applied worldwide. The FDA and NIH have adopted many ICH standards (with some
modifications).
Working with Institutional Review Boards
For all protocols that describe research that could potentially be considered human research, in the
United States, an ethics board called an Institutional Review Board (IRB) must review the protocol
and approve it (or find it exempt from human research laws) before you can start the research. You
have to submit an application along with the protocol and your plans for gaining informed consent of
potential participants to an IRB with jurisdiction over your research and ensure that you are approved
to proceed before you start.
Most medical centers and academic institutions (as well as some industry partners) run their own IRBs
with jurisdiction over research conducted at their institution. If you’re not affiliated with one of these
centers or institutions (for example, if you’re a freelance biostatistician or clinician), you may need the
services of a consulting or free-standing IRB. The sponsor of the research may recommend or insist
you use a particular IRB for the project.
Getting informed consent
An important part of protecting human participants is making sure that they’re aware of the risks of a
study before agreeing to participate in it. They also need to be fully informed as to what will happen in
the study before they can give consent to participate. You must prepare an Informed Consent Form
(ICF) describing, in simple language, the nature of the study, why it is being conducted, what is being
tested, what procedures participants will undergo, and the risks and benefits of participation. The ICF
is used to guide study staff when they explain the study to potential participants, who are then expected
to sign it if they want to participate in the study.
Potential participants must be told that they can refuse to participate with no penalty to them, and if
they join the study, they can withdraw at any time for any reason without fear of retribution or the
withholding of regular medical care. The IRB can provide ICF templates with examples of their
recommended or required wording.
Prior to performing any procedures on a potential participant (including screening tests
involved in determining eligibility), study staff must go through an approved ICF document with
the potential participant and give them time to read it and decide whether or not they want to
participate. If they choose to participate, the ICF must be signed and witnessed. The signed ICFs
must be retained as part of the official documentation for the project, along with all data collected
(including laboratory reports, ECG tracings, and records of all test products administered to the
participants), as well as records of all procedures performed on participants. The sponsor, the
regulatory agencies, the IRB, and other entities may ask to review these documents at any time as
part of oversight.
Considering data safety monitoring boards and committees
For clinical trials of interventions that are likely to be of low risk (such as drinking green tea),
investigators are usually responsible for ensuring participant safety by tracking unexpected adverse
events, abnormal laboratory tests, and other red flags during the course of the study. But for studies