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BA-BE Studies: SOP for Contingency Planning for Subject Withdrawal – V 2.0

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BA-BE Studies: SOP for Contingency Planning for Subject Withdrawal – V 2.0

Standard Operating Procedure for Contingency Planning for Subject Withdrawal in BA/BE Studies

Department BA-BE Studies
SOP No. SOP/BA-BE/140/2025
Supersedes SOP/BA-BE/140/2022
Page No. Page 1 of 9
Issue Date 17/04/2025
Effective Date 20/04/2025
Review Date 17/04/2026

1. Purpose

To define a systematic approach for handling subject withdrawals during BA/BE clinical trials, including documentation, notification, replacement strategies, and regulatory compliance to ensure study continuity and integrity.

2. Scope

This SOP applies to all clinical trials conducted at the site under the BA/BE program, covering both voluntary and investigator-mandated subject withdrawals at any stage of the study.

3. Responsibilities

  • Principal Investigator
(PI): Makes final decision on subject withdrawal, oversees documentation, and notifies sponsor/regulatory authorities.
  • Study Coordinator: Assists in documentation, tracks subject disposition, and maintains logs.
  • Medical Officer: Conducts safety assessments and records medical justifications, if applicable.
  • QA Officer: Ensures protocol compliance and verifies withdrawal records during audits.
  • 4. Accountability

    The Principal Investigator is accountable for ensuring that subject withdrawals are handled ethically, documented properly, and evaluated for impact on study validity.

    5. Procedure

    5.1 Reasons for Subject Withdrawal

    1. Subjects may withdraw from the study for the following reasons:
      • Voluntary withdrawal (personal reasons, discomfort, etc.)
      • Medical reasons (e.g., adverse events, abnormal lab results)
      • Non-compliance with study procedures
      • Protocol deviations
      • Investigator’s discretion for subject safety

    5.2 Initial Assessment and Reporting

    1. Immediately upon a subject expressing intent to withdraw, the Study Coordinator must notify the Medical Officer and PI.
    2. Conduct a medical evaluation to assess safety or adverse events leading to withdrawal.
    3. Document the event in Annexure-1: Subject Withdrawal Form, including:
      • Subject ID
      • Date and study period
      • Reason for withdrawal
      • Medical findings, if any
      • Investigator and subject signatures
    4. Update the Subject Disposition Log accordingly.

    5.3 Follow-Up and Safety Monitoring

    1. Offer voluntary follow-up visit to withdrawn subjects to assess health status.
    2. Record outcomes of the follow-up in Annexure-2: Post-Withdrawal Safety Report, if applicable.
    3. If adverse event is related to IMP, initiate SAE reporting per SOP/BA-BE/68/2025.

    5.4 Replacement of Withdrawn Subjects

    1. Check protocol-specific replacement criteria:
      • Pre-dose withdrawals: Replace with reserve subjects, if enrolled.
      • Post-dose withdrawals: Generally not replaced unless protocol allows.
    2. Activate standby subjects if identified prior to dosing.
    3. Update randomization records and ensure blinding is maintained, if applicable.
    4. Record new subject inclusion in Annexure-3: Replacement Subject Log.

    5.5 Notification to Sponsor and Ethics Committee

    1. Send written notification to the sponsor within 24 hours for all withdrawals.
    2. If withdrawal is related to safety or protocol deviation, notify IEC/IRB as per their SOPs.
    3. Maintain copies of all communications in the Trial Master File (TMF).

    5.6 Final Documentation and Archival

    1. Update eCRF or paper CRF with withdrawal status and date.
    2. Ensure all associated logs (dispensing, lab samples, consent) are reconciled and closed.
    3. Archive withdrawal forms in subject file for minimum 5 years or as per regulatory requirement.

    6. Abbreviations

    • BA/BE: Bioavailability / Bioequivalence
    • PI: Principal Investigator
    • IMP: Investigational Medicinal Product
    • SAE: Serious Adverse Event
    • IEC: Institutional Ethics Committee
    • TMF: Trial Master File

    7. Documents

    1. Subject Withdrawal Form – Annexure-1
    2. Post-Withdrawal Safety Report – Annexure-2
    3. Replacement Subject Log – Annexure-3

    8. References

    • ICH E6(R2) – Good Clinical Practice
    • Schedule Y – Drugs and Cosmetics Rules, India
    • CDSCO Bioavailability/Bioequivalence 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: Subject Withdrawal Form

    Subject ID Date Study Period Reason Investigator Signature
    SUB123 17/04/2025 P1 Personal reason Dr. Meena Joshi

    Annexure-2: Post-Withdrawal Safety Report

    Subject ID Follow-Up Date Symptoms Treatment Outcome
    SUB123 20/04/2025 None NA Recovered

    Annexure-3: Replacement Subject Log

    Withdrawn ID Replaced By Period Date Remarks
    SUB123 SUB129 P1 17/04/2025 Used reserve subject

    Revision History:

    Revision Date Revision No. Details Reason Approved By
    01/01/2022 1.0 Initial SOP release New procedure QA Head
    17/04/2025 2.0 Expanded procedure for follow-up and annexures Regulatory alignment QA Head
    See also  BA-BE Studies: SOP for Verification of Study Drug Dispensing by Pharmacist - V 2.0
    BA-BE Studies V 2.0 Tags:Absolute bioavailability, AUC (area under the curve), Bioavailability, Bioequivalence, Bioequivalence criteria, CDSCO bioequivalence norms, Clinical trial registration, Cmax (maximum concentration), Confidence interval %, Crossover study design, EMA bioequivalence requirements, Ethics committee approval, FDA bioequivalence guidelines, Generic drug approval, Good Clinical Practice (GCP), Good Laboratory Practice (GLP), Half-life (t½), ICH E(R) compliance, In vitro dissolution, In vivo studies, Informed consent process, Pharmacodynamics, Pharmacokinetics, Randomized controlled trial, Regulatory submission process, Relative bioavailability, Sample size calculation, Therapeutic equivalence, Tmax (time to maximum concentration), Washout period

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