Changes to the research file (amendments)
Minor changes, such as textual changes, are generally only noted by the reviewing committee (MREC or CCMO). More important changes, such as a new participating centre, must undergo a further review. The same applies to changes which may have consequences for the safety of the research subject. These are substantial amendments.
For an amendment, you need to submit to the reviewing committee a signed cover letter, and all changed documents in which clearly is stated what changes are made (for example by a track change version). If the information in the ABR-form also changes because of the amendment, you have to create a new version of the ABR-form and submit as well. In the case of research with a medicinal product you always have to submit an EudraCT Notification of Amendment Form (B5), and, if applicable, also a modified EudraCT Application Form (B3).
Summarizing, in the case of an amendment you have to submit the following documents to the reviewing committee (MREC or CCMO):
- Cover letter (A1) containing a description of the modification(s) and an oversight of all the documents you are submitting.
- All modified and/or new documents which are part of your research file
- If the content of the information in the ABR-form (B1) changes, you also have to create a new version of the ABR-form and submit it as well.
- Only in case of research with a medicinal product (see below for more information) you have to submit an EudraCT Notification of Amendment Form (B5) and, if applicable, also a modified EudraCT Application Form (B3).
For the way of submitting, see How to submit to the review committee.
The review committee decides if a further decision is necessary. Ask the accredited MREC in question or the CCMO about their policy. A further decision is subject to the so-called ‘reasonable timeline’ of 8 weeks as stated in the General Administrative Act Law (Algemene wet bestuursrecht, Awb). This timeline can be extended with a maximum of 8 weeks.
The Penaly and Appeal Act (Wet Dwangsom en beroep bij niet tijdig beslissen) applies when a request for a further decision is not reviewed within the legal timeline by an accredited MREC or the CCMO. If you do not agree with a decision made by an MREC then you can, as an interested party and under certain conditions, submit an administrative appeal to the CCMO. If you do not agree with a decision made by the CCMO then you can submit an objection to the CCMO.
Research with a medicinal product
In the case of research with a medicinal product the sponsor determines if the amendment is substantial or not. See for more information the guidance document of the European Commission.
A further review is only necessary for a substantial amendment. The documents you are required to submit to the review committee are listed above. A timeline of 35 days applies to the review of an amendment. Non-substantial amendments do not have to be submitted to the reviewing committee.
In the case of research with a medicinal product, the substantial amendment must, inaddition to the review committee, also be submitted to the competent authority (CCMO or Ministry of Health, Welfare and Sport) for a ‘No grounds for non-acceptance’. Please note: You are required to submit only the following documents to the competent authority:
- Cover letter, see the template cover letter amendment to the competent authority (A1)
- An EudraCT form notification of amendment (B5)
- If applicable, a changed EudraCT clinical trial application form (B3), digitally in the form of a pdf and in xml format in ToetsingOnline.
How to submit:
- To the review committee
- To the competent authority (only required in case of research with a medicinal product)
Any other documents do not have to be submitted to the competent authority. Note: the competent authority does not send a confirmation of receipt. The review timeline of maximum 35 days starts on the day after the competent authority has received the complete submission. If the competent authority has no objections, a ‘No grounds for non-acceptance’ is issued per e-mail. The e-mail is sent to the registered user for the file concerned in ToetsingOnline. If it concerns a research which started before the 1st of March 2006 and which is not registered in ToetsingOnline, then an e-mail is sent to the submitting party.
Addition of a participating centre
Addition of a new participating centre is considered a substantial amendment and must be submitted for review to the reviewing committee (MREC or CCMO). If it concerns research with a medicinal product then the substantial amendment must also be submitted to the competent authority.
The following applies to a submission to the reviewing committee: is the centre already mentioned in the ABR form and/or the EudraCT Application Form (Annex 1)? Then it is still considered a substantial amendment. However, in this case you do not have to submit a changed ABR form and/or new EudraCT Application Form. The Research Declaration (I2) (with cover letter) and the EudraCT form notification of amendment (B5) (previously Annex II ) is sufficient.
The competent authority (in the case of research with a medicinal product) only has to receive the cover letter and the EudraCT form notification of amendment (B5). The Research Declaration does not have to be submitted. The submission of EudraCT forms is only necessary for research with a medicinal product.
For the way of submitting, see How to submit.
The procedure for the review of substantial amendments is slightly different for certain types of research: