AYUSH - GCP

Dr Sathiya Rajeswaran
Research Offi cer
SCRI,CCRS,Chennai

All roads meet a common goal

Roads are different goal is same

ICMR
WHO
OECD-ICH
CDSCO

Goal
Patient safety primary goal

GCP?
Good Clinical Practice is a set of guidelines which
encompasses the
design
conduct
termination
audit
analysis
reporting and
documentation of the studies involving humansubjects.

Fundamental tenet of GCP

Science at any point of time should not taken as granted
and harm the subject.
ensure that the studies are scientifically and ethically
sound.
clinical properties of the ASU medicine under
investigation are properly documented

Science if taken granted?

Phase I trial sub :

Two cardinal principles:

Protection of the rights of humansubjects.
Authenticity of ASU medicine clinical trial data
generated.
Guidelines are formulated based on CDSCO Document
on GCP Guidelines (2001) for Clinical Trials on
Pharmaceutical Products.
ASU medicines research in India at all stages of drug
development, whether prior or subsequent to product
registration in India.

Swift Reminiscence
1.1 Act
Wherever relevant, the Act means Drugs & Cosmetics
Act 1940 (23 of 1940) and the Rules made thereunder.
1.2 Adverse Event (AE)
Any untoward medical occurrence (including a
symptom / disease or an abnormal laboratory finding )
during treatment with a pharmaceutical product in a
patient or a human volunteer that does not necessarily
have a relationship with the treatment being given.

 Adverse Drug Reaction (ADR)

(a) In case of approved ASU Medicines: A noxious and
unintended response at doses
normally used or tested in humans
(b) In case of new unregistered ASU Medicines: A noxious
and unintended response at any
dose(s)

ADR Vs AE
The phrase ADR differs from AE, in case of an ADR there
appears to be a reasonable possibility that the adverse
event is related with the medicinal product being studied. In
clinical trials, an untoward medical occurrence seemingly
caused by overdosing, abuse dependence and interactions
with other medicinal products is also considered as an ADR.
Adverse drug reactions are type A (pharmacological) or type
B (idiosyncratic). Type A
reactions represent an augmentation of the pharmacological
actions of a drug. They are dose dependent and are,
therefore, readily reversible on reducing the dose or
withdrawing the drug.
In contrast, type B adverse reactions are bizarre and cannot
be predicted from the known pharmacology of the drug.

Audit of a Trial
A systematic verification of the study, carried out by
persons not directly involved, such as:
(a) Study related activities to determine consistency
with the Protocol
(b) Study data to ensure that there are no contradictions
on Source Documents. The audit should also compare
data on the Source Documents with the interim or final
report. It
should also aim to find out if practices were employed in
the development of data that would impair their validity.
(c) Compliance with the adopted Standard Operating
Procedures (SOPs)

ASU Act
1.5 Ayurveda Siddha Unani Drugs- (Added from D&C Act)
Ayurvedic, Siddha or Unani durg includes all medicines
intended for internal or externaluse for or in the diagnosis,
treatment, mitigation or prevention of [disease or disorder in
Human beings or animals, and manufactured exclusively in
accordance with the formulae described in, the authoritative
books of Ayurvedic, Siddha and Unani Tibb system
ofmedicine, specified in the First Schedule;
1.6 Patent or Proprietary Medicine- (Added from D&C Act)
In relation to Ayurvedic, Siddha or Unani Tibb systems of
medicine of all formulations containingonly such ingredients
mentioned in th formulae described in the authoritative books
of Ayurveda,Siddha or Unani Tibb system of medicine
specified in the first Schedule, but does not include
amedicines which is administered by parenteral route and
also a formulation included in theauthoritative books as
specified in clause (a)

 1.8 Blinding / Masking

A method of control experimentation in which one or
more parties involved are not informed of the treatment
being given. Single blind refers to the study subject(s)
being unaware, while Double blind refers to the study
subject(s) and/or investigator(s), monitor, data analyst(s)
are being unaware of the treatment assigned.
1.9 Case Record Form (CRF)
A document designed in consonance with the Protocol, to
record data and other information on each trial subject.
The Case Record Form should be in such a form and format
that allows accurate input, presentation, verification, audit
and inspection of the recorded data. A CRF may be in
printed or electronic format.

Exercise -1
RGM phase I

Phase I if to b carried out to b in healthy volunteers

Phase I if to b carried out to b in Cancer pts

Phase I
The objective of studies in this Phase is the estimation of safety and tolerability
with the initial administration of an ASU Drugs / other T M new drug into
human(s). Studies in this Phase of development usually have non-therapeutic
objectives and may be conducted in healthy volunteers subjects or certain types
of patients.
Drugs with probable toxicity e.g.drugs with Schedule E-I ingredients are usually
studied in patients. Phase I trials should preferably be carried out with access to
the necessary facilities to closely observe and monitor the Subjects.
(ii) Studies conducted in Phase I, usually intended to involve one or a
combination of the following objectives:(iii) Maximum tolerated dose: To determine the tolerability of the dose range
expected to be needed for later clinical studies and to determine the nature of
adverse reactions that can be
expected. These studies include both single and multiple dose administration.
(iv) Early Measurement of Drug Activity: Preliminary studies of activity or
potential
therapeutic benefit may be conducted in Phase I as a secondary objective.
Such studies are generally performed in later Phases but may be appropriate
when drug activity is readily measurable with a short duration of drug exposure
in patients at this early stage.

Phase II
(i) The primary objective of Phase II trials is to evaluate the
effectiveness of an ASU
drug for a particular indication or indications in patients with the
condition under study and to determine the common short-term
side-effects and risks associated with the drug.
Studies in Phase II should be conducted in a group of patients who
are selected by relatively narrow criteria leading to a relatively
homogeneous population.
These studies should be closely monitored. An important goal for
this Phase is to determine the dose(s) and regimen for Phase III
trials. Doses used in Phase II are usually (but not always) less than
the highest doses used in Phase I. These studies should be intended
to provide an adequate basis for marketing approval for ASU Drugs.
(ii) Additional objectives of Phase II studies can include evaluation of
potential study
endpoints, therapeutic regimens (including concomitant
medications) and target populations
(e.g. mild versus severe disease) for further studies in Phase II or III.
(iii) These objectives may be served by exploratory analyses,
examining subsets of data and

Phase III
Studies in Phase III are designed to confirm the
preliminary evidence accumulated in Phase II that a drug
is safe and effective for use in the intended indication
and recipient population. Studies in Phase III may also
further explore the dose-response relationships
(relationships among dose, and clinical response), use of
the drug in wider populations in different stages of
disease, or the safety and efficacy of the drug in
combination with other drug(s).

Controversy over drug in diff

demography
The `opinion poll' on Nimesulide conducted by the
Indian Medical Association calling it `safe' may not end
the controversy over the popular fever drug yet. For not
only have medical researchers questioned the process
but some leading doctors have directly written to the
Drug Controller of India to ban its use.

Phase III Contd

For ASU drugs approved outside India, Phase III studies
needs to be carried out primarily to generate evidence of
efficacy and safety of the drug in Indian patients when used
as recommended in the prescribing information. Prior to
conduct of Phase III studies in Indian subjects, Licensing
Authority may require detailed safety studies and if possible,
pharmacokinetic studies to be undertaken to verify that the
data generated in Indian population is in conformity with the
data already generated abroad.
(iv) If the application is for the conduct of clinical trials as a
part of multi-national clinical development of the drug, the
number of sites and patients as well as the justification for
undertaking such trials in India should be provided to the
Licensing Authority along with the application

Phase IV
Post Marketing trials are studies (other than routine
surveillance) performed after drug approval and related to
the approved indication(s). These trials go beyond the prior
demonstration of the drugs safety, efficacy and dose
definition.
These trials may not be considered necessary at the time of
new drug approval but may be required by the Licensing
Authority for optimizing the drugs use. They may be of any
type but should have valid scientific objectives.
Phase IV trials include additional drug-drug interaction(s),
dose response or safety studies and trials designed to
support use under the approved indication(s),
e.g. mortality/morbidity studies, epidemiological studies etc.

Data Safety Management Board

The Data and Safety Monitoring Board (DSMB) is a
board, charged with monitoring the accumulating data
from a pharmaco therapeutic clinical trial to detect and
report early evidence of pre specified or unanticipated
benefit or harm to trial participants that may be
attributable to one of the treatments under evaluation.
The DSMB will conduct an independent, objective review
of all accumulated data from both blinded and unblinded
clinical trials in such a manner as to maximize benefit to
the trial participants and to the research effort.

Interim analysis
An interim analysis is any assessment of data done
during the patient enrolment or follow-upstages of a trial
for the purpose of assessing center performance, the
quality of the data collected, or treatment effects.

Vulnerable Participant
A vulnerable participant is any individual who lacks the
ability to fully consent to participate in a study.

Study design
Information on Anupanam, Pathyam,Udal vaagu, Pre
requisite procedures(Bethi , Vaanthi,Anjanam,NasiyamTherapeutic) other relevant scientific considerations of
siddha system of medicine if appropriate and required.

Inc / Exc Criteria

Questionnaire for Udal Vaagu evaluation if applicable is
included.

Safety handling of ASU Drugs

a. Measures to be implemented to ensure the safe
handling and storage of theASU Medicine.
b. System to be followed for labelling of the product(s)
(code numbering etc.)
c. The label should necessarily contain the following
information: the words For Clinical Studies only, the name or a code number
of the study, name and
contact numbers of the investigator, name of the
institution, subjects
identification code.

Informed Consent in Non-Therapeutic

Study :
In case of a Non-Therapeutic Study the consent must always be
given by the
subject. Non-Therapeutic Studies may be conducted in subjects
with consent of a legal representative or guardian provided all
of
the following conditions are fulfilled:
1. The objective of the Study can not be met by means of a
trial
in Subject(s) who can personally give the informed consent
2. The foreseeable risks to the Subject(s) are low
3. Ethics Committees written approval is expressly sought on
the inclusion of such Subject(s)

Trial in Children:
children will not be involved in research that could be carried out
equally well withadults; the purpose of the research is to obtain
knowledge relevant to health needs of children.
For clinical evaluation of a new drug the study in children should
always be
carried out after the phase III clinical trials in adults. It can be studied
earlier only if the drug has a therapeutic value in a primary disease of
the children
Parent or legal guardian of each child has given proxy consent;
The assent of the child should be obtained to the extent of the child's
capabilities such as in the case of mature minors, adolescents etc;
Research should be conducted in settings in which the child and
parent can obtain adequate medical and psychological support;
If interventions intended to provide direct diagnostic, therapeutic or
preventive benefit for the individual child subject must be justified in
relation to anticipated risks involved in the study and anticipated
benefits to society;

Assent
Paediatric Subjects are legally unable to provide written informed
consent, and are
dependent on their parent(s)/legal guardian to assume responsibility
for their
participation in clinical studies. Written informed consent should be
obtained from the parent/legal guardian.
However, all paediatric participants should be informed to the
fullest extent possible about the study in a language and in terms
that they are able to
understand.
Where appropriate, paediatric participants should additionally
assent to enrol in the study. Mature minors and adolescents should
personally sign and date separately designed written assent form.
Although a participants wish to withdraw from a study must be
respected, there may be circumstances in therapeutic studies for
serious or life-threatening diseases in which, in the opinion of the
Investigator and parent(s)/legal guardian, the welfare of a paediatric
patient would be jeopardized by his or her failing to participate in
the study. In this situation, continued parental/legal guardian
consent should be sufficient to allow participation in the study.

PSUR
Periodic safety update reports
marketing
Circumstances.

- Essential in Post

Ordinarily all dosage forms and formulations as well as

indications for new drugs should be covered in one PSUR

Investigator in AYUSH Trial

The investigator should be qualified by education, training and
experience to
assume responsibility for the proper conduct of the study and should
have
qualifications prescribed by the Central Council of Indian Medicine
(CCIM).
However, the Principle Investigator / Chief Investigator should be from
respective ASUsystem. The investigator should provide a copy of the
curriculum vitae and / or other relevant documents requested by the
sponsor, the ethics committee, the CRO or the regulatory authorities.
He / she should clearly understand the time and other resource
demands the study is likely to make and ensure they can be made
available throughout the duration of the study.
The investigator should also ensure that other studies do not divert
essential subjects or facilities away from the study at hand.

THANK
YOU