So how often should we be taking GCP training? ICH states that it is actually up to the sponsor’s discretion as to how often you should be taking GCP training. A lot of companies do set the guidelines of every two years, but these are not official guidelines. However, in recent audit findings the Regulatory Authorities (RA) have found that people are not being trained frequently enough on GCP and therefore lots of issues during the studies are arising. They are asking sponsors to tighten up on how often their employees take their GCP training. The FDA in particular are in their own words “coming down hard on sponsors regarding GCP training”. Their suggestion being that all staff when starting a new study should be up to date with all the training required to carry out their job, which includes being up to date with all GCP guidelines.
So, what about the E6R2 update? Do I have to now retake GCP training? Well as you have just read above the requirement is that you are up to date. So if you haven’t taken GCP training since the E6R2 update was implemented in June 2017, then you will have to familiarise yourself with the new changes. Good news is you don’t have to fully re sit GCP, you can just do the update with proof that you have done so along with your up to date GCP certificate. However, depending on how long ago you took your GCP training it may well be worth just retaking it as long as the training provider has included the recent update, and remember you can never have too much training!
In line with audit findings, the RA also have suggested that people remain up to date with their informed consent training. This is one of the biggest bug bears in audit findings: informed consent not being taken properly. I was recently made aware of a study in which a whole site’s data was unable to be used as the informed consent was incorrectly taken, things such as: not dated, not signed, taken after procedure had started, wrong version being used. If the site staff had recently had their training updated, this would have saved the study having to abandon the site data and saved the sponsor time and money.
Section 8 of the GCP is regarding essential documents. This again is one area that always crops up during audits. Although the GCP guidelines cover essential documents this is not in great detail so it is important to make sure you are up to date with your essential documents training –especially if you are working at sites. Proper documentation is critical to the success of a clinical study. Every aspect of the study must be documented in order to obtain useful data and demonstrate compliance with Good Clinical Practice (GCP) guidelines and Good Documentation Guidelines (GDP) and with all applicable regulations. Again there is no set rule as to how often you need to take essential documents training. I would recommend taking this as often as possible to keep yourself up to date and your mind fresh in order to avoid getting some negative audit findings.
If you are reading this and starting to think: “I haven’t taken these training modules for a while”, or even worse you can’t actually remember when you last took them (don’t worry we have all been there!), pop over to trainingonline4u.com and take a look at the training offered. If you are thinking you need all 3 modules, you are in luck as they are currently offering a discount offer to help keep you up to date without breaking the bank!