Before the start of the clinical trial, all Investigators will undergo training in pharmacovigilance requirements and obtain detailed written instructions for recording and reporting of AEs. These instructions for pharmacovigilance will be part of the Investigator's Site File.
7.1. Definitions (according to the Directive 2001/20/EG)
For clinical trials, effective legislation has introduced the following definitions.
Table 2: Definitions of safety signals in clinical trials
Adverse event
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AE
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Any untoward medical occurrence in a patient or clinical trial subject administered a medicinal product and which does not necessarily have a causal relationship with this treatment.
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Adverse drug reaction
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ADR
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All untoward and unintended responses to an investigational medicinal product related to any dose administered
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Serious adverse event
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SAE
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A serious adverse event/reaction is any untoward medical occurrence or effect that at any dose:
- Results in death;
- Is life-threatening;
- Requires hospitalization or extension of existing hospitalization;
- Results in persistent or significant disability or incapacity;
- Is a congenital anomaly or birth defect.
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Serious adverse reaction
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SADR
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Unexpected adverse reaction
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UADR
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Adverse reaction, the nature, severity, or outcome of which is not consistent with the product information (SmPC)
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Suspected unexpected serious adverse reaction
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SUSAR
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Any suspected adverse reaction related to the study treatment that is both serious and unexpected.
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7.2.AE surveillance, recording and documentation
AE could be diseases or symptoms which occur or worsen after the enrolment of a patient in the clinical trial. All AEs need to be documented, no matter if the investigator suspects a causal connection to the study medication. AE will be monitored and documented from the day of giving informed consent until the end of participation in the study (i.e., Day 360).
Subjects will be instructed to report any AEs that they experience to the investigator. The investigator should actively ask about AEs.
Each AE should be described, documented in the eCRF, and evaluated to determine:
- Seriousness (see Chapter 7.4);
- Severity (see Chapter 7.5);
- Causality, i.e. relation to the study medication (see Chapter 0.);
- Duration (start and end dates or whether it continues).
- Action taken (no action taken; study medication discontinued; prolongation of the ongoing hospitalization; administration of a drug etc.)
AE needs to be followed until its resolution, i.e. until it subsides, stabilizes, becomes chronic, or the subject dies.
If AE fulfils the criteria of SAE, a separate form must be completed besides the standard eCRF record (see Chapter 7.7).
AEs will be recorded according to the Medical Dictionary for Regulatory Activities (MedDRA). The most recent MedDRA version at the start of the study will be used.
7.3. Treatment of AE
A patient with an AE must receive appropriate therapy. The investigator may decide to discontinue the study medication. The patient will remain under medical supervision until the investigator believes that the AE has been resolved.
7.4. Assessment of seriousness
AE is considered serious if it fulfils the definition in Chapter 7.1.
Some situations can be considered as SAE even if they do not fulfil the criteria of the definition. These are important medical events that may not be immediately life-threatening, or result in death, or hospitalization but may jeopardize the subject, or may require intervention to prevent one of the other outcomes listed in the definition above. These should also be considered SAE – e.g., allergic bronchospasm, convulsions, or other states requiring treatment.
If AE fulfils the criteria of SAE, a separate Serious Adverse Event Form must be completed and sent to the sponsor. For the procedure see Chapter 7.7.
In this clinical trial, the following SAE are excluded from the notification requirement:
- SAE which occurs after enrolment (i.e., after giving informed consent), but before the study medication was initiated;
- Hospitalization(s) planned before the enrolment;
- Death not related to the dexamethasone use.[1]
7.5.Assessment of intensity (severity)
The intensity (severity) of an AE should be evaluated according to these 5 categories:
Grade 1
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AE is asymptomatic or mildly symptomatic, requires only observation, no medical intervention
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Grade 2
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AE with medium intensity, requires local, non-invasive, or small-scale treatment
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Grade 3
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AE is medically significant, requires hospitalization or extension of ongoing hospitalization, but it is not directly life-threatening
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Grade 4
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AE is life-threatening and requires urgent significant medical intervention
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Grade 5
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AE leads to death
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7.6. Assessments of causality
To assess the relation between administration of the study medication and the AE, the following definitions apply:
- Related – The event is known to occur with the study medication, there is a reasonable possibility that the study medication caused the AE, or there is a temporal relationship between the study medication and AE. Reasonable possibility means that there is evidence to suggest a causal relationship between the study medication and the AE.
- Not related– There is not a reasonable possibility that the administration of the study medication caused the AE, there is no temporal relationship between the study medication and AE onset, or an alternate aetiology has been established.
7.7. Reporting of SAE and SUSAR
The Investigator is obliged to report any SAE within 24 hours after he/she learns about it to the Sponsor using Serious Adverse Event Form (SAE Form). The blank forms are stored in the Investigator’s Site File. The announcement will be done by e‑mail: [email protected]
If at that point all required information is not available, succeeding records will be sent by the investigator. Sponsor will check the notification completeness and formal plausibility. If required, queries will be made and followed up.
In the case of death, a copy of the autopsy record should be added. If the death of the subject complies with the definition of SUSAR (see Chapter 7.1), it will be reported as SUSAR (see below).
Sponsor has full responsibility for the safety of the clinical trial. Further reporting of AEs to the competent authorities according to the legal requirements is the responsibility of the sponsor.
Follow-up
All SAEs should be followed until their resolution, i.e., they subside, stabilize, become chronic, or the subject dies followed. In case of early termination because of SAE occurrence, the subject should be followed until SAE resolution. All necessary extra visits will be recorded in the eCRF as "Unscheduled visits".
Follow-up information is sent using a new SAE Form stating that this is a follow-up to the previously reported SAE and giving the date of the original report. Within 24 hours of receipt of follow-up information, the investigator must update the SAE form and submit any supporting documentation (e.g., laboratory test reports, subject discharge summary, autopsy report etc.) The follow-up information should describe whether the event has resolved or continues, if and how it was treated and whether the patient continued or withdrew from trial participation.
Reporting of SUSAR
SAE related to the study medication fulfilling the criterion of unexpectedness (i.e., SUSAR) must be reported by the sponsor to the Ethics Committee and the EudraVigilance database (module EVCTM), at the latest 15 days after it becomes known. Sponsor will also inform all Investigators involved in the trial. Reporting to the EudraVigilance database will be performed via regulatory authority according to the agreement between the sponsor and the regulatory authority. In case of a fatal or life-threatening SUSAR, the sponsor will report all relevant information immediately, at the latest 7 days after the event becomes known. Any subsequent additional information is forwarded within the next 8 days if necessary.
7.8.Pregnancy
Pregnant or breastfeeding women cannot be included in the study. Pregnancy testing (hCG, blood sample) is obligatory at enrolment in women of childbearing potential (i.e. from menarche to the onset of postmenopausal state). In case the information regarding menstrual cycle cannot be obtained from the patient due to her health or consciousness status, pregnancy testing is also necessary independently of patient’s age. If statim hCG is not available at the moment of enrolment, investigators should perform urine pregnancy testing. Urine test strips will be supplied to the trial centres, where statim hCG is not available, e.g. on weekends or public holidays.
Participants, men and women, must comply with the required contraception measurements from the enrolment to at least 1 week after the last dose of dexamethasone. Sexual abstinence is considered as the adequate contraception method for this clinical trial. Newly-emerged pregnancy in the hospitalization phase of the trial is highly unlikely. However, if it is diagnosed, dexamethasone treatment must be stopped. If a participant becomes pregnant during the follow-up phase, she must inform the investigator.
The Investigator should report the pregnancy to the Sponsor within 24 hours of learning of its occurrence using Pregnancy Form. This announcement will be done by e‑mail: [email protected]
Pregnancy should be followed by the investigator until completion. If it ends for any reason before the anticipated date, the investigator should notify the sponsor. At the completion of the pregnancy, the investigator will document the outcome of the pregnancy. If the outcome of the pregnancy meets the criteria for classification as SAE (e.g., spontaneous abortion, stillbirth, neonatal death, postpartum complication, or congenital anomaly), the investigator should follow the procedures for reporting an SAE (see Chapter 7.7).
[1] The sponsor expects a high mortality rate due to the natural course of the disease in patients that need ICU care. Relatedness of death to dexamethasone use will be assessed by the trial investigator. Cases considered “not related” will not be separately reported by the sponsor to the RA/EC. The sponsor will be notified of them through eCRF records, and RA/EC will be informed by the sponsor through periodical Annual Reports and final CSR. Cases of death considered “related” will be handled as SAE at the trial site and reported separately and immediately by the sponsor to the RA/EC.