Investigator Responsibilities and Oversight

Part of Good Clinical Practice (GCP) — ICH E6(R3): Roles and Responsibilities in Clinical Trials.

About 7 minutes. Free, in your language, no account needed.

Why this matters

Many site inspection findings are oversight findings, not knowledge findings. A competent person did a task nobody had delegated to them. ICH E6(R3) is explicit: the investigator may delegate the activity, but the investigator keeps the responsibility.

The six terms you must be able to define

These are the core definitions from the ICH E6(R3) Glossary.

TermE6(R3) definition, in short
Good Clinical Practice (GCP)A standard for the planning, initiating, performing, recording, oversight, evaluation, analysis and reporting of clinical trials. It gives assurance that results are reliable and that participants' rights, safety and well-being are protected.
InvestigatorA person responsible for the conduct of the clinical trial, including the participants for whom that person has responsibility. If a team conducts the trial, the investigator is the responsible leader, and may be called the principal investigator.
Investigator site"The location(s) where trial-related activities are conducted and/or coordinated under the investigator's/institution's oversight."
Sub-investigatorAny individual member of the trial team designated and under the oversight of the investigator to perform significant trial-related procedures or make important trial-related decisions. Examples: associates, residents, research fellows.
SponsorAn individual, company, institution or organization that takes responsibility for the initiation, management and arrangement of the financing of a clinical trial. A trial may have several sponsors.
Service provider"A person or organization (commercial, academic or other) providing a service used by either the sponsor or the investigator to fulfill trial-related activities."

Note the change from the previous revision. E6(R2) treated the contract research organization (CRO) separately. In E6(R3), the Glossary entry for CRO says only "See Service Provider". A CRO is now one kind of service provider, and so is a central laboratory or an electronic data capture supplier.

Qualifications and training

E6(R3) section 2.1 requires the investigator to be "qualified by education, training and experience to assume responsibility for the proper conduct of the trial" and to "provide evidence of such qualifications". Evidence means a current curriculum vitae, training records and licenses where they apply. The investigator must also be familiar with the appropriate use of the investigational product, as described in the protocol, the current Investigator's Brochure or other sources the sponsor supplies.

Resources

Section 2.2 sets two requirements sites often treat as optional.

An honest feasibility answer protects participants. An optimistic one produces rushed visits.

Responsibilities, delegation and the delegation record

Section 2.3 is the core of this lesson. Three rules follow.

Delegation does not move responsibility. The investigator "retains the ultimate responsibility and should maintain appropriate oversight of the persons or parties undertaking the activities delegated". Oversight "should depend on the nature of the delegated activities and be proportionate to the importance of the data being collected and the risks to trial participant safety and data reliability."

Training is targeted, not blanket. Trial-related training for people assisting in the trial "should correspond to what is necessary to enable them to fulfill their delegated trial activities that go beyond their usual training and experience." A qualified phlebotomist does not need training in venepuncture. That person may still need training on the protocol-specific tube order.

The delegation record is proportionate. The investigator should ensure a record is maintained of the persons and parties to whom activities were delegated. Documentation of delegation "should be proportionate to the significance of the trial-related activities." E6(R3) then adds a genuinely new allowance: "In situations where the activities are performed as part of clinical practice, delegation documentation may not be required."

Section 2.3 adds two points. Agreements the investigator or institution makes with service providers should be documented. The investigator or institution must permit monitoring and auditing by the sponsor, inspection by regulatory authorities, and IRB/IEC review where applicable.

Communication with the IRB/IEC

Section 2.4 places these duties on the investigator or institution, or in some regions the sponsor.

Compliance with the protocol

Section 2.5 requires the investigator or institution to sign the protocol, or an alternative contract, to confirm agreement with the sponsor. The investigator complies with the protocol, GCP and applicable regulatory requirements.

E6(R3) states two obligations on deviations. The investigator "should document all protocol deviations". For those deemed important, the investigator explains the deviation and implements measures to prevent recurrence where applicable. The investigator should deviate "only where necessary to eliminate an immediate hazard(s) to trial participants", and must then inform the sponsor promptly and report to the IRB/IEC and, where applicable, regulatory authorities.

In practice

At Dr. Sarah's hypertension site, a new nurse, Rafael, begins performing 12-lead electrocardiograms (ECGs) for trial visits. He does ECGs daily in the clinic. He is not on the delegation record.

Ana, the coordinator, asks two questions. Is the ECG a trial activity or part of usual clinical practice? Here the protocol requires it at set time points and it supports a safety endpoint, so it is a trial activity. Is it significant? Yes.

So delegation must be documented, and Rafael needs protocol-specific ECG training, not general ECG training. Ana adds him to the delegation record with the correct start date, files his curriculum vitae and training record, and asks Dr. Sarah to sign. The ECGs already performed are documented as a deviation and reported to the sponsor.

Responsibility cannot be delegated.

Key takeaways