INSTITUTIONAL REVIEW BOARD/INDEPENDENT ETHICS COMMITTEE (IRB/IEC)

Research in 20th Century

Ethics Ethics is not definable, is not implementable, because it is not conscious; it involves not only our thinking, but also our feeling. … Valdemar W. Setzer

ICH GCP 1.31 Institutional Review Board (IRB) or Independent Ethics Committee (IEC) An independent body constituted of medical, scientific, and non-scientific members, whose responsibility is to ensure the protection of the rights, safety and well-being of human subjects involved in a trial by, among other things, reviewing, approving, and providing continuing review of trial protocol and amendments and of the methods and material to be used in obtaining and documenting informed consent of the trial subjects.

ICMR GUIDELINES ON IRB/IEC “It is mandatory that all proposals on biomedical research involving human participants should be cleared by an appropriately constituted Institutional Ethics Committee (IEC), also referred to as Institutional Review Board (IRB), Ethics Review Board (ERB) and Research Ethics Board (REB) in other countries, to safeguard the welfare and the rights of the participants….”(ICMR, 2006). (

So What is Ethics Committee? Any board, committee or other group formally designated by an institution to Review Approve the initiation of and Conduct periodic review of biomedical research involving human subjects.

All proposals on biomedical research involving human subjects must be cleared by an Ethics Committee

Ethics Committees: Why? An objective review of research activities involving human subjects by a group of diverse individuals is most likely to protect human subjects and promote ethically sound research

Ethics Committees: Why? To protect the study subjects’ well-being, rights & confidentiality To meet the mandate of Declaration of Helsinki To make clinical research - acceptable to regulatory authorities - journal editors

For What to submit to Ethics Committee? Pharmaceuticals Medical Devices Medical Radiation and Imaging Surgical Procedures Medical Records Biological Samples Epidemiological, Social and Psychological Investigations All Clinical Research!

PRE-REQUISITES FOR EFFECTIVE IRB FUNCTIONING Scope for making independent decisions Functioning independent of the institution (head of the institution should not be head of IRB) Democratic functioning (all members should have their say)

OVERVIEW- Ethical Review Procedures Basic responsibilities Composition Terms of reference Training Regulation Review procedures Submission of application Decision making process Review process Periodic review Continuing review Interim review Monitoring Record keeping Administration and management Special considerations

BASIC RESPONSIBILITIES Safeguard the rights, safety, and well-being of all trial subjects Ensure and verify that universal ethical values and safety standards are followed with a view on local community values and customs Help in the development and the education of research community responsible to local health care requirements

COMPOSITION A reasonable number of members who collectively have the qualifications and experience to review and evaluate the science, medical aspects and ethics of the proposed trial

COMPOSITION Multidisciplinary and multisectorial Independence and Competence –two hallmarks Number of persons: 8 -12(Maximum of 15 members recommended) Quorum –minimum of 5 Chairperson –outside the Institution Member Secretary –same institution Others –mix of medical/non-medical, scientific and non-scientific persons, lay persons from the community Adequate representation of age and gender Subject experts, if needed

TERMS OF REFERENCE To include Terms of Appointment Specify these in the SOP SOP to be made available to each member Written SOPs –to be updated periodically based on the changing requirements Extension of membership for another term Preferable to appoint persons trained in bioethics or persons conversant with ethical guidelines and laws of the country Nomination of substitute member in case of continuous missing of meetings by a member due to illness or other unforeseen circumstances

REGULATION Registration of all IECs under a Biomedical Research Authority, to be set up under the proposed Bill on Biomedical Research on Human Participants (Promotion and Regulation)

REVIEW PROCEDURES Before research is initiated, the IEC should review every research proposal on human participants Ensure scientific evaluation has been completed Evaluate the possible risks, expected benefits, privacy, confidentiality and the justice issues Screening of proposals by Member-Secretary/Secretariat Proposals to be categorized into three types –Exemption from review, Expedited review, and Full review

SUBMISSION OF APPLICATION Application in a prescribed format along with the study protocol as prescribed in SOP of IEC concerned To include, among other details, study title, objectives, rationale for study etc. Plan to withdraw or withhold standard therapies in the course of the research Probable ethical issues Funding details Agreement to comply with national and international GCP protocols for clinical trials.

DECISION MAKING PROCESS Complete and adequate review Periodic meetings at frequent intervals Review of new proposals Annual progress of ongoing studies Review SAE reports Assess final reports Meetings to be minuted, approved and signed by Chairperson/alternate Chairperson/designated member of the IEC Decisions to be based on broad consensus.

REVIEW PROCESS SOP to state review process SOP to clarify whether review to be done by all reviewers/primary reviewers Review to be done in formal meetings No decision through circulation of proposals Meetings at regular intervals

PERIODIC REVIEW Six months to one year CONTINUING REVIEW For continuation, new information, adverse event monitoring, follow-up, after completion of project INTERIM REVIEW By a sub-committee

INTERIM REVIEW Re-examination of proposal already examined by the IEC Research study of a minor nature such as examination of case records etc.; An urgent proposal of national interest.

MONITORING Need for oversight mechanism Actual site visits Periodic status reports SAE reports Reports of monitoring by sponsor and recommendations by DSMB, if needed by IEC

RECORD KEEPING Documentation to be dated, filed and preserved per written procedures Strict confidentiality during access and retrieval Records for: composition of IEC, CV of IEC members, records of training, SOP, guidelines, protocols, correspondence, agenda, meeting minutes Records to be maintained for 3 years after completion/termination of study

ADMINISTRATION AND MANAGEMENT Full time secretariat Record keeping space Members to be compensated reasonably Reasonable fees for review and administrative processes Allocation of reasonable amount of funds

SPECIAL CONSIDERATIONS Research involving: Children Pregnant and lactating women Vulnerable participants, and Those with diminished autonomy Issues pertaining to commercialisation of research International collaboration Observations and suggestions of IEC should be given in writing in unambiguous terms in such instances.

CONCLUSION Success of an IRB depends on: The quality and engagement of members Procedures Documentation, and Institutional commitment -financial resources, degree of autonomy and investigator adherence to norms.

REFERENCES ICH –GCP, E6 (R1) (1996), Section 3 (1996) ( ICMR Guidelines for Biomedical Research on Human Subjects (Sep 2000) ( World Medical Association Declaration of Helsinki (1964, last amended in October 2000), Section B.13 ( CIOMS International Ethical Guidelines for Biomedical Research involving Human Subjects (2002), Guidelines 2 and 3 ( U.S. Food and Drug Administration (US FDA), 21 CFR Part 56 ( Code of Federal Regulations, Title 45, Part 46, Subpart A, Section (1991) (

THANK YOU “Knowing is not enough; we must apply. Willing is not enough; we must do.” —Goethe