FDA Clinical Investigator Inspection List, who is Inspected and What are the Results for Countries Outside US?

Main Article Content

Bjarne Madsen Härdig, RN, PhD Pyotr G Platonov, MD, PhD

Abstract

Background: The purpose of this analysis was to revisit the open US Food and Drug Administration (FDA) inspection list results from clinical trials and show the possibilities of evaluating inspection results between different world regions and explore what aspects of clinical trial deficiencies are most often reported.


Aims: The aim of this study was to evaluate inspection results from different regions of the world and the deficiencies most often reported.


Methods: On October 10, 2021, the clinical Investigator Inspection List was download as an Excel spreadsheet (Microsoft, Seattle, USA) from the FDA homepage. Data were extracted and categorized as: Number of inspections in each region and country, number and % of actions found during the inspections, number and % of deficiencies found – in total and in the different regions and countries. No statistical comparison was made on the analysed data in the article.


Results: The total number of inspections performed by the FDA outside the US between 1980 and October 2021 was 3,222. The number of voluntary actions varies in the same manner as the number of inspections. The number of “no actions indicated” increased after 1994, which may indicate that adding new and smaller countries to participate in clinical trials does not affect the quality of the clinical trials. The results shows that most common action registered by the FDA was “voluntary actions indicated (VAI)” (56.6%) followed by “no action indicated (NAI)” (38.6%), while “official action indicated (OAI)” were rare (4.1%). “VAI” and “NAI” were registered in all regions. "VAI” were indicated for topics related to documentation and reporting in 787 inspections (24.4%), protocol violation in 683 inspections (21.2%)), informed consent/institutional review board in 257 inspections (8.0%). The same type of deficiencies was noted for “OAI”; however, these were significantly rarer.


Conclusion: The US Food and Drug Administration only monitors a small number of all clinical trials performed worldwide (1.3%). Despite the large difference in the number of FDA inspections performed in different regions worldwide, the structure of inspection findings is remarkably similar across the globe.

Article Details

How to Cite
HÄRDIG, Bjarne Madsen; PLATONOV, Pyotr G. FDA Clinical Investigator Inspection List, who is Inspected and What are the Results for Countries Outside US?. Medical Research Archives, [S.l.], v. 10, n. 11, nov. 2022. ISSN 2375-1924. Available at: <https://esmed.org/MRA/mra/article/view/3303>. Date accessed: 26 apr. 2024. doi: https://doi.org/10.18103/mra.v10i11.3303.
Section
Research Articles

References

1. The International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use. Available from (2022-07-10) URL: http://www.ich.org.
2. Mentz RJ, Hernandez AF, Berdan LG, et al. Good Clinical Practice Guidance and Pragmatic Clinical Trials: Balancing the Best of Both Worlds. Circulation. 2016; March 1;133(9): 872–880. doi:10.1161/CIRCULATIONAHA.115.019902.
3. The European Union Medical Device Regulation. Regulation (EU) 2017/745 (EU MDR) Available from (2022-07-10) URL: https://eumdr.com/
4. Eric L. Eisenstein, Philip W. Lemons II, Barbara E. Tardiff, Kevin A. Schulman, King Jolly, PharmD and Robert M. Califf. Reducing the costs of phase III cardiovascular clinical trials. Am Heart J. 2005; Mar;149 (3): 482-8. doi: 10.1016/j.ahj.2004.04.049.
5. ClinicalTrials.gov database, U.S. National Library of Medicine. Available from (2022-07-10) URL: https://clinicaltrials.gov/ct2/resources/trends
6. EudraCT (European Union Drug Regulating Authorities Clinical Trials Database). Available from (2022-07-10) URL: https://eudract.ema.europa.eu/
7. Läkemedelsverket, Swedish Medical Products Agency. Available from (2022-07-10) URL: https://www.lakemedelsverket.se/en
8. European Medicines Agency (EMA), Science Medicines Health. Available from (2022-07-10) URL: https://www.ema.europa.eu/en
9. FDA an agency within the Department of Health and Human Services. Available from (2022-07-10) URL: https://www.fda.gov/about-fda/fda-organization
10. Clinical Investigator Inspection List (CLIIL). Current through October 2021. Available from (2022-07-10) URL: https://www.fda.gov/drugs/drug-approvals-and-databases/clinical-investigator-inspection-list-cliil.
11. Platonov P. Clinical trials in Russia and Eastern Europe: recruitment and quality. Int J Clin Pharmacol Ther. 2003; Jul;41(7): 277-80. doi: 10.5414/cpp41277.
12. Platonov PG, Varchavsky S. FDA inspections outside the USA: An Eastern European perspective. Applied Clinical Trails. 2004; 13 (9): 60-66.
13. Paul H Caldron, Svetlana I Gavrilova, Siegfried Kropf. Why (not) go east? Comparison of findings from FDA Investigational New Drug study site inspections performed in Central and Eastern Europe with results from the USA, Western Europe, and other parts of the world. Drug Design, Development and Therapy 2012; 6: 53–60.
14. Sonia K. Morgan-Linnell, David J. Stewart, and Razelle Kurzrock. U.S. Food and Drug Administration Inspections of Clinical Investigators: Overview of Results from 1977 to 2009. Clin Cancer Res; 2013; July 1: 2014. doi: 10.1158/1078-0432.CCR-13-3206
15. James R. Dixon, Jr. The International Conference on Harmonization Good Clinical Practice guidelines. Quality Assurance. 1999: 6: 65–74.
16. Eisenstein EL, Collins R, Cracknell BS et al. Sensible approaches for reducing clinical trial costs. Clin Trials. 2008; 5: 75–84
17. Jackson N, Atar D, Borentain M etal. Improving clinical trials for cardiovascular diseases: a position paper from the Cardiovascular Roundtable of the European Society of Cardiology. Eur Heart J 2016; 37: 747–754.
18. Martin R. Cowie, Juuso I. Blomster, Lesley H. Curtis et al. Electronic health records to facilitate clinical research. Clin Res Cardiol. 2017; 106: 1–9
19. Stefan James, Sunil V Rao and Christopher B Granger. Registry-based randomized trials – a new clinical trial paradigm. Nat Rev Cardiol. 2015; May;12(5): 312-6. doi: 10.1038/nrcardio.2015.33.
20. Sathian B, Asim M, Banerjee I, Pizarro AB, Roy B, van Teijlingen ER, do Nascimento IJB, Alhamad HK. Impact of COVID-19 on clinical trials and clinical research: A systematic review. Nepal J Epidemiol. 2020; Sep 30;10 (3): 878-887. doi:10.3126/nje.v10i3.31622.
21. Steen RG. Retractions in the medical literature: who is responsible for scientific integrity? Am Med Writ Assoc J. 2011; 26: 2-7.
22. Herson J. Strategies for dealing with fraud in clinical trials. Int J Clin Oncol. 2016; 21: 22–27. DOI 10.1007/s10147-015-0876-6
23. Kirkwood AA, Cox T, Hackshaw A. Application of methods for central statistical monitoring in clinical trials. Clin Trials. 2013; 10(5): 783-806.