The IRB holds the PI responsible for the overall management of an approved study. Management of the study encompasses the ethical, technical, administrative, and fiscal elements of a project. The PI may delegate certain tasks, but retains ultimate responsibility and accountability. Principal investigators are required to:
- Ensure the ethical conduct of the research study and protect the rights and welfare of research participants by complying with the IRB approved study protocol, and adhering to all University and State policies, and federal regulations, and applicable guidance,
- Ensure the training requirement for the protection of human participants in research (CITI on-line training modules, www.citiprogram.org) are completed by all personnel working on the study,
- Supervise and ensure that all study personnel receive appropriate training, and conduct the study in accordance with the approved protocol (including approved amendments),
- Guide, mentor and advise student researchers,
- Ensure that all research activities have IRB approval and other approvals required by the institution before human participants are involved, and implement the research activity as it was approved by the IRB,
- Report any real or potential conflicts of interests of the PI or any study personnel in compliance with conflict of interest policies and management plans,
- Obtain informed consent from participants or legally authorized representative before participants are involved in the research, and document consent as approved by the IRB. A copy of the IRB-approved and validated informed consent document must be used to consent each participant. Participants must be provided with a copy of the form after it has been signed, unless the IRB has specifically waived this requirement. The consent process must include a discussion of the study between the person obtaining consent and the participants,
- Maintain written records of IRB reviews, decisions, research records and informed consent documents,
- Obtain IRB approval for and notify the sponsor (if applicable) of any proposed change to the research protocol prior to its implementation, except when necessary to eliminate apparent immediate hazards to the participants,
- Obtain re-approval by reporting progress of approved research to the IRB, in the manner prescribed by the IRB,
- Promptly report to the IRB any adverse events, protocol deviations or other unanticipated problems involving risks to participants or others. PIs should not undertake any action with an external funding agency regarding an unanticipated problem or noncompliance without first contacting the IRB Chair or the DRC to determine the correct course of action,
- Verify that IRB approval has been obtained from all participating institutions in collaborative activities with other institutions, and that continuing review by other institutions is maintained,
- Ensure the privacy of participants is maintained,
- Ensure all data are collected, transmitted and stored according to the IRB’s Data Security Guidance for Human Subjects Research and UConn’s Confidential Data Policy,
- Use the most current version of IRB forms and document templates, which can be downloaded from the IRB website,
- Oversee the budget and expenditures related to the study to ensure that adequate resources are available, including staff, equipment supplies, participant incentives, storage space etc., to conduct the study at the University and any other performance site for which the PI is responsible,
- Provide the IRB with audit or inspection reports or findings issued by regulatory agencies, cooperative research groups, contract research organizations, the sponsor, or the funding agency,
- Maintain, when applicable, accurate records on the receipt, use and disposition of excess drugs/devices,
- Conduct the study in compliance with internal policies and federal regulations including 45 CFR 46 and 21 CFR 50 – Protection of Human Participants, 21 CFR 312 – Investigational New Drug Application and 21 CFR 812 – Investigational Device Exemptions; Good Clinical Practices and, when applicable, 21 CFR 210 – Current Good Manufacturing Practice in Manufacturing, Processing, Packing, or Holding of Drugs and 21 CFR 211 – Current Good Manufacturing Practice for Finished Pharmaceuticals, and the ethical principles outlined in the Belmont Report,
- Retain research records for 3 years after the study completion date.
Responsibilities of All Key Personnel
The IRB holds all study personnel (including PI and co-investigators) responsible for meeting certain obligations. Study personnel are required to:
- Fulfill the training requirement for the protection of human participants in research (CITI on-line training modules, www.citiprogram.org), and understand the ethical standards and regulatory requirements governing research activities with human participants,
- Comply with applicable UConn IRB policies and procedures and federal regulations regarding human subjects research,
- Document contact with participants, e.g., obtaining informed consent or informing participants of changes that may affect their willingness to continue participating,
- Provide a thorough explanation of the study in lay terms to the participant during the consent process,
- Provide the participant with an opportunity to ask questions and have them answered when obtaining informed consent and throughout their participation,
- Understand the appropriate use of an investigational intervention (drug or device) as described in the protocol, investigator brochures, product information/drug labeling, and various other available sources such as newsletters, safety alerts, or communications from sponsors, if applicable,
- Be familiar with and follow the adverse event and protocol deviation reporting requirements.