SOP Guide for Pharma

BA-BE Studies: SOP for Safety Reporting to Sponsor and Ethics Committee – V 2.0

BA-BE Studies: SOP for Safety Reporting to Sponsor and Ethics Committee – V 2.0

Standard Operating Procedure for Safety Reporting to Sponsor and Ethics Committee in BA/BE Studies

Department BA-BE Studies
SOP No. SOP/BA-BE/149/2025
Supersedes SOP/BA-BE/149/2022
Page No. Page 1 of 11
Issue Date 17/04/2025
Effective Date 20/04/2025
Review Date 17/04/2026

1. Purpose

To define the standardized process for identifying, documenting, and reporting adverse events (AEs) and serious adverse events (SAEs) to the Sponsor and Ethics Committee (EC) in compliance with GCP, Schedule Y, and applicable regulatory guidelines during BA/BE studies.

2. Scope

This SOP applies to all clinical trials involving healthy volunteers conducted under BA/BE protocols at the research site,

and includes all study team members involved in safety monitoring, documentation, and regulatory communication.

3. Responsibilities

  • Principal Investigator (PI): Reviews all safety data, assesses causality and severity, and signs off SAE reports.
  • Clinical Safety Officer: Coordinates safety documentation, prepares reports, and ensures timelines are met.
  • Clinical Research Coordinator (CRC): Assists in identifying and documenting AEs and SAEs in source documents and CRFs.
  • QA Department: Audits safety reporting logs and ensures compliance with reporting SOPs and timelines.

4. Accountability

The Medical Director is accountable for ensuring timely and accurate safety reporting to the Sponsor and EC as per protocol and regulatory requirements.

5. Procedure

5.1 Adverse Event Identification and Initial Reporting

  1. All medical issues experienced by subjects, whether related or unrelated to the study drug, must be recorded as AEs.
  2. The CRC must notify the Clinical Safety Officer and PI within 2 hours of identifying any SAE.
  3. Document details in source notes, AE Log, and Annexure-1: Adverse Event Reporting Form.

5.2 SAE Assessment and Classification

  1. The PI shall evaluate and classify the event based on:
    • Seriousness (e.g., hospitalization, life-threatening, disability)
    • Expectedness (based on Investigator’s Brochure or Product Insert)
    • Causality (related/unrelated/probable/possible)
  2. Severity grading (mild, moderate, severe) must be documented.

5.3 SAE Reporting to Sponsor

  1. Initial SAE report must be sent to the Sponsor within 24 hours of awareness using Annexure-2: SAE Notification Form.
  2. Include:
    • Subject details (coded ID)
    • Event description and timelines
    • Concomitant medications
    • Outcome (if available)
    • Medical assessment
  3. Follow-up reports must be submitted within 7 calendar days or earlier upon request.

5.4 Reporting to Ethics Committee (IEC/IRB)

  1. Submit a copy of the SAE report to the IEC within 7 working days of occurrence.
  2. Include covering letter, SAE form, PI assessment, and any hospital documents in a compiled dossier (Annexure-3).
  3. Ensure acknowledgment receipt is recorded in Annexure-4: EC Submission Log.

5.5 Safety Follow-Up and Monitoring

  1. Ensure regular follow-up with the subject until the resolution or stabilization of the SAE.
  2. Update sponsor and EC with outcome status using Annexure-5: SAE Follow-Up Form.

5.6 Regulatory Compliance and Timelines

  1. All reports must comply with Schedule Y timelines and applicable ICH guidelines.
  2. Maintain SAE communication records for a minimum of 5 years post-study completion.

5.7 Serious Breaches

  1. If the SAE indicates a serious breach of GCP or protocol:
    • Notify the Sponsor and EC immediately
    • Initiate internal CAPA (Corrective and Preventive Action)
    • Document in Annexure-6: Serious Breach Report

6. Abbreviations

  • AE: Adverse Event
  • SAE: Serious Adverse Event
  • EC: Ethics Committee
  • PI: Principal Investigator
  • CRC: Clinical Research Coordinator
  • CAPA: Corrective and Preventive Action

7. Documents

  1. Adverse Event Reporting Form – Annexure-1
  2. SAE Notification Form – Annexure-2
  3. SAE Submission Dossier to EC – Annexure-3
  4. EC Submission Log – Annexure-4
  5. SAE Follow-Up Form – Annexure-5
  6. Serious Breach Report – Annexure-6

8. References

  • ICH E6(R2) – Good Clinical Practice
  • Schedule Y – Drugs and Cosmetics Rules, India
  • WHO Guidelines for Clinical Safety Reporting

9. SOP Version

Version: 2.0

10. Approval Section

Prepared By Checked By Approved By
Signature
Date
Name
Designation
Department

11. Annexures

Annexure-1: Adverse Event Reporting Form

Subject ID VOL1071
Date of AE 15/04/2025
Description Mild dizziness post-dose
Severity Mild
Outcome Resolved

Annexure-2: SAE Notification Form

Subject ID VOL1085
SAE Type Hospitalization due to syncope
Onset Date 16/04/2025
PI Assessment Possibly related

Annexure-3: SAE Submission Dossier to EC

Document Included
Cover Letter Yes
SAE Form Yes
Hospital Records Yes
PI Assessment Yes

Annexure-4: EC Submission Log

Date Subject ID Submitted To Mode Received By
17/04/2025 VOL1085 IEC-A Email Dr. Sangeeta Iyer

Annexure-5: SAE Follow-Up Form

Subject ID VOL1085
Event Outcome Recovered on 18/04/2025
Final Assessment Event resolved without sequelae

Annexure-6: Serious Breach Report

Issue Failure to notify SAE within 24 hours
Impact Regulatory non-compliance
CAPA Re-training of CRC, escalation SOP amended

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 to include new annexures and follow-up formats Inspection Readiness QA Head
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