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GUIDELINES FOR PRINCIPLES AND RULES FOR GOOD
CLINICAL PRACTICES OF ADVANCED THERAPY MEDICINAL
PRODUCTS
17.04.2013
1
1. PURPOSE
This guideline is prepared to regulate the detailed rules for the good clinical practices of
advanced therapy medicinal products.
2. DEFINITIONS
2.1. Donation: Donation of human or animal tissue or cells designed for human
applications.
2.2. Human application: Use of tissues and cells in human recipients or extracorporeal
applications.
2.3. Tissue/cell center: A hospital or any other legal person, organization or entity which
undertakes processing, handling, storage or distribution of human tissues or cells.
2.4. Donor: Any alive or dead human or animal source from which human cells or tissues
are derived.
2.5. Efficiency follow-up: Systematic collection and compilation of data designed to
provide information about efficacy or efficiency of a medicinal product.
2.6. Safety follow-up: Systematic collection and compilation of data designed to provide
information about safety of a medicinal product.
2.7. Animal facility: A facility for activities relating to xenogeneic cell-based medicinal
products.
2.8. Advanced therapy medicinal product: Tissue- and cell-derived medicinal products for human use categorized as gene therapy medicinal products, somatic cell therapy medicinal products, tissue-engineering products and combined advanced therapy medicinal products.
2.9. Traceability process: Ability to localize and define each individual tissue/cell unit
during each stage from processing, testing and supplying through storage to distribution
to recipients or disposal units. This also means the ability to define the production site or
the tissue center, which receives, processes or stores tissues/cells as well as the donor
and to determine the recipients at the medical site(s), which administer the related
tissues/cells to the recipients; the traceability process also includes the competency to
localize and determine any data relating to the products and materials in contact with
these tissues/cells.
2.10. Blood center: A body or institution responsible for collecting and testing human blood
or blood components, irrespective of the purpose of use, and for processing, storage and
distribution procedures during the requested transfusion. Blood banks are excluded.
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2.11. Clinical follow-up: Follow-up of individual subjects by the investigator. This follow-up
includes prevention, screening, observation, diagnosis and treatment of diseases, as well
as injuries, complications, advers reactions and medical errors.
2.12. Supply: Process of procuring tissues and cells.
2.13. Supplier organization: A health services facility or a hospital or any other institution or
organization, not accredited, allocated, authorized or licensed as a tissue center,
responsible for supplying human tissues and cells.
3. DONATION, SUPPLY AND TESTING OF INVESTIGATIONAL ADVANCED
THERAPY MEDICINAL PRODUCTS
3.1. Except for the sponsor; investigators and manufacturers/importers and other parties,
including tissue centers, blood centers, supplier organizations, animal facilities and
donors, should be considered in relation to investigational advanced therapy medicinal
products (ATMPs). The responsibilities of these parties and applicable regulations
should be taken into consideration.
3.2. Donation, supply and testing of human cells and tissues used in the manufacture of
investigational advanced therapy medicinal products (ATMPs) should be performed
according to the "Regulation on Human Tissues and Cells and Safety of Related
Centers”.
3.3. Particularly if the investigational ATMP to be used in clinical trials contains human cells
and tissues, the legal requirements for donors should comply with the relevant
regulation.
3.4. If the tissues and cells used in the production of investigational ATMP are derived from
animal sources, the processes relating to donation should comply with the Good
Manufacturing Practices (GMP).
4. TISSUE CENTERS OR BLOOD CENTERS AND ANIMAL FACILITIES
4.1. The responsibilities of the tissue center or the blood center and the supplier organization
with regard to donation, supply, testing, traceability requirements and other technical
requirements (e.g., processing, handling, storage and distribution) of human tissues and
cells, including blood cells, to be used in the production of an investigational ATMP are
outlined in the “Regulation on Human Tissues and Cells and Safety of Related Centers”.
4.2. If tissues or cells of animal origin are used in production of investigational ATMPs, the
requirements for sourcing/donation, supply and testing are stated in the GMP guidelines
and the relevant regulation.
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5. PRODUCTION AND IMPORT OF INVESTIGATIONAL ADVANCED
THERAPY MEDICINAL PRODUCTS
5.1. The requirements for production and import of investigational ATMPs are stated in the
relevant regulation.
6. BASIC PRINCIPLES
6.1. Use of each investigational ATMP must be traceable. Individual products, use of sources,
manufacture, packaging, storage, shipping and delivery to hospital/organization/private
application should be traceable via subject management, reconciliation and disposal or
final procedures.
6.2. The connection number in the supervision chain (from donation to subject application)
should not be more than necessary. If a product or any part of a product is sourced from
a donor, records should contain sufficient details to enable tracing of the connections to
the donor and the individual subject receiving the product (or vice versa).
6.3. Subjects should be followed up during and after the clinical trial period to enable data
collection when required about their own treatment procedures. The content of the
follow-up and, if applicable, the long-term follow-up after the end of the trial should be
determined based on the content of the investigational ATMP and risk analysis and
current information obtained about the relevant investigational ATMP. The procedures
should be continued throughout the required follow-up period and contact with the
subjects should be maintained.
6.4. If tissues and cells of animal origin are used in production of an investigational ATMP,
special cells and tissues of animal origin (e.g., cell sequences used in the production of
viral vectors) should be derived according to the regulatory requirements.
6.5. The medical care of subjects and medical decisions made should be the responsibility of
a qualified physician or dentist. However, the sponsor’s representative must be present
during application of the investigational ATMP to the subject. This expert representative
may provide advice and information to principle investigator, but principle investigator
should remain responsible for the decision to stop or change the method of application.
7. TRACEABILITY
7.1. General Needs
7.1.1. If an investigational ATMP contains human cells or tissues, the sponsor,
manufacturer and investigator/institution at the center where the product is used
must ensure that a traceability system is already in place, in accordance with or
complementary to the requirements stated in the regulations regarding
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traceability requirements for tissue centers and blood centers. In case of tissues or cells
of animal origin, the same traceability requirements apply, as stated in the relevant
regulation.
7.1.2. There should be a connection between the donor/animal source and the donation
process at the tissue center/animal facility; a connection between the donation process
and the product at the manufacturing site; and a connection between the product and
the subject at the investigator’s site. Traceability should be possible in both ways, from
source to subject and from subject to source.
7.1.3. Good clinical practices include accountability/transparency requirements for
investigational products (IP). These requirements contribute significantly to
traceability starting from the manufacturer to the release of the IP. Traceability
requirements may be met by establishing sites that enable combination of traceability
and IP accountability in order to process each particular requirement.
7.1.4. Traceability requirements should be in line with the requirements outlined in the GMP
guidelines.
7.1.5. Should the clinical trial be suspended or discontinued prematurely or the product
development interrupted, the sponsor’s obligation to ensure that the traceability system
is continued must remain. If ownership of the investigational ATMP is assigned to
another legal institution, the new owner must assume the responsibility to maintain the
traceability. Should the sponsor go bankrupt or be liquidated, or if the ownership is not
assigned to another legal institution, the traceability records are submitted to the
national competent authority.
7.1.6. Traceability methods and documentation process must be explained in the clinical trial
protocol and modified if necessary.
7.1.7. Traceability requirements should be in accordance with the regulations for free
distribution and processing of personal information. Thus, the system must allow the
complete traceability criteria, from donor to recipient, by providing the following,
using anonymous encoding systems:
7.1.7.1. The identity of human donors should be protected and these donors should
only be identified by code numbers that can be traced back to the tissue centers/blood
centers and the full identification procedures.
7.1.7.2. The identity of subject should be protected and these subjects should only be
identified by code numbers that can be traced back to the full identification procedures
by the investigator’s site.
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7.2. Responsibilities
7.2.1. Regarding the investigational ATMP, the sponsor is responsible for ensuring that
the traceability system is established and maintained. The system must ensure
tracking of the individual products or starting materials and raw materials
including all materials that come into contact with cells or tissues contained in the
product, and use of sources, manufacturing, packaging, storage, shipment and
delivery at the investigator’s site using the individual product through voluntary
or other final compliance, disposal or destruction of the product.
7.2.2. If more than one party is included, the sponsor should ensure that the tasks of
each party are complete and determined and that traceability integrity is
maintained (e.g., the investigator who obtains tissues or cells from an autologous
donor prior to the production of the investigational ATMP should be the same
investigator at the site who is responsible for management of subjects).
7.2.3. The sponsor should ensure that a connection between the investigator’s site
where the product is used and the donor/donation supplier organization and the
investigational ATMP is established and should guarantee that the traceability
system is established and maintained with the help of agreements made between
the tissue center or the blood center or the animal facility, the manufacturer and
the investigator’s site.
7.2.4. The tissue center/blood center, supplier organizations or animal facility are
responsible for using a traceability system, for supply and donation of cells or
tissues required for production of investigational ATMPs, to trace the material
back until delivery to the manufacturer. These activities should be in accordance
with the relevant guidelines.
7.2.5. The manufacturer is responsible for using a traceability system for the
manufacturing period between reception of the finished investigational ATMP
from supplier organization, the tissue/cell center or blood center or animal facility
to delivery of the investigational ATMP to the sponsor for use in the clinical trials
and delivery to the clinical trial site. Supply or delivery of the investigational
ATMP to the sponsor is performed or controlled by the manufacturer. If the
sponsor monitors delivery of the investigational ATMP from the manufacturer to
the clinical trial site, the sponsor is responsible to ensure traceability of these
process stages.
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7.2.6. The investigator or pharmacist is responsible for implementing a subject and
product traceability system at the clinical trial site. This system should include
details that enable to connect each product with the investigator or the subject
receiving the product.
7.3. Archiving for Traceability Process by Sponsor, Manufacturer, Investigator and Trial Site
7.3.1. The sponsor of the site where the investigational ATMP is used should retain any
part of the traceability records of the tissue center/supplier organization, animal
facility, manufacturer and trial site for at least 30 years after the expiry date of the
product or for a longer period, if required by the clinical trial approval conditions
or based on the agreement with the sponsor. For tissue centers, if this period is
longer than the period mentioned in the relevant regulation, the sponsor should
ensure with agreements that traceability records are retained throughout the
specified period.
7.3.2. The minimum data set to be retained by each party is detailed in ANNEX-1.
8. SAFETY REPORT AND LONG-TERM FOLLOW-UP
8.1. Reporting of adverse events and reactions by the sponsor and principal investigator in
relation to clinical trials is stated in the relevant regulation. New events relating to the
conduct of the trial and development of the investigational ATMP and that may affect
the subject’s safety should be reported within the specified time frame using the
expedited reporting procedure. This procedure should include the following at a
minimum:
8.1.1. Serious adverse events which are related to the trial methods and may require an
amendment in the conduct of the trial;
8.1.2. Significant hazards for subject population.
8.2. The sponsor should provide the principal investigator with necessary information and
training relating to product-specific requirements or any other additional protocol for
adverse event reporting. The reporting process should be clearly explained and detailed
in the clinical trial protocol. The following safety issues should be addressed:
8.2.1. Adverse events relating to the product application procedure (surgical or other),
8.2.2. Suspected and confirmed infection conditions,
8.2.3. Unexpected reactions (e.g., hypersensitivity, immunological, toxic or other
reactions and re-emergence of the current virus, as a result of a modification in
production or function of the viral vector),
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8.2.4. Adverse events relating to a product error (including lack of efficiency),
8.2.5. Adverse events relating to medications required to be used concomitantly (e.g.
immunosuppression),
8.2.6. Adverse events relating to medical devices which are part of the product or used
for product application.
8.3. The differentiated cause-effect assessment of the safety issues mentioned above should
be explained in the clinical trial protocol and implemented in the adverse event
reporting system.
8.4. If a serious adverse reaction is observed with an investigational ATMP containing cells
or tissues or with combined investigational ATMPs, all relevant parties should be
notified.
8.5. The necessity, period and nature of the follow-up procedure should be determined by
the sponsor, based on a risk analysis including close contact, and current information
obtained about the investigational ATMP and the nature of the investigational ATMP.
The sponsor should also consider the relevant regulation concerning follow-up and risk
evaluation of subjects receiving the special forms of investigational ATMPs for more
detailed information about the required follow-up type and period.
8.6. The follow-up process should be adapted to the specific product requirements,
explained in the protocol and amended as necessary in line with the development
studies with the investigational ATMP; it should clearly define the follow-up activities
and should be performed before and after the end of the clinical trial.
8.7. The rationale for the selected follow-up, including the current sponsor information,
should be documented and retained as a required clinical trial document.
8.8. The follow-up procedure should consider the following aspects:
8.8.1. Follow-up for the protection of the subject (for example, clinical follow-up),
8.8.2. Follow-up with the aim to collect personal data (may not require all subjects), e.g.
safety follow-up and efficiency follow-up.
8.9. All subjects participating in a clinical trial conducted with an investigational ATMP
should receive an alarm card from the principle investigator, which should at least
contain the name of the subject, contact number of the principle investigator and
information about the medical treatment received and should be approved by the ethics
committee, permitted by the Turkish Medicine and Medical Device Agency and
previously agreed by the sponsor.
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8.10. The protocol should define the end of the trial and which follow-up procedure will be
used after termination of the trial. Safety and efficiency follow-up (like trial visits),
requiring an effective data collection procedure, should be part of the clinical trial,
whereas clinical follow-up and passive data collection procedures should be performed
after termination of the trial.
8.11. If follow-up is required after termination of the trial, particularly if follow-up involves
a long period of time, the sponsor should ensure that a procedure is in place for
follow-up of subjects undergoing procedures with the product, even if product
development is interrupted or the (former) sponsor ceases to exist as a legal
organization. This procedure should be stated in the protocol in a way that it can be
amended when necessary and archived as follows:
8.11.1. Appropriate information about follow-up of subjects after end of clinical trial,
provided to the healthcare authority which acts as a center for specific clinical
trials,
8.11.2. Telephone numbers providing data/consultancy in case of complications,
8.11.3. In case of serious adverse reactions, the Turkish Medicine and Medical Device
Agency, study site and sponsor should be notified and in case of safety/efficiency
issues, other sources of available data and independent records and the subject
alarm cards, informing the investigators about the product, should at least contain
the subject’s name, a 24-hour available contact number of the investigator and
information about the medical treatment. These should be previously agreed by
the sponsor, approved by the ethics committee and permitted by the Turkish
Medicine and Medical Device Agency. These items can be the same as those used
in the clinical trial, if they are not amended or provided as additional information
to conform to advanced follow-up procedures after termination of the trial.
8.12. If a subject withdraws from the trial voluntarily or at the discretion of the investigator,
follow-up should be continued depending on the consent obtained from the subject.
9. Turkish Medicine and Medical Device Agency
9.1. When assessing the approval for a clinical trial using an investigational ATMP,
Turkish Medicine and Medical Device Agency consider the adequacy of the follow-up
strategy and traceability arrangements, including definitions of completion of trial and
risk assessments.
10. ETHICS COMMITTEE
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10.1. To issue an ethical opinion about clinical trials requiring use of an investigational
ATMP, the ethics committee should carefully consider the relevant regulation and the
following aspects:
10.1.1. Traceability arrangements for protection and confidentiality of the subjects’
personal data,
10.1.2. In case of problems arising after end of the trial, information to be provided to the
subject for each product use (alarm card) and follow-up arrangements prior to and
after end of the trial, including the subsequent procedures for subjects
withdrawing from the trial,
10.1.3. Arrangements regarding close contact with recipients during follow-up,
10.1.4. for ethical issues relating to suitability of specific investigational ATMPs, written
informed consent forms and other documents,
10.1.5. For management of the investigational ATMP, situations where the sponsor’s
representative has to be present when the investigational ATMP is applied to the
subject,
10.1.6. Irreversible contents of specific investigational ATMPs and information provided
to subjects on this subject,
10.1.7. Special conditions where the donor is a relative of the subject, in order to protect
from “sibling/parent” pressure.
11. PRINCIPAL INVESTIGATOR AND OTHER INVESTIGATORS
Principal investigators and other investigators in clinical trials of investigational
ATMPs should:
11.1. establish and maintain a traceability system at clinical sites,
11.2. retain their parts of traceability records of a relevant person,
11.3. be aware of the reporting procedure of adverse events and reactions, including
reactions to application of the investigational ATMP,
11.4. have knowledge about the risk analysis of the investigational ATMP,
11.5. have knowledge about requirements of storage, handling, management, disposal and
elimination of the investigational ATMP, including environmental risks and dangers
resulting from close contact and product handling,
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11.6. have knowledge of requirements for use, application, implementation or management
of the investigational ATMP and its clinical, efficiency and safety follow-up,
11.7. ensure that special requirements for application of the investigational ATMP, such as
standardization of healthcare professionals’ surgical methods and training, are
forwarded to the study site by the investigator, including surgeons and other experts,
11.8. Inform trial subjects and, if applicable, their legal representatives about issues relating
to the investigational ATMP.
12. INFORMED CONSENT FORM
Apart from the provisions in the relevant regulation, an informed consent form or any
other written information provided to trial subjects should particularly contain
following issues:
12.1. Traceability arrangements, including provisions for protection and confidentiality of
the subjects’ personal data,
12.2. In case of problems arising after end of the trial, information to be provided to the
subject for each product use and follow-up arrangements prior to and after trial
termination, including the subsequent procedures for subjects withdrawing from the
trial,
12.3. Unsuitable conditions for long-term follow-up, if applicable,
12.4. Definition of relationship to the follow-up procedure following trial termination and
definition of trial termination,
12.5. The irreversible nature of the investigational ATMP, if applicable,
12.6. The need for the sponsor representative to be present for help and support during
management of the investigational ATMP, if applicable,
12.7. Risks and measures, including reduction procedures of investigational ATMPs
requiring gene therapy,
12.8. Any information obtained during the follow-up procedure and guiding information
about how possible risks resulting from close contact should be forwarded.
13. SPONSOR
13.1. The sponsor should establish and maintain a traceability system at clinical sites,
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13.2. The sponsor should retain parts of the traceability records for a specified period,
13.3. The sponsor should implement the appropriate adverse events and adverse reactions
reporting procedure required by the relevant regulation for investigational ATMPs,
13.4. The sponsor should provide information and documents, stating that the ongoing risk
analysis is performed and provided based on information about the product type and its
purpose of use, provided to the subject and the investigator assigned to the clinical trial
through the investigator’s brochure or its updates or through informed consent forms or
their updates,
13.5. The sponsor should share the risk analysis for combined products and the risk
management plan for the device part with the investigators,
13.6. The sponsor should define the need, period and nature of the necessary clinical, safety or
efficiency follow-up, including the procedures performed after withdrawal of subjects,
13.7. The sponsor should ensure that special requirements for application of the
investigational ATMP, such as standardization of surgical procedures and training
processes used by the principle investigator and other investigators, are implemented,
13.8. The sponsor should have knowledge about requirements of storage, handling,
management, disposal and elimination of the investigational ATMP, including
environmental risks and dangers resulting from close contact and product handling,
13.9. The sponsor should provide training to investigators about a specific treatment
requiring collaboration and about the use, application, implementation or management
procedures of investigational ATMPs that may require surgical procedures which may
affect safety and efficiency of the product. The sponsor should obtain information for
the standardization and optimization of these procedures during clinical development.
The sponsor should also determine whether his/her personnel should play a role in
these procedures and explain this in the agreements made with the clinical trial site and
in the protocol or related documents submitted to the ethics committee and the Turkish
Medicine and Medical Device Agency,
13.10. The sponsor should consult the national competent authorities about bio-safety, if
applicable.
14. PROTOCOL
Considering the contents of the protocol, the sponsor should at least take the following
issues into consideration:
14.1. When designing the protocol, the variables for the diseases and the nature of the used
investigational ATMPs should be considered; the protocol should estimate the important
flexibility that may be required for addressing this variability in the use of specific
investigational ATMPs. For example: the acceptable range for the cell numbers
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and cell applicability during administration to the subjects, acceptability windows for
inclusion and exclusion of criteria.
14.2. If the investigational ATMP contains human cells or tissues, the protocol should
contain a short description of the following:
14.2.1. Verification that donation, supply and testing procedures of human tissues and
cells are in accordance with the relevant regulation,
14.2.2. Whether the donor type and donation is part of the trial procedure,
14.2.3. Compatibility of the compliance criteria of the donated material with the
specified requirements.
14.3. If the investigational ATMP contains a medical device (e.g., a combined ATMP), the
protocol should include a short description of the following:
14.3.1. Device characteristics, performance and purpose,
14.3.2. A rationale for combining the investigational ATMP with the medical device,
which may provide information about the effects alone or in combination,
14.3.3. Compliance of the product with the essential requirements stated in the relevant
regulation.
14.4. When necessary, detailed instructions for trial blinding should be provided (e.g., when
the person responsible for subject randomization to the examination needs to remain
blinded or when the person responsible for application of the investigational ATMP
needs to be blinded, while the person at the clinical site cannot be blinded at the
preparation stage of the investigational ATMP).
14.5. The traceability procedures should be documented.
14.6. Information relating to the specific requirements for safety reporting, including the
procedures performed during the follow-up period after termination of the trial should
be included.
14.7. The termination of the trial should be described and its relation to the follow-up period
following termination of the study should be clarified.
14.8. Information about the required follow-up strategy (including the follow-up
procedures after study termination) for the investigational ATMP, together with the
rationale and goals based on an adequate risk evaluation, should be included.
14.9. Regarding the follow-up strategy, in particular the specific requirements for subjects
withdrawing from the trial voluntarily or at the discretion of the investigator should be
stated.
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14.10. If there is a specific application requiring special treatment with collaboration and this
application requires surgical procedures that may affect product efficiency or safety,
information about application of an investigational ATMP should be provided. If
applicable, this should contain information regarding the standardization and
optimization of the required procedures, including surgical procedures.
14.11. For application of an investigational ATMP, information and rationale should be
provided concerning the necessity of the sponsor representative to be present during
the administration of the investigational ATMP to the subject.
14.12. Instructions for whether a local preparation or a dilution is necessary should be
included.
14.13. For investigational ATMPs requiring gene therapy, information about viral reduction
and necessary measures should be provided, if applicable.
15. INVESTIGATOR’S BROCHURE
Considering the contents of the investigator’s brochure, the sponsor should at least
take the following issues into consideration:
15.1. Explanation of the scope and adequacy of the available information and their
limitations,
15.2. Information obtained from the ongoing risk analysis, based on the available data about
the purpose of use and product type, including the risk associated with the application
method (e.g., surgical operation, concomitant medication and related devices),
15.3. Information about the risk management plan (for launched products),
15.4. Information about the risks resulting from a product error,
15.5. Information about the safe use, storage, prevention and elimination of the product,
15.6. Information about short- and long-term safety issues relating to the investigational
ATMPs, such as issues relating to medical devices for combined ATMPs or infections,
immunogenicity/immunosuppression and malignant transformations.
16. REQUIRED DOCUMENTS
16.1. For maintaining records, the rules stated in the relevant regulation are applicable.
Traceability records should be stored for a minimum of 30 years after the expiry date of
the product or for a longer period if set forth in the agreement with the sponsor or
required by the conditions of clinical trial authorization.
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16.2. While protecting the data stipulated by law for both the donor and the clinical trial
subject, each party should make any required information available related to subject
information of the subjects taking part in the clinical trial conducted at the relevant
clinical trial site with the investigational ATMP and donor information at the supply
field of the investigational ATMP prior to completion or termination of the trial, during
the trial and subsequent processes with the aim to ensure two-way traceability.
16.3. Prior to the beginning of the clinical trial phase, during the planning stage, the
following documents should be prepared and filed before the formal start of the trial:
16.3.1. Tissue center/blood center, manufacturer, sponsor and investigator/trial site file:
Procedures, responsibilities and documentation details required to document the
relation to the subject receiving the donor product (or vice versa),
16.3.2. Sponsor file:
16.3.2.1. Documents used to determine the follow-up strategy,
16.3.2.2. Information about the required follow-up strategy (including the
follow-up procedures after study termination) for the investigational
ATMP, together with the rationale and goals based on an adequate risk
evaluation.
16.4. During the clinical trial, the following documents should be included in the file:
16.4.1. Tissue center/blood center or animal facility file:
16.4.1.1. Traceability records connecting the donor/animal source to the
donated material,
16.4.1.2. Updates of procedures, responsibilities and documentation
details required to document the relation to the subject receiving the
donor product (or vice versa).
16.4.2. Manufacturer file:
16.4.2.1. Traceability records for connection of the manufactured
investigational ATMP with the donated material,
16.4.2.2. Updates of procedures, responsibilities and documentation
details required to document the relation to the subject receiving the
donor product (or vice versa).
16.4.3. Sponsor file:
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16.4.3.1. Traceability records for connecting the manufactured
investigational ATMP with the clinical trial site and the clinical trial
site with the patient code,
16.4.3.2. Updates of procedures, responsibilities and documentation
details required to document the relation to the subject receiving the
donor product (or vice versa),
16.4.3.3. Any updates on the documentation used to determine the
follow-up strategy,
16.4.3.4. Information about the required follow-up strategy (including the
follow-up procedures after study termination) for the investigational
ATMP, together with the rationale and goals based on an adequate risk
evaluation.
16.4.4. Principle investigator/trial site files:
16.4.4.1. Traceability records for connecting the manufactured
investigational ATMP with the clinical trial site and the clinical trial
site with the patient code, patient ID and the medical file,
16.4.4.2. Updates of procedures, responsibilities and documentation
details required to document the relation to the subject receiving the
donor product (or vice versa).
16.5. After the trial is completed or terminated, all documents stated in this guideline and
stored by each relevant party should be filed together with the documents below:
16.5.1. Tissue center/blood center/animal facility file: Final traceability records
connecting the donated material with the donor/animal,
16.5.2. Manufacturer file: Final traceability records connecting the manufactured
investigational ATMP with the donated material,
16.5.3. Sponsor file:
16.5.3.1. Final traceability records connecting the investigational ATMP,
manufactured for the clinical trial site, with the clinical trial site and
the patient code,
16.5.3.2. Documentation of follow-up procedures, collected data and
contact information, clinical follow-up, safety follow-up and
efficiency follow-up.
16.5.4. Principle investigator/trial site file:
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16.5.4.1. Final traceability records connecting the manufactured
investigational ATMP delivered to the clinical trial site and the
clinical trial site to the patient code, patient ID and the medical file,
16.5.4.2. Documentation of follow-up procedures, collected data and
contact information, clinical follow-up, safety follow-up and
efficiency follow-up.
18. REPEALED REGULATIONS
The “Guidelines for Principles and Rules for the Good Clinical Practices of Advanced
Therapy Medicinal Products”, which entered into force pursuant to the Authority Approval
No. 7668, dated 05.09.2011, have been repealed.
19. ENFORCEMENT
These guidelines shall enter into force on their date of approval.
20. ANNEXES
ANNEX-1 TRACEABILITY RECORDS
1. Tissue Centers and Supplier Organizations
As stated in the relevant regulation.
2. Blood Centers
As stated in the relevant regulation.
3. Animal Facilities
As stated in the relevant regulation. In addition:
3.1. Source animal identification
3.2. Donor description including the following at a minimum:
3.2.1. Description of the animal facility
3.2.2. Animal ID number
3.2.3. Location of the facility
3.2.4. Type of donation (e.g., single & multiple tissue; alive & dead)
3.3. Product description including at least the following:
3.3.1. Description of the animal facility
3.3.2. Type of tissue and cell/product (basic terminology), anatomical class, if available
3.3.3. Pool number (if applicable)
3.3.4. Number of aliquots (if applicable)
3.3.5. Expiry date
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3.3.6. Tissue/Cell state (e.g., in quarantine, suitable for use)
3.3.7. Description of the product origin, materials used in the production stages, additives
coming into contact with tissues and cells and their effects on quality or safety.
3.3.8. Determination of the facility providing the final label
3.3.9. Description of the user facility and distribution dates:
3.3.10. Distribution date/Disposal
3.3.11. Description of the user facility
4. Manufacturers
4.1. Information on the material received from the supplier organization, depending on
whether it is a tissue center or an animal facility:
4.1.1. Description of the tissue center/animal facility/any agent (if applicable)
4.1.2. Type of tissue and cell/product (basic terminology)
4.1.3. Pool number (if applicable)
4.1.4. Number of aliquots (if applicable)
4.1.5. Tissue/Cell state (e.g., in quarantine, suitable for use)
4.2. Description of the investigational ATMP, including at least the following:
4.2.1. Tissue/Cell state (e.g., in quarantine, suitable for use)
4.2.2. Description of the product origin, materials used in the production stages, additives
coming into contact with tissues and cells and their effects on quality or safety
4.2.3. Description of the sponsor, contract research organization or principal
investigator/institution/site for the person to whom the product is supplied
4.2.4. Product name/code
4.2.5. Pharmaceutical form, route of administration, dosage unit amounts and strength
4.2.6. Group or code number
4.2.7. Trial reference code
4.2.8. Investigational identification number
4.2.9. Expiry date
4.2.10. Distribution date/Disposal
4.2.11. Launch of the finished product by a qualified person
5. Sponsor
5.1. According to the regulations for good clinical practices, the following documents
should be retained by the sponsor before, during and after the trial:
5.1.1. Shipping records of the IP
5.1.2. IP certificate of analysis
5.1.3. Assignment of treatment and decoding documentation
5.1.4. IP traceability at the site, covering the final usage of both used and unused products
5.2. These records and the necessary information for traceability purposes and the
minimum data set should be retained for 30 years after the expiry date of the product
or for a longer period, based on the conditions of the clinical trial authorization and the
agreements made. These should at least include the following:
5.2.1. Description of manufacturing site
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5.2.2. Description of the principle investigator/institution using the investigational
ATMP
5.2.3. Product name/code
5.2.4. Pharmaceutical form, route of administration, dosage unit amounts and strength
5.2.5. Group or code number
5.2.6. Trial reference code
5.2.7. Trial subjects' identity number
5.2.8. Expiry date
5.2.9. Date of application
5.3. In addition to those mentioned above, the investigator’s brochure and the latest
version of the protocol should be retained for the same time period to provide
information about the product and application.
6. Principal investigator and trial site for human application
6.1. According to the regulations for good clinical practices, the following documents
should be retained by the sponsor before, during and after the trial:
6.1.1. Shipment records of the IP
6.1.2. IP certificate of analysis
6.1.3. Assignment of treatment and decoding documentation
6.1.4. List of subject identification codes
6.1.5. IP traceability, covering the final usage of both used and unused products
6.2. These records and the necessary information for traceability purposes and the
minimum data set should be retained for 30 years after the expiry date of the product
or for a longer period, based on the conditions of the clinical trial authorization and the
agreements made. These should at least include the following:
6.2.1. Description of principle investigator and trial site
6.2.2. Whenever applicable, description of sponsor and contract research organization,
6.2.3. Description of manufacturing site
6.2.4. Product name/code
6.2.5. Pharmaceutical form, route of administration, dosage unit amounts and strength
6.2.6. Group or code number
6.2.7. Trial reference code
6.2.8. Trial identification code
6.2.9. List of subject identification codes (to connect trial subject code to subject name)
6.2.10. Expiry/retesting date
6.2.11. Date of application
6.3. Product name/code, trial reference code, trial subject code, date of application and
dosing information should also be included in the mentioned medical records, in order
to connect these to the retrospective product description and the prospective sponsor
and investigator traceability records.
6.4. Any records at the trial site, containing information about unused or disposed products
and their final state, should be retained.