Translate this page into:
Ethics committees in India: A study to assess the implementation of registration requirements as per New Drug and Clinical Trial Rules and the scale of standardization
Correspondence to MURUGANANTHAN KRISHNAN; murugananthan.K@novartis.com
[To cite: Krishnan M, Sherief HS. Ethics committees in India: A study to assess the implementation of registration requirements as per the New Drug and Clinical Trial Rules and the scale of standardization. Natl Med J India 2023;36:109–11. DOI: 10.25259/NMJI_986_21]
Ethics committees (ECs) are responsible to safeguard the rights, safety and well-being of all trial subjects of reviewed and approved study/trial protocol, as per set international standards within the Good Clinical Practice (GCP) guidelines of the International Conference on Harmonization (ICH) of Technical Requirements for Registration of Pharmaceuticals for Human use1 and Declaration of Helsinki.2 In India, clinical trials (CTs), bioavailability/bioequivalence (BA/BE) study, biomedical and health research are governed by the New Drug and Clinical Trial Rules (NDCT),3,4 2019 vide notification number G.S.R.227(E) dated 19 March 2019.
The ECs related to CTs, BA/BE are registered with the Central Drugs Standard Control Organization (CDSCO), Directorate General of Health Services, India appointed by the Ministry of Health and Family Welfare (MoHFW), Government of India. The registration of an EC for CT, BA/ BE is valid for a period of 5 years from the date of its issue, unless suspended or cancelled by the central licensing authority and is to be renewed every 5 years.
The ECs related to biomedical and health research are registered with the authority designated by the Central Government in the MoHFW, Department of Health Research (DHR) under National Ethics Committee Registry for Biomedical and Health Research (NECRBHR). The provisional registration is granted on receipt of an application which is valid for a period of 2 years. On scrutiny of documents submitted and if satisfied as per requirements, the final registration is granted by the DHR, which is valid for a period of 5 years from the date of its issue, unless suspended or cancelled by the designated authority at the DHR.
The National Ethical Guidelines for Biomedical and Health Research Involving Human Participants by ICMR (2017)5 recommends that ECs should register with the relevant authority as per the regulatory requirements. It also mentions that the certification and accreditation by ECs are voluntary exercises and help in quality assurance and quality improvement to ensure adherence to best practices in protecting the dignity, rights, safety and well-being of study participants. Accreditation is a long-term strategy.6,7 The National Accreditation Board for Hospitals and Healthcare Providers (NABH)8 was set up to establish and operate EC accreditation programmes for the CDSCO registered ECs. The accreditation is valid for a period of 3 years. The EC involved in review and approval of observational studies, registry trials, non-interventional clinical trials/research, biomedical health research are excluded from accreditation.
The NDCT mandates approval from a registered EC for the conduct of CT, BA/BE, biomedical or health research. The list of EC registration and re-registration within the CDSCO (along with the registration and re-registration letter), the list of EC registration with the DHR and accreditation are available in the public domain. We evaluated the status of registered, reregistered and accredited ECs in the country during 2013–2021 to understand the implementation of new requirements on registration of EC as per NDCT 2019 and assess the scale of standardization. We also documented the progress and pattern of registrations and distribution all over India.
METHODS
The EC registered and re-registered from Indian regulatory authority websites—CDSCO,9 DHR10—NAITIK portal (naitik.gov.in) and NABH8 during 2013–2021 were extracted manually. The status of ECs analysed according to the states within the country, type (institution or independent) of EC, year-wise distribution on registration, re-registration and accreditation status to assess the scale of diversity. The data used for this study were obtained from publicly available websites and not linked to any identifiable individual. No explicit individual consent was required. A descriptive analysis was done for the information extracted from different sources using Microsoft Excel.
RESULTS
According to the list of medical colleges approved by the Medical Council of India, dental colleges, hospitals with Diplomate National Board (DNB) courses, hospitals accredited with the NABH, Scientific and Industrial Research Organization (SIRO) recognized by the Department of Science and Industrial Research (DSIR) and Indian Institute of Technology, there are 2414 eligible ECs for oversight of research activities involving human participants. According to the list of ECs registered, 1122 (46%) ECs from these institutions are registered with the CDSCO and 702 (29%) ECs are with the DHR (Table I). The registered and re-registered ECs with the CDSCO, registered ECs with the DHR and accredited ECs across Indian states and Union Territories (UTs) are shown in Table II. Figure 1 shows the trend of registrations and re-registrations of ECs with the CDSCO, during 2013–2021, accreditation of ECs during 2018– 2021 and registration of ECs with the DHR during 2019–2021.
Agency | n(%) |
---|---|
Healthcare institutions (medical colleges, dental colleges | 2414 (%) |
and hospitals) and medical research institutions | |
Registered with CDSCO | 1315 (54) |
CDSCO—corrected* | 1122 (46) |
Institutional ECs | 973 (87) |
Independent ECs | 149 (13) |
Re-registered with CDSCO | 1660 |
Re-registered with CDSCO—corrected* | 1416 |
Institutional ECs | 1286 (91) |
Independent ECs | 130 (9) |
Registered with DHR | 702 (29) |
Provisional registration (2 years) | 675 (97) |
Institutional ECs | 657 (97) |
Independent ECs | 18 (3) |
Final registration (5 years) | 27 (3) |
Institutional ECs | 26 (96) |
Independent ECs | 1 (4) |
Accredited with NABH | 1 7 9 |
Accreditation/certification valid | 1 2 8 |
Accreditation/certification expired | 1 4 |
Provisionally accredited | 8 |
Renewal under progress | 1 9 |
Suspended/voluntary withdrawal | 1 0 |
State/ Union Territory | Registered with CDSCO* | Re-registered with CDSCO* | Registered with DHR (provisional+final) | Accreditation with NABH |
---|---|---|---|---|
Andaman and Nicobar Islands | 1 | 0 | 1 | 0 |
Andhra Pradesh | 127 | 121 | 2 8 | 4 |
Assam | 1 4 | 1 3 | 6 | 2 |
Bihar | 1 2 | 7 | 4 | 1 |
Chandigarh | 0 | 2 | 2 | 0 |
Chhattisgarh | 2 0 | 7 | 0 | 0 |
Daman and Diu | 1 | 0 | 0 | 0 |
Delhi | 9 4 | 8 7 | 5 3 | 1 2 |
Goa | 9 | 6 | 1 | 0 |
Gujarat | 165 | 176 | 4 4 | 1 4 |
Haryana | 2 0 | 3 2 | 1 8 | 5 |
Himachal Pradesh | 3 | 4 | 3 | 0 |
Jammu and Kashmir | 4 | 2 | 3 | 0 |
Jharkhand | 8 | 3 | 5 | 0 |
Karnataka | 8 4 | 155 | 8 5 | 2 2 |
Kerala | 3 2 | 8 9 | 5 0 | 8 |
Madhya Pradesh | 1 6 | 2 1 | 1 3 | 2 |
Maharashtra | 165 | 309 | 114 | 5 3 |
Manipur | 0 | 1 | 2 | 0 |
Meghalaya | 0 | 1 | 1 | 0 |
Mizoram | 4 | 0 | 3 | 0 |
Nagaland | 0 | 0 | 1 | 0 |
Odisha | 1 6 | 2 4 | 8 | 2 |
Puducherry | 5 | 1 2 | 1 1 | 1 |
Punjab | 1 8 | 2 6 | 1 5 | 5 |
Rajasthan | 4 0 | 5 1 | 2 0 | 6 |
Sikkim | 1 | 2 | 1 | 0 |
Tamil Nadu | 102 | 115 | 9 1 | 2 0 |
Telangana | 4 9 | 1 5 | 4 5 | 6 |
Tripura | 2 | 0 | 0 | 0 |
Uttar Pradesh | 7 2 | 6 6 | 3 9 | 3 |
Uttarakhand | 6 | 6 | 5 | 0 |
West Bengal | 3 1 | 6 3 | 2 3 | 1 3 |
Total | 1122 | 1416 | 702 | 179 |
Registration and re-registration of EC with CDSCO
About 87% of registered ECs are institutional; the remaining (13%) are independent ECs. Maharashtra and Gujarat lead the list of registered ECs with the CDSCO followed by Andhra Pradesh, Tamil Nadu, Delhi, Karnataka and Kerala.
Registration of EC with DHR
About 97% of registered ECs are institutional and overseeing biomedical and health research (i.e. academic clinical trials). The registration of ECs for biomedical and health research under the DHR as per NDCT rules 2019 started with a low proportion in 2019 (18, 2.5%). The registrations peaked in 2020 (357, 51%) and 2021 (327, 46.6%), despite the impact of Covid-19 lockdowns. This depicts the commitment of ECs for regulatory compliance. Other possible reason could also be the need of initiation of biomedical and health research on Covid-19-related studies, which was the need of hour. Maharashtra (114, 16.2%) leads in registration of EC with the DHR for approving biomedical and health research, followed by Tamil Nadu (91, 12.9%), Karnataka (85, 12.1%) and Andhra Pradesh (73, 10.9%). Several states and UTs (Andaman and Nicobar Island, Chandigarh, Daman and Diu, Himachal Pradesh, Jammu and Kashmir, Jharkhand, Manipur, Meghalaya, Mizoram, Nagaland, Sikkim) had less than 5 registered ECs. There were no registered ECs from Arunachal Pradesh, Lakshadweep, Dadra and Nagar Haveli and Tripura.
Accreditation
Only 16% of registered ECs were accredited with the NABH. The accreditation of ECs with the NABH had an impact in 2020 (35, 20%) and 2021 (35, 20%) compared to 2019 (71, 40%) due to Covid-19-imposed lockdown. The slow accreditation may be due to lack of motivation as it is a voluntary self-improvement process, huge workload, lack of dedicated workforce, etc. Maharashtra (53, 29.6%) leads with the most accredited ECs in the country, followed by Karnataka (22, 12.3%) and Tamil Nadu (20, 11.2%). Half the states/UTs (19 states) did not have even a single accredited EC.
DISCUSSION
This is possibly the first effort to profile ECs registered/reregistered with the CDSCO, ECs registered with the DHR and accreditation with the NABH, as per the NDCT. There is lack of clarity on the target ECs operating as the ECs continue their new registrations annually: 142 new ECs registered in 2021, 166 in 2020, 132 in 2019. The registered institutional ECs does not reflect the total number of ECs that exist in the country. The possible reasons could be that few institutions are unaware of the registration requirements or the EC institutionalized considering the demand of research uptake. The registrations and re-registrations of ECs during 2013–18 lost their validity in 2021, considering that their registrations were valid for 3 years. As of December 2021, a total of 1115 ECs possessed valid registrations, i.e. the registered ECs (440) and re-registered ECs (675) during 2019–21 may possess valid registrations.
The data regarding number of applications under review and rejected are missing in the registration of ECs with the CDSCO while registration with the DHR provides a provisional certificate (validity for 2 years) and final registration (valid for 5 years) after scrutiny of applications. The NABH data provide details on application, accredited list and status such as renewal under progress, suspended, voluntary withdrawal and provisional accreditation. The skewed distribution of ECs among states and concentration in certain states suggests that research is under-represented geographically with limited access for patients to participate in clinical trials—particularly for orphan drugs. One of the limitations of our study is that the data and information published on websites of the concerned agencies were analysed, which may have incomplete or missing data due to lags in posting information on websites.
NDCT 2019 brought clarity for registration of ECs which review biomedical and health research under the DHR. The registration of ECs with the DHR are positively trending in scale, while accreditation with the NABH was stagnant during the Covid-19 years. The possible explanation for low volume of registered ECs undergoing accreditation needs to be explored with evidence for value proposition of accreditation on quality oversight. The current governance model also imposes on the governing bodies of EC registration to conduct inspections to ensure regulatory adherence and harmonized functioning. Alternatively, the NABH accreditation should be stimulated to strengthen and harmonize EC functioning and quality oversight.
Promoting digital EC functioning in the era of technology may ease the monitoring of EC functioning by regulators. The ECs are empowered for patient protection and quality oversight; hence, capability building to scale up the functioning of ECs in the technological era is the need of the hour.
References
- The International Conference on Harmonization of Technical Requirements for Registration of Pharmaceuticals for Human Use. Guideline for Good Clinical Practice, ICH. Available at https://database.ich.org/sites/default/files/E6_R2_Addendum.pdf (accessed on 7 Dec 2021)
- [Google Scholar]
- World Medical Association Declaration of Helsinki: Ethical Principles for Medical Research Involving Human Subjects. Available at https://jamanetwork.com/journals/jama/fullarticle/1760318 (accessed on 7 Dec 2021)
- [Google Scholar]
- Central Drugs Standard Control Organization, New Drug and Clinical Trials Rules 2019. Available at https://cdsco.gov.in/opencms/export/sites/CDSCO_WEB/Pdf-documents/NewDrugs_CTRules_2019.pdf (accessed on 7 Dec 2021)
- [Google Scholar]
- New drugs and clinical trials rules 2019: Changes in responsibilities of the ethics committee. Perspect Clin Res. 2020;11:37-43.
- [CrossRef] [PubMed] [Google Scholar]
- ICMR, National Ethical Guidelines for Biomedical and Health Research involving Human participants. Available at https://ethics.ncdirindia.org/asset/pdf/ICMR_National_Ethical_Guidelines.pdf (Section 4.15, page 48) (accessed on 7 Dec 2021)
- [Google Scholar]
- Accreditation—A solution for problems or a fresh problem? Perspect. 2015;6:123-4.
- [PubMed] [Google Scholar]
- Accreditation of research in India: One step at a time. Perspect Clin Res. 2014;5:1-2.
- [CrossRef] [PubMed] [Google Scholar]
- National Accreditation Board for Hospitals and Healthcare Providers (NABH) Available at www.nabh.co/ClinicalTrial.aspx (accessed on 21 Dec 2021)
- [Google Scholar]
- Central Drugs Standard Control Organization, Ethics Committee. Available at https://cdsco.gov.in/opencms/opencms/en/Clinical-Trial/Ethics-Committee/ (accessed on 7 Dec 2021)
- [Google Scholar]
- Department of Health Research. Available at https://naitik.gov.in/DHR/Homepage (accessed on 7 Dec 2021)
- [Google Scholar]