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Table 5 Consideration of streamlining in clinical trials for provision of OOS products

From: Challenges and opportunities in the compassionate use of out-of-specification products in autologous regenerative medicine

Timing

MAHs (sponsor)

Medical institutions

Clinical Trials

Before starting

Extrusion

Items that can be streamlined

Preparation of Investigational Brochures (IB) may be substituted with the package inserts

Items that cannot be streamlined

Preparation of clinical trial protocols and informed consent forms

Compensation for participants

Preparation for clinical trial product management

Site setup (medical institution and investigator selection, site training)

Clinical Trial Notification (CTN)

Clinical trial contract

IRB review application preparation

Maintenance of records

Items that can be streamlined

Agreement with IB may be substituted with the package inserts

Items that cannot be streamlined

Agreement to the clinical trial protocol and informed consent form

Site setup

Clinical trial contract handling

IRB review support

Clinical Trials

After starting

Permanent

Items that can be streamlined

Storage of essential documents (case report forms, data obtained in clinical trials, and simplification of storage periods)

Items that cannot be streamlined

Regular confirmation of clinical trial system maintenance

Evaluation of safety information, reporting to authorities and medical institutions (annual reporting, sharing of information with other sites)

IRB review for protocol revisions, etc

Maintenance of CTN

monitoring

investigators, site staff, and site trial system

Items that can be streamlined

Maintenance of records (simplification of source documents and retention period)

Items that cannot be streamlined

Maintaining and continuing training of investigators and staff to conduct clinical trials in compliance with protocols and GCP

IRB support (ongoing review, protocol revision support, etc.)

Each time

Items that can be streamlined

Procedures for converting commercial products to investigational products (product re-labelling)

Collection of case report forms

Handling of subject safety information

EDC

Verification of source data

Items that cannot be streamlined

Collection of case report forms

Monitoring

Participant eligibility

Confirmation of patient consent status

Ensuring the safety of participants

Items that can be streamlined

None

Items that cannot be streamlined

Safety information evaluation, reporting to sponsor