- 18 Apr 2021, 14:52
#4733
ICH GCP and Indian GCP differs on Investigator qualification, SOPs, data analysis, essential documents, monitor responsibilities, drug label and document retention. The differences are detailed below for your references.
Difference Between ICH GCP and Indian GCP
1. Investigator Qualification
ICH – GCP: (4.1.1)
The investigator(s) should be qualified by education, training, experience to assume responsibility for the proper conduct of the trial, should meet all the qualifications specified by the applicable regulatory requirement(s) .
Indian GCP: (3.3.1)
The investigator should be qualified by education, training and experience to assume responsibility for the proper conduct of the study and should have qualifications prescribed by the Medical Council of India (MCI).
2.Investigator and sponsor’s SOPs
ICH – GCP:
Investigator to comply with the protocol (4.5) and leaves the task of monitoring compliance to SOPs to monitors and auditors (5.19.1).
Indian GCP: (3.1.3)
The Sponsor should establish detailed Standard Operating Procedures (SOP’s). The Sponsor and the Investigator(s) should sign a copy of the Protocol and the SOPs or an alternative document to confirm their agreement.
3. Investigators responsibility for data analysis
ICH – GCP: (4.10)
When the trial is completed, the investigator has to provide the Independent Ethics Committee (IEC) with a summary of the outcome of trial.
Indian GCP: (3.3.8)
The completion of the study should be informed by the investigator to the institution, the sponsor and the ethics committee. The investigator should sign and forward the data (CRFs, results and interpretations, analyses and reports, of the study from his / her centre to the sponsor and the ethics committee.
4.Essential Documents
ICH – GCP: (8.2)
Investigator/ Sponsor
Institution
Indian GCP:
(APPENDIX V)
Investigator / Institute
Sponsor
CRO
IEC
5. Monitor Responsibilities
ICH – GCP: (5.18.4)
Communicating deviations from the protocol, SOPs, GCP, and the applicable regulatory requirements to the investigator and taking appropriate action designed to prevent recurrence of the detected deviations.
Indian GCP: (3.2.2)
The monitor should promptly inform the sponsor and the ethics committee in case any unwarranted deviation from the protocol or any transgression of the principles embodied in GCP is noted.
6.Drug Label
Indian GCP: (2.3.1.6)
In the section on protocol, it is mentioned that drug label should include name and contact numbers of investigator and name of institution.
This is not a global practice.
This will lead to practical difficulties in global trials where the labels are uniform with minor changes made if required by local laws and practice.
7.Document Retention
ICH – GCP: (5.18.4)
Essential documents should be retained until at least 2 years after the approval of a marketing application in an ICH region.
Indian GCP: (4.9)
Indian GCP mandates that the sponsor should make arrangements for safe and secure custody of all study related documents and material for a period of three years after the completion of the study or submission of the data to the regulatory authorities whichever is later.
Difference Between ICH GCP and Indian GCP
1. Investigator Qualification
ICH – GCP: (4.1.1)
The investigator(s) should be qualified by education, training, experience to assume responsibility for the proper conduct of the trial, should meet all the qualifications specified by the applicable regulatory requirement(s) .
Indian GCP: (3.3.1)
The investigator should be qualified by education, training and experience to assume responsibility for the proper conduct of the study and should have qualifications prescribed by the Medical Council of India (MCI).
2.Investigator and sponsor’s SOPs
ICH – GCP:
Investigator to comply with the protocol (4.5) and leaves the task of monitoring compliance to SOPs to monitors and auditors (5.19.1).
Indian GCP: (3.1.3)
The Sponsor should establish detailed Standard Operating Procedures (SOP’s). The Sponsor and the Investigator(s) should sign a copy of the Protocol and the SOPs or an alternative document to confirm their agreement.
3. Investigators responsibility for data analysis
ICH – GCP: (4.10)
When the trial is completed, the investigator has to provide the Independent Ethics Committee (IEC) with a summary of the outcome of trial.
Indian GCP: (3.3.8)
The completion of the study should be informed by the investigator to the institution, the sponsor and the ethics committee. The investigator should sign and forward the data (CRFs, results and interpretations, analyses and reports, of the study from his / her centre to the sponsor and the ethics committee.
4.Essential Documents
ICH – GCP: (8.2)
Investigator/ Sponsor
Institution
Indian GCP:
(APPENDIX V)
Investigator / Institute
Sponsor
CRO
IEC
5. Monitor Responsibilities
ICH – GCP: (5.18.4)
Communicating deviations from the protocol, SOPs, GCP, and the applicable regulatory requirements to the investigator and taking appropriate action designed to prevent recurrence of the detected deviations.
Indian GCP: (3.2.2)
The monitor should promptly inform the sponsor and the ethics committee in case any unwarranted deviation from the protocol or any transgression of the principles embodied in GCP is noted.
6.Drug Label
Indian GCP: (2.3.1.6)
In the section on protocol, it is mentioned that drug label should include name and contact numbers of investigator and name of institution.
This is not a global practice.
This will lead to practical difficulties in global trials where the labels are uniform with minor changes made if required by local laws and practice.
7.Document Retention
ICH – GCP: (5.18.4)
Essential documents should be retained until at least 2 years after the approval of a marketing application in an ICH region.
Indian GCP: (4.9)
Indian GCP mandates that the sponsor should make arrangements for safe and secure custody of all study related documents and material for a period of three years after the completion of the study or submission of the data to the regulatory authorities whichever is later.