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Table 3 Observations sent to sponsors from PBSL’s review of CTA and amendments

From: Regulating clinical trials in a resource-limited setting during the Ebola public health emergency in Sierra Leone

Areas of review

Observations

General requirements

▪ Trial not registered with a PBSL approved clinical trial registry

• No or incomplete DSMB charter, including membership, the charter of work, study review criteria/stopping rules, curriculum vitae, and conflict of interest details

• Completed PBSL CTA application form not available

• Pharmacy manual not provided

• No contractual agreement between the sponsor and principal investigator

• No local principal investigator was recruited

Clinical protocol

• No specification for assessment of efficacy and safety

• No criteria for participant selection

• Unclear study endpoints

• Studies containing no local sub-investigators and study pharmacists

• Favourable opinion from the SLESRC not available

• A description of the design of the trial to be conducted was not provided

• A description and justification of the trial treatment and the dosage and dosage regimen of the investigational product were not provided

• A detailed description of the “stopping rules” or “discontinuation criteria” is unavailable.

• Valid insurance certificate for the study duration that must be provided before study initiation is not available.

• The informed consent information sheet does not have details of the Chairman of the Sierra Leone Ethics and Scientific Review Committee for participants to contact if they have ethical issues.

• Procedures for monitoring subject compliance not provided

• The sponsor intends to conduct a phase 2 clinical trial, but the phase 1 trial report was not available

• No details of causality assessment parameters and serious adverse events/reaction toxicity grading such as those for haematology and biochemistry

• No evidence of GCP training for the principal investigator and other key staff

• No details of IP data handling and recording keeping

Quality review

• Process validation protocol and report were not available

• Evidence of Good Manufacturing Practice compliance for the manufacturing site(s) of IP and excipients not available

• Analytical Procedures and batch analyses for IP and excipients not provided

• No analysis report of reference standards, including test methods, acceptance criteria, and results

• Post-approval stability protocol and stability commitment for ongoing stability studies of IP not provided

• Sample of labels not available

• The product dossier for the placebo was not provided

• The parameters, test methods, specifications or acceptance criteria and results for the pre-master virus seed are not available

• Genotypic and phenotypic characterisation of the master virus seed was not available

• No read-outs or tracings for characterisation of impurities

• No tracings or read-outs for analytical method validation

Biostatistics review

• Criteria for the termination of the trial are not available

• Timing of any planned interim analysis though, was planned not provided

• Incomplete statistical analysis plan submitted before data lock, with no authors’ name and signature, version number and date, and no inclusion and exclusion criteria

Nonclinical review

• Investigator’s brochure not provided

• No developmental and reproductive toxicity data to support use in pregnancy

  1. PBSL Pharmacy Board of Sierra Leone, DSMB Data Safety Monitoring Board, CTA clinical trial application, SLESRC Sierra Leone Ethics and Scientific Review Committee, GCP Good Clinical Practice, IP investigational product, PI principal investigator