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EDC Management Sheet: Precautions For Sheet Completion Ver.1.00
EDC Management Sheet: Precautions For Sheet Completion Ver.1.00
EDC Management Sheet: Precautions For Sheet Completion Ver.1.00
00
海外とのコミュニケーションのために日本製薬工業協会にて自主的に翻訳したものであり、翻訳内容については責任を負えないことを予めご了承ください。
訳注2:GCPの運用通知については、対応するICH-GCPを引用しております。そのため、PMDAのシートにはないICH-GCPについても記載しております。
Regarding clinical trials, etc. using EDC, record the summary of the procedures for assuring the quality of data etc.
(3 In using electronic record, since appropriate system selection, appropriate allocation of authority of entry and modification to users, appropriate use by the
) authorized users, etc. are important to prevent falsification or loss of data, specifically record the means and procedures for assuring the quality of data
etc.
Though this sheet is introduced as a material to be reviewed in compliance inspections by PMDA, it is also assumed that the sponsors/marketing
(4
authorization holders (MAH) etc. Use it as a self-checking tool by recording the information on ongoing clinical studies etc., and updating and maintaining
) as needed after the completion of compliance inspections or in changing the systems/procedures, etc.
(5 In this sheet, start recording from clinical trials, etc. included in the application package to be inspected in the first compliance inspection using this sheet.
) For compliance inspections for the second time and later, do not delete the contents of the sheet submitted previously, but add only the items changed.
(7 "Operational Procedure Sheet" and "Operating Experience Sheet" can be maintained in separate files. In such a case, they can be submitted as separate
) files without integrating them for the inspections.
It is possible to modify the format and use it according to type of management in the sponsors/MAHs etc.
(8 ・ If you want to maintain the sheet by MS-Word, create MS-Word version of the Management sheet in your company and use it.
) ・ Each item in the sheet is the minimum to be confirmed. Regarding the items, it is possible to add items appropriately based on the actual management
conditions, but it is required to deal with them properly while holding necessary information.
Specifically record the information common to the system according to each item in the sheet.
(1 Specifically record the summary of the procedure and resulting documents so that people other than the reporter can understand the contents of the
) written procedures.
Based on the actual condition of each sponsor/MAH etc., it can be organized by adding attachment appropriately.
(2 When the same procedures have ever been used in multiple clinical trials, etc., provide the information common to the system.
) Regarding the individual written procedures to each clinical trials, etc., record them in "Operating Experience Sheet" by each clinical trials, etc.
(3 If there are changes, etc. in the sheet items including the revision of the documented procedures, do not delete the contents before changes, but add the
) updates by inserting a column to the right in sequence.
(4
If there are multiple written procedures to be recorded, add rows appropriately and use them.
)
Regarding the events to be recorded in the section of 6. "(Critical) system faults occurred and incompliance with the procedure during the trial," "Matters
pointed out in previous inspections," and improvements made, The sponsor/MAH etc. is to judge based on the items pointed out in the previous
(5
inspections and the items to which the company offered improvement as a response to the inquiries.
) Occurrences of the situation where data entry couldn't be reflected correctly (lack of data or audit trail, data collection errors occurred due to error in setup
of individual clinical trials, etc.), improper use of user ID etc which affected on the blindness, safety of the subjects/patients, and so on are included.
(2 Describe individual resulting contracts, written procedures, etc. for each clinical trial.
) When the same procedures are used in multiple trials in this system, describe the information common to the system in "Operational Procedure Sheet."
In this sheet, record not only the information of clinical trials, etc. included in the application package subject to the compliance inspection (including
(3
clinical trials, etc. performed abroad) but also that of clinical trials, etc. (clinical trials, etc. in Japan local and global clinical trials including Japan) which
) was ongoing or started with this EDC system after the first compliance inspection using this sheet.
(4 In the column "In-scope of this time of inspection?", check either "Yes" or "No" according to whether or not clinical trials, etc. listed are subject to the
) compliance inspection when this sheet is submitted.
1
EDC Management Sheet (for Sponsor/Marketing Authorization Holder ※Ver1.00
(MAH)) Operational Procedure Sheet (JPMA Translation)
2
Name of the sponsor or the
MAH
3
※In this sheet, "Clinical trials, etc." means "clinical trials, post-marketing clinical trials, and use-results
surveys".
4 1. System overview
5
Non-functional updates:
• Medical coding – updated disclaimer.
Date/period of Contract, etc. Contract date: Contract date: Contract date: Contract date:
Contract period (from): Contract period (from): Contract period (from): Contract period (from):
25
Contract period (until): Contract period (until): Contract period (until): Contract period (until):
Automatic contract renewal £No £Yes Automatic contract renewal £No £Yes Automatic contract renewal £No £Yes Automatic contract renewal £No £Yes
26
27 Name of vendor/contracted resource (2)
Date/period of Contract, etc. Contract date: Contract date: Contract date: Contract date:
Contract period (from): Contract period (from): Contract period (from): Contract period (from):
29
Contract period (until): Contract period (until): Contract period (until): Contract period (until):
Automatic contract renewal £No £Yes Automatic contract renewal £No £Yes Automatic contract renewal £No £Yes Automatic contract renewal £No £Yes
30
35
Authenticity of Electromagnetic records should have integrity, accuracy and reliability, and the responsibility for their creation, modification, and deletion should
36 ER/ES Guideline 3.1.1. Electromagnetic be clear.
Records In order to ensure their authenticity, the following requirements should be met;
Other
Document number:
Document title:
Version:
44
Effective date:
Differences from previous version:
Summary of the procedure and resulting
documents
58
Readability of
The contents of electromagnetic records should be provided as human readable format (output to display devices, print to paper and duplicate to
59 ER/ES Guideline 3.1.2. Electromagnetic
electromagnetic recording media).
Records
65
Storability of Electromagnetic records should be retained in a condition under which their authenticity and readability are ensured throughout their retention
66 ER/ES Guideline 3.1.3. Electromagnetic period.
Records In order to ensure their storability, the following requirements should be met;
71
Entry column
84 Regulatory requirements Management Method * Provide the information about the organization who directly administers the electromagnetic records. If the sponsor / MAH actively participate in the system administration,
provide the both information
Person responsible
86 Thomas Kaponen, Director
Kai Eriksson
Yusuke Nakazawa
87 Administrators Yasuya Yoshimura
Mariko Noda
Junzhen Ma
89 Facilities/equipment
Training
ER/ES Guideline 5.
Persons intending to use * Describe the training for
electromagnetic records and the person who
electronic signatures as administers/maintains All of the above receive regular training
90 documents and source electromagnetic records. that is documented in their respective
documents in their submissions Training for end users is Training Records at PCG Japan.
for the approval or licensing of described in the above
medical products and for section of "Education and
registration of conformity training on securing of
certification bodies should have security"
defined the specifics related to
the person in charge,
administrators, organization,
91 Post completion of the Clinical Trial etc.
facilities, and training that are
required for the use of
electromagnetic records and
Person responsible
92 electronic signatures.
93 Administrators
94 Organization
95 Facilities/equipment
Training
97
98
6. "(Critical) system faults occurred and incompliance with the procedure during the trial," "Matters pointed out in previous
inspections," and improvements made
• (Critical) system faults occurred and incompliance with the
procedure during the trial
• Matters pointed out in the prior inspection
Date of the inspection / date
99 when the sponsor knew the System (version) Trial number *Such occurrence as lack of data or audit trails, data collection Improvement status (including the consideration of impact to other trials)
situation error occurred due to an error in setting an individual trial, event
which influenced blindness or safety of trial subjects,
unauthorized use of use ID and so on will be specified.
100
101
102
103
104 7. Revision history of this EDC Management Sheet
105 Revision number Document date Contents
106 1
107 2
108 3
1
EDC System Sheet (for sponsor / MAH) Operating Experience Sheet (JPMA Translation)
2 Vendor/Contracted resource
Written procedures of
(Contract for each clinical trial) *In case another written
System Trial substance Procedure of validation upon requesting user registration,
Trial In-scope of this time * The individual agreement stated in Written procedure for training procedures is to be added, Date of application for
number
Name code or product Title of the Clinical Trial etc. (Period of Clinical Trial etc.: - )
of inspection? the Operational Sheet "2.
setting of trial information granting ID/password,
on security insert a new column to Brand/trade name CTD number
(version) name (Trial specific UAT etc.) reviewing users, removing the approval
Subcontracting agreement" will be provide the information.
registered users
specified.
3 1 Name of vendor/contracted resource Document number: Document number: Document number: Document number:
Scope of outsourced services: Document title: Document title: Document title: Document title:
Contract date: Version: Version: Version: Version:
Contract period (from): Effective date: Effective date: Effective date: Effective date:
□ Yes
□ No Contract period (to): Summary of the procedure Summary of the procedure Summary of the procedure Summary of the procedure
Automatic contract renewal £No and resulting documents: and resulting documents: and resulting documents: and resulting documents:
£Yes Completion date of UAT:
4 2
5 3
6 4
7 5
Revision History EDC Management Sheet (Template)
(Templ
Date of Template
ate) Revision Comment
Creation/Revision
Ver
1.0 3/27/2013 Newly Issued