III.
WHEN OVERSIGHT OF A PREVIOUSLY APPROVED CLINICAL
INVESTIGATION TRANSFERS FROM THE ORIGINAL IRB TO ANOTHER
IRB NOT PART OF THE SAME INSTITUTION
When transferring IRB review and oversight of clinical investigations from one IRB to another
IRB, FDA recommends that a plan for the transfer process be documented in a written agreement
between the original and receiving IRBs, if appropriate.
9,10
The agreement should address how
the IRBs should handle, and document as appropriate, the following eight steps. We describe
each of these steps in more detail below. Please note, this list is not meant to be exhaustive.
Additional actions may be necessary and/or appropriate.
(1)
Identifying those studies for which IRB oversight is being transferred;
(2)
Ensuring the availability and retention of pertinent records;
(3)
Establishing an effective date for transfer of oversight, including records, for the clinical
investigation(s);
(4)
Conducting a review of the study(ies) by the receiving IRB, where appropriate, before it
accepts responsibility for the study(ies);
(5)
Confirming or establishing the date for the next continuing review;
(6)
Determining whether the consent form needs to be revised;
8
FDA encourages the use of central IRBs, in appropriate circumstances, as a mechanism to reduce burden and
delays in the conduct of multicenter clinical trials. The goal of the centralized process is to increase efficiency and
decrease duplicative efforts that do not contribute to meaningful human subject protection. For additional
information relating to the use of central IRBs, see FDA’s Guidance, “Using a Centralized IRB Review Process in
Multicenter Clinical Trials,” available at
http://www.fda.gov/RegulatoryInformation/Guidances/ucm127004.htm
.
9
FDA recognizes that for transfer of oversight to an IRB at the same institution, a written agreement may not be
necessary as the process may be addressed by the institution’s established procedures (assuming all appropriate steps
described in Section III are covered).
10
In general, some IRBs may have a policy not to transfer or accept a study until a final transfer contract or similar
agreement is signed by both the original and receiving IRBs.
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