At Advarra, we often get questions about exactly what events should be reported to the IRB. We understand that “reportable events” can be tricky: some are addressed specifically in the regulations; some are covered in regulatory guidance documents; and some are left to be defined by individual IRBs’ policies. In this blog, we will take a look at what the regulations do and do not say about IRB reporting requirements and how Advarra has addressed some of the undefined “gray areas.”
In 2009, FDA released a guidance document on adverse event reporting to IRBs, which is intended to “assist the research community in interpreting requirements for submitting reports of unanticipated problems, including certain adverse events reports” to the IRB.
For research conducted under an IND, the guidance states:
- Investigators are required to report promptly “to the sponsor any adverse effect that may reasonably be regarded as caused by, or probably caused by, the drug. If the adverse effect is alarming, the investigator shall report the adverse effect immediately” (21 CFR 312.64[b]).
- Sponsors are specifically required to notify all participating investigators (and FDA) in a written IND safety report of “any adverse experience associated with the use of the drug that is both serious and unexpected” and “any finding from tests in laboratory animals that suggests a significant risk for human subjects” (21 CFR 312.32[c][i][A],[B]).
- And, more generally, sponsors are required to “keep each participating investigator informed of new observations discovered by or reported to the sponsor on the drug, particularly with respect to adverse effects and safe use” (21 CFR 312.55[b]).
- Investigators are required to report promptly “to the IRB… all unanticipated problems involving risks to human subjects or others,” including adverse events that should be considered unanticipated problems (21 CFR 56.108[b], 21 CFR 312.53[c][vii], and 21 CFR 312.66).
So what does this mean in practice?
- Investigators report to the sponsor: Any adverse event that is determined to be caused by (or probably caused by) the drug.
- Sponsors report to investigators and FDA: Any adverse events associated with the study drug that are both serious and unexpected as well as any finding from animal research that suggests a significant risk to human subjects.
- Sponsors should also keep investigators informed of any new observations regarding the drug, especially adverse events and safe use concerns.
- Investigators report to the IRB: All unanticipated problems involving risks to human subjects or others, including adverse events that are unanticipated problems.
The challenge: determining which adverse events should be considered unanticipated problems warranting submission to the IRB. Apart from a few serious, uncommon adverse events, usually considered to be strongly related to drug exposure (e.g., Stevens Johnson syndrome, hepatic injury, anaphylaxis), single/isolated adverse event reports typically do not meet the criteria of an UAP.
FDA states in its guidance Safety Reporting Requirements for INDs and BA/BE Studies that “FDA believes that the sponsor is better positioned than the individual investigator to assess the overall safety of the investigational drug because the sponsor has access to serious adverse event reports from multiple study sites and multiple studies and is able to aggregate and analyze these reports. Moreover, the sponsor is more familiar with the drug’s mechanism of action, class effects, and other information. For these reasons, investigators must immediately report any serious adverse event to the sponsor, whether or not the investigator considers the event to be drug related (21 CFR 312.64[b]).”
What Is an Unanticipated Problem Involving Risks to Human Subjects or Others (UAP)?
An unanticipated problem or UAP, which is only defined in FDA guidance, is:
- Unexpected (in terms of nature, severity, or frequency) given the information provided in research-related documents and the characteristics of the subject population being studied;
- Related or possibly related to participation in the research; and
- Suggests that the research places subjects or others at a greater risk of harm than was previously known or recognized.
This means a SAE that is expected, as identified in the study documentation, but is occurring at greater frequency or severity, as determined by the sponsor’s assessment, should be reported to the IRB as an unanticipated problem. But SAEs that have been determined to be unrelated to the study, or are directly related to the subject population’s disease, should not be submitted to the IRB. And for SAEs where relatedness has not yet been determined and further analysis is required, submission to the IRB should only happen once it has been determined that the SAE was related to the test article.
Per FDA, “[i]t is important to note that some events that would not meet the criteria for reporting in an IND safety report would be considered unanticipated problems involving risk to human subjects (e.g., informed consent or privacy issues, certain adverse events that could not be caused by the investigational drug, such as events that occur prior to test article administration as a result of a washout period or due to a screening procedure).”
SAEs that occur at other sites and are provided to each investigator (like IND safety reports or suspected unexpected serious adverse reactions [SUSARs]) should only be submitted to the IRB following the sponsor’s assessment that the event(s) in fact meet the criteria of an unanticipated problem. For multisite studies, the sponsor will typically report an unanticipated problem on behalf of all sites.
It is important to note that unanticipated problems will have implications for the conduct of the study, such as an update to the protocol (e.g., additional safety monitoring, updates to inclusion/exclusion criteria, etc.), changes to the ICF and/or investigator’s brochure, etc.
The IRB must be notified of a UAP promptly, but no later than 2 weeks or 10 business days from the time of identification.
At Advarra, when SAEs or safety reports that do not meet the UAP criteria are submitted to the IRB, the submitting party will receive acknowledgement of receipt only. The item will not be reviewed by the IRB. When these items are submitted by a sponsor or CRO, Advarra’s default process is to generate an acknowledgement of receipt to all open sites, though sponsors/CROs may opt out of this process.
For Advarra’s specific reporting requirements, consult our IRB Handbook, available in the Reference Materials section of the Advarra CIRBI Platform. Not sure if an event should be reported to the IRB? Contact your Study Coordinator for assistance.