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The EFGCP Report on
  The Procedure for the Ethical Review of Protocols for
          Clinical Research Projects in Europe
                                     (Mar 2012)

                                       Turkey

  1. What laws or regulations apply to an application for
  conducting a clinical trial in Turkey?
Laws: (in Turkish)

Sağlık Hizmetleri Temel Kanunu "Ek Madde 10" (6 April 2011)
Araştırma ve Geliştirme Faaliyetlerinin Desteklenmesi Hakkında Kanun (2008)
Türk Ceza Kanunu (2005)
Sağlık Bakanlığının Teşkilat ve Görevleri Hakkında Kanun (13 December 1983)
İspençiyari ve Tıbbi Müstahzarlar Kanunu (1928)


Regulation:
Regulation On Clinical Trials (19 Aug 2011)



Regulation on Clinical
     Trials.pdf




  2. Which government, legal or authoritative body or bodies is or
  are responsible for the establishment and/or accreditation of
  (research) ethics committees for IMPs, and for their supervision
  and quality? Are there different (research) ethics committees
  reviewing other projects?

Ministry of Health (MoH) is the responsible authority for the accreditation of Ethics
Committees (ECs).


  3. What is the process for achieving clinical trial authorisation
  from the competent authority in Turkey?


Questions 3 and 4 are most appropriately answered together for Turkey


  4. What is the process for obtaining ethical review of a clinical
  trial protocol by a competent (research) ethics committee in
  Turkey?
                                                                        Turkey- March 2012
(1) The application dossier for a clinical trial will be prepared according to the Guideline for
Good Clinical Practice and other applicable guidelines, using the application form and its
relevant annexes posted on the Ministry’s website, and will be reviewed for Ministry
permission and ethics committee approval according to this Regulation and the guidelines to be
issued by the Ministry.

(2) In multi-center clinical trials, the scientific and ethical approval will be obtained of the
ethics committee in the locality where the coordinating center is located. Notifications will be
made to ethics committees in places where the other sites are located.

(3) The application for a clinical trial will be made to the relevant ethics committee or general
directorate by the sponsor, consisting of natural/juristic person(s), or by a contract research
organization domiciled in Turkey appointed by the sponsor. If the sponsor has no representative
domiciled in Turkey, the application for a clinical trial must be submitted through a contract
research organization domiciled in Turkey.

(4) Applications to obtain Ministry approval for conducting a clinical trial that have been
granted ethical and scientific approval with any substances or products which and which may
involve investigation in human beings, including clinical trials with medical devices, BA/BE
trials, comparability studies for biosimilar products, Phase I, Phase II, Phase III and Phase IV
drug clinical trials, clinical trials with advanced therapy medicinal products, observational
studies with drugs, observational studies with medical devices, clinical trials with traditional
herbal medicinal products and cosmetic products or raw materials, will be made to the General
Directorate of Pharmaceuticals and Pharmacy. a) For clinical trials with Class III medical
devices or with implants or long-term invasive devices in Class IIa or Class IIb, the study
sponsor or a contract research organization delegated by the sponsor will, upon the approval of
the ethics committee concerned, make an application to the General Directorate of
Pharmaceuticals and Pharmacy, and the application will be evaluated within sixty days after the
notification date. b) For all clinical trials with medical devices, excluding the ones mentioned in
subparagraph (a), and all other drug clinical trials will be evaluated within not more than thirty
days by the relevant general directorate.

(5) Applications to obtain Ministry approval for conducting clinical trials with industrial
advanced medicinal products or non-industrial advanced medicinal products, gene therapy
clinical trials, stem cell transplantation trials, organ or tissue transplantation trials and clinical
trials with a novel surgical procedure which have been given scientific and ethical approval will
be made to the General Directorate of Health Services. These applications will be evaluated
within not more than sixty days.

(6) If the general directorate concerned adopts an unfavorable decision regarding the request for
conducting the clinical trial, this decision will be notified to the applicant, together with the
rationale for the decision. The sponsor will be granted a single opportunity to resubmit the
application after making amendments to address the issues raised in the decision, or to file a
reasoned objection against the decision. If the requested changes are not fulfilled or an
acceptable justification cannot be offered, the general directorate concerned may reject the
clinical trial.

(7) In the case of clinical trials with cellular therapies using products containing genetically
modified organisms or products involving gene therapy, the thirty days specified for Ministry
approval may be extended for an additional thirty days. However, in cases where it becomes
necessary to hold detailed deliberations or to consult non-Ministerial third party experts, the
timeline may be extended further by an additional ninety days, depending on the subject matter
of the study

                                                                                 Turkey- March 2012
5. Is there a single organisation to which to apply for ethical
 review of a clinical trial for an investigational medicinal product,
 regardless of whether this is for a single site or multiple sites?

No. As of today, there are 52 different Ethics Committees in 26 different cities.

In multi-center clinical trials, the scientific and ethical approval will be obtained of the ethics
committee in the locality where the coordinating center is located. Notifications will be made to
ethics committees in places where the other sites are located.




 6. What are the website for the organisation that issues
 guidelines on the ethical review of a clinical trial for an
 investigational medicinal product?


The websites of the MoH General Directorate of Pharmaceuticals and Pharmacy:
      Turkish: http://www.iegm.gov.tr/Default.aspx?sayfa=klinik&lang=tr-TR
      English: http://www.iegm.gov.tr/Default.aspx?sayfa=clinical_dep&lang=en

The website of the Clinical Research Association:
http://www.klinikarastirmalar.org.tr/en/index.php


 7. Is there a procedural interaction between the national or local
 competent authority and the (research) ethics committee during
 the approval process?


No. Ethics committees are independent in their function of reviewing and approving clinical
trial applications from a scientific and ethical perspective. The decisions of an ethics committee
shall not be approved separately by the President of Refik Saydam Hıfzısıhha Center, the
rector, the dean, or the chief physician.

Permission of the Ministry is required to commence a clinical trial that has been approved by
ethics committee.



 8. Does the application to the EC and to the competent authority
 have to be submitted in parallel, or, if not, in which order?


No. Sequential. First EC and then Regulatory Authority (MoH) application is performed.




                                                                               Turkey- March 2012
9. How many (research) ethics committees that consider CTIMPs
 are there in Turkey?

NA


 10. How are ECs funded in Turkey? Do they charge fees? If yes
 what is their scale of fees?

During the application below listed fees should be paid to the bank account of the
institution of related EC/MoH:

      Phase I: 2.045,32 TL ( 870 €)

      Phase II: 2.045,32 TL ( 870 €)

      Phase III: 2.045,32 TL ( 870 €)

      Phase IV: 1.025,42 TL (436 €)

      Registry: 1.025,42 TL (436 €)


(Indicative Exchange Rates Announced on 16-Mar-2012 by the Central Bank of Turkey ->
1 € = 2,35 TL)



 11. Who is responsible for submitting the request for ethical
       review to the competent ethics committee for single-site
       and for multi-site clinical trials?

The application for a clinical trial will be made to the relevant ethics committee or general
directorate by the sponsor, consisting of natural/juristic person(s), or by a contract research
organization domiciled in Turkey appointed by the sponsor. If the sponsor has no
representative domiciled in Turkey, the application for a clinical trial must be submitted
through a contract research organization domiciled in Turkey. If there is no sponsor
application is made by principal investigator or by coordinator in multi-center trials.

 12. How is a “single opinion” achieved for multi-site studies?


First step: EC approval
Application is made to the related Ethics Committee for the purpose of receiving approval
scientifically and ethically for clinical trials.
According to kind of clinical trial, application is made to the related Ethics Committee with
the application form and cover letter samples prepared considering the appropriate
application form and application cover letter samples published at the website of General
Directorate for Pharmaceuticals and Pharmacy (www.iegm.gov.tr).



                                                                            Turkey- March 2012
Second step: MoH permission

Permission of the Ministry is required to commence a clinical trial that has been approved
by an ethics committee. The study sponsor will make an application to the General
Directorate of Pharmaceuticals and Pharmacy to obtain permission of the Ministry.

In order to receive Ministry permission after the received scientific and ethical approval
application is made to General Directorate for Pharmaceuticals and Pharmacy for clinical
trials to be conducted with medical devices, for bioavailability/bioequivalence (BA/BE)
studies, for comparability studies of bio-similar products, for Phase I, Phase II, Phase III,
and Phase IV drug clinical trials, for clinical trials to be conducted with advanced treatment
medicinal products, for observational drug studies, for observational medical device
studies, for efficacy and safety studies to be conducted with cosmetic raw materials or
products, and for clinical trials to be conducted with traditional herbal medicinal products.
In order to receive Ministry permission following scientific and ethical approval, for
clinical trials to be conducted with non-industrial advanced medicinal products application
is made to General Directorate of Treatment Services for clinical trials to be conducted with
industrial advanced medicinal products, for gene treatment clinical trials, for stem-cell
transplantation trials, for organ and tissue transplantation trials, and for new surgery method
trials.


 13. How many members serve on an EC?


Ethics committees, comprised of not less than seven (7) and not more than fifteen (15)
members with at least one (1) of them a non-health care professional and one (1) a jurist,
and the majority consisting of health care professionals holding a doctorate or medical
residency degree.

 14. How many members constitute a quorum?

Ethics committee members will convene with the two thirds majority of total number of
members, and adopt decisions by the favorable vote of a simple majority of its full
membership.


 15. How are EC members appointed?

Ethics committees will be established with Ministry approval within universities upon the
proposal of the rector, within Refik Saydam National Public Health Agency upon the
proposal of the President of Refik Saydam National Public Health Agency, or at teaching
and research hospitals upon the proposal of the chief physician, and commence functioning
as of the approval date by the Ministry.




                                                                            Turkey- March 2012
16. How is the independence of members ensured?


In “Regulation On Clinical Trials” it states:

ARTICLE 11 – b) Ethics committees are independent in their function of reviewing and
approving clinical trial applications from a scientific and ethical perspective. The decisions
of an ethics committee need not be ratified by the President of Refik Saydam National
Public Health Agency, the rector, the dean, or the chief physician.



 17. How are conflicts of interest of EC members avoided?

Ethics committee members who are affiliated with the study sponsor or have a role in the
study being reviewed may not take part in ethics committee discussions and nor in the
voting on the study concerned, nor may they have their signature under the committee
decision. [In “Regulation On Clinical Trials”, ARTICLE 11 – e]


 18. Whatare (R)EC members appointed?
 15. How backgrounds and/or qualifications of members are
 actively sought?


In “Regulation On Clinical Trials” it states in ARTICLE 10:

(10) An Ethics Committee for Drug Clinical Trials will consist of members that have at
least the following qualifications:
       a) Specialist physicians, at least one of whom with experience as an investigator in a
clinical trial that was organized according to the guidelines for good clinical practice;
       b) A pharmacist or doctor of medicine holding a doctorate or medical residency
degree in pharmacology;
       c) A biostatistician or physician holding a doctorate or medical residency degree in
public health;
       ç) A person holding a doctorate, medical residency or master’s degree in medical
ethics (deontology), if available;
       d) A jurist;
       e) A non-health care professional.
(11) An Ethics Committee for Bioavailability/Bioequivalence Trials will consist of
members that have at least the following qualifications:
       a) Specialist physicians, at least one of whom with experience as an investigator in a
clinical trial that was organized according to the guidelines for good clinical practice;
       b) A pharmacist or doctor of medicine holding a doctorate or medical residency
degree in pharmacology;
       c) A biostatistician or physician holding a doctorate or medical residency degree in
public health;
       ç) A pharmacist holding a doctorate degree in pharmaceutical technology;
       d) A pharmacist or chemist holding a doctorate degree in pharmaceutical chemistry or
analytical chemistry;


                                                                           Turkey- March 2012
e) A person holding a doctorate, medical residency or master’s degree in medical
ethics (deontology), if available;
       f) A jurist;
       g) A non-health care professional.
(12) An Ethics Committee for Non-drug Clinical Trials will consist of members that have at
least the following qualifications:
       a) Persons holding a doctorate or medical residency degree, at least one of whom with
experience as an investigator in a clinical trial that was organized according to the
guidelines for good clinical practice;
       b) A biostatistician or physician holding a doctorate or medical residency degree in
public health;
       c) An engineer or expert in the field of biomedicine, or, if unavailable, a biophysicist
or physiologist who is preferably a medical graduate;
       ç) A person holding a doctorate, medical residency or master’s degree in medical
ethics (deontology), if available;
       d) A jurist;
       e) A non-health care professional.
(13) An Ethics Committee for Clinical Trials will consist of members that have at least the
following qualifications:
       a) Persons holding a doctorate or medical residency degree, at least one of whom with
experience as an investigator in a clinical trial that was organized according to the
guidelines for good clinical practice;
       b) A pharmacist or doctor of medicine holding a doctorate or medical residency
degree in pharmacology;
       c) A biostatistician or physician holding a doctorate or medical residency degree in
public health;
       ç) An engineer or expert in the field of biomedicine, or, if unavailable, a biophysicist
or physiologist who is a preferably medical graduate;
       d) A person holding a doctorate, medical residency or master’s degree in medical
ethics (deontology), if available;
       e) A jurist;
       f) A non-health care professional.



 19. How does the EC obtain specialist expertise?

Where necessary, ethics committees may solicit the written opinion of experts in a relevant
field or subfield, and invite them to attend meetings in capacity of an advisor. [In
“Regulation On Clinical Trials”, ARTICLE 11 – ğ]



 20. What are the training requirements for members of RECs?


From the EC members at least one Specialist physician, should have experience as an
investigator in a clinical trial that was organized according to the guidelines for good
clinical practice.



                                                                            Turkey- March 2012
21. What training programmes are available for REC members in
 Turkey?

Some of the pharmaceutical companies organize ICH-GCP trainings for investigators and
EC members.

On the other hand, starting from mid 2009 the MoH also conducts ICH-GCP training
programmes for ECs.


 22. What are the timelines for the assessment of single- and
 multi-site studies?


For ECs: Ethics committees will form their opinion and communicate it to the applicant
within thirty days after the application date. Should additional information or clarifications
become necessary during the ethics committee review, all of the requests will be
communicated to the applicant in a single request. A second request will not be made to the
applicant. The review process will be frozen until the required data and documents are
submitted to the ethics committee.

For MoH: All drug clinical trials will be evaluated within not more than thirty days by the
relevant general directorate.

 23. How are substantial amendments submitted during the
       review process dealt with?


If, after the commencement of a clinical trial, the need arises to make any of the
amendments described in the Guideline for Good Clinical Practice, such amendment(s) will
be notified to the ethics committee concerned, to be approved by the sponsor, and to the
relevant general directorate. Should the amendments be found acceptable, the ethics
committee will approve them within fifteen days, and the general directorate concerned
within thirty days, to the extent they find the amendments acceptable.


 24. How does an REC assess the suitability of investigators and
       of sites?

In the application dossier, the CVs of principal investigators are included and ECs assess
the suitability of investigators according to their CVs.

In “Regulation On Clinical Trials” it states the suitability of study sites are defined as
follows:

      Clinical trial sites, standards, and applications for authorization
      ARTICLE 16 – (1) Clinical trials may only be conducted at centers for health
practice and research established within universities, including Gülhane Military Medical
                                                                             Turkey- March 2012
Academy (GATA), approved centers for research and development subordinate to
universities, Refik Saydam National Public Health Agency and the Ministry’s teaching and
research hospitals which are suitable for and possess appropriate staff, equipment and
laboratory means that enable ensuring the safety of research subjects and proper conduct
and monitoring of a clinical trial, and appropriate emergency care should it be necessary.
       (2) Clinical trials conducted at centers mentioned above may be supplemented with
other health institutions or organizations meeting the criteria specified herein, provided it
will be under coordination and responsibility of these centers.
       (3) Phase I drug trials, BA/BE trials and comparability studies for biosimilars:
       a) These studies will be conducted at health institutions or organizations subordinate
to the Ministry or universities or at centers for research and development approved by the
Ministry which possess the necessary means to provide emergency care.
       b) Centers established for conducting these studies may not commence operating
without obtaining approval of the Ministry. Applications to obtain Ministry approval will
be made to the General Directorate of Pharmaceuticals and Pharmacy, using the application
form posted on the Ministry’s website and relevant annexes, in accordance with applicable
guidelines. The Ministry will give its approval for the trial site within ninety days after the
application, provided that during the inspection of proposed trial sites by the General
Directorate of Pharmaceuticals and Pharmacy the accuracy of the data and documents
submitted with the application is demonstrated, and the trial site is shown to meet the
necessary requirements. The Ministry will conduct subsequent inspections of these sites
every three years, or in shorter intervals as may be deemed necessary, and may either renew
its previous approval or suspend the site’s operations depending on the inspection outcome.
       c) Centers that obtain approval from the Ministry for the trial site may commence the
activities described in this paragraph, to the extent that such centers will be obligated to
obtain the approval of relevant ethics committee and permission of the Ministry for each
study that they will conduct.
       (4) Sites where clinical trials will be conducted on the basis of the Guideline for Good
Clinical Practice must minimally have:
       a) the necessary staff and equipment at an adequate level, appropriate to the nature of
the study,
       b) the facilities and means necessary for storing and dispensing the investigational
product in a manner appropriate to its nature,
       c) the means and equipment to provide appropriate care to subjects, including cases
requiring emergency care,
       ç)the sufficient means and equipment to enable transferring subjects to a more
advanced health institution/organization, where necessary, and
       d) the sufficient means and equipment to retain the data and documents relating to the
clinical trial and subjects, for the period prescribed in the Guideline for Good Clinical
Practice, after the study is completed.



 25. How are the requirements for (research) ethics committees
 to review the contractual or financial arrangements in clinical
 trials for both investigators and hospitals handled?

The application dossier includes the overall study budget, plus any special budgets and
financial contracts that are signed between the institution, the sponsor and the investigator.


                                                                            Turkey- March 2012
26. How are the requirements for ethics committees to review
 the compensation arrangements for study subjects handled?

Insurance coverage shall be provided against any bodily injury or death of a volunteer
taking part in a clinical trial due to the investigational medicinal product or any procedures
applied at the time of the clinical trial. It must be documented, therefore, by the sponsor of
the trial that all patients and healthy volunteers taking part in a clinical trial have been
provided insurance coverage by the sponsor of the clinical trial against any injury
associated with taking part in the clinical trial concerned.

Accordingly, the relevant ethics committee and the Ministry must be presented with an
insurance policy or, in the case an insurance policy cannot be submitted, a certified
authentic copy of the insurance policy or certificates of insurance clearly indicating the
terms and conditions of insurance in reference to the insurance policy concerned.


 27. Is there an ongoing quality assurance process (e.g. audits,
         inspections, internal SOP) for (research) ethics
         committees in Turkey?

For ethics committees to function in a standardized manner, the Ministry will establish an
Ethics Committee Standard Operating Procedure and post it on the Ministry website,
updating it as necessary. Ethics committees will carry out their functions according to these
set of standards.

Ethics committees who fail to operate in line with the ethical guidelines, or fail to meet the
requirements laid down in the Ethics Committee Standard Operating Procedure, or found in
a Ministry audit to be lacking the space, secretarial services, archiving services or
equipment essential to fulfilling the function of an ethics committee will be issued a
warning by the Ministry. The approval may be withdrawn if the ethics committee fails to
address the issues that gave rise to the warning within the prescribed timeframe.

Clinical trials being conducted, trial sites, sponsors and contract research organizations,
manufacturing sites of investigational products, laboratories where analyses relevant to the
trial are being performed, and ethics committees may be inspected in and/or outside of the
country by the Ministry, with or without advance notice, to determine compliance with this
Regulation and other applicable regulatory provisions.



 28. Is there an appeal mechanism?


Appeal mechanisms are mentioned in the attached guidelines of Ministry of Health.



       GUIDELINE       Guideline Regarding
   REGARDING APPLICA   Application Format Fo


                                                                           Turkey- March 2012
29. How do ECs deal with SUSAR reports and Annual Safety
 Reports?



                                              GUIDANCE ON THE
                                             COLLECTION, VERIFI
According to attached guideline:




 30. How are ‘substantial amendments’ defined?


Examples Regarding Matters That Might Require Significant Amendment in Clinical
Trials

         The amendments indicated below are examples and amendments are not limited to
these.

         Samples of Basic Significant Amendment

            -     Physical and mental health of the volunteers,
            -     Scientific value of the trial,
            -     System and method on conducting the trial ,
            -     Quality and safety of the investigational product used in the trial.

         Amendments Regarding Trial Protocol/Plan

            -      Purpose of the trial,
            -     Design of the trial,
            -     Volunteer informed consent form (SICF),
            -     Method/methods of volunteer recruitment for the trial,
            -     Efficacy measurements,
            -     Addition or omitting of tests or measurements,
            -     Number of volunteers,
            -     Age interval of volunteers,
            -     Inclusion criteria for the trial,
            -     Exclusion criteria for the trial,
            -     Monitoring of volunteer safety,
            -     Duration of exposure to investigational product,
            -     Change in dosage of investigational product,
            -     Change of comparator drug,
            -     Statistical analysis.

         Amendments Regarding Administrative Structuring
           -    Change of principal investigator,

                                                                                Turkey- March 2012
-      Change of coordinating investigator,
   -      Change of trial site and/or addition of new trial sites,
   -      Change of sponsor or legal representative,
   -       Change of contract research organization,

Amendments Regarding Investigational Product
  -     Change in quality data of investigational product,
  -     Change in title or code of investigational product,
  -     Change in internal package material,
  -     Change in producer of active substance,
  -     Change in Manufacturing process of active substance,
  -     Change in specifications of active substance,
  -     Change(s) in information related to Manufacturing of medical product,
  -     Change in specifications of medical product,
  -     Change(s) in specifications of excipients in cases the performance of
      investigational product is affected,
  -     Change in shelf life of investigational product,
  -     Basic change made in formulation,
  -     Change in storage conditions,
  -     Change in test methods of active substance,
  -     Change in test methods of medical product,
  -     Change in test methods of excipients not related to pharmacopeia.

Amendments Made Related to Pre-clinical Pharmacology and Toxicology Data
for Ongoing Trials
    -    Results of newly made pharmacology tests,
    -     New interpretation of available pharmacology tests,
    -    Results of newly performed toxicity tests,
    -    New interpretation of available toxicity tests,
    -    Results of new interaction studies.

Amendments Made in Data Regarding Usage During Clinical Trial and in
Humans for Ongoing Trials
  -     Change pertaining to safety information occurring in the clinical trial
     process of the investigational product or during its usage in human,
  -     Results of new clinical pharmacology tests,
  -     New interpretation of available clinical pharmacology tests,
  -     Results of new clinical trials,
  -     New interpretation of available clinical trial data,
  -     New data obtained from the usage of investigational product in human,
  -     New interpretation of available data regarding the usage of investigational
     product in human.




                                                                     Turkey- March 2012
31. What are the indemnity insurance requirements for research
 projects?


It was defined in the attached “Guidance On Insuring Subjects in a Clinical Trial” and
“Guidance On Insuring Volunteers in a Clinical Trial” guidelines of MoH.



   GUIDANCE ON      GUIDANCE_ON_INS
INSURING SUBJECTS   URING_VOLUNTEERS_




 32. What are the indemnity insurance requirements for ethics
 committee members themselves?


No mandatory requirement exists.


 33. How is informed consent obtained from vulnerable subjects
       who are potentially to be involved in a clinical trial?


a) After the subjects are given information sufficiently and in a manner comprehensible to
them on the clinical trial, their written consent will be obtained and documented on the
Subject’s Informed Consent Form. In cases when a witness is necessary, persons affiliated
with the trial may not act as a witness.
b) In the event that the study involves conducting genetic and/or pharmacogenetic
investigation of samples collected from subjects, or collecting germ cells such as sperms or
ovules, the subject’s consent must be obtained separately for each study.
c) The legal representative is competent in cases where the subject is unable to consent.
ç) No samples or similar data obtained from individuals, including during noninvasive
studies, may be used without permission of the individual or that of his or her legal
representative.
d) Signed consent of the donors or of their legal representatives must be obtained for using
collected blood, urine, tissue, radiological images or similar materials for purposes of
clinical research. However, in the event that it is no longer possible to contact a material’s
donor or his or her legal representative, the collection will be regarded anonymous,
provided that the ethics committee establishes that this is the case and gives its permission.
The data collected from a collection may be used for purposes of clinical research, provided
that the owner’s identification details are kept confidential.




                                                                           Turkey- March 2012
34. How do ECs assess the progress and outcome of research
       projects that they have approved?


With the annual reports and final report.

An ethics committee may monitor a clinical trial approved by it, with or without prior
notice. Moreover, the Ministry may ask an ethics committee to monitor a clinical trial. The
ethics committee submits its monitoring report to the relevant general directorate at the
latest within ten days. The reports will be evaluated by the general directorate concerned.


 35. How does the EC ensure reception of the Annual Safety
 Report and the Summary of the Final Report of a research
 project that it has approved?

ECs follow-up the studies according to timelines. The first annual report should be
submitted one year after the approval date of MoH and then yearly submission should be
done until the end of study. After all the study patients have completed the study in all sites
in Turkey, then the Final Report should be submitted.

The responsibility to ensure regular submission of the reports to the relevant general
directorate rests with the sponsor.


 36. Do national regulations in Turkey allow research on healthy volunteer
 children (subjects under 16)?



No trial may be conducted in children. However, where the subject of research is directly
related to children or is a clinical condition that can be investigated only in children, or it is
necessary to verify the applicability of adult data to children, it may be permitted to conduct
a study in children within the below premise, provided that the study carries no foreseeable
serious risk to subjects’ well-being and it is expected that the study will directly benefit the
subjects:

a) If the child is capable to assess the information provided to him or her and reach a
conclusion on the matter, all information relevant to the trial will be communicated to the
child in an appropriate manner. If the child refuses to participate in the trial or requests to
withdraw from the trial at any phase, he or she will be removed from the study.

b) The ethics committee will not approve a clinical trial in children unless a favorable view
for conducting the study in children has been given by a pediatric psychiatrist or a
pediatrician, or, in the case of a clinical trial in children related to pediatric dentistry, by a
dental practitioner who holds a doctorate or medical residency degree in pediatric dentistry.

c) A common medical view must exist that the investigational product carries no known
risk to children.
                                                                              Turkey- March 2012
ç) The written consent of the legal representatives will be obtained after informing them.
The legal representatives may withdraw their written consent at their discretion, even if the
study causes no unfavorable effect on the children.

d) The ethics committee concerned will be informed on the clinical, ethical, psychological
and social issues associated with the trial, by a pediatric psychiatrist or a pediatrician, or, in
the case of a clinical trial in children related to pediatric dentistry, by a dental practitioner
who holds a doctorate or medical residency degree in pediatric dentistry, and give
consideration to the protocol accordingly.

e) No compelling incentive and/or financial benefit may be offered in connection with a
clinical trial in children, other than the covering of necessary expenses arising from
children’s participation in the trial.




 37. Do national regulations in Turkey allow payment, (other than expenses),
 to children taking part in research?



No


 38. Do RECs invite or allow a) applicants or b) observers to attend
 committee meetings?


No, but occasionally a sponsor or an investigator may be invited for questions about their
own study.

 39. Are the minutes of ethics committee meetings made public?



No, they are not made public.

 40. Is there any scope for Chairman’s actions in between meetings?


No.

 41. Do ethics committees ever appoint subcommittees for any specific
 purpose?


Where necessary, ethics committees may solicit the written opinion of experts in a relevant
field or subfield, and invite them to attend meetings in capacity of an advisor.



                                                                              Turkey- March 2012
42. Is there a national policy on the registration of clinical trials before they
start?



No.


43. If the answer to Q42 is ‘yes;, do ethics committees have any role to play
in reviewing such registration?




44. If the answer to Q42 is ‘yes’, is this register of clinical trials made
available to the public?




                                                                        Turkey- March 2012

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Regulatory Process for Clinical Trials in Turkey

  • 1. The EFGCP Report on The Procedure for the Ethical Review of Protocols for Clinical Research Projects in Europe (Mar 2012) Turkey 1. What laws or regulations apply to an application for conducting a clinical trial in Turkey? Laws: (in Turkish) Sağlık Hizmetleri Temel Kanunu "Ek Madde 10" (6 April 2011) Araştırma ve Geliştirme Faaliyetlerinin Desteklenmesi Hakkında Kanun (2008) Türk Ceza Kanunu (2005) Sağlık Bakanlığının Teşkilat ve Görevleri Hakkında Kanun (13 December 1983) İspençiyari ve Tıbbi Müstahzarlar Kanunu (1928) Regulation: Regulation On Clinical Trials (19 Aug 2011) Regulation on Clinical Trials.pdf 2. Which government, legal or authoritative body or bodies is or are responsible for the establishment and/or accreditation of (research) ethics committees for IMPs, and for their supervision and quality? Are there different (research) ethics committees reviewing other projects? Ministry of Health (MoH) is the responsible authority for the accreditation of Ethics Committees (ECs). 3. What is the process for achieving clinical trial authorisation from the competent authority in Turkey? Questions 3 and 4 are most appropriately answered together for Turkey 4. What is the process for obtaining ethical review of a clinical trial protocol by a competent (research) ethics committee in Turkey? Turkey- March 2012
  • 2. (1) The application dossier for a clinical trial will be prepared according to the Guideline for Good Clinical Practice and other applicable guidelines, using the application form and its relevant annexes posted on the Ministry’s website, and will be reviewed for Ministry permission and ethics committee approval according to this Regulation and the guidelines to be issued by the Ministry. (2) In multi-center clinical trials, the scientific and ethical approval will be obtained of the ethics committee in the locality where the coordinating center is located. Notifications will be made to ethics committees in places where the other sites are located. (3) The application for a clinical trial will be made to the relevant ethics committee or general directorate by the sponsor, consisting of natural/juristic person(s), or by a contract research organization domiciled in Turkey appointed by the sponsor. If the sponsor has no representative domiciled in Turkey, the application for a clinical trial must be submitted through a contract research organization domiciled in Turkey. (4) Applications to obtain Ministry approval for conducting a clinical trial that have been granted ethical and scientific approval with any substances or products which and which may involve investigation in human beings, including clinical trials with medical devices, BA/BE trials, comparability studies for biosimilar products, Phase I, Phase II, Phase III and Phase IV drug clinical trials, clinical trials with advanced therapy medicinal products, observational studies with drugs, observational studies with medical devices, clinical trials with traditional herbal medicinal products and cosmetic products or raw materials, will be made to the General Directorate of Pharmaceuticals and Pharmacy. a) For clinical trials with Class III medical devices or with implants or long-term invasive devices in Class IIa or Class IIb, the study sponsor or a contract research organization delegated by the sponsor will, upon the approval of the ethics committee concerned, make an application to the General Directorate of Pharmaceuticals and Pharmacy, and the application will be evaluated within sixty days after the notification date. b) For all clinical trials with medical devices, excluding the ones mentioned in subparagraph (a), and all other drug clinical trials will be evaluated within not more than thirty days by the relevant general directorate. (5) Applications to obtain Ministry approval for conducting clinical trials with industrial advanced medicinal products or non-industrial advanced medicinal products, gene therapy clinical trials, stem cell transplantation trials, organ or tissue transplantation trials and clinical trials with a novel surgical procedure which have been given scientific and ethical approval will be made to the General Directorate of Health Services. These applications will be evaluated within not more than sixty days. (6) If the general directorate concerned adopts an unfavorable decision regarding the request for conducting the clinical trial, this decision will be notified to the applicant, together with the rationale for the decision. The sponsor will be granted a single opportunity to resubmit the application after making amendments to address the issues raised in the decision, or to file a reasoned objection against the decision. If the requested changes are not fulfilled or an acceptable justification cannot be offered, the general directorate concerned may reject the clinical trial. (7) In the case of clinical trials with cellular therapies using products containing genetically modified organisms or products involving gene therapy, the thirty days specified for Ministry approval may be extended for an additional thirty days. However, in cases where it becomes necessary to hold detailed deliberations or to consult non-Ministerial third party experts, the timeline may be extended further by an additional ninety days, depending on the subject matter of the study Turkey- March 2012
  • 3. 5. Is there a single organisation to which to apply for ethical review of a clinical trial for an investigational medicinal product, regardless of whether this is for a single site or multiple sites? No. As of today, there are 52 different Ethics Committees in 26 different cities. In multi-center clinical trials, the scientific and ethical approval will be obtained of the ethics committee in the locality where the coordinating center is located. Notifications will be made to ethics committees in places where the other sites are located. 6. What are the website for the organisation that issues guidelines on the ethical review of a clinical trial for an investigational medicinal product? The websites of the MoH General Directorate of Pharmaceuticals and Pharmacy: Turkish: http://www.iegm.gov.tr/Default.aspx?sayfa=klinik&lang=tr-TR English: http://www.iegm.gov.tr/Default.aspx?sayfa=clinical_dep&lang=en The website of the Clinical Research Association: http://www.klinikarastirmalar.org.tr/en/index.php 7. Is there a procedural interaction between the national or local competent authority and the (research) ethics committee during the approval process? No. Ethics committees are independent in their function of reviewing and approving clinical trial applications from a scientific and ethical perspective. The decisions of an ethics committee shall not be approved separately by the President of Refik Saydam Hıfzısıhha Center, the rector, the dean, or the chief physician. Permission of the Ministry is required to commence a clinical trial that has been approved by ethics committee. 8. Does the application to the EC and to the competent authority have to be submitted in parallel, or, if not, in which order? No. Sequential. First EC and then Regulatory Authority (MoH) application is performed. Turkey- March 2012
  • 4. 9. How many (research) ethics committees that consider CTIMPs are there in Turkey? NA 10. How are ECs funded in Turkey? Do they charge fees? If yes what is their scale of fees? During the application below listed fees should be paid to the bank account of the institution of related EC/MoH:  Phase I: 2.045,32 TL ( 870 €)  Phase II: 2.045,32 TL ( 870 €)  Phase III: 2.045,32 TL ( 870 €)  Phase IV: 1.025,42 TL (436 €)  Registry: 1.025,42 TL (436 €) (Indicative Exchange Rates Announced on 16-Mar-2012 by the Central Bank of Turkey -> 1 € = 2,35 TL) 11. Who is responsible for submitting the request for ethical review to the competent ethics committee for single-site and for multi-site clinical trials? The application for a clinical trial will be made to the relevant ethics committee or general directorate by the sponsor, consisting of natural/juristic person(s), or by a contract research organization domiciled in Turkey appointed by the sponsor. If the sponsor has no representative domiciled in Turkey, the application for a clinical trial must be submitted through a contract research organization domiciled in Turkey. If there is no sponsor application is made by principal investigator or by coordinator in multi-center trials. 12. How is a “single opinion” achieved for multi-site studies? First step: EC approval Application is made to the related Ethics Committee for the purpose of receiving approval scientifically and ethically for clinical trials. According to kind of clinical trial, application is made to the related Ethics Committee with the application form and cover letter samples prepared considering the appropriate application form and application cover letter samples published at the website of General Directorate for Pharmaceuticals and Pharmacy (www.iegm.gov.tr). Turkey- March 2012
  • 5. Second step: MoH permission Permission of the Ministry is required to commence a clinical trial that has been approved by an ethics committee. The study sponsor will make an application to the General Directorate of Pharmaceuticals and Pharmacy to obtain permission of the Ministry. In order to receive Ministry permission after the received scientific and ethical approval application is made to General Directorate for Pharmaceuticals and Pharmacy for clinical trials to be conducted with medical devices, for bioavailability/bioequivalence (BA/BE) studies, for comparability studies of bio-similar products, for Phase I, Phase II, Phase III, and Phase IV drug clinical trials, for clinical trials to be conducted with advanced treatment medicinal products, for observational drug studies, for observational medical device studies, for efficacy and safety studies to be conducted with cosmetic raw materials or products, and for clinical trials to be conducted with traditional herbal medicinal products. In order to receive Ministry permission following scientific and ethical approval, for clinical trials to be conducted with non-industrial advanced medicinal products application is made to General Directorate of Treatment Services for clinical trials to be conducted with industrial advanced medicinal products, for gene treatment clinical trials, for stem-cell transplantation trials, for organ and tissue transplantation trials, and for new surgery method trials. 13. How many members serve on an EC? Ethics committees, comprised of not less than seven (7) and not more than fifteen (15) members with at least one (1) of them a non-health care professional and one (1) a jurist, and the majority consisting of health care professionals holding a doctorate or medical residency degree. 14. How many members constitute a quorum? Ethics committee members will convene with the two thirds majority of total number of members, and adopt decisions by the favorable vote of a simple majority of its full membership. 15. How are EC members appointed? Ethics committees will be established with Ministry approval within universities upon the proposal of the rector, within Refik Saydam National Public Health Agency upon the proposal of the President of Refik Saydam National Public Health Agency, or at teaching and research hospitals upon the proposal of the chief physician, and commence functioning as of the approval date by the Ministry. Turkey- March 2012
  • 6. 16. How is the independence of members ensured? In “Regulation On Clinical Trials” it states: ARTICLE 11 – b) Ethics committees are independent in their function of reviewing and approving clinical trial applications from a scientific and ethical perspective. The decisions of an ethics committee need not be ratified by the President of Refik Saydam National Public Health Agency, the rector, the dean, or the chief physician. 17. How are conflicts of interest of EC members avoided? Ethics committee members who are affiliated with the study sponsor or have a role in the study being reviewed may not take part in ethics committee discussions and nor in the voting on the study concerned, nor may they have their signature under the committee decision. [In “Regulation On Clinical Trials”, ARTICLE 11 – e] 18. Whatare (R)EC members appointed? 15. How backgrounds and/or qualifications of members are actively sought? In “Regulation On Clinical Trials” it states in ARTICLE 10: (10) An Ethics Committee for Drug Clinical Trials will consist of members that have at least the following qualifications: a) Specialist physicians, at least one of whom with experience as an investigator in a clinical trial that was organized according to the guidelines for good clinical practice; b) A pharmacist or doctor of medicine holding a doctorate or medical residency degree in pharmacology; c) A biostatistician or physician holding a doctorate or medical residency degree in public health; ç) A person holding a doctorate, medical residency or master’s degree in medical ethics (deontology), if available; d) A jurist; e) A non-health care professional. (11) An Ethics Committee for Bioavailability/Bioequivalence Trials will consist of members that have at least the following qualifications: a) Specialist physicians, at least one of whom with experience as an investigator in a clinical trial that was organized according to the guidelines for good clinical practice; b) A pharmacist or doctor of medicine holding a doctorate or medical residency degree in pharmacology; c) A biostatistician or physician holding a doctorate or medical residency degree in public health; ç) A pharmacist holding a doctorate degree in pharmaceutical technology; d) A pharmacist or chemist holding a doctorate degree in pharmaceutical chemistry or analytical chemistry; Turkey- March 2012
  • 7. e) A person holding a doctorate, medical residency or master’s degree in medical ethics (deontology), if available; f) A jurist; g) A non-health care professional. (12) An Ethics Committee for Non-drug Clinical Trials will consist of members that have at least the following qualifications: a) Persons holding a doctorate or medical residency degree, at least one of whom with experience as an investigator in a clinical trial that was organized according to the guidelines for good clinical practice; b) A biostatistician or physician holding a doctorate or medical residency degree in public health; c) An engineer or expert in the field of biomedicine, or, if unavailable, a biophysicist or physiologist who is preferably a medical graduate; ç) A person holding a doctorate, medical residency or master’s degree in medical ethics (deontology), if available; d) A jurist; e) A non-health care professional. (13) An Ethics Committee for Clinical Trials will consist of members that have at least the following qualifications: a) Persons holding a doctorate or medical residency degree, at least one of whom with experience as an investigator in a clinical trial that was organized according to the guidelines for good clinical practice; b) A pharmacist or doctor of medicine holding a doctorate or medical residency degree in pharmacology; c) A biostatistician or physician holding a doctorate or medical residency degree in public health; ç) An engineer or expert in the field of biomedicine, or, if unavailable, a biophysicist or physiologist who is a preferably medical graduate; d) A person holding a doctorate, medical residency or master’s degree in medical ethics (deontology), if available; e) A jurist; f) A non-health care professional. 19. How does the EC obtain specialist expertise? Where necessary, ethics committees may solicit the written opinion of experts in a relevant field or subfield, and invite them to attend meetings in capacity of an advisor. [In “Regulation On Clinical Trials”, ARTICLE 11 – ğ] 20. What are the training requirements for members of RECs? From the EC members at least one Specialist physician, should have experience as an investigator in a clinical trial that was organized according to the guidelines for good clinical practice. Turkey- March 2012
  • 8. 21. What training programmes are available for REC members in Turkey? Some of the pharmaceutical companies organize ICH-GCP trainings for investigators and EC members. On the other hand, starting from mid 2009 the MoH also conducts ICH-GCP training programmes for ECs. 22. What are the timelines for the assessment of single- and multi-site studies? For ECs: Ethics committees will form their opinion and communicate it to the applicant within thirty days after the application date. Should additional information or clarifications become necessary during the ethics committee review, all of the requests will be communicated to the applicant in a single request. A second request will not be made to the applicant. The review process will be frozen until the required data and documents are submitted to the ethics committee. For MoH: All drug clinical trials will be evaluated within not more than thirty days by the relevant general directorate. 23. How are substantial amendments submitted during the review process dealt with? If, after the commencement of a clinical trial, the need arises to make any of the amendments described in the Guideline for Good Clinical Practice, such amendment(s) will be notified to the ethics committee concerned, to be approved by the sponsor, and to the relevant general directorate. Should the amendments be found acceptable, the ethics committee will approve them within fifteen days, and the general directorate concerned within thirty days, to the extent they find the amendments acceptable. 24. How does an REC assess the suitability of investigators and of sites? In the application dossier, the CVs of principal investigators are included and ECs assess the suitability of investigators according to their CVs. In “Regulation On Clinical Trials” it states the suitability of study sites are defined as follows: Clinical trial sites, standards, and applications for authorization ARTICLE 16 – (1) Clinical trials may only be conducted at centers for health practice and research established within universities, including Gülhane Military Medical Turkey- March 2012
  • 9. Academy (GATA), approved centers for research and development subordinate to universities, Refik Saydam National Public Health Agency and the Ministry’s teaching and research hospitals which are suitable for and possess appropriate staff, equipment and laboratory means that enable ensuring the safety of research subjects and proper conduct and monitoring of a clinical trial, and appropriate emergency care should it be necessary. (2) Clinical trials conducted at centers mentioned above may be supplemented with other health institutions or organizations meeting the criteria specified herein, provided it will be under coordination and responsibility of these centers. (3) Phase I drug trials, BA/BE trials and comparability studies for biosimilars: a) These studies will be conducted at health institutions or organizations subordinate to the Ministry or universities or at centers for research and development approved by the Ministry which possess the necessary means to provide emergency care. b) Centers established for conducting these studies may not commence operating without obtaining approval of the Ministry. Applications to obtain Ministry approval will be made to the General Directorate of Pharmaceuticals and Pharmacy, using the application form posted on the Ministry’s website and relevant annexes, in accordance with applicable guidelines. The Ministry will give its approval for the trial site within ninety days after the application, provided that during the inspection of proposed trial sites by the General Directorate of Pharmaceuticals and Pharmacy the accuracy of the data and documents submitted with the application is demonstrated, and the trial site is shown to meet the necessary requirements. The Ministry will conduct subsequent inspections of these sites every three years, or in shorter intervals as may be deemed necessary, and may either renew its previous approval or suspend the site’s operations depending on the inspection outcome. c) Centers that obtain approval from the Ministry for the trial site may commence the activities described in this paragraph, to the extent that such centers will be obligated to obtain the approval of relevant ethics committee and permission of the Ministry for each study that they will conduct. (4) Sites where clinical trials will be conducted on the basis of the Guideline for Good Clinical Practice must minimally have: a) the necessary staff and equipment at an adequate level, appropriate to the nature of the study, b) the facilities and means necessary for storing and dispensing the investigational product in a manner appropriate to its nature, c) the means and equipment to provide appropriate care to subjects, including cases requiring emergency care, ç)the sufficient means and equipment to enable transferring subjects to a more advanced health institution/organization, where necessary, and d) the sufficient means and equipment to retain the data and documents relating to the clinical trial and subjects, for the period prescribed in the Guideline for Good Clinical Practice, after the study is completed. 25. How are the requirements for (research) ethics committees to review the contractual or financial arrangements in clinical trials for both investigators and hospitals handled? The application dossier includes the overall study budget, plus any special budgets and financial contracts that are signed between the institution, the sponsor and the investigator. Turkey- March 2012
  • 10. 26. How are the requirements for ethics committees to review the compensation arrangements for study subjects handled? Insurance coverage shall be provided against any bodily injury or death of a volunteer taking part in a clinical trial due to the investigational medicinal product or any procedures applied at the time of the clinical trial. It must be documented, therefore, by the sponsor of the trial that all patients and healthy volunteers taking part in a clinical trial have been provided insurance coverage by the sponsor of the clinical trial against any injury associated with taking part in the clinical trial concerned. Accordingly, the relevant ethics committee and the Ministry must be presented with an insurance policy or, in the case an insurance policy cannot be submitted, a certified authentic copy of the insurance policy or certificates of insurance clearly indicating the terms and conditions of insurance in reference to the insurance policy concerned. 27. Is there an ongoing quality assurance process (e.g. audits, inspections, internal SOP) for (research) ethics committees in Turkey? For ethics committees to function in a standardized manner, the Ministry will establish an Ethics Committee Standard Operating Procedure and post it on the Ministry website, updating it as necessary. Ethics committees will carry out their functions according to these set of standards. Ethics committees who fail to operate in line with the ethical guidelines, or fail to meet the requirements laid down in the Ethics Committee Standard Operating Procedure, or found in a Ministry audit to be lacking the space, secretarial services, archiving services or equipment essential to fulfilling the function of an ethics committee will be issued a warning by the Ministry. The approval may be withdrawn if the ethics committee fails to address the issues that gave rise to the warning within the prescribed timeframe. Clinical trials being conducted, trial sites, sponsors and contract research organizations, manufacturing sites of investigational products, laboratories where analyses relevant to the trial are being performed, and ethics committees may be inspected in and/or outside of the country by the Ministry, with or without advance notice, to determine compliance with this Regulation and other applicable regulatory provisions. 28. Is there an appeal mechanism? Appeal mechanisms are mentioned in the attached guidelines of Ministry of Health. GUIDELINE Guideline Regarding REGARDING APPLICA Application Format Fo Turkey- March 2012
  • 11. 29. How do ECs deal with SUSAR reports and Annual Safety Reports? GUIDANCE ON THE COLLECTION, VERIFI According to attached guideline: 30. How are ‘substantial amendments’ defined? Examples Regarding Matters That Might Require Significant Amendment in Clinical Trials The amendments indicated below are examples and amendments are not limited to these. Samples of Basic Significant Amendment - Physical and mental health of the volunteers, - Scientific value of the trial, - System and method on conducting the trial , - Quality and safety of the investigational product used in the trial. Amendments Regarding Trial Protocol/Plan - Purpose of the trial, - Design of the trial, - Volunteer informed consent form (SICF), - Method/methods of volunteer recruitment for the trial, - Efficacy measurements, - Addition or omitting of tests or measurements, - Number of volunteers, - Age interval of volunteers, - Inclusion criteria for the trial, - Exclusion criteria for the trial, - Monitoring of volunteer safety, - Duration of exposure to investigational product, - Change in dosage of investigational product, - Change of comparator drug, - Statistical analysis. Amendments Regarding Administrative Structuring - Change of principal investigator, Turkey- March 2012
  • 12. - Change of coordinating investigator, - Change of trial site and/or addition of new trial sites, - Change of sponsor or legal representative, - Change of contract research organization, Amendments Regarding Investigational Product - Change in quality data of investigational product, - Change in title or code of investigational product, - Change in internal package material, - Change in producer of active substance, - Change in Manufacturing process of active substance, - Change in specifications of active substance, - Change(s) in information related to Manufacturing of medical product, - Change in specifications of medical product, - Change(s) in specifications of excipients in cases the performance of investigational product is affected, - Change in shelf life of investigational product, - Basic change made in formulation, - Change in storage conditions, - Change in test methods of active substance, - Change in test methods of medical product, - Change in test methods of excipients not related to pharmacopeia. Amendments Made Related to Pre-clinical Pharmacology and Toxicology Data for Ongoing Trials - Results of newly made pharmacology tests, - New interpretation of available pharmacology tests, - Results of newly performed toxicity tests, - New interpretation of available toxicity tests, - Results of new interaction studies. Amendments Made in Data Regarding Usage During Clinical Trial and in Humans for Ongoing Trials - Change pertaining to safety information occurring in the clinical trial process of the investigational product or during its usage in human, - Results of new clinical pharmacology tests, - New interpretation of available clinical pharmacology tests, - Results of new clinical trials, - New interpretation of available clinical trial data, - New data obtained from the usage of investigational product in human, - New interpretation of available data regarding the usage of investigational product in human. Turkey- March 2012
  • 13. 31. What are the indemnity insurance requirements for research projects? It was defined in the attached “Guidance On Insuring Subjects in a Clinical Trial” and “Guidance On Insuring Volunteers in a Clinical Trial” guidelines of MoH. GUIDANCE ON GUIDANCE_ON_INS INSURING SUBJECTS URING_VOLUNTEERS_ 32. What are the indemnity insurance requirements for ethics committee members themselves? No mandatory requirement exists. 33. How is informed consent obtained from vulnerable subjects who are potentially to be involved in a clinical trial? a) After the subjects are given information sufficiently and in a manner comprehensible to them on the clinical trial, their written consent will be obtained and documented on the Subject’s Informed Consent Form. In cases when a witness is necessary, persons affiliated with the trial may not act as a witness. b) In the event that the study involves conducting genetic and/or pharmacogenetic investigation of samples collected from subjects, or collecting germ cells such as sperms or ovules, the subject’s consent must be obtained separately for each study. c) The legal representative is competent in cases where the subject is unable to consent. ç) No samples or similar data obtained from individuals, including during noninvasive studies, may be used without permission of the individual or that of his or her legal representative. d) Signed consent of the donors or of their legal representatives must be obtained for using collected blood, urine, tissue, radiological images or similar materials for purposes of clinical research. However, in the event that it is no longer possible to contact a material’s donor or his or her legal representative, the collection will be regarded anonymous, provided that the ethics committee establishes that this is the case and gives its permission. The data collected from a collection may be used for purposes of clinical research, provided that the owner’s identification details are kept confidential. Turkey- March 2012
  • 14. 34. How do ECs assess the progress and outcome of research projects that they have approved? With the annual reports and final report. An ethics committee may monitor a clinical trial approved by it, with or without prior notice. Moreover, the Ministry may ask an ethics committee to monitor a clinical trial. The ethics committee submits its monitoring report to the relevant general directorate at the latest within ten days. The reports will be evaluated by the general directorate concerned. 35. How does the EC ensure reception of the Annual Safety Report and the Summary of the Final Report of a research project that it has approved? ECs follow-up the studies according to timelines. The first annual report should be submitted one year after the approval date of MoH and then yearly submission should be done until the end of study. After all the study patients have completed the study in all sites in Turkey, then the Final Report should be submitted. The responsibility to ensure regular submission of the reports to the relevant general directorate rests with the sponsor. 36. Do national regulations in Turkey allow research on healthy volunteer children (subjects under 16)? No trial may be conducted in children. However, where the subject of research is directly related to children or is a clinical condition that can be investigated only in children, or it is necessary to verify the applicability of adult data to children, it may be permitted to conduct a study in children within the below premise, provided that the study carries no foreseeable serious risk to subjects’ well-being and it is expected that the study will directly benefit the subjects: a) If the child is capable to assess the information provided to him or her and reach a conclusion on the matter, all information relevant to the trial will be communicated to the child in an appropriate manner. If the child refuses to participate in the trial or requests to withdraw from the trial at any phase, he or she will be removed from the study. b) The ethics committee will not approve a clinical trial in children unless a favorable view for conducting the study in children has been given by a pediatric psychiatrist or a pediatrician, or, in the case of a clinical trial in children related to pediatric dentistry, by a dental practitioner who holds a doctorate or medical residency degree in pediatric dentistry. c) A common medical view must exist that the investigational product carries no known risk to children. Turkey- March 2012
  • 15. ç) The written consent of the legal representatives will be obtained after informing them. The legal representatives may withdraw their written consent at their discretion, even if the study causes no unfavorable effect on the children. d) The ethics committee concerned will be informed on the clinical, ethical, psychological and social issues associated with the trial, by a pediatric psychiatrist or a pediatrician, or, in the case of a clinical trial in children related to pediatric dentistry, by a dental practitioner who holds a doctorate or medical residency degree in pediatric dentistry, and give consideration to the protocol accordingly. e) No compelling incentive and/or financial benefit may be offered in connection with a clinical trial in children, other than the covering of necessary expenses arising from children’s participation in the trial. 37. Do national regulations in Turkey allow payment, (other than expenses), to children taking part in research? No 38. Do RECs invite or allow a) applicants or b) observers to attend committee meetings? No, but occasionally a sponsor or an investigator may be invited for questions about their own study. 39. Are the minutes of ethics committee meetings made public? No, they are not made public. 40. Is there any scope for Chairman’s actions in between meetings? No. 41. Do ethics committees ever appoint subcommittees for any specific purpose? Where necessary, ethics committees may solicit the written opinion of experts in a relevant field or subfield, and invite them to attend meetings in capacity of an advisor. Turkey- March 2012
  • 16. 42. Is there a national policy on the registration of clinical trials before they start? No. 43. If the answer to Q42 is ‘yes;, do ethics committees have any role to play in reviewing such registration? 44. If the answer to Q42 is ‘yes’, is this register of clinical trials made available to the public? Turkey- March 2012