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Considerations for the Conduct of Clinical Trials of Medical Products During Major Disruptions Due to Disasters and Public Health Emergencies

FinalCenter for Drug Evaluation and Research Center for Biologics Evaluation and Research Center for Devices and Radiological Health Oncology Center of Excellence09/21/2023

Description

This guidance recommends approaches that sponsors of clinical trials of medical products can consider when there is a major disruption to clinical trial conduct and operations due to disasters or public health emergencies, which can include but are not limited to hurricanes, earthquakes, military conflicts, infectious disease outbreaks, or bioterrorist attacks. The appendix to this guidance further explains those approaches by providing answers to questions that the Agency has received about conducting clinical trials during major disruptions.

Scope & Applicability

Product Classes

4
Cellular therapy

complex IPs where storage conditions could affect stability

Class III Device

Generally recommended for Enhanced Documentation; Regulatory classification mentioned for implantable sensors and HPV tests; Mentioned in the context of an in vitro nucleic acid test for CMV DNA.

Class II Device

Devices subject to section 522 postmarket surveillance orders; devices subject to postmarket surveillance orders

Gene therapy

Products that modify or manipulate the expression of a gene; Products involving genetic modification; A research scientist in a university laboratory has developed a gene therapy.

Stakeholders

10
Institutional Review Boards

Bodies responsible for evaluating trial risks and benefits for pregnant participants.; IRBs experienced in this population may advise on compensation.

Applicants

Entities submitting supplements to BLAs

sub-investigator

HCPs performing study-specific research procedures

local HCP

healthcare professional administering IP who is not a sub-investigator

witness

participates on the call to confirm patient agreement to participate in the trial

Legally authorized representative

may sign informed consent on behalf of the participant; provides written consent if the patient is unable to do so

IRB

Institutional Review Board providing study approvals

Investigator

Responsible for qualifications, training, and trial conduct; Individual responsible for trial conduct and data governance at a site.; May delegate tasks but retains overall responsibility; Person responsible for the conduct of the clinical trial at a trial site; Responsible for trial conduct and participant safety; Responsible for trial conduct, data integrity, and investigational product management.; Individual responsible for trial conduct at a site and informing the institution.; maintaining

Sponsors

Assist sponsors in the nonclinical evaluation

Clinical Investigators

Individuals responsible for monitoring and reporting protocol deviations

Regulatory Context

Attributes

2
Product Stability

Shelf life considerations if administration schedules are revised.

Certified copy

verified copy of original record with same information

Identified Hazards

Hazards

4
immediate hazards

protocol amendments necessary to prevent apparent immediate hazards

Public Health Emergencies

Emergencies resulting from Hurricane Helene and Hurricane Milton causing supply disruptions.

Disasters

Events such as hurricanes, earthquakes, or military conflicts impacting trials.

Public Health Emergency

Disruption causing the need for contingency measures in clinical trials.

Related CFR Sections (20)

Related Warning Letters (10)

  • Clinical Investigator/Sponsor

    Ralph A. DeFronzo, M.D.

    2025-09-23
  • Clinical Investigator

    Shirish M. Gadgeel, M.D.

    2025-09-09
  • Clinical Investigator

    Mark J. Savant, M.D

    2025-07-15
  • Clinical Investigator

    Peter Michael, M.D.

    2025-07-01
  • Bioresearch Monitoring Program

    Amy Lightner, MD

    2025-06-03
  • Clinical Investigator

    Nana Barseghian, M.D.

    2025-05-06
  • Clinical Investigator

    Mehran Michael Bahrami, M.D.

    2025-03-18
  • Clinical Investigator

    Han C. Phan, M.D.

    2024-12-03
  • Clinical Investigator

    Namita A. Goyal, M.D.

    2024-10-22
  • Clinical Investigator

    Julio R. Flamini, M.D./Clinical Integrative Research Center of Atlanta

    2024-09-03

See Also (8)