Standard Operating Procedure for Clinical Trial Incident Reporting in BA/BE Studies
Department | BA-BE Studies |
---|---|
SOP No. | SOP/BA-BE/142/2025 |
Supersedes | SOP/BA-BE/142/2022 |
Page No. | Page 1 of 10 |
Issue Date | 17/04/2025 |
Effective Date | 20/04/2025 |
Review Date | 17/04/2026 |
1. Purpose
To define a standardized and compliant method for identifying, recording, evaluating, and reporting incidents that occur during the conduct of clinical trials in BA/BE studies, ensuring corrective and preventive actions and adherence to GCP and regulatory guidelines.
2. Scope
This SOP applies to all clinical personnel involved in BA/BE studies and covers all types of incidents including protocol deviations, adverse events, safety breaches, procedural non-compliances, or
3. Responsibilities
- Clinical Investigator: Responsible for assessing, documenting, and reporting the incident and its impact on subject safety or data integrity.
- Study Coordinator: Maintains the incident reporting log and ensures documentation of all reports and follow-ups.
- QA Officer: Reviews all incident reports for CAPA requirements and ensures compliance audits.
- Clinical Operations Manager: Ensures that systemic issues are identified and escalated for resolution.
4. Accountability
The Principal Investigator is accountable for ensuring that all trial-related incidents are reported, assessed, documented, and resolved in a timely and compliant manner.
5. Procedure
5.1 Identification of Incidents
- Incidents may include but are not limited to:
- Subject safety concerns
- Non-compliance to protocol procedures
- Improper handling of IMP or samples
- Failure of monitoring devices
- Breaches in confidentiality
- Any staff member who identifies an incident must immediately inform the Study Coordinator and PI.
5.2 Preliminary Documentation
- Complete the Incident Reporting Form (Annexure-1) including:
- Date and time
- Location
- Description
- Persons involved
- Immediate actions taken
- Assign a unique Incident ID following format: INC/YY/XXX (e.g., INC/25/001).
- Log the incident in Annexure-2: Clinical Incident Log.
5.3 Incident Evaluation and Impact Assessment
- PI shall evaluate whether the incident:
- Affects subject safety
- Impacts study integrity
- Requires deviation reporting to sponsor/IEC
- Medical Officer shall assess need for medical intervention or AE/SAE reporting.
- QA to verify whether it is a repeat incident or systemic issue.
5.4 Corrective and Preventive Actions (CAPA)
- PI and QA team jointly define:
- Corrective Action: Steps taken to immediately address the issue
- Preventive Action: Steps to prevent recurrence
- Document CAPA in Annexure-3: CAPA Implementation Log.
- Assign follow-up timelines and responsible persons.
5.5 Communication and Reporting
- Report the incident to the sponsor within 24–48 hours if:
- Subject is withdrawn
- Major protocol deviation occurred
- Data integrity is impacted
- Notify IEC/IRB per their SOPs if incident is classified as reportable.
- File copies of all communications in TMF and subject file if relevant.
5.6 Closure and Archival
- Upon implementation of CAPA, update incident status as “Closed” in the log.
- All supporting documents, logs, and communications must be archived in the QA section of the TMF.
6. Abbreviations
- BA/BE: Bioavailability / Bioequivalence
- PI: Principal Investigator
- AE: Adverse Event
- SAE: Serious Adverse Event
- CAPA: Corrective and Preventive Action
- IEC: Institutional Ethics Committee
- TMF: Trial Master File
7. Documents
- Incident Reporting Form – Annexure-1
- Clinical Incident Log – Annexure-2
- CAPA Implementation Log – Annexure-3
8. References
- ICH E6(R2) – Good Clinical Practice
- Schedule Y – Drugs and Cosmetics Rules, India
- CDSCO BA/BE Guidelines
9. SOP Version
Version: 2.0
10. Approval Section
Prepared By | Checked By | Approved By | |
---|---|---|---|
Signature | |||
Date | |||
Name | |||
Designation | |||
Department |
11. Annexures
Annexure-1: Incident Reporting Form
Incident ID | Date | Description | Persons Involved | Immediate Action |
---|---|---|---|---|
INC/25/003 | 17/04/2025 | Blood sample mislabeled | Ravi Sharma | Sample discarded |
Annexure-2: Clinical Incident Log
Incident ID | Status | Date | Reported By | Closed On |
---|---|---|---|---|
INC/25/003 | Closed | 17/04/2025 | Ravi Sharma | 19/04/2025 |
Annexure-3: CAPA Implementation Log
Incident ID | Corrective Action | Preventive Action | Responsible | Due Date |
---|---|---|---|---|
INC/25/003 | Sample discarded, volunteer re-sampled | Barcode scanning training | QA Officer | 22/04/2025 |
Revision History:
Revision Date | Revision No. | Details | Reason | Approved By |
---|---|---|---|---|
01/01/2022 | 1.0 | Initial release | New SOP | QA Head |
17/04/2025 | 2.0 | Expanded CAPA and classification of incidents | Audit compliance | QA Head |