| How does the CIRB process
work? (Detailed Version) |
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Here is a
more detailed review of the steps involved in the review
process for the Central IRB and the local IRB: |
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CIRB Procedures
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As outlined in the NCI CIRB Operations Office Standard Operating Procedures, the CIRB receives the protocol, the informed consent document(s), a completed
CIRB application and, when appropriate, an investigator drug brochure from the
Cooperative Group via the Protocol Information Office at NCI. The CIRB staff clarifies
any initial issues with the Study Chair of the Cooperative Group, designates the
next meeting date for review, and assigns primary reviewers (two for the Adult CIRB and three for the Pediatric CIRB).
The CIRB Chair decides if additional expertise (e.g., a consultant) needs to be brought
into the review process.
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The
CIRB members meet at least once a month.
At the meetings the Board members discuss the protocol and may consult by telephone with
the Study Chair to explore any concerns they may have.
Per the NCI CIRB Board Standard Operating Procedures, the Board takes one of the following actions for each protocol:
approve, approve pending modification, table, or disapprove. Any non-approval is
followed up with communication with the Study Chair to resolve, wherever possible,
outstanding issues identified by the Board.
After approval or disapproval, the Study Chair
of the Cooperative Group is formally notified.
For each protocol, the CIRB's primary reviews, minutes, notification letters,
and any other correspondence are posted in a separate section of this web site for
participating institutions to access.
In addition to conducting initial reviews, the CIRB conducts Continuing Reviews and
reviews of Serious Adverse Events (SAEs), Data Safety Monitoring Board (DSMB) reports,
protocol amendments, national subject recruiting materials, etc. These actions
are also posted on the web site for prompt access by participating institutions.
LOCAL INSTITUTION PROCEDURES
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A local
investigator at a participating institution who wishes to enroll
subjects in a CIRB-approved study downloads the Local IRB Facilitated Review Packet and any other documents as desired by their local IRB, from the
Participant side of this website and submits these documents
to his/her local IRB. Alternately, local IRB Office Staff can download these same materials for submission to the IRB.
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Each
local IRB designates at least one voting member of the
IRB to conduct the "facilitated review" of the study that the
investigator submitted. The role of the person(s) is to
determine whether there are local concerns that need to be
addressed and whether to accept the CIRB Review. Local IRBs need
to comply with
OHRP guidance that, "…an institution relying upon another
institution's IRB has a responsibility to ensure that the
particular characteristics of its local research context are
considered through subsequent review by appropriate designated
institutional officials, such as the Chairperson and/or other
members of its local IRB."
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The
designated person(s) examines the materials available on the
CIRB web site, and/or such other information as they may seek,
so they can decide whether a particular protocol and informed
consent documents are acceptable and whether they are
appropriate in their local context. We have created the
Quick Guide and the
Procedures Checklist for your use.
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Local
IRB policies should specify if that person(s) has more than a
"yea or nea" authority, whether they (or other IRB members) can
propose/approve additions to the protocol or word substitutions
in the informed consent (see next paragraph). Local IRBs have
the option to accept the CIRB approval "as is", accept it with
de minimus modifications (see below), or they may decide not to
accept the CIRB review and require that the investigator submit
the protocol for full Board review at their site. If the
designated person(s) do not accept the CIRB review they may
still utilize CIRB written materials as resources for their
local process.
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Local
boilerplate additions to the informed consent dealing with state
and local law, institutional requirements, or IRB policies may
be added to the local consent form. No CIRB approved information may be
deleted from the informed consent document. Local IRBs may also make
minor word substitutions or additions in the informed consent
document, particularly to facilitate better comprehension by the
local population, as long as the proposed changes do not
alter the meaning of the CIRB approved contents.
Additional risks may be added to the informed consent document. Revisions/changes to the local consent form other than those
described above require full board review at the local level,
facilitated review may not be used, and the CIRB
cannot serve as the IRB of record for the study at the local
site.
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The
local IRB must notify the Central IRB Operation's Office each
time it accepts the CIRB review of a study. Clicking on the
"Facilitated Review Acceptance" button/link within the main menu
for each study and completing
the Facilitated Review
Acceptance Form does this. In order for the CIRB to
become the Official IRB of Record for the site for a particular
study, this form needs to be completed and submitted. A separate
form must be submitted for each study review that is
accepted.
The CIRB
will use this reply to set up a database both for record keeping
and notification purposes. The CIRB will notify the local IRB when
there are any actions taken on the study, e.g., an SAE report
provoking a change in the consent form, an approved protocol
amendment, a change in the protocol/informed consent resulting
from the Continuing Review, etc.
DIVISION OF CIRB AND LOCAL
RESPONSIBILITIES - DRAWING THE LINE
What exactly will the CIRB do for the participating local IRBs, and what do
the local IRBs have to do in this shared arrangement? It is important that the
combined efforts results in a complete program of human subjects protection.
For more details please refer to the following document which clarifies the
respective responsibilities of the parties;
"Division of Responsibilities between NCI's
Central IRB and Local Institutions".
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