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Device Approval Process
The FDA is also in charge of regulating new medical devices. The device approval
process at the FDA varies based on the degree of risk inherent in the device. Class 1
devices carry little risk for the patient; they include devices such as elastic bandages
and surgical instruments. Class 2 devices carry slightly higher risk for the patient;
they include such devices as infusion pumps and motorized wheelchairs. Class 3
devices are high-risk devices and thus require the most regulatory scrutiny. Class 3
devices include replacement heart valves and implantable defibrillators. Obviously,
the approval requirements for a class 3 device are much higher than for a class 1
device.
,Clinical Trial Study Designs
There are many types of clinical trials, and there are some general trial design
concepts that you need to understand. One key concept is the randomization of
study therapy.
When you randomly assign patients to study therapy, you reduce potential
treatment bias. Another key concept is treatment blinding. Blinding a patient to
treatment means that the patient does not know what treatment is being
administered. In a single-blind trial, only the patient does not know which
treatment is being administered. In a double- blind trial, neither the patient nor the
patient's doctor or the staff administering treatment knows which treatment is
being given. On occasion there may
even be a triple-blind trial, where the patient, the patient's doctor, and the staff
analyzing the trial data do not know which therapy is being given.
There are other trial design concepts for you to be aware of. A clinical trial can
be carried out at a single site or it can be a multi-center trial. In a single-site trial,
all of the patients are seen at the same clinical site, and, in a multi-center trial,
several clinical sites are used. Multi-center trials are needed to eliminate site-
specific bias or because there are more patients required than a single site can
enroll.
Trials may be designed to determine superiority, equivalence, or non-inferiority
between therapies. A superiority trial is intended to show that one therapy is
significantly better than another. An equivalence trial is designed to show that
there is no clinically significant difference between therapies. A non-inferiority
trial is designed to show that one therapy is not inferior to anothertherapy.
Finally, trials can follow parallel or crossover study designs. In a parallel trial,
patients are assigned to a therapy that they remain on, and they are compared with
patients in alternate therapy groups. In a crossover trial, patients switch or change
therapy assignments during the course of the trial.
,International Conference on Harmonization (ICH)
The International Conference on Harmonization (ICH) is a non-profit group that
works with the pharmaceutical regulatory authorities in the United States, Europe,
and Japan to develop common regulatory guidance for all three. The goal of the
ICH is to define a common set of regulations so that a pharmaceutical
regulatory application in one country can also be used in another. Over time, the
Food and Drug Administration (FDA) usually adopts the guidelines developed by
the ICH, so you can watch the development of guidance at the ICH to see what
FDA requirements may be forthcoming.
Study Data Tabulation Model (SDTM)
The SDTM defines the data tabulation data sets that
are to be sent to the FDA as part of a regulatory submission. The FDA has endorsed
the SDTM in its Electronic Common Technical Document (eCTD) guidance and the
Study Data
Specifications document. The SDTM was originally designed to simplify the
production of
case report tabulations (CRTs). Therefore, the SDTM is designed to be listing
friendly, but not necessarily friendly for creating statistical summaries and analysis.
, Clinical Data Interchange Standards Consortium (CDISC)
The Clinical Data Interchange Standards Consortium (CDISC) is a non-profit group
that defines
clinical data standards for the pharmaceutical industry. CDISC has developed
numerous data
models that you should familiarize yourself with. Three of these models are of
particular importance to you:
• Study Data Tabulation Model (SDTM). The SDTM defines the data tabulation
data sets that
are to be sent to the FDA as part of a regulatory submission. The FDA has endorsed
the SDTM in its Electronic Common Technical Document (eCTD) guidance and the
Study Data
Specifications document. The SDTM was originally designed to simplify the
production of
case report tabulations (CRTs). Therefore, the SDTM is designed to be listing friendly,
but not necessarily friendly for creating statistical summaries and analysis.
• Analysis Data Model (ADaM). The CDISC ADaM team defines data set
definition guidance
for the analysis data structures. These data sets are designed for creating statistical
summaries
and analysis. As a statistical programmer, you may find these data sets to be the
primary source for your reporting work. You may be very involved in the creation of
these data sets.
• Define-XML. Previously known as the "Case Report Tabulation Data Definition
Specification," Define-XML is the replacement model for the old data definition
file (define.pdf) sent to the FDA with electronic submissions. Define-XML is
based on the CDISC Operational Data Model (ODM) and is intended to provide a
machine-readable version of define.pdf via define.xml. Because define.xml is a
machine-readable file, the metadata about the submission data sets can easily
be read by computer applications.
This
enables the FDA to work more easily with the data submitted to it. It may also
enable you to
do your work more efficiently and effectively if you are able to leverage your
metadata.
You will be exporting, importing, and even creating data for these models, so it is