The following are frequently asked questions about IBC Servicepoint and IBCS. If your question is not
here please email us at ibcs@wirb.com for more help.
FAQs for Sites
FAQs for Sponsors
FAQs for Committee Members
IBC FAQ FOR SITES
Where can I learn more about gene transfer and vectors?
Sponsor-supplied documents such as the protocol and brochure are usually the best sources.
(Keep in mind though that the sponsor and the IBC may have different perspectives on a
particular gene transfer product: the sponsor may view a product as safe and simple to
administer, but the IBC may take a more conservative view about safety measures.) Professional
societies such as the American Society of Gene Therapy
(
www.asgt.org) and the American
Biological Safety Association (
www.absa.org) also
have informative websites.
Where can I learn more about biosafety?
The American Biological Safety Association (
www.absa.org)
is a very good resource. The most authoritative source is the CDC -- see Section
Iv of the "BMBL" at
http://www.cdc.gov/biosafety/publications/. Your state
OSHA office should have a website describing state rules, and likely this will
have useful links.
What are the sponsor’s responsibilities under the NIH Guidelines?
Sponsors are regulated mainly by the FDA, not the NIH, and the NIH Guidelines do
not assign particular responsibilities to sponsors. The premise of the NIH Guidelines is
that the researchers are responsible for biological safety, so the PI is the regulatory ‘touch point’ for the NIH.
Can we close a study with IBC when the last subject goes “off study”?
It depends on the protocol and the biology of the rDNA product. According to the
NIH, the local IBC has the responsibility to decide when IBC oversight can end. Each local IBC
will make its own determination about this. For the IBC, the study is certainly active as long as
there is product at the site, or future dosing could occur. Even if the IBC allows the study to close
before the end of long-term follow-up (LTFU), the study will still be under oversight by the IRB,
the FDA, and the NIH.
Why is LTFU different from protocol to protocol?
In the US, gene transfer is considered experimental, with possible unknown or delayed long-term
consequences. Therefore, long-term follow-up (LTFU) generally goes on for much longer than in
drug or device studies—like years or life-long. Current FDA guidance calls for the duration of
LTFU to relate to risk characteristics of the specific recombinant product;
FDA CBER Guidance for Industry, Gene Therapy Clinical Trials – Observing Subjects for Delayed Adverse Events.
Some older protocols have not been amended to shorten their LTFU.
What if my sponsor goes out of business during LTFU?
The Institution and PI remain responsible for conducting the research as specified in the
protocol approved by the IRB and the IBC. This would include all tests or procedures (such
as cancer screening or sample collection) included in the long-term follow-up. Although
PIs are permitted to delegate to the sponsor the responsibility for annual reporting to
the NIH, the PI remains ultimately responsible. Sites should fully understand the potential
financial burdens of the LTFU at the time they agree to take on the research.
What are the implications of having our site visit be “BSL1” versus “BSL2”?
Practically any clinical site that handles body fluids should be able to provide
Biosafety Level 2 (BSL2) containment using routine medical precautions,
procedures and equipment. BSL2 controls offer additional protection to the agent, the site
workers, and the environment. Compared to BSL1, the biggest differences are more
attention to proper signage, decontamination, transport, and disposal of the
gene transfer product. Also, many (but not all) BSL2 products require the
use of a certified biologiacal safety cabinet (BSC, sometimes referred to as a
"hood") to prepare the prodct, so this can be a challenge if the site does not
already have a BSC.
If we are a BSL1 site, can we do BSL2 research?
Not unless the site upgrades to meet BSL2 requirements and is approved by the
IBC.
However, a site approved to provide BSL2 should be able to do research at BSL1
as long as the protocol and IBC requirements are met.
How can we find supplies such as eyewashes, spill kits, surface decontaminants, etc.?
Check with your usual medical supplies provider. Also, we will include at least
one biosafety professional from your local area who will probably be able to
suggest reliable suppliers in your area. The Scientific Specialists in the
IBCS office may be able to share some resources, too.
IBC FAQ FOR SPONSORS AND CROs
Do you offer "central IBC" services?
No. There is no such thing. Unlike IRB regulations, the NIH Guidelines do not provide for central IBC review,
so one IBC cannot review for a multi-center trial. To assure the interests of the community are represented, each institution must set up
its own separate IBC, and IBC Services does this. A local IBC can serve multiple units of an institution (such as satellite
offices) in the same local area. NIH Guidelines require each IBC to have at least two unaffiliated
local members, and recommend including at least one member representing the people who actually handle
the rDNA product (“laboratory technical staff”).
How long does it take for research to be approved?
For a site we are already working with, the review meeting will typically occur within a few weeks,
or less in urgent circumstances. For a new site starting gene transfer research for the first time,
once we receive complete information about the protocol and identify who at the site will work with
us to prepare for the review, it generally takes about 8 weeks to hold the first meeting of a new IBC.
Depending on local circumstanced, it can be shorter or longer. The steps that tend to be the most
time consuming are:
recruiting local members--the site can help with this by suggesting possible contacts who
are unaffiliated with the site. IBC Services will make the contact and train the local members.
Under the NIH Guidelines, local members "represent the interest of the surrounding community with
respect to health and protection of the environment (e.g., officials of state or local public health
or environmental protection agencies, members of other local governmental bodies, or persons active
in medical, occupational health, or environmental concerns in the community)". We seek members who
have the interest and willingness to prepare for the meetings by reading all the meeting materials,
and the flexibility to be able to schedule teleconferences during work hours.
recruiting a site visitor--we arrange for local biosafety professionals (such as
biosafety officers, infection control nurses, etc.) to inspect the sites, and inform the IBC about
the facility. So suggestions can be very helpful in speeding up the process. Again, IBC Services
provides the training.
arranging the site visits--sometimes Study Coordinators are over-committed. It takes
time to prepare for a successful site inspection. The PI can speed things up by providing enough
time for the Coordinator to make the necessary preparations, or designating other staff to work
with the site visitor.
site SOPs, installing equipment, etc--IBC Services can provide templates, but only the
research team can customize them to fit local conditions. Sometimes equipment such as eyewashes
must be installed. How long this takes depends on local efforts.
surprises--sometimes the protocol-related documents include requirements that are
difficult for a particular site to implement (examples: product must be stored or prepared “in a
pharmacy”, or staff who could become pregnant may not handle the product). These restrictions are
not always recognized during site qualification discussions, and can be a source of delay when IBC
Services checks on implementation plans.
The IBC review process moves fastest when the PI stays involved, provides adequate resources to the
Study Coordinator, makes it clear to the study team that arranging for the site visit and IBC review
are work priorities.
What can a sponsor do to speed the process?
Site selection makes a big difference. Sites that already have an NIH-registered IBC and experience
with gene transfer obviously have a head start. Some sites may lack appropriate space (such as space
for a new freezer, or a room with impervious flooring to allow spill clean up), a key piece of
equipment (such as a biosafety cabinet or locking freezer) or a capability (such as an on-site
pharmacist for agent storage and preparation if required by protocol)
Be sure the protocol, investigator brochure, and any special handling instructions are reviewed so
they are complete, up to date, and consistent between documents. Contradictory statements in the
brochure, the protocol, can result in delay of approval.
IBC FAQ FOR COMMITTEE MEMBERS
How do I become a committee member?
Members are appointed by IBC Services. We include members of the local community as well as professionals
in related fields (biosafety, genetics, virology, pharmacology, etc.). If you are interested in participating
on an IBC, coordinated by IBC Services (WIRB, Inc.), please contact us at (360) 252-2850 or
ibcs@wirb.com to introduce yourself as a prospective member.
How do I review my meeting documents?
The review documents for IBC meetings are posted on IBC Services secured website,
IBC Servicepoint. As a
Committee Member you will be provided a username and password to access
Servicepoint. Online video
instructions for navigating in Servicepoint can be viewed at
Training. If you have any difficulties
with the website please contact us at (360) 252-2850 or
ibcs@wirb.com. The
website is designed to support Internet Explorer, Firefox, and Safari.
Here is a link to the
IBC Servicepoint Members page