GCP · Blog

GCP Blog — Field notes from clinical research

August 2026 Edition

The Lead Story

The Lead
GCP10 min read

IRB Waiver of Consent: Three Decisions, Five Criteria, and What the 2024 FDA Rule Changed

When a coordinator says "we got a consent waiver," they could mean any of three legally distinct things. The first question is which regulatory track governs the study, because FDA-regulated drug and device investigations run under 21 CFR Parts 50 and 56, while federally conducted or supported research runs under the Common Rule at 45 CFR 46, and the criteria, while now harmonized, are not interchangeable citations. The second question is whether the ask is a full waiver of consent or an alteration that drops or modifies some elements. The third is whether you are waiving consent at all, or only waiving documentation, the signed form. Conflating these is what turns a defensible submission into a finding.

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Recent dispatches

GCP

Informed Consent Form Template: Build an Inspection-Ready ICF from the Required-Elements Checklist (ICH E6(R3) / 21 CFR 50)

If you searched for an "informed consent form template," you were probably hoping for a blank .doc you could drop your protocol title into and print.

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GCP

Data Safety Monitoring Board (DSMB): When You Need One, and How to Charter It

Most teams ask "should we have a DSMB?" far too late, usually when a reviewer flags its absence.

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GCP

Pharmacovigilance in Clinical Trials: The Classify-Then-Clock Workflow for AE, SAE, and SUSAR Reporting

Most pharmacovigilance (PV) explainers tell you that PV is the science of monitoring drug safety and that it is important.

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GCP

SAE Reconciliation: A Field-Level Discrepancy-Resolution Workflow That Closes Before Lock and Never Lags the SUSAR Clock

Most published SAE reconciliation guidance stops at four verbs: extract, compare, resolve, document.

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GCP

Expedited Safety Reporting in Clinical Trials: The Four-Gate Clock for SAEs, SUSARs, and IND Safety Reports

This guide is written for clinical-ops, PV/drug-safety associates, CRAs, and study-startup leads who own the safety-reporting SOP and need to know whether their day-zero definition and SUSAR classification would survive a BIMO or GCP inspection.

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GCP

Clinical Equipoise as a Monitorable Trial Condition: Who Owns It, When It Breaks, and What GCP Makes You Do

This guide is for clinical-ops staff, principal investigators, CRAs, and QA/regulatory readers who already know the textbook definition of equipoise and now have to make a protocol, a DSMB charter, and an amendment process actually hold it accountable.

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GCP

Essential Documents in a Clinical Trial: The ICH E6(R3) 'Essential Records' Function Test, Not a Frozen Checklist

For years, "essential documents" meant one thing to most clinical-ops and QA teams: the ICH E6(R2) Section 8 table, organized before / during / after, copied into an SOP and treated as the definitive list.

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GCP

The eTMF, Operationalized: Completeness, Timeliness, and Quality That Survive a GCP Inspection

The vendor pages will tell you an eTMF is "the digital version of the TMF, with version control and audit trails, and it helps with GCP compliance." That is where they stop, and it is exactly where the real work starts.

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GCP

The Clinical Research Coordinator as a GCP-Accountability Map: Which CRC Duties Carry Regulatory Weight Under ICH E6(R3) and 21 CFR 312

If you are an early-career coordinator, you have read a dozen pages that list what a CRC does.

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The archive

100 pieces

EDC, eCRF, eCOA and IWRS as One Regulated Data Flow: Who Owns the Source Record and Where ALCOA Breaks at the Seams

Clinical Trial Design and Management as One Quality-by-Design Chain: From Critical-to-Quality Factors to Risk-Based Oversight

Clinical Trial Site Monitoring: The Visit-Type Lifecycle (SSV, SIV, IMV, COV) and the SIV Enrollment Gate

The TMF Reference Model as a Tailoring Exercise: Mapping DIA/CDISC Zones to ICH E6(R3) Essential Records

Clinical Trial Close-Out Checklist: A Dependency-Gated Sequence Built on GCP and 21 CFR Part 312

The Monitoring Visit Report as Oversight Evidence: A GCP-Audit-Ready MVR, Not a Filled-In Form

Data Safety Monitoring Plan vs. Medical Monitoring Plan vs. DSMB Charter: Which One Your Trial Needs, Who Signs It, and How They Fit Together

Protocol Deviation Management: An Impact-Classified Triage-and-Timeline Workflow Under ICH E6(R3) and 21 CFR 312

Risk-Based Monitoring in Clinical Trials: The Quality-by-Design Chain That Decides Where a Monitor Goes

The Quality-by-Design Clinical Trial Protocol: Engineering Out Deviations with Critical-to-Quality Factors and a Defensible Schedule of Activities

The Protocol Deviation Log, Engineered: Columns, Classification, and the Timelines an Inspector Reads as Control

Clinical Trial Endpoints as a Pre-Locked Contract: Who May See Endpoint and Interim Data, When, and What Counts as a Deviation

CTMS vs eTMF: Which System Is the System of Record (and Why GCP Findings Live on That Boundary)

Choosing an eTMF System That Survives a GCP Inspection: A Sponsor's Defensibility Framework

Screen Failure in Clinical Trials: How to Calculate the Rate, Document It Under GCP, and Read It as a Critical-to-Quality Signal

There Is No FDA IND Database: What You Can Actually Look Up, and How the Form-1571 IND Clock Really Works

IRB Approval, Decoded: Pick Your Review Tier Before You Submit (Exempt, Expedited, or Full Board)

Types of Audits in Clinical Trials: A Risk-Mapped Framework for Inspection Readiness

Clinical Trial Registration on ClinicalTrials.gov: The Two Questions and Three Clocks That Decide Your Deadline

TMF vs ISF: An Ownership-and-Reconciliation Contract, Not a Location Table

CAPA in Clinical Trials: The Four-Gate Workflow That Closes a Finding and Keeps It Closed

Electronic Data Capture Software: The Four GCP and Part 11 Obligations That Decide Whether 'Compliant' Survives an Inspection

ICH GCP After E6(R3): What the July 2025 Standard Requires Now, and How It Maps to FDA 21 CFR 312

The Trial Master File Checklist That Survives an Inspection: Completeness, Timeliness, and Quality Over a Document List

Central vs. Local IRB: What a Reliance Agreement Moves, and the GCP Duties It Can Never Transfer

Vulnerable Populations in Clinical Research: A Triage-and-Safeguard Playbook (Not a List to Memorize)

Drug Accountability in Clinical Trials: Closing the Custody Chain Before the Inspector Opens the Log

From Word Template to Defensible Essential Document: Making an Informed Consent Form GCP-Compliant

Clinical Research Coordinator Responsibilities: A Delegation-Mapped Guide to Staying In Scope for an FDA Inspection

Remote Monitoring in Clinical Trials: An RBQM Method That Survives an Inspection, Not a COVID Stopgap

Medical Monitor Responsibilities in Clinical Trials: The Four Safety Decisions, Their Reporting Clocks, and the Records That Prove Them

FDA DSUR Guidance: The DIBD-Anchored Annual Filing That Consolidates Your IND Annual Report (Not a Template)

Protocol Feasibility Assessment as an ICH E8 Quality-by-Design Gate: Run It on the Draft, Before Lock

Clinical Trial Terminology, Grouped by Workflow and Stamped to ICH E6(R3) (2025)

Clinical Trial Sponsor Responsibilities: The Non-Delegable Oversight System Under ICH E6(R3)

The Clinical Trial Agreement, Decoded: A Clause-by-Clause Negotiator's Playbook for the GCP Duties You Cannot Sign Away

The Delegation of Authority Log: Who Did What, and Whether They Were Qualified To

Risk-Based Quality Management (RBQM) Under ICH E6(R3): Quality Designed In, Not Inspected In

The Clinical Study Report (CSR): ICH E3 Structure as a Reasoning Framework

The Clinical Monitoring Plan: A Risk-Based Blueprint, Not a Visit Schedule

SUSAR Reporting: Suspected, Unexpected, Serious, and the Clocks That Follow

Informed Consent in Clinical Trials: A Continuous Process, Not a Signature

Source Data Verification (SDV): Targeted, Risk-Based, and Paired With Source Data Review

Form FDA 1572: The Investigator's Binding Commitment, Not a Form-Fill

Adverse Event and SAE Reporting in Clinical Trials: One Decision Tree, Two Reporting Tracks

ALCOA and ALCOA+ Data Integrity in Clinical Trials: What the Acronym Actually Requires

The Trial Master File (TMF): An Inspection-Ready System, Not a Document Checklist

Protocol Deviations in Clinical Trials: Classify, Report, and Prevent Under ICH E6(R3)

Clinical Trial Budget Management: Building Compliant, Efficient Budgets in the ICH E6(R3) Era

Clinical Trial Delays Cost Prevention: Reducing Timeline Risk Without Compromising Compliance

Clinical Trial Milestones: Navigating FDA and ICH Regulatory Checkpoints for Successful Trial Execution

Audit Trail Requirements FDA 21 CFR Part 11 Clinical Research: What Regulators Expect and Why It Matters

Clinical Trial Management Guidelines: Applying FDA and ICH E6(R3) Standards for Modern, Risk-Based Trial Execution

Clinical Trial Project Management Challenges: Overcoming Regulatory Complexity, Enrollment Barriers, and Operational Risk

Clinical Study Startup Checklist: FDA and ICH E6(R3) Requirements to Prevent Costly Trial Delays

GCP SOP Template Clinical Trial Documentation ICH E6(R3): Building Compliant, Risk-Based SOPs for Modern Trials

Clinical Trial Project Management Guidelines: ICH GCP and FDA Requirements

ICH E6(R3) GCP Guidelines for Clinical Trials

Clinical Trial Compliance GCP Regulatory Guidelines: How to Meet FDA and ICH E6(R3) Expectations Without Derailing Your Study

CTMS Clinical Trial Management System Regulatory Compliance: Meeting FDA and 21 CFR Part 11 Requirements with Confidence

Clinical Trial Closeout Procedures: Ensuring FDA and ICH E6(R3) Compliance While Protecting Long-Term Data Integrity

CTMS vs EDC: Key Differences for Clinical Trial Management Teams

ICH E6(R3) Clinical Trial Risk Management Framework

FDA Clinical Trial Phases I II III IV Regulatory Guidance

Clinical Trial Compliance: Navigating ICH E6(R3) GCP Requirements in a Risk-Based Regulatory Era

CTMS and EDC Comparison as Clinical Data Management Systems

Vendor Management Clinical Trials CRO Oversight: Meeting FDA Expectations While Maintaining Control and Accountability

Clinical Site Selection Feasibility Checklist: FDA and ICH E6(R3) Criteria to Prevent Delays and Compliance Risk

ICH E6(R3) GCP Guidelines FDA EMA Implementation

Site Initiation Visit Checklist

Clinical Project Management GCP Pharmaceutical Research Guidelines

Clinical Trial Vendor Management: CRO Oversight and FDA Guidance

Clinical Trial Risk Management ICH E6(R3) Framework

FDA 21 CFR Part 11 Audit Trail Requirements Compliance

Site Initiation Visit Checklist GCP FDA Guidance

Clinical Trial Phases Lifecycle FDA ICH E6 Guidance

Clinical Trial Sponsor Oversight Responsibilities

Clinical Trial Team Roles Responsibilities GCP Guidelines

ICH E6 GCP Guidelines for Clinical Trials

Clinical Trial Startup FDA ICH E6 GCP Requirements

FDA 21 CFR Part 11 Electronic Records Software Compliance Guidance

Investigator Initiated Trials IIT Management

The Importance of Good Clinical Practice in Real-World Evidence Studies

The Role of Ethics in Clinical Trials: A Deep Dive

Overcoming Common GCP Compliance Challenges in Clinical Research

The Role of Good Clinical Practice in Pediatric Clinical Trials

The Role of Technology in Streamlining GCP Compliance and Clinical Trial Management

Mastering GCP Compliance: Top Tips for Clinical Trial Sites

Risk-Based Monitoring in Good Clinical Practice: An Innovative Approach

How to Ensure Data Integrity in Clinical Research

Navigating Patient Rights and Safety in Clinical Studies

Understanding the Principles of GCP

Good Clinical Practice in the Era of Remote and Decentralized Clinical Trials

Introduction to ICH E6 Good Clinical Practice Guidelines

Breaking Down the Elements of Informed Consent

The Importance of Protocol Compliance in Clinical Trials

Essential Documents in Good Clinical Practice: A Comprehensive Guide

Establishing GCP Compliance in Clinical Research Organizations

The Evolution of Good Clinical Practice Guidelines A Historical Overview

Data Quality and Good Clinical Practice