Archive for May, 2008

Multinational Clinical Trials: Breaking Language and Cultural Barriers



Applied Clinical Trials

Cultural differences Culture is a largely unspoken, shared agreement on deep values within a community. Culture is manifested as social patterns of speech and behavior. Many emerging clinical trial sites differ from traditional markets in that deep values within the culture favor the community over the individual. Social status is revered, as are behaviors geared toward building long term relationships.

Cultural values and behaviors present benefits and challenges for those sponsoring multinational clinical trials, in terms of internal management and external relationships with subjects, investigators, and regulatory bodies. Internally, sponsors may have to opt for more senior personnel to be involved. Externally, cultural differences influencing medical practice and patient behavior are likely to show up in the course of a clinical trial in key areas such as subject enrollment and compliance, scheduling subject visits, investigator compensation and training, informed consent, adverse event reporting, source data, auditing, and internal communications.

These examples show how language and cultural differences may require additional attention and resources during a multinational clinical trial.

Subject enrollment Subject enrollment and retention is often faster and easier in nontraditional markets. Sponsors are drawn to these markets by the abundance of treatment-naïve subjects within large urban centers with a hospital infrastructure.

One study estimates that in the United States, 66% of subjects enroll independently of their doctors. In Latin America 80% of subjects are offered enrollment by their doctors.4 This difference is important when preparing recruitment plans and materials.

Religion may also affect enrollment, for example, in a trial requiring a complete sexual history from women in a predominantly Catholic country. If the basic premise of a trial is at odds with a sites culturally prescribed ethics (whether derived from religious or secular principles), a sponsor may consider selecting a different site, or modifying the protocol. Another option here may also be to use an experienced local partner for protocol preparation and subject enrollment.

Subject compliance Subjects in some countries are very compliant and eager to attend all study visits. They tend to listen to their doctors and follow orders unequivocally. In Russia and Japan, for example, a culture of compliance dictates that patients follow doctors orders explicitly. This tradition presents a benefit to sponsors enrollment is quick and retention is high.

Reporting of adverse events One corollary to this culture of compliance is that subjects (in Russia and Japan, for example) may not readily report adverse events. They may not complain, because they don t want to jeopardize their status as a participant or lose access to medical treatment or they may be too sick. Investigators may need training to actively solicit adverse events from subjects.5

Informed consent The culture of compliance may also create difficulties in documenting informed consent. Japanese and Russian subjects and their families traditionally prefer the attitude of I put myself in your hands, doctor. A full informative discussion of risks requires investigators in those countries to break the pattern of treating patients without sharing with them the sometimes frightening details of their illness.

In countries with low literacy, permission may not be documented on a form.6 Regulators may have difficulty confirming that subjects received proper information about risks and benefits, and that their participation was not coerced.

Scheduling subject visits Sponsors need know about differences in medical practice. In Latin America, a typical physician schedule includes hospital rounds in the morning, and afternoon work in private clinics. Hospital staff, required to help a principal investigator during subject visits, may only work in the morning.7

Source records Source data may not be saved. If they are, they may be illegible, handwritten notes in the local language, making translation difficult. The sponsor can opt to remain at the site or to find another where source data is traditionally kept. If there are other benefits for staying at a particular site, sponsors may need to budget additional resources to train site personnel on standard operating procedures (SOPs) for source data and quality standards, to supply computer equipment and computer support, to provide templates to ease recording, and to ensure that site staff members are computer literate.8

Investigator recruiting Investigators may be participating in a clinical trial because it increases their status in the community, a powerful incentive in relationship-based cultures like India and Latin America. Sponsors may solidify investigator dedication by including key regional investigators in scientific publications and presentations at conferences and symposia.

Data collection and reporting Investigators and subjects often use local languages during their interactions. Data and hospital records may be recorded in the local language, requiring translation.

Local expressions for symptoms and ailments may be translated literally, misleading data analysts. For example, in some developing countries, subjects may describe a respiratory infection with a phrase that literally translates as stomach moves in waves, suggesting a problem with the stomach, rather than with breathing.9 Literal translations may require sponsors to send repeated queries for clarification. Worse, sponsors may not recognize the report as an error, compromising the study.

Learning methods and investigator training Cultural differences influence investigator training, in terms of choosing who participates in the training and which learning methods and support materials will be effective with that audience. Resident physicians in Latin America may fill out the case report forms themselves, a role that defines them as important audience members. Sponsors must also consider hierarchy when inviting participants. Superiors may feel overlooked if they are not invited when subordinates are, even if it is the subordinates who actually need the training.

Learning methods also vary. Americans and Canadians often prefer to jump to the end of a lesson. Pacific Rim learners may prefer a sequence featuring theory followed by a learning experience. Europeans may favor a high volume of detail and structure.

To address variations in language fluency, sponsors should also address the content of training materials. If published in English only, sponsors may benefit from providing them to participants in advance, so that they have a chance to prepare comments and questions for the meeting. Graphics and diagrams may also be used to bridge language barriers, although care should be taken to consider the cultural appropriateness of images. Sponsors may consider publishing some key training materials in local languages. Finally, if simultaneous translation is used during the training, sponsors should ensure that the translator is also technically fluent in the appropriate medical field, and allot twice the amount of time they normally would for that portion of the training.

Quality assurance audits Input errors and varied terminology may lead to duplications in reporting, and other inconsistencies that are difficult for auditors to interpret.10 One alternative is for sponsors to invest in a computer-based audit management system with key words for major findings and centralized templates for reporting findings and documenting action plans.

Staffing the clinical trial and quality assurance teams Differences in cultural values, specifically around collaboration and hierarchy, play a role in the degree of cross-functional involvement in developing protocols and staffing quality assurance teams. In general, individual and department roles may be more specifically defined, and more senior people may be involved than in comparable organizations in the United States.

In Japan, for example, protocols are approved at a high organizational level, and development may involve specialists from Clinical Development, Statistics, Regulatory Affairs, and Drug Supply. In contrast, Western companies enlist broad support, adding Quality Control, Drug Discovery, Project Planning, and Marketing to the protocol development team.

In contrast to the United States, physicians are routinely among the staff of German Quality Assurance departments.11 Finally, cultural differences influence rigorous regulatory compliance, which affects the projects target standards. The Japanese, for example, may tend to set standards of quality assurance so high that partners fear they are unachievable.

A sponsor may choose to globalize quality assurance by taking some concrete steps including a Partnership Approach within the clinical trial organization. International management teams share responsibilities for preparing audit plans, budgets, workload distribution, and strategy. Furthermore, auditors from corporate management partner with those from site quality assurance into joint audit teams to help smooth out language and cultural barriers at lower levels in the organization.

Final tips Sincere respect for unique cultures and their differences is the first step in building best practices for conducting a multinational clinical trial. Applying a partnership approach to build supportive external relationships is likely to serve sponsors well, especially in relationship-based cultures. Sponsors should continually seek opportunities to develop relationships with local regulators, as well as with investigative sites in academia, public hospitals, and private institutions. Investigators, study coordinators, and clinical development team members should experience training about the cultural differences they are likely to encounter, and learn appropriate ways to handle those differences.

Accurate translation is the key to handling language-related issues. Training materials and forms should be prepared in local languages, and a simplified version of English is recommended for international meetings and correspondence. Sponsors should also choose translators who are technically fluent in the terminology of the relevant medical field.

Sponsors who prepare for differences between national infrastructures, languages, and cultures, and who allow for the unexpected, will succeed in controlling costs and cycle times and in building strong development teams around the world.

References 1. Office of the Inspector General Report, The Globalization of Clinical Trials (OIG, Washington, DC, September 2001).

2. Clinical Trial and Regulatory Best Practices in Japanese Affiliates of Multinational Firms (Pittiglio Rabin Todd and McGrath. 1503 Grant Rd., Ste. 200, Mountain View, CA, 94040).

3. Barbara Wallraff,What Global Language, The Atlantic Monthly, November 2000, 5264.

4. Eduardo Motti, Implementing Clinical Studies in a Traditional vs. a Non-traditional site, DIA Annual Meeting, June 17, 2003.

5. Khin Maung U, How Regulators See Clinical Data from Diverse Countries in a Single Study, presented at the DIA Annual Meeting, June 17, 2003.

6. Carolyn Rugloski, Training Considerations When Conducting Global Trials, proceedings of the DIA Annual Meeting, June 17, 2003.

7. Diego Glancszpiegel, Clinical Trials in Latin America, Applied Clinical Trials, May 2003, 3841.

8. Jorge Guerra, How Pharma Companies (and CROs) Decide on the Placement of International Clinical Studies, proceedings of the DIA Annual Meeting, June 17, 2003.

9. John Murray, interview on Fresh Air, National Public Radio, July 9, 2003.

10. Beat Widler, How Can We Bring More Structure into the Audit Process and into Audit Reports, proceedings of DIA Annual Meeting, June 19, 2003.

11. Hans Poland, How to Globalize Clinical Quality Assurance, DIA Annual Meeting, June 19, 2003.

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Actavis Totowa (formerly known as Amide Pharmaceutical, Inc.) recalls all lots of Bertek and UDL Laboratories Digitek® (digoxin tablets, USP) as precaution

Morristown, NJ — April 25, 2008 — Actavis Totowa LLC, a United States manufacturing division of the international generic pharmaceutical company Actavis Group, is initiating a Class I nationwide recall of Digitek® (digoxin tablets, USP, all strengths) for oral use. The products are distributed by Mylan Pharmaceuticals Inc., under a “Bertek” label and by UDL Laboratories, Inc. under a “UDL” label.

The voluntary all lot recall is due to the possibility that tablets with double the appropriate thickness may have been commercially released. These tablets may contain twice the approved level of active ingredient than it appropriate.

Digitek® is used to treat heart failure and abnormal heart rhythms. The existence of double strength tablets poses a risk of digitalis toxicity in patients with renal failure. Digitalis toxicity can cause nausea, vomiting, dizziness, low blood pressure, cardiac instability and bradycardia. Death can also result from excessive Digitalis intake. Several reports of illnesses and injuries have been received.

Actavis manufactures the products for Mylan and the products are distributed by Mylan and UDL under the Bertek and UDL labels. Bertek and UDL are affiliates of Mylan.

Post is directly sourced from the FDA webdsite.

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Medrad XDS Extravasation Detector Wins Excellence Award

Medrad and development partner, Battelle Medical Device Solutions, have received a 2008 Medical Design Excellence Award (MDEA) for their XDS extravasation detector.

The XDS helps detect leaking intravenous contrast media from the injection site into surrounding tissue during computed tomography diagnostic studies.

A multidisciplinary panel of jurors reviewed the entries in the MDEA competition, according to Medrad.

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FDA: Phototherapy Company Did Not Report Burn Complaints

National Biological Corp. received a warning letter for quality system violations, including failure to report complaints to the FDA.

Of the 21 complaints reviewed during an FDA inspection, five involved a device malfunction, and one said three patients were burned with the company’s UV phototherapy systems that are used to treat dermatological disorders. None of these complaints had a documented medical device reporting (MDR) assessment, the letter said.

National Biological responded to the agency, saying it would use the FDA’s MDR flowchart to document the review of each complaint.

In the warning letter, the FDA acknowledged receipt of the firm’s response to the Form 483 observations but could not evaluate its adequacy because National Biological failed to provide documentation for actions it claims to have taken and numerous proposed corrective actions it projects will be completed in June or July.

National Biological told the FDA it is reviewing the complaints received in the past two years and will include all failure investigation results, MDR reviews and corrective and preventive actions (CAPAs) conducted in the complaints. It expects to complete this process by July 15.

The company also said it is integrating the complaint, CAPA and all appropriate failure-investigation-activity documents by June 1. The FDA asked for an update on the progress of these actions.

The warning letter is available at www.fda.gov/foi/warning_letters/s6759c.pdf.

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