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
- All medical issues experienced by subjects, whether related or unrelated to the study drug, must be recorded as AEs.
- The CRC must notify the Clinical Safety Officer and PI within 2 hours of identifying any SAE.
- Document details in source notes, AE Log, and Annexure-1: Adverse Event Reporting Form.
5.2 SAE Assessment and Classification
- 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)
- Severity grading (mild, moderate, severe) must be documented.
5.3 SAE Reporting to Sponsor
- Initial SAE report must be sent to the Sponsor within 24 hours of awareness using Annexure-2: SAE Notification Form.
- Include:
- Subject details (coded ID)
- Event description and timelines
- Concomitant medications
- Outcome (if available)
- Medical assessment
- Follow-up reports must be submitted within 7 calendar days or earlier upon request.
5.4 Reporting to Ethics Committee (IEC/IRB)
- Submit a copy of the SAE report to the IEC within 7 working days of occurrence.
- Include covering letter, SAE form, PI assessment, and any hospital documents in a compiled dossier (Annexure-3).
- Ensure acknowledgment receipt is recorded in Annexure-4: EC Submission Log.
5.5 Safety Follow-Up and Monitoring
- Ensure regular follow-up with the subject until the resolution or stabilization of the SAE.
- Update sponsor and EC with outcome status using Annexure-5: SAE Follow-Up Form.
5.6 Regulatory Compliance and Timelines
- All reports must comply with Schedule Y timelines and applicable ICH guidelines.
- Maintain SAE communication records for a minimum of 5 years post-study completion.
5.7 Serious Breaches
- 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
- Adverse Event Reporting Form – Annexure-1
- SAE Notification Form – Annexure-2
- SAE Submission Dossier to EC – Annexure-3
- EC Submission Log – Annexure-4
- SAE Follow-Up Form – Annexure-5
- 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 | 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 |