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Approval Pathways and Case Examples


Case Report Example Click here for printer friendly version

During the course of normal sign-out, Dr. Smith notices that patient Jones has an unusual variant of renal cell carcinoma that has features noteworthy enough to warrant writing up and submitting as a case report. She remarks on this to the resident, who is interested in collaborating in this project.

Two facts govern the type of approval necessary for this case. The first is that it is not possible to anonymize an individual case, so that it is not possible to obtain an OHSR exemption for this research. The second fact is the protocol status of the patient and whether the case report relates to the protocol.

Variation 1: The patient is enrolled in an NIH protocol studying renal cell carcinoma. Follow Approval Path D.

Variation 2: The patient is enrolled in an NIH protocol for diabetes and the renal cell carcinoma was identified incidentally and removed without a new protocol consent (such as the UOB tissue procurement protocol). Follow Approval Path E.

Variation 3: The case was received as a consultation case from a pathologist outside the NIH. The patient is not enrolled on any protocol. Follow Approval Path F.


Basic Science Investigation Example

Dr. Nobel, a Ph.D. molecular biologist in the NCI, has discovered a new gene that she feels is linked to breast cancer. She would like to investigate its expression in human tissue to describe its expression in normal breast and breast cancer and to relate expression to prognosis. The factors which govern her use of the tissues mainly revolve around whether or not she is using anonymized tissue samples.

Variation 1: At the start of her study she obtained 20 coded specimens of tissue from a publicly available tissue bank. The tissue bank strips all identifiers from the tissue prior to sending them to Dr. Nobel. Follow Approval Path C.

Variation 2: She contacts the Post-mortem section to obtain autopsy tissues from multiple organs to look at the distribution of gene expression. Follow Approval Path B.

Variation 3: She sets up a collaboration with Dr. Rutger, an oncologist, who has a protocol written to include the search for new oncomarkers in breast cancer. She would like to obtain tissues from his patients. Follow Approval Path D.


Obtaining Fresh Tissue from Living Patients

Dr. Xerxes would like to create tumor cDNA libraries from patients with colon carcinoma. For a variety of reasons he would like to get this tissue from patients undergoing surgery at the Clinical Center. He is aware that Dr. Coldnife, a surgeon, has a tissue procurement protocol written for patients he operates on.


Variation 1: Because the tissue must be obtained as fresh as possible, it is not practical to try to anonymize the tissue collection. Therefore, and OHSR exemption from IRB review is not appropriate. In order to get the fresh tissue, Dr. Xerxes must do the following:

1. Contact Dr. Coldnife in order to arrange a collaboration. If Dr. Coldnife's protocol is yet to be written, Dr. Xerxes might be able to participate as an associate investigator. If the protocol is already in place, it would have to be written to include the construction of cDNA libraries. If the protocol does not include this permission, he would have to follow Approval Path E to get the IRB's permission to proceed.

2. Each time tissue was collected, a "Tissue Procurement and Transfer Form" would have to be filled out and signed by a PI or AI on the protocol. If Dr. Xerxes was one of the AI's, he could sign for himself.

Variation 2: Dr. Xerxes and Dr. Coldnife set up a mechanism to anonymize samples via a third party not involved in the research. The third party delivers tumor samples to Dr. Xerxes' lab stripped of any information that would allow him to identify the patient. Dr. Xerxes would follow Approval Path C to get permission for his project, but would have to explain the anonymization process in detail on the OHSR form.


Protocol Case Review example

Dr. Hamm is asked to review a series of cases by Dr. Owens, an NIH PI, so that pathology data from the cases is contributed by a single pathologist.

Variation 1. The case evaluation involves review of previously prepared slides with or without additional tests already covered by the protocol. Dr. Hamm follows Approval Path D.

Variation 2. Dr. Owens and Dr. Hamm decide that it would add much to the study to look at non-lesional tissue for germline mutations, an experiment that is not covered already in the protocol. They now need to follow Approval Path E, and would probably have to amend the protocol and re-consent patients in this particular instance.


Reference Pathologist/Basic Scientist example

Dr. Alphabeta is named as the reference pathologist for a large multicenter trial. She will be receiving slides from a central data center that have been coded, but which are ultimately still linked to the original patient information.

Variation 1. NIH is participating in the multicenter trial, and an NIH IRB has approved the study. Dr. Alphabeta is an associate investigator on the NIH protocol. Follow Approval Path C.

Variation 2. NIH is not participating in the trial. Dr. Alphabeta would still be able to use Approval Path C, but would need to provide OHSR with documentation of IRB approvals from the participating centers.

Variation 3. Dr. Alphabeta is a molecular biologist receiving tissue samples from the multicenter trial, and her part of the project is covered under the protocol. She would still Follow Approval Path C, as above.


Use of tissue for test development example

Dr. Britainnica, and his technician, Ms. Americana, are evaluating a new antibody for use in the clinical diagnostic lab. They would like a collection of tumors and normal tissues for titration and validation. There is no intention to publish the information.

Variation 1. This is part of clinical service and a necessary part of bringing a new test into the diagnostic service. There is no ethical approval required. (Approval Path A). Tissues for this purpose need to be chosen according to the tissue use guidelines. (See below)

Variation 2. After validating the new test, Dr. Britainnica realized that they have discovered new things about the antibody worthy of publication. They would like to summarize their findings and publish them. If they used anonymous tissue to begin with, they need to follow Approval Path C to get permission to write the paper. If non-anonymized tissues were used, they would need to follow Approval Path F.

Tissue Use Guidelines

In order to protect prospectively collected protocol biopsies from being used for non-protocol purposes, we have formal guidelines for selection of tissues for non-protocol related research. In all cases, sufficient tissue should remain in the slide files/archive for the patient's future diagnostic needs.

1. Tissues collected as part of a specific protocol will be flagged as such by the ordering physician, and the protocol number will be recorded in the LIS as part of the specimen registration procedure. (We are working on the information systems issues now.)

2. If the tissues collected as part of a specific protocol are "limited" (defined below), then they may not be used as test controls or as part of research studies without the permission of the PI.

3. Limited specimens are defined as single block specimens. Larger, multi-block specimens may be made available for non-protocol, anonymized studies so long as at least one block is retained for the purposes of the protocol. If there is doubt about what may be released from a large case, then an impartial judgment should be sought from pathology attending staff uninvolved in the research.

4. Specimens obtained off-protocol (for diagnosis only), may be used for anonymized research or as controls.

5. In all situations, the patient's needs should come first, then the protocol's, and any other use of the tissue last.

Approval Pathways Click here for printer friendly version

Approval Path A
Approval Path B
Approval Path C
Plan of Research

Non-research use of tissue

• Tissue for titering probes, controls

• Educational use

• Validation of clinical test (no intention to publish)

• Clinical review

• Uses for laboratory QA/QC

Tissues are all from deceased patients

• Autopsy tissue

• Surgical/cytology tissue from patients with known death dates

Tissues are irreversibly anonymized (stripped of any link to the original patient)

• Samples from the archive recoded by the archivist)

• Samples anonymized by a tissue repository

• Samples anonymized according to an IRB-approved protocol

Ethical Approval Step • None required • None required • Apply to OHSR for exemption from IRB review

IF YOUR STUDY DOES NOT INVOLVE THE TISSUE ARCHIVEOR LABORATORY OF PATHOLOGY TECHNICAL RESOURCES,STOP HERE, YOU ARE DONE

TRC Approval Step


• None required, fill out form for archivist to retrieve samples • Submit information below with TRC form, check "autopsy/ deceased patient" box • Submit information below with TRC form
Additional Information Needed • List of materials to be pulled, delivered to archivist

• Autopsy case numbersand/or

• Death dates of patients

• If tissues are from NIH archive, search criteria for possible cases

• Copy of OHSR exemption approval

What Happens Next • Archivist pulls materials

• TRC form is reviewed and approved

• Archivist pulls materials

• TRC form is reviewed and approved

• Databases queries are performed if necessary

• Archivist pulls materials

• Recuts, etc. are anonymized by archivist or other third party

Approval Path D
Approval Path E
Approval Path F
Research Type

Identifiable tissues obtained for research outlined in an NIH or non-NIH IRB approved protocol with appropriate patient consent

• Protocol driven case review

• Case report or series on NIH patients for protocol-related pathology

• Molecular or biochemical analysis on NIH patient material

• Evaluation of samples from another institution obtained under protocol

Identifiable tissues obtained via an NIH or non-NIH IRB approved protocol to be used in research not outlined in original protocol

• Research to examine tissues using probes/techniques not envisioned at the time of protocol approval

• Germline research on tissues obtained under a non-germline protocol

Identifiable tissues not obtained as part of an IRB-approved protocol

• Case report or series on non-NIH patients using tissue obtained through routine care

• Molecular or biochemical investigation of non-NIH tissues not obtained on a specific research protocol

Ethical Approval Step

• NIH protocol: review proposed research with PI to make sure that the research is covered under original protocol. Work must done as collaboration.

• Non NIH protocol: Apply to OHSR for exemption from NIH IRB review, will need copy of IRB approval from outside institutions

• Apply to IRB for waiver of consent

or

• Write amendment to protocol to include new research. (Required for germline example).

IRB may decide not to waive consent. If the waiver is denied, a standard protocol or amendment will have to be written and informed consent (re)obtained.

• Apply to IRB for waiver of consent. If the waiver is denied, a standard protocol will have to be written and informed consent obtained
IF YOUR STUDY DOES NOT INVOLVE THE TISSUE ARCHIVEOR LABORATORY OF PATHOLOGY TECHNICAL RESOURCES,STOP HERE, YOU ARE DONE.
TRC Approval Step

• Submit information below with TRC form

• PI/AI signature required

• Submit information below with TRC form

• PI/AI signature required for amended protocols

• Submit information below with TRC form
Additional Information Needed

• Case list

• Protocol number

• Copy of OHSR exemption (if obtained)

• Case list

• Protocol number

• Copy of IRB waiver

• Case list

• Copy of IRB waiver or new protocol number

What Happens Next

• TRC form is reviewed and approved

• Queries are run against the database if necessary

• Archivist pulls materials

• TRC form is reviewed and approved

• Queries are run against the database if necessary

• Archivist pulls materials

• TRC form is reviewed and approved

• Queries are run against the database if necessary

• Archivist pulls materials

Last Updated 1/12/2009 3:42:52 PM

 

 
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