Protocol and Conduct
Comparison of FDA, EPA, OECD GLP | Protocol & Conduct | ||
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Topic | FDA | EPA | OECD |
Requirement for a Protocol |
58.120 (a) Each study shall have an approved written protocol that clearly indicates the objectives and all methods for the conduct of the study. |
792.120 (a) Each study shall have an approved written protocol that clearly indicates the objectives and all methods for the conduct of the study. |
Section II 8.1.1. For each study, a written plan should exist prior to the initiation of the study. The study plan should be approved by dated signature of the Study Director and verified for GLP compliance by Quality Assurance personnel as specified in Section 2.2.1.b., above. The study plan should also be approved by the test facility management and the sponsor, if required by national regulation or legislation in the country where the study is being performed. |
Protocol Content |
58.120
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792.120
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Section II
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Protocol Amendment | 58.120 (b) All changes in or revisions of an approved protocol and the reasons therefore shall be documented, signed by the study director, dated, and maintained with the protocol. |
792.120 (b) All changes in or revisions of an approved protocol and the reasons therefor shall be documented, signed by the study director, dated, and maintained with the protocol. |
Section II 8.1.2. a) Amendments to the study plan should be justified and approved by dated signature of the Study Director and maintained with the study plan. |
Protocol Deviation |
Section II 8.1.2. b) Deviations from the study plan should be described, explained, acknowledged and dated in a timely fashion by the Study Director and/or Principal Investigator(s) and maintained with the study raw data. |
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Protocol for Short-term Studies |
Section II 8.1.3. For short-term studies, a general study plan accompanied by a study specific supplement may be used. |
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Conduct of a Study in Accordance with the Protocol |
58.130 (a) The nonclinical laboratory study shall be conducted in accordance with the protocol. |
792.130 (a) The study shall be conducted in accordance with the protocol. |
Section II 8.3.2. The study should be conducted in accordance with the study plan. |
Test System Conformity with the Protocol |
58.130 (b) The test systems shall be monitored in conformity with the protocol. |
792.130 (b) The test systems shall be monitored in conformity with the protocol. |
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Labeling of Specimens |
58.130 (c) Specimens shall be identified by test system, study, nature, and date of collection. This information shall be located on the specimen container or shall accompany the specimen in a manner that precludes error in the recording and storage of data. |
792.130 (c) Specimens shall be identified by test system, study, nature, and date of collection. This information shall be located on the specimen container or shall accompany the specimen in a manner that precludes error in the recording and storage of data. |
Section II 8.3.1. A unique identification should be given to each study. All items concerning this study should carry this identification. Specimens from the study should be identified to confirm their origin. Such identification should enable traceability, as appropriate for the specimen and study. |
Availability of Gross Findings to Pathologists |
58.103 (d) Records of gross findings for a specimen from postmortem observations should be available to a pathologist when examining that specimen histopathologically. |
792.130 (d) In animal studies where histopathology is required, records of gross findings for a specimen from postmortem observations shall be available to a pathologist when examining that specimen histopathologically. |
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Manual Recording of Data |
58.130 (e) All data generated during the conduct of a nonclinical laboratory study, except those that are generated by automated data collection systems, shall be recorded directly, promptly, and legibly in ink. All data entries shall be dated on the date of entry and signed or initialed by the person entering the data. |
792.130 (e) All data generated during the conduct of a study, except those that are generated by automated data collection systems, shall be recorded directly, promptly, and legibly in ink. All data entries shall be dated on the day of entry and signed or initialed by the person entering the data. |
Section II 8.3.3. All data generated during the conduct of the study should be recorded directly, promptly, accurately, and legibly by the individual entering the data. These entries should be signed or initialled and dated. |
Changes to Manually Recorded Data |
58.130 (e) Any change in entries shall be made so as not to obscure the original entry, shall indicate the reason for such change, and shall be dated and signed or identified at the time of the change. |
792.130 (e) Any change in entries shall be made so as not to obscure the original entry, shall indicate the reason for such change, and shall be dated and signed or identified at the time of the change. |
Section II 8.3.4. Any change in the raw data should be made so as not to obscure the previous entry, should indicate the reason for change and should be dated and signed or initialled by the individual making the change. |
Automated Recording of Data |
58.130 (e) In automated data collection systems, the individual responsible for direct data input shall be identified at the time of data input. |
792.130 (e) In automated data collection systems, the individual responsible for direct data input shall be identified at the time of data input. |
Section II 8.3.5. Data generated as a direct computer input should be identified at the time of data input by the individual(s) responsible for direct data entries. |
Changes to Data Recorded by Automated Systems |
58.130 (e) Any change in automated data entries shall be made so as not to obscure the original entry, shall indicate the reason for change, shall be dated, and the responsible individual shall be identified. |
792.130 (e) Any change in automated data entries shall be made so as not to obscure the original entry, shall indicate the reason for change, shall be dated, and the responsible individual shall be identified. |
Section II 8.3.5. Computerised system design should always provide for the retention of full audit trails to show all changes to the data without obscuring the original data. It should be possible to associate all changes to data with the persons having made those changes, for example, by use of timed and dated (electronic) signatures. Reason for changes should be given. |