970409_clinical trial in malaysia ( taipei 8 april 2008)
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Clinical Trial and Compliance Section
National Pharmaceutical Control BureauMinistry of Health Malaysia
CLINICAL TRIALIN MALAYSIA
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OUTLINE
Introduction
Regulation and Ethical Oversight of Clinical Trialin Malaysia
Guidelines and Legal Requirements
Compliance
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Regulation and EthicalOversight of Clinical Trial in
Malaysia
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Ensuring Ethical Research:A joint responsibility
Investigative sites
supported by
dedicatedResearch
Organization
Sponsors play by
the rules
IEC/IRB with
dedicated Admin
support
Regulatory
Authority enforce
the rules
NCCR
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1. National Committee for Clinical1. National Committee for Clinical
Research(NCCR)Research(NCCR)
Forum for dialogue among all parties: Regulatory authority,IECs, Sponsors, Investigators from MOH/Universities/Private hospitals
Promulgate & implement various guidelines:- GCP, Bioequivalence (BE) studies, GLP, Guidelines forApplication For CTIL/ CTX etc
Training on GCP
Site-inspection for clinical trials
Review processes for approval of clinical trials
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2. Investigative sites &
Research organization
This is where the action is; where investigatorsenroll patients into the trial
Ethical trial conduct & compliance requires:
Adequate resources to conduct the trial Training, eg GCP certification
Independent monitoring of trial conduct
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3. Sponsors
Sponsor pay for the research, and own the IPR Mostly industry sponsors (mostly drug trials) or
government grant agency (eg NIH of the MOH,MOSTE)
Recruitment of well qualified investigators
Avoid undue influence of investigators and patients
Independent monitoring /audit by sponsors: commonpractice for industry
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4. IEC/ IRB
An independent body constituted of medical professionalsand non-medical members whose responsibility it is toensure the protection of the rights, safety and well-beingof human subjects involved in a trial and to provide public
assurance of that protection, by, among other things,reviewing and approving the trial protocol, the suitabilityof the investigator(s), facilities, and the methods andmaterial to be used in obtaining and documentinginformed consent of the trial subjects. ICH GCP 1.27
In Malaysia, for MOH/private sites, this is the MedicalResearch & Ethics Committee of the MOH (MREC);
universities have their own IECs.
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Application for Conduct of Clinical
Trial in MOH, Malaysia
START
Investigator submit application
Secretariat Standing Committee
for Medical Research (SSCMR)
Research Review Committee
SSCMR
Medical Research
Ethics Committee
SSCMR
Medical Research Ethics
Committe
SSCMR
Investigator
STOP
Investigator
Investigator
Incomplete
Complete
amendmentsyes
no
amendments
yes
no
Approval/rejection
Inform decision
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5. Regulatory Authority
Drug Control Authority (DCA)
An authority established for the purposeof regulating the Control of Drugs and
Cosmetics Regulations, 1984 DCA has a broad public protection mission to
ensure the safe use of regulated products thatare themselves safe and efficacious
Ensure Implementation of trial related guidelinesand legislation
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Guidelines and Legal
RequirementsGuidelines:
Malaysian Guidelines for GCP (Updated 2004) Guidelines for Application of CTIL and CTX in Malaysia
NIH Guideline for Research conduct in MOH
Laws
Control of Drugs and Cosmetics Regulation 1984 The Poison Regulation (Psychotropic Substances) 1989
Sale of Drugs Act 1952
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Regulatory compliance
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Malaysia GCP Guidelines 5.20.3The DCA will enforce the rules and punitiveaction will be decided by the DCA
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4.Malaysian GCP4.1 Investigators Qualifications and
Agreements
4.1.1The investigator (s) should be qualified byeducation, approved training in Good ClinicalPractice certification and experience to assumeresponsibility for the proper conduct of the trial,
should meet all the qualifications specified by theapplicable regulatory requirement (s), and shouldprovide evidence of such qualifications through up-to-date curriculum vitae and/ or other relevant
documentation requested by the sponsor, theIRB/IEC and/or the regulatory authority (ies)
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Control of Drugs and Cosmetics
Regulations 1984 (Revised 2006)
Regulation 29. Directions(1) The Director of Pharmaceutical Services
may issue written directives or guidelines to
any person or a group of persons as hethinks necessary for the better carrying outof the provisions of these Regulations andin particular relate to-
(a) clinical trials or
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(2) Any person to contravenes anydirectives or guidelines issued bythe Authority under subregulation (1)
commits an offence.
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Control of Drugs and Cosmetics
Regulations 1984
Regulation 12(1)(c): Clinical Trial ImportLicence (CTIL)
A Clinical trial import licence in Form 4 inthe Schedule, authorising the licensee to import anyproduct for purposes of clinical trials,
notwithstanding that the product is nota registered product
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Regulation (15) Exemptions
Regulation 15(5) : Clinical Trial Exemption (CTX)
Any person who wishes to manufacture
any products solely for the purpose ofproducing samples for registration/clinicaltrials under these Regulations may on
application be exempted by the Authorityfrom the provisions of regulation 7(1).
Control of Drugs and Cosmetics
Regulations 1984
C t ti f R l ti 7(1) f
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Contravention of Regulation 7(1) ofthe Control of Drugs and CosmeticRegulations 1984
The penalty comes under parent actsSection 12, Sale of Drug Acts 1952(Revised 1989)
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CTIL and CTX ApplicationCTIL Application
For unregistered products. Product when used or
assembled (formulated orpackaged) in away different
from the approved form. Form BPFK 442.4
Fees : RM 500 for eachproduct
Licence A for Poisons (whereapplicable)
DCA approval based on:-
- approval from IRB/IEC
- complete information oninvestigational products
CTX Application
For unregistered products-manufactured locally.
Form BPFK 443.1
Fees : Free of charge
Licence A for Poisons (whereapplicable)
DCA approval based on:-
- approval from IRB/IEC- complete information oninvestigational products
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How complete is the information submitted? How fast sponsor/ PI respond to queries ?
Adherence to established procedures For CTIL and CTX - Ethical Approval given
prior to release of CTIL/CTX
Factors affecting speed of approval
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Compliance
Who does inspections?
By the local Regulatory Authority External Regulatory Authorities
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Dont just believe what we say
Malaysia
s favorable experience withsponsors audit and regulatoryinspection
Sponsor pre-qualification or on-study audit Pfizer, Sanofi-Aventis, B Braun, Beaufour
Ipsen, etc
Regulatory inspection
EMEA
FDA
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www.bpfk.gov.my
Thank You
For Your Kind Attention