Last update: February 6, 2011
UBC BCCA Research Ethics Board
Policies
Some procedures for the UBC BCCA REB may differ from the UBC REB's. The items below are to assist in providing information for BCCA researchers for requirements that may be specific to the BCCA REB.
| BCCA REB Policy |
Effective Date or Date of Last Update |
| Who should submit ethics applications to the BCCA REB and the UBC REBs "One Board of Record" agreement. |
February 12, 2008 |
| Adding a participating centre to an approved study |
March 20, 2008 |
| Certificates of Approval |
July 6, 2009 |
| Clinical Trials Agreement (CTA) |
January 30, 2008 |
| Fee for Ethical Review |
January 30, 2008 |
| Focus Groups |
February 27, 2004 |
| Listing PI, Co-investigators, and Reporting Changes or Temporary Leave of absence of an investigator |
November 4, 2009 |
| Person Obtaining Consent |
March 8, 2004 |
|
Protocol Deviations |
April 22, 2006 |
| Registration for Publication |
November 12, 2009 |
| Requirement for Informing or Re-Consenting Subjects When There Is an Update to an Investigator Brochure (IB). |
March 20, 2008 |
| Signatures on Application Forms |
April 3, 2006 |
| Subject Handouts and Advertisements |
March 8, 2004 |
| TCPS Tutorial required for Medical Residents and Graudate Students |
Dec 7, 2010 |
|
Use of Secondary Identifiers |
January 13, 2004 |
| Use of Term "Subject" vs "Participant" vs "Patient" |
January 13, 2004 |
UBC BCCA REB
Details about who should submit ethics applications to the UBC BCCA REB and the UBC Research Ethics Boards "One Board of Record" agreement is posted on our FAQ webpage:
"I am uncertain as to where to submit my application"
Back to Top
Adding a Participating Centre to an Approved Trial
The BCCA principal investigator must submit an amendment to the UBC BCCA REB to add a participating centre to a trial that is currently active and approved by the UBC BCCA REB.
Once the amendment is approved, the additional BCCA (or other) center must adopt the up to date REB approved protocol and trial-associated documents, format, content, and consent forms for the trial. These up to date documents reflect all previously reported serious adverse event (SAE) reports or safety letters already approved or acknowledged by the UBC BCCA REB. No additional center specific documentation will be provided by the REB beyond our standard approval certificates (i.e. the certificate of amendment that records approval of the addition of the participating centre).
Back to Top
CERTIFICATES OF APPROVAL (Effective March 1, 2004)
(Revised; May 1, 2004, April 22, 2006, January 30, 2008, June 29, 2009, July 6, 2009)
The Certificate of Approval will be issued only upon completion/receipt of the following, if applicable;
1. The BCCA REB has approved the project.
2. The Clinical Trial Agreement (legal contract) If applicable. (Effective for studies reviewed after May 1, 2004, revised January 30, 2008).(Refer to:Clinical Trial Agreement)
3. The REB Review Fee, if applicable.(Effective May 1, 2004) (Refer to Fee for ethical review)
Note: This Fee is separate from the SAE fee which is billed separately (Refer to SAE Fee.)
4. A copy of the Health Canada NOL (No Objection Letter) if applicable, is received for a new submission and (Effective April 22, 2006) any subsequent amendment that may require Health Canada Approval (such amendments require full board approval). A waiver to provide a copy of the HC NOL prior to the REB issuing the certificate may be requested by the PI and considered by the REB under exceptional circumstances where Health Canada may require the REB approval prior to issuing their (HC) approval. Under such circumstances the HC NOL must be submitted (as an amdnement in RISe) when it becomes available. (Refer to Scientific Peer Review : BC Cancer Agency)
5. For US affiliated Studies the REB will only issue the certificate upon approval of the project and completion of applicable administrative requirements. (Refer to: US affiliated Studies)
6. Final documents containing only “highlights” will be accepted. However, if a document is approved by the REB and it contains “tracked changes” the REBA will request that a final version be submitted by accepting the “tracked changes “ (leaving the version date the same and no additional changes to the document) before issuing the certificate of approval.
7. Registration for Publication of Clinical Trials (if applicable); the name of the registry and registration number must be provided (this must be a registry accepted by the International Committee of Medical Journal Editors (ICMJE). (Refer to: Policies: BC Cancer Agency)
8. (Tri-Council Policy Statement) TCPS Tutorial must be completed by medical residents and graduate students participating in conducting a research project.
(Refer to: Policies: BC Cancer Agency)
Effective July 1, 2009 the UBC BCCA REB Certificates of Approval no longer includes the digital signature of the REB Chair(s). Details: Memo re Policy on Electronic Signatures 
Back to Top
Clinical Trials Agreement (CTA) - New Policy effective May 1, 2004, revised January 30, 2008
Reference: Tri-Council Policy Statement (TCPS):
Section 7: Clinical Trials http://www.pre.ethics.gc.ca/english/policystatement/section7.cfm
Article 7.3: REB's shall examine the budgets of clinical trials to assure that ethical duties concerning conflict of interest are respected.
Projects requiring submission of the Clinical Trials Agreement:
Criteria:
All Industry related and "for-profit" sponsored studies require a "Clinical Trials Agreement" between the sponsor, the BC Cancer Agency and the investigator.
Exclusion Criteria:
The following types of trials may be excluded from the Clinical Trials Agreement requirement:
i. Cooperative groups (i.e; NSABP);
ii. National Cancer Institute of Canada Clinical Trials Group
iii. Grant from a non-profit organization, for example, CIHR, NIH or a cancer-specific foundation
iv. BCCA internal
The CTA requirement may be waived in other circumstances as agreed by the BCCA REB. A request for waiver must be submitted in writting with an explanation.
Submission of CTA
- One copy of the completed and signed CTA is to be submitted to the BCCA REB (attach to Section 9.8 in the RISe application).
- It is the responsibility of the BCCA Principal Investigator to submit the CTA to the BCCA REB.
- (Update October 5, 2005) If one consolidated CTA covers all participating centres for a trial, then only that one CTA is required. If there is a CTA specific for each participating centre, the REB requires a copy of all CTAs, however, the REB may release the certificate of approval upon review and approval of the BCCA PI submitting centre's CTA. The CTA for additional participating centres must be submitted when they become available by submitting an amendment in RISe and attaching the CTA in Section 9.8 of the application.
- (Update February 8, 2007) If the CTA is amended, the amended version must also be submitted to the REB as an amendment in RISe.
- (Update January 30, 2008) If the CTA is received and approved by the REB and it includes a clear statement that the sponsor is bound by the agreement to pay the $3000 REB fee, the REB will issue the certificate pending receipt of payment (providing all other provisos have been satisfied). The language must be clear and easily identified in the contract. An example of preferred wording is below. The REB will accept other language with clearly similar intent. However, in situations where such language is not clearly evident in the CTA, the REB will continue to withhold the certificate of approval until the payment is received.
Example of wording:
"Ethics Committee Fee
A payment of $3,000 for the initial ethics committee review will be issued by [sponsor name] upon receipt of the appropriate invoices from the institution.
Back to Top
Fee for Ethical Review - Effective May 1, 2004, revised January 30, 2008
For full details of the REB fee for ethical review and the SAE review fee, including criteria for fee waiver and refunds please refer to the BCCA Fee webpage.
Back to Top
Focus Groups (Effective February 27, 2004)
The BCCA REB considers focus groups to be ordinarily of minimal risk and, thus, research projects including focus groups may be considered for expedited review provided all other criteria for expedited review are met and the informed consent clearly indicates that the subject agrees to consider all information about other members in the group confidential.
Back to Top
Listing of Principal Investigators, Co-investigators and Reporting Changes or Temporary Leave of Absence (Effective May 27, 2003, Revised Nov 11, 2008, Nov 4, 2009, Feb 6, 2011)
- The REB (RISe) Application Form m
ust identify;
-BCCA Principal Investigator (PI) responsible for the study (section 1.1)
-all co-investigators (Section 1.3)
-the lead PI (only one) for each additional participating "BCCA centre" (Section 11)
-Note: Section 4.2B may be used to identify individuals or sites that must appear on the certificates of approval that will otherwise not appear (see below).
- BCCA REB certificates will list;
-the BCCA PI responsible for the study (Section 1.1 in RISe)
-the lead PI (only one) for each additional participating "BCCA centre" (Section 11 in RISe)
-any information entered into section 4.2B (in RISe) exactly "as entered" by the applicant on each certificate unless an amendment is submitted by the applicant.
- BCCA REB certificates do NOT list;
- co-investigators (from section 1.3 in RISe)
- study personnel from sections 1.2, 1.4 or 1.5 in RISe.
If an individual from one of these sections must appear on the certificate, the applicant may enter them in section 4.2B (in RISe) which will appear exactly "as entered" by the applicant on each certificate unless an amendment is submitted.
- The consent document(s) must identify;
- the lead PI responsible for the study (this should match Section 1.1 in RISe).
- the lead PI (only one) for each additional participating centre (covered by the REB approval)
- the subject's study doctor if different from above
- a 24/7 emergency contact
- a non-emergency contact person other than the PI (i.e. Dept. Head) for concerns about the conduct of the study
- the UBC Research Subject Information Line (noted in the BCCA REB consent template)
Note: It is NOT a requirement of the BCCA REB to list all co-investigators in the consent document.
- Permanent changes or a leave of absence of six months or longer of any investigator(including co-investigators) must be reported to the REB. If a PI or co-investigator is 'relinquishing their responsibility' for six months or longer an amendment must be submitted to notify the REB of the change (even if there is a "designated coinvestigator with signing authority in RISe"). The consent document should be revised if the study is open to accrual so that subjects yet to be enrolled will be given the revised approved consent. Already enrolled subjects may be verbally informed about the change of an investigator (this should be documented in the subject's file), or they may be reconsented with the revised approved consent if the PI deems it necessary based on the status of the study and already enrolled subjects.
- Changing the PI: If you need to change the PI permanently or temporarily (as noted above), submit an Amendment to the REB using the RISe system. This involves completing the "change of PI form" located in the Amendment PAA Coversheet in RISe. The form requires the signature of the following and to then be reattached in the PAA Coversheet as a .pdf file;
-the current PI
-the new PI
-the new PI's Department Head.
If the PI is not available to sign the form then provide an explanation on the form as to why they are not available to sign it.
If the PI is not available to submit the amendment; a coinvestigator with signing authority listed in RISe can submit the amendment. The PI can access RISe from any location where they can access the internet. If the PI cannot access the internet to either submit the amendment or designate a coinvestigator with signing authority (see below), then contact the REB by email for instructions (reb@bccancer.bc.ca ).
- Designating Coinvestigators with Signing Authority: Once a study is approved, the PI should immediately designate up to 2 "Coinvestigators with Signing Authority" in RISe from the list of approved coinvestigators. These coinvestigators may submit applications in RISe on behalf of the PI. Only the PI can designate these individuals which can be done quickly in RISe (it does not require submission to the REB) and takes effect as soon as the PI adds their name. Note: If the PI or coinvestigator is relinquishing their responsibility for six months or longer (regardless of whether there is a designated coinvestigator with signing authority in RISe) submission of an amendment to notify the REB is still required, and if applicable, a revised consent document. See instructions to: Designate Coinvestigators with Signing Authority in RISe
Back to Top
Person Obtaining Consent (Effective March 8, 2004)
The BCCA Consent Document(s) signature page must state "Person Obtaining Consent", and include their signature, printed name, study role and date of signature. (Refer to BCCA Consent Templates )
The "Person obtaining Consent" must be a person sufficiently familiar with the study, the disease being treated and the process of informed consent to be able to obtain properly informed consent and, thus, will usually be the investigator or a designated research assistant, however, in accordance with the Tri-Council Policy Statement D1 Article 2.4 which states "In a research team, the principal researcher is ultimately responsible for the actions of those acting with delegated authority" (Also see UBC CREB Guide 39.8.4 )
Reminder for investigator: The investigator should independently document the obtaining of informed consent in the medical record, noting date, the subject's full understanding of the risks and benefits of enrollment and the voluntary nature of participation.
Back to Top
Protocol Deviations (exemptions, violations, waivers)
(Effective February 27, 2004; Updated June 22,2005, April 22, 2006)
A protocol deviation is an unanticipated or unintentional divergence or departure from the expected conduct of an approved study that is not consistent with the current research protocol, consent document or study addenda.
Examples of protocol deviations include:
i) changes in procedures initiated to eliminate immediate hazards to study subjects;
ii) enrolment of subjects outside protocol inclusion/exclusion criteria, whether agreed to or not by the sponsor;
iii) medication/intervention errors [i.e. incorrect drug/intervention, incorrect dosage of the drug];
iv) inadvertent deviation in specific research intervention procedures or timing of the research intervention which could impact upon the safety or efficacy of the study-related intervention or upon the experimental design [n.b. this would not include appointment deviations usually];
v) breach of confidentiality or privacy whereby confidential information about a subject is revealed in inappropriate settings, or to persons without a need to know, or by data exposure (computer security breach, documents left unsecured), and;
vi) significant deviation from the consenting process.
Furthermore, it is the responsibility of the Principal Investigator to notify the REB of all protocol deviations that:
1) expose subjects to potential increased risk;
2) compromise the integrity of the entire study;
3) are repetitive in nature;
4) alter subject eligibility, or
5) affect the privacy of the subject.
Timeframes for Reporting Protocol Deviations
1) A deviation from, or change of, the protocol to eliminate immediate hazards to the study subjects must be reported to the REB within 5 days of its discovery.
2) All other deviations must be reported to the REB within 15 days of their discovery.
Back to Top
Registration for Publication (Expanded Definition Includes Phase I Clinical Trials)
Update posted: September 19, 2008; revised Oct. 23/08; revised Nov 12, 2009
Publication of the results of research studies, whether positive or negative, is of obvious value to society and an ethical obligation of investigators to the subjects who voluntarily participated. In recognition of this ethical obligation the journals represented by the International Committee of Medical Journal Editors (ICMJE) require that research studies initiated after June 2005 be registered before the research starts or they will not be considered for publication. Ongoing studies that started prior to June 2005 were required to have been registered by September 2005. The ICMJE provides a "definition" of studies that require registration and a list of acceptable registries. This is summarized below showing the change between the previous and current definition.
The International Committee of Journal Editors (ICMJE) recently implemented an expanded (2007) definition of research studies that must be registered and extended the list of acceptable registries.
If there is any possibility of the intent to publish results of a research study, it must be registered BEFORE the research starts. Principal Investigators must ensure that a study is registered and appropriately updated when the study is complete or results are published.
This applies to all research studies of healthcare interventions that involve prospective enrollment of subjects that began enrollment on or after July 1, 2008.
Previous: International Committee of Journal Editors Definition (2005)
“Any research project that prospectively assigns human subjects to intervention and comparison groups to study the cause-and-effect relationship between a medical intervention and a health outcome. The trial must have at least one prospectively assigned concurrent control or comparison group in order to trigger the requirement for registration.”
This definition previously excluded Phase I trials.
Current: International Committee of Journal Editors Definition (2007)
"Any research study that prospectively assigns human participants or groups of humans to one or more health-related interventions to evaluate the effects on health outcomes.”
This is meant to be interpreted broadly to include drugs, devices, surgical procedures, behavioural, dietary interventions, process-of care-changes or other management studies which have the intent to modify a health outcome.
This new definition includes Phase I trials.
Please note effective September 27, 2008, the US Food and Drug Administration mandated the submission of “basic results” data for certain clinical trials of drugs, biologics, and devices,. This obligation is mandatory for all trials that are not Phase 1 or small device feasibility studies that have at least one site in the US, regardless of who sponsors, finances, or conducts the trial. In general, these summary results data must be submitted within 12 months of the completion of data collection for the primary outcome measure.
http://www.icmje.org/update_fdaaa.html
http://www.icmje.org/faq_clinical.html
BCCA REB Registration Requirements:
All new research studies that require registration must be registered before the initial BCCA REB certification of approval will be issued.
Ordinarily, studies will have already been registered by the sponsor so the Principal Investigator need only verify with the sponsor or registry that the study has been registered and enter the registration information in the REB (RISe) application form (section 711A & B).
Clinical trials must be registered with a registry that meets the requirements of the ICMJE. For information on acceptable registries which now include any primary register that participates in the World Health Organization International Clinical Trial Registry Platform.
For details and the ICMJE list of acceptable registries see the following articles and links:
http://www.icmje.org/ ICMJE (International Committee of Journal of Editors)
http://www.icmje.org/faq.html ICMJE Frequently Asked Questions (FAQs) about the above update and list of registries.
http://clinicaltrials.gov is one of the clinical trial registries of federally and privately supported clinical trials conducted in the United States and around the world that is accepted by the ICMJE.
Additional references:
http://www.icmje.org/publishing_10register.html
http://www.icmje.org/update_june07.html
CMAJ June 21 2005 article
CMAJ June 21 2005 editorial
Back to Top
Requirement for Informing or Re-Consenting Subjects When There Is an Update to an Investigator Brochure (IB).
The REB considers it to be the responsibility of the study sponsor, the accountable investigators and the study team, to practice due diligence and oversight for clinical trials, including the safety of subjects.
Therefore, the REB relies on the study investigators and the sponsoring agency to use their best judgment in determining when new information, or changes to an IB warrants disclosure to subjects, or re-consenting.
The REB requires that any new information obtained and documented in an IB or other document be submitted to the REB, together with an explanation of what changes were made, and the decision of the study sponsor/team as to the actions to be taken in light of the new information. The REB reserves the right to request an alternate action be taken if deemed necessary.
Back to Top
Signatures on Application Forms (Effective February 18, 2004)
April 3, 2006: This policy is no longer applicable as all submissions to the REB are to be made using the new Researcher Information Services (RISe) system.
The BCCA REB will accept digital signatures on the first page of application forms sent by e-mail (it will not be necessary to send the original in follow-up). If a digital signature is not available then e-mail the whole application form as usual and one copy of the signed first page by fax or mail (do not fax the entire application).
Back to Top
Subject Handouts and Advertisements (Effective March 8, 2004)
Any document that the subject will be given such as a contact letter, questionnaire, journal or log etc., or advertisements for the study, and that the subject would not have been given anyway whether on the trial or not, must be submitted to the REB for approval in keeping with
UBC CREB Guidance Note 6.2 ( http://rise.ubc.ca/helpCenter/GN/CREB_Guidance_Notes.html#Guide6.2 ) Information that is supplied to patients whether they are on the trial or not, or for the standard treatments given during trials, does not need REB review.
The BCCA REB requires that document(s) for review be submitted separately (even if it was included in the protocol as an appendix) and must be in the same format that will be given to the subject (or as advertised) with a version date in the footer for tracking purposes. The submitted document(s) will be listed on the approval certificate with that version date and must match the one given to the subject. Changes to the approved document must be submitted to the REB with an updated version date (a revised protocol will not be required unless there are other changes to the protocol). Note: The consent document should also mention what handouts the subject will receive, the purpose of the handout, for example, if this is for the subject to keep, or if this is to be returned and if so to whom and where it will be kept.
Back to Top
Graduate students and medical residents (involved in human subject research) are required to complete the Tri-Council Policy Statement (TCPS) Research Tutorial.
Effective April 3, 2006, new applications became subject to an additional requirement that all graduate students and medical residents involved in the project complete the TCPS tutorial BEFORE the application is submitted to the REB. The REB requires that
all PIs are familiar with the TCPS and recommends completion of the TCPS Tutorial, especially when the PI supervises or teaches classes for graduate students or medical residents.
Certificates do not need to be attached to the ethics applications, however, copies should be retained by the PI and be available on request.
December 2010: The original TCPS tutorial has now been retired with the release of the 2nd Edition of the TCPS and the new tutorial will be released in February 2011(http://pre.ethics.gc.ca/pdf/eng/tcps2/TCPS_2_FINAL_Web.pdf)
In the interim, graduate students and medical residents should fulfill this requirement by completing the CHRPP (Course in Human Research Participant Protection) instead. See: Educational Opportunities
Back to Top
Use of Secondary Identifiers (Effective January 13, 2004)
- For all study data records that leave the BC Cancer Agency, unique independent identifying numbers such as social insurance number, telephone number, hospital or BC Cancer Agency number must not be included.
- The primary identifier on such data records should be the subject's study code which may include the subject's initials. Note that NCIC CTG trials require the use of initials in the study code.
- A secondary identifier such as the date of birth, has been requested by some sponsors and NCIC-CTG. The hospital or BCCA number cannot be used, however, the date of birth may be provided as a secondary identifier if requested.
- The BCCA REB is satisfied that this will provide reasonable protection of confidentiality for subjects, while decreasing the potential for error or producing fraudulent records.
- To maintain consistency other sponsors will be allowed to follow the same policy with regard to secondary identifiers on request and with adequate justification.
- While such secondary identifiers as initials and date of birth are considered non-standard in some areas of human research (as noted in the UBC CREB guidance notes for consent documents, see GN #29
http://rise.ubc.ca/helpCenter/GN/CREB_Guidance_Notes.html#Guide29.1 ) such use is standard in the field of cancer research.
Back to Top
Use of the term "Subject" vs "Participant" vs "Patient" (Effective January 13, 2004)
The individual participating in a study should be referred to as the "subject" or, if for some special reason that is not thought appropriate, "participant". The chosen term must be used consistently in the title of the study and throughout the document.
Back to Top