Insert lead inspector’s competent authority logo / emblem GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site On behalf of the European Medicines Agency Insert name of the competent authority of LI Inspector in charge of this inspection report Name: [Insert details] Position: [Insert details] Address: [Insert details] Tel: [Insert details] Email: [Insert details] [Insert EMA inspection reference number] [Insert CA inspection reference number] [Insert site name, identification or abbreviation and type] Final Inspection report: [Insert dd.mmm.yyyy] Responses to final inspection report: [Dated as per Addendum 1 dd.mmm.yyyy] Evaluation of inspection responses: [Dated as per Addendum 2 dd.mmm.yyyy] 30 Churchill Place ● Canary Wharf ● London E14 5EU ● United Kingdom Telephone +44 (0)20 3660 6000 Facsimile +44 (0)20 3660 5555 E-mail info@ema.europa.eu Website www.ema.europa.eu An agency of the European Union © European Medicines Agency, 2016. Reproduction is authorised provided the source is acknowledged. This inspection report may only be reproduced in its entirely and must not be circulated or published without the European Medicines Agency’s consent, nor may any additions be made to the report. GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 2/20 Table of contents 1. Administrative information ...................................................................... 5 2. Background and general information....................................................... 6 2.1. Reason and cause for the inspection ....................................................................... 6 2.2. Reference texts .................................................................................................... 6 2.3. Grading of findings ............................................................................................... 6 2.4. List of persons involved in the trial and contacted during the inspection ...................... 7 3. Personnel, facilities and equipment ......................................................... 7 4. Administrative aspects of the trial ........................................................... 8 4.1. Application / notification to competent authority....................................................... 8 4.2. Contacts with the independent ethics committee (IEC) .............................................. 8 4.3. Contacts with other committees, any other validation or authorisation ........................ 9 4.4. Contract(s), agreement(s) ..................................................................................... 9 5. Trial documents ....................................................................................... 9 6. Conduct of the trial ................................................................................ 10 7. Documentation and reporting of efficacy data ....................................... 11 8. Documentation and reporting of safety data ......................................... 11 9. Investigational Medicinal Product(s) (IMPs) ......................................... 11 10. Data handling ...................................................................................... 12 11. Laboratories, technical departments ................................................... 12 12. Monitoring and auditing ...................................................................... 13 13. Summary, discussion and conclusions ................................................. 13 14. Date and signature(s) of lead and other inspectors, experts if applicable .................................................................................................................. 15 15. Appendices .......................................................................................... 16 15.1. Summary of activities inspected ......................................................................... 16 15.2. Trial documentation and approvals ..................................................................... 18 GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 3/20 Abbreviations [Review and amend list as necessary] ADR adverse drug reaction AE adverse event CA competent authority CAPA corrective action preventive action CHMP Committee for Medicinal Products for Human Use CRA clinical research associate (e)CRF (electronic) case report form CRO contract research organisation CTM clinical trial manager CSR clinical study report IB investigator’s brochure ICF informed consent form ICH International Conference on Harmonisation (I)EC (Independent) Ethics Committee IMP investigational medicinal product IR inspection report IVRS interactive voice response system IWRS interactive web response system MAA marketing authorisation application MVR monitoring visit report PIS patient information sheet QA quality assurance RA regulatory authority SAE serious adverse event SAR serious adverse reaction SOP standard operating procedure SUSAR suspected unexpected serious adverse reaction GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 4/20 1. Administrative information Investigational Medicinal Product(s) Product(s): [name; active ingredient (INN); batch number] Application EMA reference number: [insert] Name and full address of the applicant: [insert] Clinical trial EudraCT number [insert] Sponsor [insert name and full address] Trial protocol code [insert] Trial protocol title [insert] Number of investigator sites [insert total number of sites in trial] Number of subjects [insert total number of trial subjects recruited] Site details Principal investigator [insert] Address [insert] Key data from site inspected Number of subjects at this site [insert] First patient first visit [insert] Last patient last visit [insert] Screened [insert] Randomised [insert] Withdrawals/drop outs [insert] Clinical trial report [insert] Dates of inspection [insert] Inspection Team Authority Country Reporting Inspector (RI) [insert] [insert] Lead Inspector (LI) [insert] [insert] Inspector (I) [insert] [insert] Expert (E) [insert] [insert] Observer (P) [insert] [insert] GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 5/20 2. Background and general information 2.1. Reason and cause for the inspection Text [Include short paragraph describing the reason and scope of the inspection, but not a copy of the notification letter with the list of items] 2.2. Reference texts [Review the following list and amend as necessary and consider the versions valid during the conduct of clinical trial] Directive 2001/20/EC of the European Parliament and of the Council of 4 April 2001 Directive 2001/83/EC as amended by Directive 2003/63/EC of 25 June 2003 Directive 2005/28/EC of the European Commission of 8 April 2005 CPMP/ICH/135/95 ‘Note for Guidance on Good Clinical Practice’, July 1996 World Medical Association Declaration of Helsinki, in the version, [Insert applicable respective Version] GMP, Annex 13 Manufacture of investigational medicinal products, [insert applicable respective Version] [Insert any Local law(s) and regulations] 2.3. Grading of findings Critical (CR) Definition Conditions, practices or processes that adversely affect the rights, safety or wellbeing of the subjects and/or the quality and integrity of data. Critical observations are considered totally unacceptable. Possible consequences Rejection of data and/or legal action required. Remark Observation classified as critical may include a pattern of deviations classified as major, bad quality of the data and/or absence of source documents. Manipulation and intentional misrepresentation of data belong to this group. Major (MA) Definition Conditions, practices or processes that might adversely affect the rights, safety or wellbeing of the subjects and/or the quality and integrity of data. Major observations are serious deficiencies and are direct violations of GCP principles. GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 6/20 Major (MA) Possible consequences Data may required. be rejected and/or legal action Remark Observations classified as major, may include a pattern of deviations and/or numerous minor observations. Minor (MI) Definition Conditions, practices or processes that would not be expected to adversely affect the rights, safety or wellbeing of the subjects and/or the quality and integrity of data. Possible consequences Observations classified as minor, indicate the need for improvement of conditions, practices and processes. Remark Many minor observations might indicate a bad quality and the sum might be equal to a major finding with its consequences. Comments: The observations might lead to suggestions on Definition how to improve quality or reduce the potential for a deviation to occur in the future. 2.4. List of persons involved in the trial and contacted during the inspection Text [For investigator trials: Include a section listing the investigator(s), nurses and other key personnel involved in the trial and interviewed, as well as sponsor personnel available at inspection (for example QA personnel, CRAs); section may be replaced by a scanned copy of the list of attendees with below mentioned details completed during the inspection put in the appendices] For sponsor trials: Include a section listing the key personnel of sponsor/CRO involved in the trial and interviewed at inspection (for example study director, medical monitor, study manager, lead CRA, CRA(s), data manager, statisticians, medical writer, responsible persons for IMP, drug safety, QA personnel); section may be replaced by a scanned copy of the list of attendees with below mentioned details completed during the inspection put in the appendices. Full name Job title Role in the trial inspected 3. Personnel, facilities and equipment Text Describe/list observations related to: Equipment used for the characteristics of the trial inspected. GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 7/20 Characteristics of facilities used for the safe storage of IMP, samples etc. and for storage and archiving of the clinical trial documents. If applicable: Availability of the electronic equipment regarding clinical trials (planning, issues related to validation of computerized systems used for the trial). (Availability of medical equipment and/or emergency equipment in the case of phase I facilities). Security maintenance (rescue plan). Describe briefly the organisation at the inspected site, contracting out of trial-related duties, personnel involved in clinical research at the inspected site, qualification of personnel involved. Describe/list findings related to the qualification(education, experience and training) of the personnel. FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, Investigator or Sponsor and Investigator Comment Text Details 4. Administrative aspects of the trial Text The Table in Appendix section 15.2 may be completed during or following the inspection to record information necessary to support this section – it is OPTIONAL. It is provided as some reports contain tables in this and the following section and therefore some inspectors may wish to continue to do this. Describe/list observations related to: 4.1. Application / notification to competent authority Text FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, investigator or sponsor and investigator Comment Text Details 4.2. Contacts with the independent ethics committee (IEC) Text GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 8/20 FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, investigator or sponsor and investigator Comment Text Details 4.3. Contacts with other committees, any other validation or authorisation Text Describe/list observations related to: Protection of individuals with regard to the processing of personal data or agreement for genetic samples, or cell therapy research… FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, investigator or sponsor and investigator Comment Text Details 4.4. Contract(s), agreement(s) Text Describe/list observations related to contracts: e.g. sponsor/CRO with investigator, hospital, university, etc.,… FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, investigator or sponsor and investigator Comment Text Details 5. Trial documents Text GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 9/20 The Table in Appendix 15.2 may be completed during or following the inspection to record information necessary to support this section – it is OPTIONAL. It is provided as some reports contain tables in this and the previous section and therefore some inspectors may wish to continue to do this. Describe/list observations related to: Protocol, protocol amendments, investigator’s brochure, CRF, diaries/questionnaires, , versions, receipt of documents at inspected site, etc. Describe/list observations related to: signatures/delegation list, information given to trial subject (ICF/other), insurance, PIS/Consent form, subject screening log, subject enrolment log, agreements, randomisation/IVRS/IWRS/breaking code system, laboratories/technical departments, correspondence. Availability of applicable essential trial documents Findings in responsibility of the sponsor, CRO respectively, related to trial documents to be listed here as well. FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, investigator or sponsor and investigator Comment Text Details 6. Conduct of the trial Text For investigator inspections, describe briefly: - Set up of the trial, distribution of duties and functions, - subject recruitment, screening, informed consent process, confidentiality of the subjects, - inclusion, examinations, assessments, - follow up. Describe/list observations related to these aspects. FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, investigator or sponsor and investigator GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 10/20 Comment Text Details 7. Documentation and reporting of efficacy data Text Describe/list observations made regarding the source documents in particular concerning: the eligibility criteria (selection criteria compliance), treatment (dose, regime, incl. concomitant medication), source data verification and protocol compliance. Describe issues regarding the consistency of data (e.g. when comparing data listings from the CSR with source documents). (Please note: observations made concerning the procedures, i.e. the informed consent procedure, the screening process, etc. should be described in Section 6). Findings in responsibility of the sponsor, CRO respectively, related to data management, data handling or reporting to be described/ listed here as well. FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, Investigator or Sponsor and Investigator Comment Text Details 8. Documentation and reporting of safety data Text For investigator site inspections, describe/list observations made in relation to recording, assessment and reporting of AE/ADR/SAE/SAR/SUSAR to sponsor/IEC/ competent authorities/others. Availability of safety information (line listings, Dear Dr. Safety letters, Investigator Brochure, etc.). Urgent Safety Measures compliance, if any. FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, investigator or sponsor and investigator Comment Text Details 9. Investigational Medicinal Product(s) (IMPs) Text GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 11/20 Describe/list observations made regarding: receipt and storage, temperature records control (if +2+8°C or - 20 °C) dispensing, administration to trial subjects documentation, accountability of the pharmacy/investigators site, compliance, returns from clinical site /trial subjects, destruction/recovery by the sponsor, allocation of treatment, randomisation, decoding/IVR/IWRS system, documentation on decoding, manufacturing authorisation, labelling/packaging/reconstitution, extension/expiry date, relabeling if applicable. FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, investigator or sponsor and investigator Comment Text Details 10. Data handling Text Describe/list observations made regarding data management, statistics and reporting of data, as appropriate FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, investigator or sponsor and investigator Comment Text Details 11. Laboratories, technical departments Text Describe/list observations related to certification and accreditation (see also section 4), external/internal quality control programme, analytical methods used, reference values/data, labelling, transportation and storage of samples, results reporting and communication, documentation and archiving, validation. FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 12/20 Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, investigator or sponsor and investigator Comment Text Details 12. Monitoring and auditing Text Summarise monitoring visits and procedures used, actions taken by the monitor, escalation/follow up by monitor, monitor visit log and management of non-compliance. Describe/list observations related to monitoring and monitoring follow up and whether there was an impact on the data quality. Describe/list observations related to auditing – confirm if site has been audited and when. FINDING FORMATS (numbering system – x = CR1, MA1, MI1…CR2, MA2, MI2 etc): Text Details of finding and evidence Text Reference to requirement for which it is non-compliant X Text Grading – Critical/Major/Minor Text Details of any specific CAPA requests (in addition to covering letter (see SOP INS/4) Text Responsibility – Sponsor, investigator or sponsor and investigator Comment Text Details 13. Summary, discussion and conclusions Summary and Discussion Text Provide the scope of the inspection and describe what was actually inspected (very short). Quantitative result of the inspection: number and grading of the findings (e.g. X critical findings, Y major findings and Z minor findings) were observed. Summary and evaluation of critical and major findings. Findings with impact on the trial and the marketing authorisation application should be separately presented from findings with a systematic nature or which are process-related. Refer to “Points to consider on good-clinical-practice inspection findings and the benefit-risk balance” where appropriate. Ethical issues to be listed separately (e.g. vulnerable population, trial conducted in a third country without local IEC and/or CA), if any. Overall conclusion GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 13/20 Text Statement on GCP compliance and whether the trial was conducted in accordance with internationally accepted ethical standards. Statement on validity/reliability of data (specify trial data which are affected by findings, as appropriate). Describe impact of findings on overall trial data, as appropriate. Important – this section will be completed prior to receipt of any responses from the sponsor/applicant/investigator. If conclusions cannot be drawn until then, then state this clearly. The evaluation and conclusions can be then addressed in Addendum 2 to the reporte once the responses have been evaluated. Where this is a single site inspection and the IR serves as the IIR, then Addendum 2 should follow the requirements of the IIR and be written with section headings as follows: Conclusions from inspection findings Assessment of the relevance of the findings for the full trial [Discuss if the findings are process related and not site specific, and thus relevant for the overall clinical trial or clinical development programme.] Quality of the data and GCP compliance [Discuss the implication of any major or critical findings on data quality {cross reference to relevant section or the IRs} and compliance with the GCP principles. This section may need to be specific on which data were affected and to what extent. The section may need to discuss the results of any responses by the inspectee/ sponsor that are re analyses (extrapolations/sensitivity)] Recommendation for the acceptability of the clinical trial data [Provide a conclusion on whether the quality of the data inspected as a whole or in parts may be used for the evaluation by the assessors regarding acceptance/non-acceptance of the trial data.] Recommendations for follow up actions (GCP Systems) [Provide a conclusion and recommendation for any further actions regarding CAPA and re-inspection, for example, must inspect further MAA applications involving inspected organisations, in respect of any GCP system findings] GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 14/20 14. Date and signature(s) of lead and other inspectors, experts if applicable Date Print name Function Signature Date Print name Function Signature Date Print name Function Signature GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 15/20 15. Appendices 15.1. Summary of activities inspected (Please enter, which areas where inspected during the inspection, if necessary enter details or specify). Extent* Yes Extent* Partial Extent* Findings No (Y/N) Details (essential for partial/No) Personnel involved in trial Protocol and GCP training & qualifications Interviews with key personnel Delegation of duties & specimen signatures Facility review Clinical areas Laboratories Technical departments Pharmacy Technical equipment (calibration and maintenance etc.) Archiving arrangements and facilities for archiving Investigator TMF review Contract(s) & agreement(s), Institutional correspondence/approval Protocol & amendments IEC/IRB opinions/communication Regulatory approval/communication IB PIS/ICF Insurance Subject screening & enrolment log Contacts with other committees, other validation(s) or authorisation(s) Informed consent Process and completed documentation Conduct of the trial Protocol & GCP compliance Documentation and reporting of data GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 16/20 Extent* Extent* Extent* Yes Partial No Findings (Y/N) Details (essential for partial/No) (Safety data) SDV performed for pat. nos.: Documentation and reporting of data (Efficacy data) SDV performed for pat. nos.: Documentation and reporting of data (CRF design, functionality, independent copy on site etc.) Pharmacy file review/investigationa l medicinal product(s), administration, compliance, handling randomisation/IVRS, breaking code system Monitoring and auditing Other (state) * Yes – this means an assessment of this area was undertaken that was considered sufficient by the inspector to make an assessment of compliance and identify any issues. Partial – this means that a limited assessment of the area was undertaken – for example time restrictions prevented the full assessment – there may be undetected issues. No – this area was not looked at. This could be because it wasn’t necessary to address the scope of the inspection or answer any concerns/questions in the inspection request. A comment should be provided, this could be because it was not applicable – for example there was no laboratory involved in the trial, no IVRS system, etc. GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 17/20 15.2. Trial documentation and approvals (OPTIONAL TO COMPLETE) APPROVAL DATES SUBMISSION Substantial IEC/ Sponsor Investigator Any other Protocol Subject Other INITIATION/ IRB approval approval (if required version information and documents IMPLEMENTATION substantial (if applicable) approvals (NS) applicable) (S) / Non- CA DOCUMENT VERSIONS consent form DATE version /date Initial Date: #2 Date: #3 Date: #4 Date: #5 Date: #6 Date: #7 Date: #8 Date: #9 Date: GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 18/20 Addendum 1: Response from sponsor/applicant/investigator Date responses received by the inspector: insert date DD/MMM/YYYY Attach the document received from the sponsor/applicant/investigator. GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 19/20 Addendum 2: Evaluation by the inspectors of the response This summary should be prepared by the Lead Inspector and signed by all the inspectors. If the IR is to serve as the IIR as it is a single site inspection, then the sections should follow the IIR as outlined in section 13 above. Version: Insert DD/MMM/YYYY Insert text Date Print name Function Signature Date Print name Function Signature GCP INSPECTION REPORT [insert EMA inspection reference number] at investigator site Page 20/20