G. Organisation Responsibilities, Back to the index of the Guidance for the Notification of Serious Breaches of GCP or the Trial Protocol Version 6, 08 Jul 2020, MHRA

Sponsor:

There should be a formal process in place to cover the legislative requirements of serious breach notifications. These should include:

• Receipt and assessment (i.e. assessment of deviations/violations by Sponsor/delegate, isolated/systematic incident, patient(s) harmed or put at risk/data credibility etc.)
• Investigation
• Corrective and preventative action (CAPA)
• Reporting to the MHRA
• Compliance with the 7-day reporting timescale. Lack of systems and failure to report serious breaches may result in findings at GCP Inspections (the grading will depend on the impact of the issue).

Investigator/Institution:

The investigator/institution (for example, vendor, CRO or investigator site) should also have a process in place to identify and notify the sponsor of serious breaches. This may be a formal SOP or detailed in the protocol or study-specific guidance.

Consideration should be given to what actions to take if the Sponsor does not report the breach to the MHRA (due diligence is required – for example, should you continue with the trial? Should you report to the authorities?)

Retention:

Where an organisation decides to retain the documentation will depend on each organisation’s quality systems. However, as a minimum, a copy should be retained in the relevant Trial Master File/s.

Circulation:

Internally: This will depend on who needs to be informed as per the organisations procedures regarding responsibility for the decision, and notification of the serious breach to the MHRA (for example, clinical, regulatory, QA, management etc.)

Externally: This will depend on the nature of the breach and may include other MHRA departments (where legislation may require notifications, for example, CTU, DMRC), regulatory agencies and research ethics committees.

However, it is also important that the breach is circulated/made available to relevant staff for inclusion of relevant information in the clinical study report or publication. Serious breaches relating to investigator sites/laboratories should also be available to those selecting sites for studies, so that an assessment can be made before using noncompliant sites in future studies.

Back to the index of the Guidance for the Notification of Serious Breaches of GCP or the Trial Protocol Version 6, 08 Jul 2020, MHRA, Medicines & Healthcare products Regulatory Agency