical investigations involving greater than minimal risk but presenting the prospect of direct benefit to individual subjects 46.406/50.53 Clinical investigations involving greater than minimal risk and no prospect of direct benefit to individual subjects, but likely to yield generalizable knowledge about the subjects' disorder or condition. The risk represents a minor increase over minimal risk

  29. US Regulations: 45CFR46 (OHRP) and 21CFR50 (FDA), subpart D (continued) 46.407/50.54 Clinical investigations not otherwise approvable that present an opportunity to understand, prevent, or alleviate a serious problem affecting the health or welfare of children 46.408/50.55 Requirements for permission by parents or guardians and for assent by children. 46.409/50.56 Wards

  30. What is classic component analysis? A clinical investigation may include more than one intervention or procedure. Each intervention or procedure must be evaluated separately to determine whether it does or does not hold out the prospect of direct benefit to the enrolled child. This classic approach is consistent with the recommendations of the National Commission (1978) and the resulting regulations. Interventions or procedures that hold out the prospect of direct benefit should be considered under 21 CFR 50.52. Interventions or procedures that do not hold out the prospect of direct benefit should be considered under 21 CFR 50.51 or 50.53 (but not 50.52). 30

  31. Investigator Responsibilities FDA already addresses in GCP regulations SACHRP proposed in March, 2013 that OHRP regulations also address: http://www.hhs.gov/ohrp/sachrp/commsec/attachmentc- sec.letter19.pdf Not official yet, requires a notice of proposed rule making and public comment period New 46.104 Responsibilities of Investigators. 13 requirements (e.g., ensuring staff qualifications and training, IRB review, obtaining informed consent, etc.) New 46.105 Qualification Standards for Investigators. 2 requirements (e.g., education, training and experience)

  32. Investigator Responsibilities (continued) SACHRP proposed in March, 2013 that OHRP regulations also address (continued): http://www.hhs.gov/ohrp/sachrp/commsec/attachmentc- sec.letter19.pdf New 46.106 Investigator Records, Reports and Documentation. 5 requirements (e.g., how long to retain records)

  33. Overview - Conclusion Short history for context The Belmont Report and basic principles Other research ethics sources US regulations for the protection of human subjects Subpart D: Children Other subparts Investigator responsibilities Resources (after question slide)

  34. Questions? ALLENAJ@LILLY.COM

  35. OHRP Resources These resources apply to all Federal departments and agencies that follow the Common Rule OHRP regulations page: http://www.hhs.gov/ohrp/humansubjects/index.html OHRP policy and guidance page: http://www.hhs.gov/ohrp/policy/index.html OHRP vulnerable populations page (includes children): http://www.hhs.gov/ohrp/policy/populations/index.html

  36. FDA Resources FDA Clinical Trials and Human Subject Protection Page: http://www.fda.gov/ScienceResearch/SpecialTopics/Running ClinicalTrials/default.htm FDA protection of human subjects and GCP regulations page: http://www.fda.gov/ScienceResearch/SpecialTopics/Running ClinicalTrials/ucm155713.htm#FDARegulations FDA pediatrics page: http://www.fda.gov/scienceresearch/specialtopics/pediatricth erapeuticsresearch/default.htm

  37. CITI Training Collaborative Institutional Training Initiative (CITI) Run out of Univ. of Miami Research ethics training courses Used by many institutions and IRBs in the US and internationally CME available https://www.citiprogram.org/

  38. PRIM&R Public Responsibility In Medicine & Research (PRIM&R) Professional organization composed of investigators, research staff, IRB members, human research protection professionals, others Promotes highest ethical standards in research Holds regional and national training conferences International outreach programs http://www.primr.org/

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