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