Clinical research governance - MRC

Contents

Clinical trials regulations

Key facts about the regulations

In 2001 the European Union (EU) adopted the EU Clinical Trials Directive (2001/20/EC) as a framework for good management in trials of medicines for human use. The subsequent UK Medicines for Human Use (Clinical Trials) Regulations became law in 2004.

The regulations are intended to protect the rights, safety and wellbeing of research participants and to simplify and harmonise regulatory processes. They apply to trials designed to generate information on the efficacy or safety of medicines.

MRC’s policy on the UK clinical trials regulations details our requirements of MRC-funded researchers in universities or other research organisations who take on the role of investigator in a Clinical Trial of an Investigational Medicinal Product (CTIMP)

If you are planning a clinical trial but are uncertain whether it falls within the scope of the regulations, please contact the Medicines & Healthcare products

Regulatory Agency (MHRA) directly.

Summary of MRC requirements

The trial sponsor

The UK Clinical Trial Regulations define the sponsor as “an individual, company, institution or organisation which takes responsibility for the initiation, management or financing of a clinical trial.”

They do not require a single organisation or person to take on all sponsorship responsibilities, nor do all the other partners’ civil liabilities transfer to the sponsor in collaborative trials. The responsibilities of the sponsor can be accepted by:

  • an investigator
  • a single organisation
  • a group of individuals or organisations.

They may act as either co-sponsors or joint sponsors. Co-sponsors agree how best to allocate sponsor’s legal responsibilities between partners according to whichever is best placed to accept them, and where no party accepts joint liability for responsibilities allocated to other parties. Joint sponsors agree to accept joint liability for all of the sponsor’s responsibilities.

Research organisations as sponsors

The UK Clinical Trials Regulations permit a group of individuals or organisations to name themselves as the research sponsor. For new grant-funded trials, the funding application to MRC must include the names of the intended sponsors.

MRC expects that the research organisation applying for a grant will be the sponsor, or will accept an allocation of sponsorship responsibilities. If the research organisation does not accept a sponsorship role, we may refuse to fund the trial.

Informing MRC about the trial sponsor

All grant and fellowship applications to the MRC for funding for clinical studies that fall within the scope of the UK regulations must include the details of sponsorship arrangements made by the research organisation.

For new trials in MRC units or institutes, the directors of MRC units or institutes must ensure that their systems identify the authorisation and sponsorship details of new trials involving their unit or institute staff – including visitors under unit or institute supervision. These should be documented so that the information is available promptly on request by MRC head office or others.

Actions required for trials of medicinal products

Actions required of the chief investigator – likely to be principal applicant:

  • review your trial with the sponsors to ensure that it complies with the UK regulations
  • ensure you meet the requirements of the MHRA, Research Ethics Committees, HRA, NHS R&D and MRC in relation to authorisation and sponsorship
  • send details of the sponsorship arrangements to MRC
  • ensure that your trial will be well managed and monitored in respect of any inherent risks, that the principles of good clinical practice are being applied effectively, and that your safety reporting systems are robust
  • make sure that any substantial changes to your trial protocol are submitted to the MHRA and Research Ethics Committee as required.

Actions required of research organisations and MRC units and institutes:

  • ensure that appropriate arrangements for sponsorship are in place. Notify MRC directly about these or authorise the chief investigator to do so
  • ensure that you can give MRC assurance that your institutional systems for research governance under the UK policy framework for health and social care research and the UK Clinical Trials Regulations are robust.

Approvals – applies to all MRC-funded research

For research involving human participants, the research organisation must demonstrate to the MRC on request that required approvals, such as regulatory authorisations (for example CTA from MHRA), favourable opinion from the research ethics committee and HRA or NHS R&D approvals are in place or were in place before the trial started.

In addition, the chief investigator must notify the MRC if a regulator or a research ethics committee requires amendments that substantially affect the research question, methodology or costs to the extent that the project is no longer the same as that approved for funding by the MRC.

MRC does not require:

  • permissions to be in place when an application for funding is submitted to the MRC
  • to be routinely sent copies of evidence of submissions, permissions and amendments
  • to be routinely notified of changes to the protocol requested by MHRA or research ethics committees unless they substantially change the research project approved for funding by MRC.

In cases where the research is especially sensitive, MRC may ask the chief investigator for evidence of required approvals before releasing funding.

Good trials management

Investigators and research organisations should review their systems for good clinical practice and safety reporting, based on a thorough analysis of the trial risks, the systems in place to manage the risks, and the regulatory requirements. Investigators and research managers should use MHRA guidance and refer to the Clinical Trials Tool Kit for advice on trial management and monitoring. Investigators undertaking global health trials should refer to MRC Guidance on the Management of Global Health Trials.

The MHRA is committed to taking a risk-based approach to its responsibility for inspection. Systems appropriate to one kind of trial should not be applied to other kinds of trial for which the risk profile is different. Investigators should consult MHRA if in doubt about the appropriate risk management systems to adopt.

MRC-funded trials should also comply with relevant MRC policies and guidance.

Contact for more information

For more information on the UK Clinical Trials Regulations, please see the Clinical Trials Tool Kit, or contact the MRC regulatory support centre:

Email: rsc@mrc.ukri.org

Last updated: 17 August 2021

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