Recombinant DNA in Human Subjects

Institutional Biosafety Committee (IBC) Review

Research involving the use of recombinant DNA in human subjects that is sponsored by or conducted at the University of Washington (UW) requires review and approval by the UW Institutional Biosafety Committee (IBC). The IBC review process begins once all documents of the Principal Investigator's application packet are submitted. Please be aware that IBC review cannot be completed without recommendations from the NIH's Office of Biotechnology Activities (OBA), Recombinant DNA Advisory Committee (RAC). The Principal Investigator should allow eight weeks for completion of the review process due to the large amount of material for review by the subcommittee.

The UW IBC reviews the clinical proposal and RAC recommendations; review focuses on public protection (i.e., research personnel, care givers, general public, etc.). The RAC makes recommendations on research involving the use of recombinant DNA and on developments in recombinant DNA technology, including clinical trials involving recombinant DNA in human subjects. Recommendations from the RAC are required to be reviewed by the UW IBC.

Institutional Review Board (IRB) approval is required prior to subject enrollment. Other regulatory authorizations may apply. No research participant may be enrolled until:

  1. the RAC review process has been completed;
  2. Institutional Biosafety Committee (IBC) approval from the clinical trial site has been obtained;
  3. Institutional Review Board (IRB) approval has been obtained; and
  4. all applicable regulatory authorization(s) have been obtained.

IBC Application Packet

All of the following documents must be submitted to initiate IBC review:

  • Biological Use Authorization (BUA) Application
  • Completed Appendix M from the NIH Guidelines for Research Involving Recombinant DNA Molecules
  • Any correspondence with the NIH OBA Recombinant DNA Advisory Committee (OBA RAC) (e.g., OBA RAC response letter, OBA RAC reviewers' comments, PI response to OBA RAC reviewers)
  • Clinical protocol
  • Investigator's brochure
  • PI's curriculum vitae (CV)
  • Proposed consent forms
*Please allow eight weeks for completion of IBC review after all documents are submitted.*


NIH OBA Reporting Requirements

The following summarizes the NIH OBA reporting requirements for Principal Investigators. Copies of NIH OBA submissions, including cover letters, are sent to the University of Washington (UW) IBC Coordinator at ehsbio@uw.edu or Box 357165.

NIH Reporting Requirement
When
What to Submit
Initiation of clinical investigationNo later than 20 working days after enrollment of first research participant
See Appendix M-I-C-1
Additional clinical trial sitesPrior to enrollment of research participants at the new clinical trial site
See Appendix M-I-C-2
Annual reportsWithin 60 days after the one-year anniversary of the date on which the investigational new drug (IND) application went into effect, and after each subsequent anniversary until the trial is completed
See Appendix M-I-C-3
Safety Reporting*
When
See Appendix M-I-C-4
Serious adverse event: fatal or life-threatening, unexpected, and associated with use of gene transfer product.Must be reported as soon as possible, but not later than 7 calendar days after sponsor's initial receipt of the information
See Appendix M-I-C-4-a
Serious adverse event: unexpected and associated with the use of the gene transfer product, but not fatal or life-threateningMust be reported as soon as possible, but not later than 15 calendar days after the sponsor's initial receipt of the information
See Appendix M-I-C-4-a
If, after further evaluation, an adverse event initially considered not to be associated with the use of the gene transfer product is subsequently determined to be associatedMust be reported within 15 days of the determination
See Appendix M-I-C-4-a
If relevant additional clinical and laboratory data becomes available following an initial serious adverse event reportMust be reported within 15 calendar days of the sponsor's receipt of the information
See Appendix M-I-C-4-a
If a serious adverse event occurs after the end of a clinical trial and is determined to be associated with the use of the gene transfer productMust be reported within 15 calendar days of the determination
See Appendix M-I-C-4-a
Any finding from tests in laboratory animals that suggests a significant risk for human research participants including reports of mutagenicity, teratogenicity, or carcinogenicityMust be reported as soon as possible, but not later than 15 calendar days after the sponsor's initial receipt of the information
See Appendix M-I-C-4-a

*Adverse events can be reported using the NIH/FDA Genetic Modification Clinical Research Information System (GeMCRIS).


Resources


Questions


Contact the UW Institutional Biosafety Committee (IBC) Coordinator:
206.221.7770
ehsbio@uw.edu.