Our study is not using a standard medical dictionary (ie MedDRA), instead the team created a short list of expected adverse events. As we analyze our data we're now faced with a gigantic number of "Other" AEs and the possibility of expanding our code list (dictionary). If we change our AE dictionary mid-study are there any pot holes to watch out for?
You must ensure that the custom system has met validation and compliance requirements in accordance:
21 CFR Part 11
General Principle of Computer System Validation
Computerized Systems Used In Clinical Trials 2004
Computerized Systems Used In Instigations 2007
ICH E6
Procedural controls are properly in place, i.e.
SOPs on Data Updates on master files, i.e. database, external dictionaries, etc…
SOPs on Change Controls in existing records
Validity of dictionary terms and acceptability of use
QA/QC Procedures for conducting reviews and qualifications of terms and use of
Sincerely, John F. Cuspilich, Sr. Consultant RA/QA
FDA.COM
The Auditing Group, Inc.
GMP Publications, Inc. jcuspilich@auditing.com jcuspilich@fda.com
856-596-2333 - 866-GXPNews