Introduction to the Columbia Human Research Protection Program
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Introduction to the Columbia Human Research Protection Program
IRB SOPs Version 4.2 Nov. 2, 2012 Table of Contents SOP Cover Page Introduction to the Columbia Human Research Protection Program Institutional Leadership Institutional Culture Standard Operating Procedures Development Intro A B C D E F I A 1 2 Rascal 1 2 B C D E F Process for Revising Standard Operating Procedures Requirement for Submissions Definitions of Research and Human Subject Human Research Protection Program Institutional Review Boards and IRB Office IRB Administrative Staff a b c d Committees within the IRB Office a b c d 1 2 3 4 G H I J K L M II A 1) 2) Organization Administrative Support to Review Panels Compliance Oversight Team Duties Education and Training Confidentiality and Conflict of Interest 1 2 IRB SOP V4.2 TOC Education and Training Committee Policy Committee Accreditation Committee Rascal Committee Privacy Board Office of Sponsored Projects Administration Clinical Trials Office Research Pharmacy IND/IDE Assistance Program Clinical Trials Monitoring Assistance Program Spanish Translation Center Office of Research Compliance and Training Joint Radiation Safety Committee, Radioactive Drug Research Committee, and the Radiation Safety Office Institutional Biosafety Office Protocol Review and Monitoring Committee Irving Institute for Clinical and Translational Research NYP Pharmacy NYP Patient Services Administration Center for Bioethics Department Chairs, Investigators, and Departmental Administrators Institutional Review Boards Guiding Principles, Regulations, Statutes, Standards, Policies Structure Page 1 IRB SOPs Version 4.2 Nov. 2, 2012 Table of Contents II A 3 4 5 6 7 a b c d e a b B 1 2 III A B C a b c 1) 2) 3) 4) 5) 6) 7) 1) 2) 3) 4) 5) 6) 7) 8) Scope of Authority Autonomy Research Conducted by Columbia faculty, employees, and students Constitution of the Columbia IRBs Membership Qualification of Members Membership Diversity Alternate Members Use of Consultants Appointments, Terms, and Responsibilities of IRB Chairs, Vice Chairs, and Members Chair/Vice Chair Selection and Appointment Length of Term/Service Duties Resignation/Removal Education and Training Liability Coverage for IRB Chairs and Vice Chairs Confidentiality and Conflict of Interest IRB Members Selection and Appointment Length of Term/Service Duties Attendance Requirements Removal, Resignation Liability Coverage for IRB Members Education and Training Confidentiality and Conflict of Interest The Role of Non-Columbia (External) IRBs in the Columbia HRPP Reliance Agreements Reliance on a Non-Columbia IRB Reliance on a Non-Columbia IRB for a multicenter study, consortium, or study program Columbia Serving as IRB of Record for Non-Columbia Entities Research Conducted at CU by Investigators Affiliated with Other Institutions Preparation of Submissions to the IRB Preparation of Event Submissions IRB Abbreviated Submission Process 1 Industry-sponsored multicenter studies 2 3 Student-initiated research Grant-funded research 1 a b IRB SOP V4.2 TOC Personnel Principal Investigators Eligibility Research and Human Subject Determinations Page 2 IRB SOPs Version 4.2 Nov. 2, 2012 Table of Contents III C D E 2 3 Roles and Responsibilities Training Documents/Information Needed for Each Type of Event Submission materials: New protocol Submission materials: Modification Submission materials: Renewal (Continuing Review) Submission materials: Report of unanticipated problems involving risks to subjects or others Submission materials: Termination (Closure) Submission materials: Report of Protocol Deviation or Violation Submission materials: Emergency Use Report Material Needed for Review of Particular Types of Research or Situations Submission materials: Drug research Submission materials: Research with Biologics Submission materials: Device research Submission materials: Planned emergency research Submission materials: Research involving pregnant women, fetuses, and neonates Submission materials: Research involving prisoners Submission materials: Research involving children Submission materials: Research involving other vulnerable adults Submission materials: Research involving non-English speaking individuals Submission materials: Research involving students or employees as subjects 1 2 3 4 5 6 7 1 2 3 4 5 6 7 8 9 10 11 12 13 Submission materials: International research Submission materials: Substudies Submission materials: Collaborative research that will not be conducted under an IRB Authorization Agreement Submission materials: Collaborative Research that will be conducted under IRB Authorization Agreements Submission materials: Domestic research conducted at non-CU sites Submission Materials: Research Conducted at External Sites by CU Researcher Submission Materials: Transfer of Research when PI is leaving Columbia 14 15 16 17 IV A B C 1 2 3 4 5 a b c 1 IRB SOP V4.2 TOC Processing of Submissions to the IRB: Pre- and Post-IRB or ARC Review Preliminary review of submitted events Routing of submissions to IRB per level of review required Level of Review: Not Human Subjects Research Level of Review: Exempt determination Level of Review: Expedited Level of Review: Facilitative/Administrative/118 Facilitative review Administrative review “118” reviews Level of Review: Full Board Primary Reviewer system Primary reviewer system: Initial review Page 3 IRB SOPs Version 4.2 Nov. 2, 2012 Table of Contents IV C D E F V A B 2 3 4 Primary reviewer system: Continuing review (renewal) Primary reviewer system: Modifications, Unanticipated Problem reports Primary reviewer system: Terminations (closures) Post-Review Procedures Notification to Researcher: General Process Notification: Approval and Outcome of Review Notification: Disapproval Notification: Suspension Documentation of review and approval 1 2 3 IRB Pre-review and Review Criteria Pre-review of Submitted Events Pre-review: New Protocols Pre-review: Renewals (Continuing Review) Pre-review: Modifications Pre-review: Unanticipated Problem Reports Pre-review: Termination (Closure) Requests IRB Criteria for Review Risks to Subjects are Minimized (applies the principle of beneficence) 1 2 3 4 5 1 2 3 4 5 6 7 8 a b a 9 10 VI A IRB SOP V4.2 TOC 1) 2) 3) 4) 5) 6) 7) 8) 9) Risk/Benefit Ratio is Acceptable (applies the principle of beneficence) Selection of Subjects is Equitable (applies the principle of justice) Informed Consent Process is Appropriate (applies the principle of autonomy) Special Consent Situations Consent from Non-English Speaking Subjects Consent for Audio- and Video Recording Consent for Live Case Procedures Same Day Consent for Elective Procedures Consent from Women in Labor Enrolling Illiterate Subjects Enrolling Individuals with Physical Limitations Related to Writing Obtaining Consent for Future Use of Specimens Obtaining Consent for Future Contact for Research Waiver of Some or All of the Elements of Informed Consent Documentation of Informed Consent is Appropriate (applies the principle of autonomy) Waiver of Written Documentation of Consent Data and Safety will be Monitored (applies the principle of beneficence) Privacy and Confidentiality will be Protected (applies the principle of beneficence) Recruitment Methods and Advertising Material are Appropriate (applies the principles of autonomy and justice) Additional Protections are in Place for Vulnerable Subjects (applies the principle of beneficence) Potential Conflict of Interest of Investigators is Eliminated, Mitigated or Managed IRB Review of Specific Events, Types of Research, and Types of Documents IRB Review of Specific Events Page 4 IRB SOPs Version 4.2 Nov. 2, 2012 Table of Contents VI A 1 2 3 4 5 6 7 B 8 9 a b a b c a b 1 2 3 4 5 6 7 8 9 10 C VII 11 12 a b c a 1 2 3 4 A B C D IRB SOP V4.2 TOC Initial Review (Review of a New Protocol) Review of Modifications Review of Reports of Unanticipated Problems Involving Risks to Subjects or Others Review of Reports of Protocol Deviations or Violations Examples of major protocol violations: Examples of minor protocol violations Review of Emergency Use Requests Initial Notification to the IRB Consent Requirements for Emergency Use of a Test Article Documentation Required Facilitative Review Continuing Review (Renewal) Continuation Past Expiration of IRB Approval Procedures for Determining Which Projects Require Review More Often Than Annually Review of Termination (Closure) Requests Suspension and IRB-initiated For-cause Termination of Research Review of Specific Types of Research Review of Research involving Investigational Drugs Review of Research involving Medical Devices Review of Humanitarian Use Devices Review of Research involving Pregnant Women, Neonates, and Fetuses (45 CFR 46, Subpart B) Review of Research involving Prisoners (45 CFR 46, Subpart C) Review of Research involving Children (45 CFR 46, Subpart D) Determination of Risk/Benefit Category Assent Determination Inclusion of Wards in Research Review of Research involving Other Vulnerable Adults Review of Research involving Non-English Speaking Subjects Review of Research involving International Sites Review of Planned Emergency Research Emergency Research Consent Waiver Review of Research that involves Human Embryonic Stem Cells Review of Research Conducted by Students Review of Specific Types of Documents Review of Recruitment Material Review of Funding Documentation Review of Investigational Drug Brochure Review of Payments to Participants IRB Convened Meetings: Organization and Management Schedule of Meetings Agenda Preparation Primary Reviewer Assignments Voting Requirements Page 5 IRB SOPs Version 4.2 Nov. 2, 2012 Table of Contents VII E 1 2 3 4 VIII A B C D E F G IX 1 2 A E F Review of Unanticipated Problems Involving Risks to Subjects or Others (including Adverse Events) Data and Safety Monitoring Reviews or Monitoring by the Research Pharmacy, Radiation Safety Committees, or Institutional Biosafety Committee Reviews by Research Administration Offices Compliance Oversight A Education and Training Research Community B C D Board Members and Chairs Administrative Staff Researchers A B Quality Assurance and Improvement Assessment and Improvement Initiatives of Internal Processes Assessment and Improvement of External Processes A B C Subject Outreach Information for Potential Subjects Information from Research Subjects and the Community Compliance Hotline C D XI XII App. Record Retention and Documentation Records Maintained IRB Files Record Retention Term Research Records IRB Records Procedures if PI Leaves Columbia Confidentiality of Records Inspection of Records Off-site Storage of IRB Files Oversight Monitoring Renewal (Continuing Review) B X Minutes Recording of Minutes at the Convened Meeting Board Approval of Minutes Notification of IRB Action Appeal of IRB Decision I A IRB SOP V4.2 TOC Abbreviations and Terms Used in Columbia University IRB Standard Operating Procedures 2012 Alphabetical Order Page 6 IRB SOPs Version 4.2 Nov. 2, 2012 Table of Contents App. I II III B IRB SOP V4.2 TOC In Order of Appearance Referenced Regulations, Laws, Standards SOP Revision History Page 7