Liberia Medicines and Health Products Regulatory Authority

As per the LMHRA-Act, the LibCTReg, and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) is the regulatory authority responsible for clinical trial approvals, oversight, and inspections. According to the LMHRA-Act, the LMHRA operates as an autonomous government agency that reports to the President of the Republic of Liberia. In addition to its role in authorizing clinical trials, the LMHRA-Act indicates that the LMHRA’s responsibilities also include drug and health care product registration, inspections, import/export control, licensing, quality control, advertising and promotion, and pharmacovigilance and post-marketing surveillance.

Per LBR-30, the Clinical Trials Unit within LMHRA’s Pharmacovigilance & Clinical Trials Department is responsible for coordinating all aspects of clinical trials in Liberia including:

• Receiving and assessing all clinical trial applications submitted to the LMHRA
• Conducting good clinical practice (GCP) inspections of trial sites and GCP training for inspectors and the study team to ensure compliance that is in line with LMHRA regulatory requirements and international best practices
• Reviewing all reports from clinical trial sites and advising management on appropriate regulatory actions
• Investigating the conduct of clinical trials
• Suspending or stopping clinical trials (depending on the magnitude of the offense)
• Serving as secretariat for the Scientific Advisory Committee (SAC) on clinical trials
• Reviewing importation permits for investigational products (IPs) that are required for the conduct of clinical trials
• Conducting pre-submission meetings to discuss issues related to application processes
• Reviewing all reports (safety reports, quarterly reports, Serious Adverse Events (SAE) reports and final or close-out reports) from clinical trial studies conducted

Per the LibCTReg, the LMHRA can establish advisory committees for the review of clinical trial applications and for post-approval safety and compliance issues, if needed, and especially in the event of new/emerging technologies. According to LBR-29, the LMHRA has established a SAC to provide technical support to review clinical trial applications.

Other Considerations

Please note: Liberia is party to the Nagoya Protocol on Access and Benefit-sharing (LBR-3), which may have implications for studies of IPs developed using certain non-human genetic resources (e.g., plants, animals, and microbes). For more information, see LBR-17.

Contact Information

Per LBR-19, the LMHRA contact information is as follows:

Liberia Medicines and Health Products Regulatory Authority (LMHRA)
2nd & 3rd Floors Clay Building
Sekou Toure Avenue
Mamba Point
Monrovia, Liberia
Phone: (+231) 777-140-555 or (+231) 888-140-555
Email: info@lmhra.gov.lr

In Uganda, the National Drug Authority (NDA) and the Uganda National Council for Science and Technology (UNCST), in collaboration with the Uganda National Health Research Organisation (UNHRO), are involved in clinical trial oversight.

National Drug Authority

As per the NDPA-CTReg, the G-CTConduct, and the G-TrialsGCP, the NDA is the regulatory authority responsible for clinical trial approval and inspections in Uganda. The NDA grants permission for clinical trials to be conducted in Uganda in accordance with the provisions of the NDPA-Act.

As stated in the NGHRP, the NDA regulates safety, quality, efficacy, handling, and use of drugs or drug related products and devices in research, and monitors product safety and pharmacovigilance. According to UGA-29, the Clinical Trials Unit in the NDA’s Directorate of Product Safety is responsible for reviewing and approving clinical trial applications, conducting clinical trial site inspections for compliance with good clinical practice, and developing guidance documents.

Uganda National Council for Science and Technology

The NDPA-CTReg and the G-CTConduct indicate that in addition to obtaining the NDA’s permission to conduct research in Uganda, an applicant must obtain approval from the UNCST, or from an institution authorized by the UNCST. The NGHRP specifies that all persons intending to carry out research in Uganda must register their research activities with and obtain a research permit from the UNCST. Prior to approval and registration with the UNCST, approval for a clinical trial must be obtained from the ethics committee (EC) (research ethics committee (REC) in Uganda) and/or the UNCST’s National Biosafety Committee (NBC), as applicable.

As per UGA-30, the UNCST was established by the UNCST-Act as a semi-autonomous government agency under the Ministry of Science, Technology, and Innovation. The mandate of the UNCST is to develop and implement policies and strategies for integrating science and technology into national development policies; to advise the government of Uganda on policy matters necessary for promoting science and technology; and coordinate and guide national research and development in Uganda.

As per the NGHRP, the UNCST registers and, in liaison with the Research Secretariat in the Office of the President of Uganda, clears all research intended to be carried out in the country.

Uganda National Health Research Organisation

The UNHRO-Act authorizes the UNHRO to register and renew research protocols, and to implement and enforce an ethical code of conduct for health research in Uganda. The UNHRO, in collaboration with the UNCST, conducts a scientific and ethical review of all health research protocols for approval. According to the NGHRP, the UNCST consults the UNHRO, where applicable, on identified health protocols through the UNHRO’s National Health Research Ethics Advisory Board (NHREAB). The research follows established research regulatory processes, and final research clearance and registration is carried out by the UNCST. The NHREAB is advisory and provides advice on broader national political and safety issues related to research. It also provides advice related to arbitration on appeals from scientists. Expert working groups also support the NHREAB as requested.

Other Considerations

Please note: Uganda is party to the Nagoya Protocol on Access and Benefit-sharing (UGA-3), which may have implications for studies of investigational products developed using certain non-human genetic resources (e.g., plants, animals, and microbes). For more information, see UGA-21.

Contact Information

National Drug Authority

According to UGA-23, the NDA’s contact information is as follows:

National Drug Authority - Head Office
NDA Tower
P.O. Box 23096
Kampala, Uganda
Plot 93, Buganda Road, after St. Catherine Hospital

Reception Phone: +256 [0]417 788 100
Directorate of Product Safety Phone: +256 [0]417 788 124
Directorate of Inspectorate Services Phone: +256 [0]417 788 129
WhatsApp: +256 740002080

Email: ndaug@nda.or.ug

UGA-10 also provides the following contact information for the NDA’s Innovation & Research Desk:

Phone: [0]800 101 999
WhatsApp: 0740002070
Email: research@nda.or.ug

Uganda National Council for Science and Technology

As per UGA-25, the UNCST’s contact information is as follows:

Uganda National Council for Science and Technology
Plot 6, Kimera Road, Ntinda
P.O. Box 6884
Kampala, Uganda
Phone: +256 414 705500
Email: info@uncst.go.ug

Uganda National Health Research Organisation

Per UGA-42, the UNHRO’s contact information is as follows:

Uganda National Health Research Organisation
Plot 2, Berkeley Lane, Entebbe
P.O. Box 465
Entebbe, Uganda

Tel/Fax: +256 414 321766
Email: unhrodesk4@gmail.com

Overview

In accordance with the LMHRA-Act, the LibCTReg, and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) is responsible for reviewing, evaluating, and approving applications for clinical trials using registered or unregistered investigational products (IPs). According to the G-LibClinTrial, proposed clinical trials of registered medicines may include changes to indications, new methods of administration, or new combinations, etc. The G-LibClinTrial specifies that the scope of the LMHRA’s assessment includes all clinical trials (Phases I-IV). In addition, per the LibCTReg and the G-LibClinTrial, the National Research Ethics Board of Liberia (NREB) and LMHRA reviews may be conducted in parallel. However, the G-LibClinTrial and the G-NREB specify that the LMHRA will only issue final approval once NREB (ethics committee (EC)) approval is obtained.

Clinical Trial Review Process

As indicated in LBR-30, the LMHRA’s Clinical Trials Unit within the Pharmacovigilance & Clinical Trials Department is responsible for coordinating all clinical trial activities. According to LBR-29, the LMHRA has established a Scientific Advisory Committee (SAC) to review clinical trial applications.

Per the G-LibClinTrial, the LMHRA will only process an application upon receipt of a completed application and the prescribed fees. Upon receipt, the LMHRA screens the clinical trial application package for completeness and must inform the applicant in writing about the validity of the application or the formal grounds for non-acceptance of the application. After validating the application package is complete, the LMHRA conducts a scientific assessment of the application.

During the clinical trial scientific assessment process, the LibCTReg and G-LibClinTrial also explain that relevant clinical trial decisions, reports, or information from other national regulatory authorities or regional and international bodies can be recognized or used by the LMHRA. The LibCTReg further specifies that the scope/extent of utilization of relevant clinical trial decisions, reports, or information from other national regulatory authorities or regional and international bodies will be at the sole discretion of the LMHRA. In such instances, business and company secrets must remain confidential.

The LibCTReg also states that the LMHRA must inform the NREB if it is in possession of information about other clinical trials that is relevant to the board's assessment of the trial for which it is to issue an expert opinion; this applies especially to information on aborted or otherwise prematurely discontinued investigations. In such instances, business and company secrets must remain confidential. Also, the LMHRA must ensure that the list of approved and rejected clinical trial applications, the summary of evaluation reports, and the status of approved clinical trials are publicly available and periodically updated.

Per G-LibClinTrial, all applications must be evaluated with the same set of criteria based on up-to-date scientific knowledge and ethics standards, regardless of the applicant. The LMHRA may also request additional documents or changes through a query letter. Once a query has been raised and issued to the applicant, the process stops when the LMHRA receives a written response to the query. If the LMHRA requires changes to the application, the applicant must modify the application within an established timeline, or it will be rejected.

As indicated in the G-LibClinTrial, the LMHRA must issue a clinical trial certificate, including the LMHRA clinical trial number, to the applicant upon application approval. The clinical trial certificate may contain conditions required by the LMHRA with respect to the conduct or reporting of the trial. If the application is rejected, the applicant can submit a written appeal to the LMHRA’s Managing Director. Moreover, the information provided in a clinical trial application must not be disclosed by the LMHRA to a third party except with the applicant’s written consent or in accordance with the directive of the LMHRA Board of Directors.

Per the G-LibClinTrial, under certain circumstances, the LMHRA may accept an expedited application and review process for clinical trials (e.g., epidemics or other urgent public health interests requiring fast use of new medicines or health products and/or fast gathering of health product information). The LibCTReg also notes that in the case of emergency situations, the LMHRA may also apply an expedited review process and make exemptions to the documentation requirements for the submission of clinical trial applications. Refer to 2.3 of the G-LibClinTrial for additional information on how to submit an expedited clinical trial application package.

As delineated in the LibCTReg, any amendments to approved clinical trial documentation, trial arrangements, and the IPs referenced in the application must be classified and processed in accordance with the LMHRA guidelines. The G-LibClinTrial explains that depending on the nature of the change, trial amendments are regarded as substantial or non-substantial/minor amendments. Amendments to a clinical trial are regarded as “substantial” when they are likely to have significant impact on the safety or physical or mental integrity of the trial participants and/or the scientific value of the trial. Any substantial amendments to the clinical trial protocol, clinical trial arrangements, or the IP—or a related product deemed to be an amendment—must be approved by the LMHRA and the NREB before such amendments are carried out. Written NREB approval is also required before the LMHRA can reach a decision on an amendment. The LMHRA should respond within 20 calendar days upon receipt of the NREB’s written decision, and may accept or reject the amendment, or recommend a revision of the sponsor’s classification.

Per the G-LibClinTrial, non-substantial/minor amendments, by comparison, can be implemented immediately by the sponsor and should always be documented and notified to the LMHRA and the NREB as soon as possible. See the G-LibClinTrial for additional amendment requirements. See the Submission Process section for amendment submission requirements.

Per the LibCTReg, the LMHRA’s written approval of a clinical trial with IPs involving human participants is based on the conclusion that the anticipated therapeutic and public benefits justify the risk and may be continued only if compliance with this requirement is permanently monitored. An LMHRA authorization may only be refused if:

• The documents submitted are incomplete up to the expiration of an appropriate deadline given to the applicant for their supplementation
• The documents submitted, especially the data on the IP(s) and the trial protocol including the investigator's brochure (IB), do not comply with the current state of scientific knowledge, and especially, the clinical trial is unsuitable for providing proof of IP(s) safety or efficacy
• In the case of trials involving human participants, the documentation requirements (see Section 1 (d) of LibCTReg), particularly insurance coverage for trial participants, are not fulfilled
• The LMHRA is in possession of findings which indicate that the testing facility is not suitable to conduct the clinical trial
• The LMHRA is of the opinion that the number of clinical trial participants to be recruited in the trial is not scientifically justified, or
• The requirements provided for in the general conditions and special preconditions for conducting a clinical trial (see Part II (Section 2) of LibCTReg) are no longer fulfilled

The LibCTReg indicates that, in a clinical trial involving an IP that consists of, contains, or is a combination of genetically modified organisms, unjustifiable harmful effects on the health of third persons and the environment are not to be expected when the trial is conducted according to the state of scientific knowledge and in relation to the trial’s purpose.

(See the Submission Process and Submission Content sections for detailed submission requirements and the Timeline of Review section for additional LMHRA timeline information.)

The LibCTReg further explains that the LMHRA must suspend a clinical trial authorization for a limited period of time if at least one (1) of the following conditions is true:

• It becomes known that one (1) of the grounds for refusal previously indicated existed at the time the trial authorization was issued (see also Part II (Section 6 (1) of LibCTReg)
• The conditions surrounding the clinical trial do not correspond to the information contained in the authorization application
• The facts presented give reason to doubt the safety or the scientific basis of the clinical trial

Per the LibCTReg, the LMHRA must withdraw a clinical trial authorization when scientific justification for resuming the trial is not provided to address the reasons previously indicated for suspension. The LMHRA must also immediately inform the NREB through a written communication stating the grounds for its action. Before the LMHRA issues a decision, the applicant must be allowed a deadline of 10 working days to submit a statement, unless the LMHRA orders the immediate interruption of the clinical trial. The lodging of an objection and an action to rescind the withdrawal or the order to suspend the authorization should not have a suspensive effect. If the authorization to conduct a clinical trial is withdrawn or suspended, the clinical trial may not be continued. Also, if the LMHRA, in the context of its activities, becomes aware of facts which justify the assumption that one (1) or more of the investigators or the sponsor or the sponsor’s representative no longer fulfills their obligations with regard to the proper conduct of the clinical trial, the LMHRA must immediately inform this individual(s) and must order remedial measures to be taken by the individual(s).

Pursuant to Part VIII of the LMHRA-Act, the LibCTReg states that any person(s), institution(s), corporate entity(ies), their designees, or legal representatives who violates the clinical trial authorization procedures, the serious adverse event notification requirements, and/or the suspension/withdrawal provisions delineated in the LibCTReg will be liable to pay administrative fines. See the LibCTReg for details.

Inspection

As stated in the LibCTReg, the LMHRA should inspect a clinical trial site to ensure that the general public is adequately protected against the adverse event risks related to a clinical trial with IP(s); and, to confirm that the PI and the sponsor, including the sponsor’s representatives, are strictly adhering to the specific and general conditions to which the trial was authorized. The G-LibClinTrial also indicates that the LMHRA may inspect clinical trial sites and/or the sponsor's/contract research organization (CRO)’s premises and/or the manufacturer’s premises to ensure that the clinical trials comply with good clinical practice (GCP) provisions before, during, or after the trial is conducted.

Per the LibCTReg and the G-LibClinTrial, NREB representatives may accompany the LMHRA during clinical trial site inspections, or, per the LibCTReg, they may choose to do the inspections independently. The G-LibClinTrial also notes that the LMHRA may include other relevant regulatory authorities in the inspection. The PI and/or the sponsor/CRO and/or the manufacturer must be notified in writing of the inspection unless the LMHRA has reasonable cause to believe that the approved protocol is being violated. In this case, an unannounced inspection may be conducted. Following these inspections, the LMHRA must prepare an inspection report, and the report will be made available to the PI and/or sponsor while safeguarding the confidential aspects. The report may also be made available to the NREB and other regulatory authorities upon their request. Additionally, the LibCTReg specifies that the LMHRA, based on its findings, may also request additional information, suspend or stop a trial, or withdraw authorization to conduct a clinical trial, if the agency is of the opinion that the participant safety may be jeopardized, the scientific reasons for conducting the trial have changed, or the integrity of the data is compromised.

Overview

In accordance with the NDPA-CTReg, the G-CTConduct, and the G-TrialsGCP, the National Drug Authority (NDA) is responsible for reviewing, evaluating, and approving clinical trial applications for registered or unregistered medicines in Uganda. The scope of the NDA’s assessment includes all clinical trials (Phases I-IV).

The NGHRP states that research approval must be obtained from the institutional level ethics committee (EC) (research ethics committee (REC) and/or National Biosafety Committee (NBC), as applicable, prior to approval and registration with the Uganda National Council for Science and Technology (UNCST). Per the NDPA-CTReg, proof of institutional EC approval must also be submitted in a clinical trial application to the NDA. However, the G-TrialsGCP indicates that parallel submissions may be made to the NDA and the UNCST. In that instance, the NDA would not make a final decision until after the trial receives ethical clearance. NDA approval will be dependent on receipt of the protocol’s approval by the institutional EC in consultation with the UNCST. As per the NGHRP, Joint Scientific and Ethical Review (JoSER) involving the UNCST, the Uganda National Health Research Organisation (UNHRO), the NDA, and the EC, as applicable, is also available for research that involves a novel technology, product, study design, or intervention that addresses a public health need or/and emergency. See below for more information on JoSER.

Clinical Trial Review Process

National Drug Authority

The NDPA-CTReg, the G-TrialsGCP, and the G-CTConduct indicate that upon receipt of a clinical trial application, the NDA initially screens the application for completeness. If the NDA is not satisfied with the information provided, the applicant will be advised in writing to provide further information or clarification. According to the G-CTConduct, the applicant must submit their responses in writing or in any other format as advised by the NDA, and in the timeframe determined by the NDA. NDA reviews are performed following a first-in first-out principle, except for clinical trials that are to be conducted in public health emergencies such as disease outbreaks, which may be exempted.

The NDPA-CTReg indicates that in considering an application for a clinical trial, the NDA must take into account the following:

• Relevance of the clinical trial
• Suitability of the principal investigator (PI)
• Quality of the facilities to be used for the clinical trial
• Adequacy and completeness of the information and procedures to obtain consent from the clinical trial participants
• Provision for indemnity for the PI and insurance for the clinical trial participants
• Terms of the agreement between the sponsor and the PI

Per the G-CTConduct, complete applications are given a Clinical Trial Application code. Applications verified as complete will undergo one (1) of three (3) types of reviews:

• Internal review, which is further subdivided into expedited or routine review
• Expert review, which involves external reviewers co-opted by the NDA following internal procedures
• Joint reviews, which are carried out jointly with other regulatory bodies including the UNCST, the UNHRO, and the primary EC. These reviews will be coordinated by the UNCST

As stated in the G-CTConduct and the NDPA-CTReg, fast track review/authorization of an application is applicable for the following (Note: Each of the items listed below will not necessarily be found in both sources, which provide overlapping and unique elements):

• Clinical trial applications for investigational drugs to provide treatment where no therapy exists (decision will be given to the applicant within 30 working days)
• Clinical trials conducted in an emergency, such as during a disease outbreak (eligible for fast track review with a timeline of 15 working days)
• Clinical trial applications that do not explicitly meet either above criterion, but are led by the Ministry of Health in the interest of a public health intervention
• Any other circumstance that the NDA may determine

According to the G-CTConduct, the NDA may decide to a) authorize the clinical trial and issue a clinical trial certificate; b) request additional information to support the application; or c) reject the clinical trial application, providing reasoning. The NDA’s decision is communicated to the applicant in writing. The clinical trial certificate is valid for one (1) year from the date it is awarded. Per the NDPA-CTReg, the NDA may also issue a clinical trial certificate with conditions. See Appendix XI of the G-CTConduct for the NDA clinical trial process flowchart and Form 34 in Schedule 1 of the NDPA-CTReg for the format of the clinical trial certificate.

See the Submission Content section for detailed information on the contents of the clinical trial application.

The G-CTConduct states that any new information that becomes available regarding the product, such as new adverse effects or changes in formulation or the manufacturer, must be submitted to the NDA as soon as possible. Unless otherwise stated, additional information that is submitted prior to issuance of a clinical trial certificate will be considered as part of the submission and reviewed accordingly. The NDA may request supplementary information or documentation when appropriate, which should be submitted within the stated timeline, usually four (4) weeks. The NDA secretariat may grant additional time to provide information upon request by the applicant on a case-by-case basis. If the requested information is not submitted, the application will be archived within 50 working days. The application will need to be resubmitted for review.

Per the G-CTConduct, annual renewal of authorization to conduct the clinical trial is required for the trial prior to expiration of the validity. For studies that have completed follow-up for the last participant where there is no product or human participant, oversight will be deferred to the primary EC and the UNCST.

The NDPA-CTReg and the G-CTConduct indicate that the NDA may, on its own initiative, make amendments to the conditions for conducting a clinical trial where it is necessary for the safety or scientific validity of the clinical trial. The NDA will give 15 days’ notice of the intended amendment to the sponsor and the PI with reasons for the amendment and request a written response to the proposed amendments prior to effecting the amendments. As stated in the NDPA-CTReg, the NDA will, in making amendments to the conditions of conducting a clinical trial, take into consideration the response of the sponsor or PI.

The NDPA-CTReg indicates that a sponsor who intends to amend any condition of the clinical trial specified in the clinical trial certificate, or who intends to add investigators, add clinical trial sites, or change investigators, must make an application to the NDA for authorization of the amendment. The amendment applications will be considered using the procedure and requirements for an application for authorization to conduct a clinical trial.

The G-CTConduct specifies that the application to amend the conditions of a clinical trial will be screened for completeness and will essentially be complete in the first instance if it includes all the required documents, appendices, and finished checklist. Applications which are incomplete will not be evaluated, and a letter documenting the deficiencies in the application will be issued to the applicant. The NDA may request supplementary data or documentation where applicable. The NDA will consider the favorable opinion of the EC(s), the UNCST, and other relevant information, and may request that the applicant submit an interim clinical trial study report to support the decision. Additionally, the NDA may take other regulatory action such as an inspection of the clinical trial site or investigational product (IP) manufacturing facility for regulatory and protocol compliance prior to making a decision. The NDA may approve or reject the application and specify the reasons for rejection. The decision will be communicated to the applicant in writing. Changes made to the informed consent forms will be acknowledged electronically unless they are directly related to the safety of the IP. Additionally, the NDA must be notified within 90 days about delays in trial initiation once a clinical trial has been approved and a clinical trial certificate issued.

See the G-CTConduct for detailed NDA amendment review procedures and Appendix IV of the G-CTConduct for the Categorization of Amendments.

As per the G-CTConduct, the NDA may at any reasonable time conduct inspections of the trial site prior to or after issuance of a clinical trial certificate. The purpose of the inspections is to assess the staff and facilities to be used or that are being used for the conduct of the clinical trial, and to verify the availability of the necessary resources and feasibility of conducting the study at the proposed site(s). These inspections will assess the compliance of the trial conduct with the conditions of the certificate. The NDA secretariat may contact the PI or sponsor notifying them of the date(s) of inspection. The secretariat will conduct inspections routinely, or as a result of a trigger. In addition, the inspections may be done jointly with the UNCST and/or the EC.

As indicated in the G-TrialsGCP, an inspection by the NDA may involve a comparison of the practices and procedures of the clinical trial with the commitments made in the application to conduct the trial; a comparison of the data submitted to the sponsor and the NDA with the source data; and a system inspection of the sponsor, clinical laboratory, or contract research organization generating data for submission to regulatory authorities. For more information on NDA inspections, see the G-TrialsGCP.

The NDPA-CTReg states that the NDA may, by notice, suspend or terminate a clinical trial where the conditions of a clinical trial certificate are not complied with or the NDA has information regarding the safety or scientific validity of the clinical trial or the conduct of the clinical trial. The NDA notice, which must be delivered to the sponsor or PI, will apply to the clinical trial generally or to one (1) or more of the clinical trial sites. Where a notice is for the suspension of the clinical trial, the suspension must be for the period specified in the notice. The notice must indicate, where applicable, the conditions to be fulfilled before the clinical trial or, as applicable, the conduct of the clinical trial at a particular site, may resume. Before issuing a notice, the NDA must inform the sponsor or PI of the notice and the reasons for the notice, and then advise the sponsor or PI to make a written representation on the intended suspension or termination within five (5) days. The NDA must consider the written representation and inform the sponsor or PI of its decision within seven (7) working days. However, the NDA is not required to inform the sponsor or PI of the notice if it appears that there is an imminent risk to the health or safety of any person participating in or involved in a clinical trial.

Uganda National Council for Science and Technology

According to the NDPA-CTReg, the NGHRP, and the G-CTConduct, an applicant must also submit a research proposal for review and approval to the UNCST. The NGHRP indicates that the UNCST liaises with the Research Secretariat in the Office of the President on national security issues in respect to research conducted in Uganda. All persons intending to carry out research in Uganda must register their research activities with and obtain a research permit from the UNCST. The UNCST registration process is normally completed within 10 working days.

According to the NGHRP, the UNCST handles appeals arising from ECs, research institutions, and the community in consultation with other regulatory agencies. It will also act as an arbiter for a research applicant dissatisfied with a decision from the EC. A researcher who is dissatisfied with an EC’s decision may appeal to the Executive Secretary of the UNCST within 30 days from the date of receipt of EC decision. The UNCST will carry out an independent review in collaboration with other regulatory bodies where applicable. For health research, the UNCST will carry out an independent review in collaboration with the UNHRO.

See the NGHRP for information on research in advanced therapy medicinal products/advanced therapeutic medicinal products (ATMPs), traditional and complementary medicine, and genetics and genomics.

Joint Scientific and Ethical Review

As stated in the G-JoSER, a submission for joint review may be initiated by the investigator, the national regulatory agencies (NRAs) (the NDA, the UNHRO, and the UNCST), or the EC. The UNCST Secretariat will coordinate the JoSER and be present during discussions regarding the research application under review. Additionally, the final decision on whether a study is eligible for JoSER is made by the UNCST, based on the assessment of the EC and/or any other reason as determined by the NRAs.

Per the G-JoSER, an investigator must have consultations with the EC chairperson prior to submitting the research application for pre-screening. The pre-screening will take a maximum of three (3) working days. After the NRAs and EC pre-screen the documents, administrative comments, together with the scheduled date and program for the joint review, will be sent to the applicant within three (3) working days. The request for JoSER may be rejected or accepted. For accepted applications, the UNCST, in collaboration with the NRAs, will identify subject matter experts and interested parties and notify them about the review meeting within the three (3) working days. Following the identification of reviewers, a joint review meeting will be convened by the UNCST within 10 calendar days. The NGHRP notes that quorum of the primary EC is required for the joint review, and the investigator/sponsor is responsible for any logistical requirements for the review meeting.

The G-JoSER indicates that the UNCST will submit a consolidated list of comments from the joint review within three (3) days after a convened meeting. The PI must submit a formal response to the comments received at the JoSER and then submit a cover letter with required documentation to the local EC for review. The EC will convene a meeting to review the responses within five (5) working days and decide whether to approve or reject the proposal. Following EC approval, the PI must submit the approved documents to the UNCST and submit them in parallel to the NDA (where necessary). The UNCST, in collaboration with the UNHRO, will review the documentation for completeness within two (2) working days, after which a research permit may be issued. The NDA will review the clinical trial application and provide a regulatory decision within five (5) working days, after which a certificate may be issued. However, a clinical trial certificate will only be granted after a research permit is obtained from the UNCST. The EC must co-opt at least two (2) members from the JoSER committee in case of any major amendments to the previously reviewed proposal.

According to the G-JoSER, an investigator who is dissatisfied with a JoSER decision may appeal to the UNCST Executive Secretary within 15 days of the date of receipt of the decision. The UNCST, together with the relevant regulatory bodies, will carry out an independent review and make a final decision. An investigator who is dissatisfied with the EC’s decision may also appeal to the UNCST Executive Secretary within 15 days of the date of receipt of the EC’s decision. The UNCST will carry out an independent review in collaboration with other regulatory bodies where applicable.

The NGHRP states that where possible, joint monitoring of the research studies may be carried out by the EC together with the UNCST, and where applicable, the UNHRO, the NDA, and other relevant regulatory organizations.

See the G-JoSER and the NGHRP for more information on JoSER.

Liberia Medicines and Health Products Regulatory Authority

The LibCTReg and the G-LibClinTrial require proof of payment of the clinical trial application fee in the application dossier. Per LibCTReg, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) charges a non-refundable fee to submit a clinical trial application for authorization. As delineated below, authorization fees vary depending on the phase and institution conducting the study:

• Industry Funded (Phase I): $25,000 USD
• Industry Funded (Phase II): $20,000 USD
• Industry Funded (Phase III): $15,000 USD
• Clinical Research Organization (CRO) Funded Phase I: $10,000 USD
• CRO Funded Phase II: $8,000 USD
• CRO Funded Phase III: $6,000 USD
• Investigator/Local Phases III & IV: $2,500 USD
• Academic Research Trial (Individual): $2,000 USD
• Amendment (Substantial) to Clinical Trial Protocol: $1,000 USD
• Administrative Charges: $500 USD
• Material Transfer Agreement (MTA) Fees: $1,500 USD
• Good Clinical Practice (GCP) Inspections: $1,000 USD

Payment Instructions

No information is currently available regarding payment instructions.

National Drug Authority

In accordance with the NDPA-CTReg, the G-CTConduct, and the NDPA-FeesReg, applicants are responsible for paying certain non-refundable fees to the National Drug Authority (NDA) related to clinical trial applications. As set forth in the NDPA-FeesReg, the following fees apply for clinical trials involving human drugs and vaccines (except herbal drugs):

• Application to conduct a clinical trial for a registered drug – $5,000 USD
• Application to conduct a clinical trial for an unregistered drug – $8,000 USD
• Application to conduct an adaptive clinical trial – $10,000 USD
• Application to conduct a clinical trial for locally manufactured drugs – 10,000,000 Ugandan shillings
• Application for major amendment of clinical trial protocol – $700 USD
• Application for minor amendment of clinical trial protocol – $300 USD
• Notification of amendment to clinical trial protocol – $50 USD
• Application for major amendment of protocol for an adaptive clinical trial – $2,000 USD
• Annual renewal of clinical trial certificate – $500 USD
• Extension of period for a clinical trial – $1,000 USD
• Fast tracking applications – 200% of applicable fees

See the NDPA-FeesReg for NDA fees regarding the inspection of local and foreign manufacturing plants for good manufacturing practice (GMP). Additionally, see the NDPA-FeesReg and the NDPA-AmendFeesReg for drug importation fees.

Payment Instructions

The NDPA-FeesReg notes that the prescribed fee is payable at the same time that an application is made to the NDA. The NDA will not accept an application with respect to which the prescribed fee is not paid.

According to the G-CTConduct, the application fee payment details are as follows:

National Drug Authority: TIN 1000054563
Bank: Stanbic Bank Uganda
Account numbers: 9030008068851 (US Dollars) and 9030005759829 (Ugandan shillings)
Swift code: SBICUGKXXXX
Sort Code: 040147
Acceptable forms of payment: cash in the bank, real time gross settlement (RTGS), electronic funds transfer (EFT), telegraphic transfer (TT), or check

Uganda National Council for Science and Technology

As stated in UGA-20 and UGA-45, the Uganda National Council for Science and Technology (UNCST) charges a research administration and clearance fee of $300 USD, or $50 USD for East African students (except those pursuing post doctorates), to register a research proposal.

The G-JoSER indicates that research proposals submitted for Joint Scientific and Ethical Review (JoSER) have an administrative fee, which must be paid by the sponsor/principal investigator. The JoSER fee excludes the fees at the respective national regulatory agencies and ethics committees. The fees may vary depending on administrative circumstances.

Payment Instructions

According to UGA-20 and UGA-45, the payment information for UNCST fees is as follows:

Bank: Any Standard Chartered Bank
Account title: Uganda National Council for Science and Technology (UNCST)
Account numbers: 8705611811400 (US Dollars) and 0105610632101 (Ugandan shillings)
Swift code: SCBLUGKA

No additional information is available for payment of JoSER fees.

Overview

Per the G-ACRE-IRB and the G-NREB, all research involving human participants should be reviewed by an ethics committee (EC). According to the NatResHlthPlcy, Liberia has two (2) ethics committees (ECs): the National Research Ethics Board of Liberia (NREB) and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) (formerly known as the University of Liberia-Pacific Institute for Research and Evaluation Institutional Review Board (UL-PIRE-IRB)). (Note: The UL-PIRE Africa webpage has not yet been updated to reflect the transition to ACRE IRB.)

Per LBR-38, the NREB has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the ACRE IRB in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

National Research Ethics Board of Liberia

As explained in the G-NREB, the NREB is an advisory institution that reports to the Ministry of Health (MoH), and its members are appointed by the Minister of Health. The G-NREB states that the board ensures all research related protocols within and outside of Liberia are in compliance with internationally recognized ethical standards (including the Belmont Report (LBR-11), the Declaration of Helsinki (LBR-27), the International Council for Harmonisation’s Guideline for Good Clinical Practice E6(R2) (LBR-8), and the Council for International Organizations of Medical Sciences (CIOMS’) International Ethical Guidelines for Health-related Research Involving Humans (LBR-2)), as well as Liberia’s applicable regulations and guidelines. In addition, per the G-NREB and LBR-12, the NREB is responsible for reviewing research proposals involving human participants to assess their compliance with ethical principles, regulatory requirements, and international guidelines, and for approving research protocols that meet ethical standards and providing recommendations for addressing any ethical concerns.

Per the NatResHlthPlcy, the G-NREB, and LBR-12, the NREB is also responsible for the following (Note: Each of the items listed below will not necessarily be found in all sources, which provide overlapping and unique elements):

• Ensuring that researchers obtain informed consent from participants and that participants’ rights, privacy, and confidentiality are protected
• Evaluating the potential risks and benefits of research projects and ensuring that the risks are justified and minimized
• Developing and disseminating policies, guidelines, and standards for ethical conduct in research
• Providing guidance and support to researchers, research institutions, and ECs on ethical issues related to research involving human participants
• Fostering awareness and understanding of ethical principles and regulatory requirements among stakeholders in the research community
• Conducting training programs, workshops, and seminars to educate researchers, EC members, and other stakeholders on ethical principles and best practices in research ethics
• Building the capacity of research institutions and ECs to effectively review and oversee research involving human participants
• Promoting a culture of ethical conduct and responsible research practices within the research community
• Monitoring compliance with approved research protocols and ethical standards throughout the duration of research projects
• Conducting periodic reviews or audits of research activities to ensure adherence to ethical principles and regulatory requirements
• Investigating and addressing any allegations of research misconduct or breaches of ethical standards
• Establishing guidelines for the ethical review of health research protocols for use by other review boards
• Providing advice on ethical research issues to the MoH and related government ministries and agencies
• Engaging with the public, policymakers, and other stakeholders to raise awareness of ethical issues in research and to foster dialogue on ethical considerations
• Advocating for the protection of research participants’ rights and the promotion of ethical conduct in research at the national and international levels
• Collaborating with relevant government agencies, institutions, and organizations to advance the ethical governance of research
• Establishing and maintaining a repository of all protocols reviewed in the country along with completed research/study reports

Atlantic Center for Research and Evaluation Institutional Review Board

As stated in the G-ACRE-IRB, the ACRE IRB is mandated by the Board of Directors of the ACRE Africa Center, and is tasked with ensuring quality and consistency in its review of social, behavioral, clinical, and biomedical research protocols that comply with LBR-2 and the national ethical guidelines for research on human participants. However, as noted above, per LBR-28, the ACRE IRB does not review and approve clinical trial protocols. Some members of the ACRE IRB also serve on the NREB and provide expertise in the review of clinical trial protocols.

Ethics Committee Composition

National Research Ethics Board of Liberia

According to the G-NREB, the NREB is composed of 21 members who jointly represent a diverse community with a range of expertise. The G-NREB notes that the majority of the board members are clinicians, scientists, and national subject matter experts. Per LBR-18, the NREB board typically consists of experts in various fields related to research ethics, such as medicine, public health, social sciences, ethics, law, and community representatives. Board members may include researchers, ethicists, healthcare professionals, legal experts, and representatives from government agencies and civil society organizations. LBR-38 further specifies that the NREB membership includes, but is not limited to, a sociologist, an infectious disease scientist, a biologist, a lawyer, a pharmacist, an epidemiologist, a statistician, a bioethicist, a mental health specialist, a health system strengthening specialist, a religious elder, community elders, surgeons, clinicians, and public health specialists.

In addition, per LBR-18, although the NREB organization structure may vary based on its specific mandate, size, and operational requirements, the board typically consists of a chairperson/executive director, a secretariat or administrative staff, ethics review committees/panels, and advisory groups that may provide specialized expertise or support for specific activities or initiatives.

Atlantic Center for Research and Evaluation Institutional Review Board

As specified in the G-ACRE-IRB, the ACRE IRB members (full, regular, and ad-hoc) must be recommended by the ACRE IRB Chair and appointed by the ACRE Board of Directors. The IRB Executive Committee should consist of the Coordinator, the Chair, and two (2) members of the IRB recommended by the Chair in consultation with the Coordinator. The IRB Secretariat, which will handle administrative functions, should also include the Coordinator, IT Officer, and Finance Officer.

The ACRE IRB must be comprised of 12 members with the qualifications and experience, individually and collectively, to review and evaluate the scientific, medical, and ethical aspects of research protocol submissions. The ACRE IRB membership must include the following from diverse backgrounds to undertake an impartial and adequate review of research proposals:

• Scientists (including, but not limited to, professionals in natural science, social science, and behavioral science)
• Non-scientists (health practitioners, legal experts representing the community, and civil society)

In addition, the ACRE IRB must ensure social inclusivity and gender sensitivity in its membership and in the recruitment of ad-hoc reviewers. The board must include adequate representation across age, gender, community, etc., to safeguard the interests and welfare of all segments of society. ACRE IRB members must be drawn from both public and private institutions within the country.

Terms of Reference, Review Procedures, and Meeting Schedule

National Research Ethics Board of Liberia

Pursuant to the G-NREB, the NREB follows standard operating procedures (SOPs) as well as applicable ethical guidelines and regulations to ensure compliance with research ethics principles and to uphold societal interests. The NREB may seek subject matter expert opinions regarding specific research protocols and/or ethical issues, provided that the experts have no conflict of interest, including participation in the research, financial interest in the outcome, and/or involvement in competing research, among other reasons.

NREB members should meet bi-monthly for regular meetings and adhere to the board’s threshold requirement to review a minimum of three (3) complete applications at each meeting. When applicable, the NREB director may also convene ad-hoc meetings. All complete applications submitted by the deadline must be reviewed at the next regularly scheduled meeting, if the minimum applications threshold is met. Members are encouraged to attend all meetings and the quorum required for voting is two-thirds of the NREB membership. Members who cannot attend a meeting due to unforeseen reasons must inform the NREB director two (2) weeks prior to the scheduled meeting. If unable to attend, members must also advise the NREB director regarding their views or concerns on specific agenda items one (1) week prior to a scheduled meeting. Meeting agendas and research protocols should be distributed to members no later than three (3) weeks before a regular meeting. Refer to the G-NREB and LBR-12 for detailed committee requirements.

Atlantic Center for Research and Evaluation Institutional Review Board

As delineated in the G-ACRE-IRB, the ACRE IRB Chair must be the head and chief spokesperson of the board and must conduct meetings in accordance with the policies, regulations, and timetable approved by the board. ACRE IRB members must be appointed initially for a term of three (3) years, which must be renewable and is subject to the ACRE IRB Board of Directors’ decision. To maintain continuity in ACRE IRB operations, at least one-third of the membership must be retained at any given time. The outgoing Chair must be an ex-officio member of the incoming ACRE IRB. ACRE IRB members and consultant reviewers must be provided with all relevant SOPs by the Secretariat to guide in the review process of all submitted protocols. ACRE IRB members are required to review, discuss, and consider protocols submitted to the board for evaluation to safeguard the rights, safety, and well-being of study participants; review progress reports and monitor ongoing research studies appropriately; evaluate final reports and outcomes; maintain absolute confidentiality in all document deliberations at board meetings; state conflicts of interest, where applicable; and participate during deliberations. Members with a conflict of interest will recuse themselves from the review of submissions with which they have a conflict, except to answer specific questions posed by the board. Additionally, per LBR-28, ACRE IRB reviews are conducted virtually via the Zoom platform.

G-ACRE-IRB further provides that the ACRE IRB must convene a meeting every month or when deemed necessary. The Chair, or a delegated board member, must call the meeting to order, provided there is a quorum. If there is no quorum, the meeting must be rescheduled. A quorum must be greater than 50% of the voting board members at any given event. A quorum must consist of regular and/or alternate board members (persons formally selected by the board to substitute for regular members who are unavailable), and it must include at least one (1) member whose primary background is science related, and one (1) member whose primary background is not science related. Special/independent consultants cannot be used to establish a quorum. Members who are recused from the review of a protocol cannot be used to establish a quorum. A simple majority vote of ACRE IRB members in attendance is required for a protocol to be approved. The ACRE IRB Chair may also invite individuals with competence in special areas to assist in the review of issues that require expertise beyond, or in addition to, that available on the board. These individuals will be required to sign a confidentiality agreement before they review a protocol or attend a board protocol discussion, however, they are not permitted to vote. The consultant will provide the Chair with a written report to be shared with all reviewers summarizing relevant information.

Additionally, G-ACRE-IRB indicates that during IRB meetings, all deliberations must be recorded either electronically or written manually. The Secretary should also prepare meeting minutes, which include a summary of each protocol that has been considered for approval. The IRB Chair should confirm the accuracy and completeness of the minutes by signing and archiving them, together with the meeting’s agenda and other relevant attachments. Refer to G-ACRE-IRB for detailed information on ACRE IRB administrative processes.

Overview

The NGHRP indicates that research involving human participants must be approved by an institutional ethics committee (EC) (referred to as a research ethics committee (REC) in Uganda), which must be accredited by the Uganda National Council for Science and Technology (UNCST)’s Accreditation Committee for Research Ethics Committees in Uganda (ACRECU).

Ethics Committee Composition

The NGHRP states that an EC must be composed of:

• At least five (5) members
• Individuals of varying backgrounds, including consideration of gender, cultural backgrounds, and sensitivity to social issues in the community from which research participants are drawn
• At least one (1) individual whose primary concern is scientific, and at least one (1) whose primary concern is non-scientific
• At least one (1) individual who is unaffiliated with the institution
• At least one (1) lay person from the community, whose primary background is not in scientific research involving human participants, and who is capable of sharing insights about the community from which participants are likely to be drawn

Terms of Reference, Review Procedures, and Meeting Schedule

According to the NGHRP, EC members and administrators must receive a face-to-face training in human research participant protection before initiation of EC activities, and must undergo continuous education on good research regulatory practice at least once every three (3) years. Additional training in other aspects of research ethics, such as responsible conduct of research, is desirable. An EC membership term is three (3) years, after which a member is eligible for reappointment twice. A person may not serve as a member in more than two (2) ECs concurrently.

As set forth in the NGHRP, each EC must have written standard operating procedures (SOPs), including a process to be followed for conducting reviews. The following minimum requirements must be met:

• Meet at least once every three (3) months
• Research protocols must be reviewed at convened meetings at which quorum is 50% of EC members, including at least one (1) lay member. Quorum must be maintained at all times during the meeting and at voting
• Protocol approval requires a two-thirds majority of the members present at the meeting

Additionally, the NGHRP states that the EC is obligated to respond to any allegations of ethical violations in approved or rejected research studies, liaise with other ECs within and outside the country to better carry out its functions, and submit annual performance reports to the ACRECU.

The NGHRP further indicates that no EC member may participate in the EC’s initial or continuing review of any protocol for which the member has a conflict of interest, except to provide information as may be requested by the EC. An EC may also, at its discretion, invite individuals with competence in special areas to assist in the review of protocols which require expertise beyond, or in addition to, that available in the EC. These individuals do not vote at EC meetings. See the Scope of Review section and the NGHRP for additional EC review requirements.

As per the NGHRP, an EC must also prepare and maintain documentation of their activities, including the following:

• Detailed written SOPs
• Copies of reviewed research protocols, including scientific evaluations, approved consent documents, progress reports submitted by investigators, reports of injuries to research participants, and all related documents submitted with the protocols
• Meeting minutes showing attendance, conflicts of interests declared, actions taken by the EC and the vote (including number of members voting for, against, and abstaining), the basis for requiring changes or disapproving research, and a written summary of discussions of controversial issues and their resolution. ECs will provide a summary for approved protocols to the principal investigator
• Copies of confidentiality agreements, CVs, and training records of members and the EC
• Records of approvals, suspensions, amendments, and continuing review activities
• Copies of all correspondence between the EC and investigators and/or their institutions
• Statements of significant new findings provided to research participants

Documents relating to research protocols must be retained for at least five (5) years after the research study has been completed. See the NGHRP for additional EC recordkeeping requirements.

Overview

According to G-NREB and G-ACRE-IRB, the primary scope of information assessed by ethics committees (ECs) in Liberia relates to maintaining and protecting the dignity and rights of research participants and ensuring their safety throughout their participation in a study. The NatResHlthPlcy states that Liberia has two (2) ECs: the National Research Ethics Board of Liberia (NREB) and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) (formerly the University of Liberia-Pacific Institute for Research and Evaluation Institutional Review Board (UL-PIRE-IRB)). However, per LBR-38, the NREB has sole responsibility to review all clinical trial protocols. Per LBR-28, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB.

The G-NREB and the G-ACRE-IRB also state that the ECs are responsible for ensuring independent, timely, and competent reviews of all ethical aspects of the clinical research protocol. The ECs must also act in the interests of the potential research participants and the communities involved by evaluating the possible risks and expected benefits to participants, and they must verify the adequacy of confidentiality and privacy safeguards.

Atlantic Center for Research and Evaluation Institutional Review Board

The G-ACRE-IRB is tasked with ensuring quality and consistency in the ACRE IRB’s review of social, behavioral, clinical, and biomedical research protocols that comply with the Council for International Organizations of Medical Sciences (CIOMS’) International Ethical Guidelines for Health-related Research Involving Humans (LBR-2) and the national ethical guidelines for research on human participants. (Note: While the G-ACRE-IRB includes references clinical trials, per LBR-28, due to a MOU between the NREB and the ACRE IRB in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB.) See the G-ACRE-IRB for the ACRE IRB’s research review processes and guidelines regarding initial review, protocol amendments, and oversight.

Role in Clinical Trial Approval Process

As per the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) and the NREB must approve a clinical trial application prior to the sponsor or the representative initiating the clinical trial. Per the LibCTReg and the G-LibClinTrial, the NREB and LMHRA reviews may be conducted in parallel. However, the G-LibClinTrial and the G-NREB specify that the LMHRA will only issue final approval once NREB ethical approval is obtained. In addition, per the LibCTReg and the G-LibClinTrial, any substantial amendment to the approved clinical trial research protocol must be approved by the LMHRA and the NREB before such amendments are carried out.

Additionally, per the LibCTReg, the LMHRA must inform the NREB if it has information about other clinical trials that is relevant to the board's assessment of the clinical trial on which it is to issue an expert opinion; this applies especially to information on aborted or otherwise prematurely discontinued investigations. In such instances, business and company secrets must remain confidential.

As per the G-NREB, a protocol will be reviewed if the number of submitted protocols meets the board’s threshold requirement to review a minimum of three (3) complete applications at each meeting.

As delineated in the LibCTReg, the NREB provides its opinion on a clinical trial application in accordance with its written standard operating procedures (SOPs). According to LBR-20, upon receipt of a research proposal, the NREB conducts a preliminary screening to ensure that all required documents and information are included and that the proposal meets the applicable submission requirements. Incomplete or insufficient proposals may be returned to researchers with instructions for revisions or additional information. Following a preliminary screening, an ethics review committee/panel composed of experts in relevant fields, such as medicine, public health, ethics, law, and community representatives is then assigned by the NREB. Committee members review the proposals independently or collectively, depending on the complexity of the research and the availability of resources. The ethics review committee/panel thoroughly evaluates each research proposal based on established ethical review criteria.

Per LBR-31, the NREB follows established ethical review criteria to evaluate research proposals to help ensure that research studies adhere to ethical principles and protect the rights, welfare, and dignity of research participants. The ethical criteria delineated in LBR-31 include informed consent, beneficence, justice, privacy and confidentiality, respect for participants’ rights and dignity, scientific validity and integrity, and compliance with regulatory requirements. See LBR-31 for details.

Per LBR-20, the committee members also assess the ethical implications of the proposed research, including the risks and benefits to participants, the adequacy of the informed consent process, the protection of vulnerable populations, and the equitable distribution of research burdens and benefits. The review process may involve discussions, debates, and deliberations among committee members to reach consensus on the ethical acceptability of the research proposals. See also LBR-23 for additional EC review guidelines.

LBR-20 further explains that the NREB communicates the outcomes of the ethical review process to researchers, including decisions on protocol approval, conditional approval pending revisions, or rejection. Researchers receive feedback and recommendations from the EC to address any ethical concerns raised during the review process and may be required to revise their proposals, provide additional information, or address specific ethical issues before final approval is granted.

The LibCTReg also notes that a request for clinical trial authorization from the NREB may only be refused in the following cases:

• The documents submitted are incomplete after the expiration of an appropriate deadline given to the applicant for their supplementation
• The documents submitted—including the trial protocol, the investigator’s brochure, the methods for selecting trial participants, and informed consent/assent materials—do not correspond to the current state of scientific knowledge, and particularly when the clinical trial is unsuitable for providing IP(s) proof of safety or efficacy, or
• The applicable requirements specified in the general conditions for conducting clinical trials (see Part II (Section 1) of LibCTReg) are not fulfilled

Per the G-NREB, a principal investigator (PI) will be contacted in writing (by letter or email) if the NREB determines that additional materials are required to complete its review. PIs may also be asked to be available to provide presentations and/or be contacted during the meetings. The G-NREB further explains that, where applicable, the NREB should notify PIs in writing of its decision within two (2) weeks following a board meeting, after a complete review of the protocols. The NREB will also communicate its decisions to the NREB Secretariat. An approval expiration date is not specified. Pursuant to the G-NREB, PIs may also re-submit previously considered protocols, which will require a full NREB review. Per LBR-20, once all the ethical requirements have been met, the NREB grants final approval for the research proposals to proceed.

As indicated in the G-NREB, the NREB Secretariat reviews continuing review reports submitted by the PI at least eight (8) weeks prior to the approved protocol’s expiration date. If the NREB has not reviewed and approved a continuing review request by the current expiration date, study activities should cease until the board determines whether continuation of the research is in the best interest of all previously enrolled participants. Prior to the expected NREB approval expiration date, the NREB also reviews continuing review submissions for ethical approval extension requests to continue research project implementation. See LBR-6 for the NREB Continuing Review Form. See the Progress Reporting section for additional information on continuing review.

Additionally, per LibCTReg, the NREB’s clinical trial authorization must be suspended or withdrawn if the NREB subsequently becomes aware that grounds for a refusal as referred to in the clinical trial authorization procedures (see Part II (Section 5 (1)) of LibCTReg) existed at the time the authorization was issued. The authorization must be withdrawn if the NREB subsequently becomes aware that at least one (1) of the following is true:

• Requirements regarding the suitability of the investigator, the investigator’s deputy, or the trial site are no longer fulfilled
• Trial participants are no longer properly insured or the prerequisites for an exception to the insurance obligation no longer exist
• Modalities for selecting trial participants no longer correspond to the current state of medical knowledge and, especially, the clinical trial is unsuitable for providing proof of the IP(s) safety or efficacy
• Prerequisites for the inclusion of persons pursuant to the general conditions and special preconditions for conducting a clinical trial (see Part II (Sections 1-2) of LibCTReg) are no longer fulfilled. The NREB must inform the LMHRA through written communication.

For protocol amendments, per the G-NREB, the NREB must review and approve any protocol amendments prior to implementation. The NREB secretariat must first consult with the NREB Chair to determine the type of review required (full board review or expedited review based on the risk). Protocols that pose no or minimal risk to participants, have no formal informed consent process, or are subject to NREB continuing review, may be considered exempt and may qualify for expedited review. Refer to the G-NREB for detailed information on decision types and various review processes the NREB uses to consider protocol submissions.

Additionally, the G-NREB explains that, as a condition of research protocol approval, the NREB requires the PI to provide regular updates to the Secretariat from the date of approval. LBR-20 also notes that researchers are required to report any significant deviations from the approved protocol or ethical concerns arising during the course of the research to the NREB for review and guidance. The NREB may also provide ongoing monitoring and oversight to ensure continued compliance with ethical standards and regulatory requirements. The G-NREB specifies that the NREB must conduct site visits at appropriate intervals, which may, in certain cases, be unannounced to ensure the integrity of the study.

Reviews During Public Health Emergencies

As delineated in the G-CTEmergncy, in the event a public health emergency is declared in Liberia or a neighboring country by the World Health Organization (WHO), the Ministry of Health (MoH), or the National Public Health Institute of Liberia (NPHIL), the NREB will expedite the initiation of research. During such emergencies, many processes (i.e., drafting documents, translations, and obtaining approvals) will occur in parallel, rather than sequentially, as is typical during non-emergency situations.

Per the G-CTEmergncy, in addition to the NREB review form (if applicable), the following checklist will be included to streamline fast-tracking of epidemic-related research:

• Identify the research as epidemic or outbreak-related to facilitate fast-tracking
• Specify whether prior research data on the disease exists, referencing relevant local and international studies
• Ensure the inclusion of at least one (1) (preferably two (2)) PIs or co-PIs from the country where the research and review take place
• Provide qualifications of key investigators, including details of their previous experience with outbreak-relevant research
• Indicate if the protocol is part of a multicenter trial. If so, describe the status of ethics approval for the master protocol or the ethics approval from the sponsoring country

The G-CTEmergncy indicates that the NREB will also use the following guidelines to ensure compliance during health emergencies:

• Establish surge capacity for protocol reviews and implement systems for virtual discussions (via platforms like Zoom)
• Identify core members to handle the majority of the review burden, providing specialized training in outbreak-related research review to ensure high standards without compromising ethical considerations. Additional members can be called upon as demand increases
• Ensure that the Director alerts members and determines whether they are available for emergency review
• Identify subject experts (technical and ethical) within the country and abroad who are willing to serve as ad-hoc or co-opted members during outbreaks, anticipating the need to review multiple studies in a short time
• Establish a quorum consisting of one-third of NREB members, including pre-identified subject matter experts. If a pre-identified member submits their review but cannot attend the meeting, the member will still count towards the quorum

The G-CTEmergncy further states that revised SOPs will be circulated to all review committee members. Meetings may be virtual or electronic to reduce health risks during highly infectious outbreaks (e.g., COVID-19, Ebola). Protocols should be submitted electronically for efficiency, with hard copies to follow, if mandatory. PIs must inform the NREB as early as possible of their intent to submit a high-level overview of their research (e.g., trial of a new medicine or vaccine, observational study, or survey) to prepare the committee for forthcoming protocols. Face-to-face meetings with PIs are not mandatory and may be conducted electronically or virtually, if necessary. Also, protocols will be sent to reviewers within 48 hours of submission. Reviewers should complete their reviews within five (5) days during an outbreak. The PI should receive consolidated reviews with suggestions or approval within 10 working days and should respond to the review within 48 hours. The director of the NREB secretariat will be the primary contact for communication with PIs, and all communications will be documented and archived for future reference.

Overview

In accordance with the NGHRP, the central scope assessed by institutional ethics committees (ECs) (research ethics committees (RECs) in Uganda) relates to safeguarding the rights and welfare of all trial participants. An EC’s primary functions include:

• Maintaining ethical standards of practice in research
• Protecting participants and investigators from harm or exploitation
• Preserving the participants’ rights and welfare
• Providing assurance to society of the protection of participants’ rights and welfare
• Ensuring adherence to an ethical conduct of research protocol

ECs are responsible for determining whether the objectives of a research study are responsive to the needs and priorities of the proposed target population and of Uganda in general. An EC must also pay special attention to reviewing informed consent and to protecting the welfare of certain classes of participants deemed to be vulnerable (See the Vulnerable Populations; Children/Minors; Pregnant Women, Fetuses, and Neonates; Prisoners; and Mentally Impaired sections for additional information about these populations).

Additionally, the NGHRP provides a list of the basic ethical considerations for an EC’s approval of research protocols, which includes a provision for community involvement and determining whether the methods used are scientifically valid and practically feasible. See the NGHRP for the full list of basic ethical considerations.

Role in Clinical Trial Approval Process

The NGHRP states that research approval must be obtained from the institutional EC and/or National Biosafety Committee (NBC), as applicable, prior to approval and registration with the Uganda National Council for Science and Technology (UNCST). Per the NDPA-CTReg, proof of institutional EC approval must also be submitted in a clinical trial application to the National Drug Authority (NDA). However, the G-TrialsGCP indicates that parallel submissions may be made to the NDA and the UNCST. In that instance, the NDA would not make a final decision until after the trial receives ethical clearance. NDA approval will be dependent on receipt of the protocol’s approval by the institutional EC in consultations with the UNCST. As per the NGHRP, Joint Scientific and Ethical Review (JoSER) involving the UNCST, the Uganda National Health Research Organisation (UNHRO), the NDA, and the EC, as applicable, is also available for research that involves a novel technology, product, study design, or intervention that addresses a public health need or/and emergency (see the Scope of Assessment section for more information on JoSER).

As stated in the NGHRP, the EC is obligated to review research protocols in a timely manner, within at least 60 calendar days from the date of receipt of a research protocol. In the case of annual continuing review, the EC must maintain the same anniversary date of approval for any given research protocol. Additionally, the EC must notify investigators in writing about the outcome of its review of a research protocol within 14 calendar days from the date of review. If the EC does not approve a protocol, it will include a written notification with reasons for its disapproval.

As per the NGHRP, an investigator may request a fast track/speedy review of a protocol, and the EC reserves the right to accept or reject the request. This review will occur as an extraordinary meeting of the EC, and the protocol will undergo review by the full committee. The meeting and voting will be done within 14 calendar days after submission of the protocol.

Additionally, the NGHRP indicates that the ECs may use an expedited review process for research involving no more than minimal risk or for minor changes in previously approved research protocols during a period of one (1) year or less from which approval was given. Minor changes include the addition of a collaborator or spelling corrections. Expedited review processes may also be applied to annual renewal of studies, in which the only outstanding activity is data analysis and report writing. Each EC must develop standard operating procedures to define eligibility for expedited review. Expedited review may be done by the EC chairperson and/or one (1) or more EC members and must be done within 21 calendar days. The reviewers may exercise all of the authority of the EC except that the reviewers may not disapprove the research. Major changes are not eligible for expedited review, and include, but are not limited to, changes in the research methodology or a change in study procedures. See the NGHRP for more details on expedited review procedures.

As stated in the NGHRP, studies that are low risk are eligible for exemption from EC review. The EC chairperson will screen the application to ensure that the protocol satisfies the requirements and grant exemption within seven (7) working days, as applicable. For complex and high-risk studies, the UNCST will designate ECs for review, or the ECs will refer them to the UNCST for JoSER. See the NGHRP for more information on low risk studies.

According to the NGHRP, organizations participating in a collaborative research study, which involve multiple organizations locally and/or internationally, may enter into a joint EC review arrangement. Each participating organization is responsible for safeguarding the rights and welfare of research participants and complying with the NGHRP, which may involve securing EC approvals from the foreign country prior to local EC review and approval and UNCST registration. The local EC overseeing an international collaborative research study is the EC of record. Additionally, an international collaborative research study must have a Uganda-based principal investigator (PI)/co-PI listed on the protocol, who must be employed at and/or affiliated with a recognized local organization that is relevant to the area of the proposed research. Where there is conflict between national and international policies, the Ugandan standards take precedence. The UNCST will be responsible for dialogue and harmonization if local bodies are conflicting.

The NGHRP states that investigators may, with justification, request UNCST permission to submit their protocols to another accredited EC. Where the organization of primary affiliation or host institution does not have an EC, the researchers are free to choose any accredited EC to review their research protocols. For multicenter studies in-country, a single EC will conduct a review. The organization where research is to be conducted will grant administrative clearance for the study, even if that organization has an EC. The administrative clearance, which is given by the head of the organization, must be submitted prior to UNCST approval. The clearance must clearly specify the conditions under which the research is to be conducted, including meeting minimal standards of the host institution, and any research costs such as bench or other administrative fees, which the investigator must pay. The approving EC has the primary responsibility for monitoring approved studies regardless of where they are conducted. The host institution must be made aware of the monitoring activity, including the findings. Where the host institution has an EC, joint monitoring must be conducted by the approving EC of the study and the EC of the host institution.

The NGHRP indicates that ECs must conduct continuing/periodic review of approved trials, including site monitoring visits. The EC must conduct the continuing review at intervals appropriate to the degree of risk, but not less than once a year, and have a plan for onsite monitoring of approved studies. Research monitoring will also be done off site through different data sources including annual progress reports, ethics approvals, monitoring reports, and adverse event reports. Additionally, the EC is obligated to review site assessment reports as submitted by the PI for a clinical trial. Pre-inspection will be carried out based on risk assessment at the determination of the EC.

The NGHRP further delineates that changes/amendments in the research protocol cannot be implemented without prior approval from the EC, except when necessary to eliminate an apparent immediate hazard or danger to research participants. Per the NDPA-CTReg, evidence of ethical approval of the amendment to the protocol is a required element of an application to the NDA for amendment of conditions of a clinical trial. Additionally, the NGHRP states that ECs have the authority to halt or suspend approval of research that is not being conducted in accordance with the EC’s requirements, has been associated with unexpected serious harm to research participants, or contravenes the NGHRP. Any suspension of approval must include a written statement of the reasons and requirements for the suspension to be lifted, and must be reported promptly to the investigator, host institution officials, the UNCST, and other relevant regulatory agencies.

According to the NGHRP, the UNCST acts as an arbiter for a research applicant dissatisfied with an EC decision. See the Scope of Assessment section for more information.

Note: Per LBR-38, the National Research Ethics Board of Liberia (NREB) has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

National Research Ethics Board of Liberia

As described in the G-NREB, the NREB must charge a minimal fee for the review of each submission type. Submissions include research protocols, re-submissions, amendments, and continuing reviews. The fee structure is based on the following application types: research protocol, behavioral research, investigational product (IP) (clinical trial), non-clinical trial, or waiver/exemption. Fees specifically associated with conducting a clinical trial involving IPs are based on a project’s scope, duration, sample size, and complexity, as well as the types and quantities of IPs, among other criteria. The fees delineated in the G-NREB are as follows:

• Clinical trial: $7,000 USD
• Re-submission: $1,500 USD
• Continuing Review: $1,500 USD
• Amendment: $1,500 USD

Payment Instructions

No information is currently available regarding payment instructions for the NREB.

Atlantic Center for Research and Evaluation Institutional Review Board

As per the G-ACRE-IRB, the ACRE IRB fees for protocol review other than clinical trials are as follows:

• Health, Behavioral and Education Research: $500 USD
• Re-Submission: $500 USD
• Continuing Review: $500 USD
• Amendment: $250 USD
• Foreign Student: $300 USD
• Liberian Student: $100 USD

The fee for non-sponsored research conducted by individual investigators is 50 percent of the sponsored research fee.

Payment Instructions

No information is currently available regarding ACRE IRB payment instructions for protocol review other than clinical trials.

No applicable requirements.

Overview

There are no applicable regulations or guidance regarding the authorization of ethics committees (ECs) in Liberia. However, per G-NREB, the National Research Ethics Board of Liberia (NREB) is responsible for maintaining a registry of health research ECs and mitigating conflicts among ECs, researchers, and research entities.

Registration, Auditing, and Accreditation

No information is currently available on registration, auditing, and accreditation requirements.

Overview

As delineated in the NGHRP, the Uganda National Council for Science and Technology (UNCST) is the central statutory body responsible for the accreditation of institutional ethics committees (ECs) (research ethics committees (RECs) in Uganda).

Registration, Auditing, and Accreditation

As per the NGHRP, the UNCST’s Accreditation Committee for Research Ethics Committees in Uganda (ACRECU) must accredit all ECs. An organization that wishes to establish an EC must apply for accreditation of the EC at the UNCST, with assurance that the organization will comply with the requirements set forth in the NGHRP. At a minimum, the assurance must include:

• A statement of principles for protecting the rights and welfare of human research participants. This may include an existing code, declaration, or statement of ethics principles, or a statement formulated by the organization itself
• Assurance of availability of staff, office, and meeting space for the EC, as well as sufficient resources to support the EC’s operations
• A list of EC members appointed by the head of the organization or the head’s designee. The members must be identified by name, qualifications, profession, institution of affiliation, and designation on the EC
• Standard operating procedures for the EC

The NGHRP indicates that the ACRECU will review the organization’s application, and if satisfied, will accredit the EC. An EC is not permitted to commence its activities until it has been accredited. Additionally, the EC is obligated to prepare and submit annual reports of EC performance to the ACRECU.

Per UGA-33, the National Research Information Management System (NRIMS) (UGA-33) supports users in applying for accreditation as an institutional EC. See UGA-9 for the accreditation application form and the NGHRP for details on EC establishment requirements. A list of UNCST-accredited ECs is also available at UGA-37.

Overview

In accordance with the LibCTReg and the G-LibClinTrial, the sponsor, the legal representative, the principal investigator (PI), or the sponsor-investigator is required to submit a clinical trial application to the Liberia Medicines and Health Products Regulatory Authority (LMHRA) and obtain written permission from the National Research Ethics Board of Liberia (NREB) to be granted authorization to conduct a clinical trial in Liberia. However, per the G-NREB, the PI must obtain ethics committee (EC) approval. The LibCTReg and the G-LibClinTrial state that the NREB and LMHRA reviews may be conducted in parallel. Per the G-LibClinTrial and the G-NREB, the LMHRA will only issue final approval once NREB approval is obtained.

Regulatory Submission

As indicated in the LibCTReg and the G-LibClinTrial, the sponsor or the representative should submit the application form and associated documents along with the prescribed fee. Also, per the G-LibClinTrial, four (4) sets of the application should be submitted both electronically and as printed copies to the LMHRA. The clinical trial application and any accompanying material must be submitted in English. If the documents are written in another language, a certified translation is required. Per LBR-29, the sponsor's representative must also submit a power of attorney attesting that the representative is a duly appointed agent.

Additionally, per the LibCTReg and the G-LibClinTrial, any substantial amendment to the approved clinical trial documentation, trial arrangements, or the investigational product must be submitted by the applicant to the LMHRA and the NREB, together with the prescribed fee, for the evaluation and authorization related to such amendment. Per the G-LibClinTrial, the submitted amendment(s) must be indicated in a signed cover letter that specifies the clinical trial and the sponsor (applicant), and must describe the possible consequences for clinical trial participants already enrolled in the trial as well as the possible consequences for the evaluation of the results. The amendment(s) must also be described in a completed Clinical Trial Amendment form (Annex 2 of the G-LibClinTrial). The amended documents should include updated version numbers and dates. In addition, the submitted documents should clearly present scientific arguments justifying the classification of the amendment to the LMHRA and the NREB, and, where applicable, supporting information must be included with the submission.

Per the G-LibClinTrial, the signed cover letter and clinical trial application dossier should be sent to the following:

The Managing Director
Liberia Medicine and Health products Regulatory Authority (LMHRA)
2^nd & 3^rd Floors Clay Building
Sekou Toure Avenue
Mamba Point
Monrovia, Liberia

Ethics Review Submission

Note: Per LBR-38, the NREB has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

National Research Ethics Board of Liberia

As delineated in the LibCTReg, application submissions to the NREB must include all of the information and documents as required for the board’s opinion. According to the G-NREB, PIs must submit typed, dated, and signed submissions electronically and in hard copy to the NREB. The documents should be formatted in standard 12-point font, double-spaced, with the pages printed on one (1) side only. The NREB requires 15 comb-bound copies of the complete research protocol, along with the attachments listed in the G-NREB, and where applicable, an email version that includes the protocol title and the PI’s name. All protocols must also be numbered appropriately and separately from all other supporting documentation (e.g., letters, participant information sheets and consent forms, questionnaires, curriculum vitae(s) (CVs), etc.). Supporting documents should also be numbered separately. Refer to LBR-32 for the NREB Research Protocol Template.

In addition to protocol submission requirements, the G-NREB also specifies that the PI should submit the complete application for ethical review and approval of a proposed health research study to the NREB Secretariat three (3) weeks prior to the next NREB meeting. Applications submitted by a PI and researchers from foreign institutions must also include a local (resident) Liberian researcher on the research team as well as support letters and CV(s). See the G-NREB for detailed application submission requirements.

Per the G-NREB, NREB submissions should be submitted to the following address:

Director
National Research Ethics Board of Liberia (NREB)
First Floor West, John F. Kennedy Medical Center
Monrovia, Liberia
Email: nreb.liberia.gov@gmail.com

As delineated in the G-CTEmergncy, during a public health emergency in Liberia or in a neighboring country, the NREB requires protocols to be written in English and include, at a minimum, the proposed study, the corresponding ethics approval, consent or assent forms, and data collection tools and forms. In addition, along with the standard documents for review (protocols, CVs, Human Subject Protection Certificates, Good Clinical Practice, etc.), the following must be submitted:

• A collaboration letter (in the form of an MOU) with sponsor institutions and research funders, including declarations of interest, when possible
• A monitoring and safety management plan for the project provided by the PI and the study sponsor
• Data-sharing and material transfer agreements for data and biological materials, especially if samples will be exported out of the country, to ensure compliance with the Laws of Liberia (a draft version may be submitted initially)
• Clear procedures for dissemination, publication, co-authorship, co-presentation, and intellectual property rights
• Plans to disseminate findings to the affected community, to ensure continued engagement and trust, especially among research participants
• Depending on the type of research, a local insurance policy for trials and interventions may be required

Atlantic Center for Research and Evaluation Institutional Review Board

As indicated in the G-ACRE-IRB, PIs are required to submit the research protocol as part of an application packet that includes the documentation specified by the ACRE IRB submission form (see Article XXV in the G-ACRE-IRB). According to LBR-28, the ACRE IRB has not reinstated the requirement for PIs to submit eight (8) hard copies of the protocol. Applications should be submitted electronically. See the Submission Content section for additional documentation requirements.

Per the G-ACRE-IRB, all research proposals are to be submitted (either via electronic mail or in person) to:

The IRB Coordinator
Atlantic Center for Research and Evaluation (ACRE)
Ground Floor, Graduate School Building
University of Liberia
Capitol Hill
Monrovia, Liberia

Per LBR-28, proposals submitted electronically should be sent to ulpireirb@gmail.com and smithedwardg@yahoo.com, in copy.

Overview

According to the NDPA-CTReg, the G-CTConduct, the NGHRP, and the G-TrialsGCP, institutional ethics committee (EC) (research ethics committee (REC) in Uganda) approval, National Drug Authority (NDA) approval, and Uganda National Council for Science and Technology (UNCST) registration are mandatory before a study may commence.

The NGHRP states that research approval must be obtained from the institutional EC and/or National Biosafety Committee (NBC), as applicable, prior to approval and registration with the UNCST. Per the NDPA-CTReg, proof of institutional EC approval must also be submitted in a clinical trial application to the NDA. However, the G-TrialsGCP indicates that parallel submissions may be made to the NDA and the UNCST. In that instance, the NDA would not make a final decision until after the trial receives ethical clearance. NDA approval will be dependent on receipt of the protocol’s approval by the institutional EC in consultations with the UNCST. As per the NGHRP, Joint Scientific and Ethical Review (JoSER) involving the UNCST, the Uganda National Health Research Organisation (UNHRO), the NDA, and the EC, as applicable, is also available for research that involves a novel technology, product, study design, or intervention that addresses a public health need or/and emergency (see Scope of Assessment section for more information on JoSER).

Regulatory Submission

National Drug Authority

According to the NDPA-CTReg, an application to the NDA for authorization to conduct a clinical trial is submitted by a sponsor, who must be one (1) of the following:

• The drug patent holder
• A licensed person
• The drug manufacturer
• An agent of the drug patent holder or the drug manufacturer

The NDPA-CTReg states that where an agent submits the clinical trial application, the agent must also submit a power of attorney verifying their appointment as an agent or a letter of authorization (See Form 30 in Schedule 1 of the NDPA-CTReg or UGA-18). Where an application for authorization to conduct a clinical trial is for a drug under patent, the principal investigator (PI) must submit a letter of authorization from the manufacturer of the drug. Furthermore, the G-CTConduct indicates that based on the clinical trial agreement between the sponsor and the PI, the NDA will liaise with the in-country PI representing the sponsor regarding the application.

As per the G-CTConduct, the sponsor or authorized person should submit one (1) copy of the completed clinical trial application form for each application. The application must be bound in a single volume (or series of volumes), and the pages numbered sequentially. Appended documents should be bound together with the application, with tabbed sections clearly identifying each appended document. The text and diagrams must be clear and legible in 12 pt Times New Roman font. Incomplete submissions will not be received at the NDA registry. See Form 29 in Schedule 1 of the NDPA-CTReg, Appendix I of the G-CTConduct, or UGA-39 for the clinical trial application form.

According to the G-CTConduct, the application package should be submitted physically to the NDA or electronically. Electronic submissions should be sent by email to clinicaltrials@nda.or.ug or through the NDA’s integrated Regulatory Information Management System (iRIMS) (UGA-40). Physical applications must be submitted to:

The Secretary to the Authority
National Drug Authority
NDA Tower
Plot 93, Buganda Road
P.O. Box 23096
Kampala, Uganda
Phone: +256-417788100; Toll Free: 0800101999

As per the G-CTConduct, all applications and supporting data submitted to the NDA should be presented in English. Supporting documents that are not in English must be accompanied by an authenticated English translation.

The NDPA-CTReg and G-CTConduct further indicate that an application to amend the conditions of a clinical trial must use Form 35, in Schedule 1 of the NDPA-CTReg and Appendix III of the G-CTConduct. The G-CTConduct also notes that that the form is on the NDA website (see UGA-19). Per the G-CTConduct, the proposed changes must be listed in a cover letter signed by the applicant. In the cover letter, a clear step-by-step justification for each proposed change(s) must be provided, and the possible consequences with regard to the benefit/risk balance for participants already enrolled in the trial must be summarized. The subject of the cover letter must be “Application to amend CTA XXX” where XXX is the Clinical Trial Application code assigned by the NDA upon authorization of the clinical trial and indicated on the clinical trial certificate. Only one (1) copy of the completed form must be sent to the NDA. As stated in the NDPA-CTReg, an application for additional investigators, additional clinical trial sites, or change of the investigators must use Form 36 in Schedule 1 of the NDPA-CTReg or UGA-13. The application forms must, where applicable, be accompanied by evidence of ethics approval of the amendment to the clinical trial protocol and the prescribed fees. Applicants may apply for renewal of a clinical trial approval using the form found in Appendix VIII of the G-CTConduct or on the NDA website at UGA-32. See Appendix VI of the G-CTConduct for the Checklist for Application for Authorization of Renewal of Conduct of a Clinical Trial, and UGA-2 for a related clinical trial application screening renewal form.

Uganda National Council for Science and Technology

Applications for UNCST permission to conduct research in Uganda should be made through the National Research Information Management System (NRIMS) (UGA-33). Per UGA-33, NRIMS is an integrated online platform for accessing digital services provided by the UNCST. The platform supports users in applying for institutional EC permits and applying for UNCST approval to conduct research in Uganda. See UGA-33 for more information.

UGA-20 also provides the following contact information for further information on the UNCST research clearance process:

Beth Mutumba
Phone: 0414 557 025/0755 423 321
Email: b.mutumba@uncst.go.ug

Samuel Barasa
Phone: 0414 557 021/0779 452 441
Email: s.barasa@uncst.go.ug

Ethics Review Submission

UGA-20 indicates that for EC submissions, the applicant should contact the accredited committee at their institution of affiliation or obtain contacts via the UNCST website. After identifying the appropriate EC, the applicant must create an account and fill out the application on NRIMS (UGA-33).

Each EC has its own required submission procedures, which can differ regarding the application format and number of copies. According to the NGHRP, all ECs must develop standard operating procedures for submission of protocols and other requirements.

Regulatory Authority Requirements

As set forth in the LibCTReg and the G-LibClinTrial, the sponsor, the legal representative, the principal investigator (PI), or the sponsor-investigator is required to submit the following documentation to the Liberia Medicines and Health Products Regulatory Authority (LMHRA) (Note: Each of the items listed below will not necessarily be found in both sources, which provide overlapping and unique elements):

• Cover letter (signed, witnessed, and notarized) including list of documents submitted and their version numbers and date
• Clinical trial application form, including cover page
• Clinical trial protocol (see below for detailed protocol requirements)
• A list of the planned clinical trial sites and the planned number of study participants to be recruited at the sites located in Liberia
• Details of the site(s) where the trial is to be conducted, and a duly justified written statement on the suitability of the clinical trial sites adapted to the nature and use of the investigational product (IP) and including a description of the suitability of facilities, equipment, human resources, and description of expertise, issued by the head of the clinic/institution at the trial site or by some other responsible person
• Participant information sheet, informed consent form(s) (ICF(s)) or video(s), or assent form(s) in case of minor(s) or persons under legal disability who are to participate in the trial, and informed consent procedures for clinical trials in humans
• Product information for registered IPs (e.g., summary of product characteristics, patient information leaflet/package insert, and labelling)
• Investigator’s Brochure (IB) containing relevant chemical, pharmaceutical, pre-clinical pharmacological and toxicological data, and where applicable, human or animal pharmacological and safety and efficacy clinical data about the IP
• If applicable, synopsis of previous trials with the IP(s)
• If applicable, electronic copies of key, peer-reviewed publications following the International Committee of Medical Journal Editors (ICMJE) recommendations to support the application
• Copies of recruitment advertisement(s), if applicable, and questionnaires
• Investigational medicinal product (IMP) dossier, if applicable
• Product information and certificate of analysis (CoA) for concomitant and rescue medications
• Good Manufacturing Practice (GMP) certificate issued from the national regulatory authority of the country where the IP is manufactured, translated into English
• CoA of the IP(s)
• Certificate(s) of accreditation for the central laboratories
• Workload forms for investigators
• Signed declaration by the applicant (including a commitment to adhere to the ethical principles outlined in the Declaration of Helsinki (LBR-27) and the International Council for Harmonisation (ICH)’s Guideline for Good Clinical Practice E6(R2) (LBR-8))
• Signed declaration by the national PI
• Signed curriculum vitae (CV) for all key staff participating in the conduct of the clinical trial (e.g., PI and/or co-investigators, study coordinator, regional and local monitor, contract research affiliate, etc.)
• Signed declaration(s) by each investigator(s)
• Signed joint financial declaration between the sponsor and the PI
• Signed declaration by the sub-investigators and key staff participating in the trial
• Signed declaration by the regional clinical trial monitor(s)
• Signed declaration by the sponsor/sponsor-investigator
• Proof of registration with the Pan African Clinical Trials Registry (PACTR) (LBR-36) or another World Health Organization (WHO) Primary Registry (LBR-35)
• Active clinical trial insurance for Phase I, II, and III trials
• Evidence of insurance coverage for prospective participants
• Proof of sponsor indemnification for investigators and trial site
• Good Clinical Practice (GCP) certificates for the investigators
• Proof of registration of the key investigators with a professional statutory body, if applicable
• Proof of residence in Liberia for the PI
• Proof of professional indemnity (i.e., malpractice insurance)
• Study budget
• In case of parallel submission, proof of submission of the clinical trial application to the National Research Ethics Board of Liberia (NREB)
• The written permission of the NREB in case of sequential submission, and in case of parallel submission, the updated versions of documents or information as requested by the NREB, for the conduct of the clinical trial, if applicable
• Information on the composition of the Data and Safety Monitoring Board (DSMB)—including the list, terms of reference, and CVs for its members—justifying their expertise as members of the DSMB
• Summary of product characteristics or other professional information for all registered medicines used in the trial, or the international equivalent if the medicines are not registered in Liberia
• Registered IPs should include the registered indication or registered dosage regimen
• Recruitment arrangements
• Request for authorization of export of biological samples out of Liberia as well as the respective material transfer agreement (MTA), if applicable
• Summary of the clinical trial (100-150 words) to be made publicly available on the LMHRA website
• Proof of payment of the appropriate application fee

Refer to the LibCTReg and the G-LibClinTrial for detailed application requirements and expedited application documentation requirements.

The LibCTReg also notes that in the case of emergency situations, the LMHRA may also make exemptions to the documentation requirements for the submission of clinical trial applications. Refer to 2.3 of the G-LibClinTrial for additional information on how to submit an expedited clinical trial application package.

Ethics Committee Requirements

Note: Per LBR-38, the NREB has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

National Research Ethics Board of Liberia

As indicated in the G-NREB, for clinical trials and biomedical/epidemiological study submissions, the following documents may be included, but are not limited to:

• Full protocol and executive summary (refer to LBR-32 for research protocol template)
• Sponsor’s protocol, if applicable (per LBR-32)
• Signed agreement between sponsors and PI, where applicable
• A statement that the researcher(s) agree to comply with ethical principles set out in relevant guidelines
• IB
• MTA for shipment of specimen(s)/biological material(s) outside of Liberia, where applicable (See also Specimen Import & Export and Consent for Specimen sections)
• Data Sharing Agreement, where applicable
• Administrative information on study sponsors
• Signatory page of key persons from the collaborative institutions involved in the study (i.e., Sponsor Signatory Approval Page duly signed, with date, where applicable)
• Written ICF with dates and version number and translations into the local language, where necessary
• Written parental consent form for children under 17 years of age (if study involves minors)
• Written parental consent form and assent form for children under 18 years of age (15-17 years) (if study involves adolescents)
• All forms, documents, and community engagement advertisements to be used in the recruitment of potential participants
• All data collection forms to be used in the research including, but not limited to, case report forms, questionnaires, interview schedules, etc., clearly indicated and dated
• Referral forms for treatment, where applicable
• Study budget
• Study timeline
• Any other information deemed necessary to facilitate the review process
• Current CV(s) of PI and co-investigator(s), if not submitted to the NREB in the preceding 12 months
• Profile on previous study (i.e., Phase I & Phase II studies, where applicable)
• Investigator Agreement (PI’s responsibility), page duly signed with name and date, and current Certificate of Training in GCP for PI(s)
• DSMB membership and charter of work/current member CVs
• Insurance coverage for study participants
• Scientific review approval
• LMHRA approval letter for use of the IPs/devices and clinical trial approval (this should be submitted after the NREB approval)

Atlantic Center for Research and Evaluation Institutional Review Board

Per the G-ACRE-IRB, the following documentation must be submitted along with the application for an initial application review of a protocol for clinical research other than a clinical trial:

• Cover letter
• Protocol summary (Article XXV (Section 25.02) in the G-ACRE-IRB)
• Protocol and/or amendments (including data collection instruments, surveys, tests, questionnaires, debriefing information, etc.)
• IB, where applicable
• Evidence of submission and/or approval from other ECs, where applicable
• Proof of research ethics training (i.e., certificate in human subject protection) by research team members
• ICFs, where applicable
• Questionnaires and other study instruments, where applicable (including interview schedules, recruitment and interview scripts, and recruitment materials (Article XXV (Section 25.02) in the G-ACRE-IRB)
• DSMB and Institutional Biosafety Committee (IBC) records, if applicable
• MTA, if applicable (See also Specimen Import & Export and Consent for Specimen sections)
• Status report for ongoing study (applicable for continuing review)
• Letter of collaboration or support with collaborating entity/researcher(s), if applicable
• Capacity building plan for collaborating agency/researcher, if applicable
• Investigator(s) CVs
• Social corporate responsibility plan for communities, if applicable
• Letter from an appropriate official permitting research activities on their premises, if the research/recruitment will take place in or through schools, businesses, care facilities, or other organizations
• Budget

Clinical Protocol

Liberia Medicines and Health Products Regulatory Authority

Per the G-LibClinTrial, the contents and format of the clinical trial protocol should follow the requirements laid down in LBR-8. Refer to LBR-8 for detailed protocol guidelines.

In addition, as indicated in the G-LibClinTrial, the protocol should contain a statement indicating that the trial will be conducted in compliance with the protocol, GCP, and the applicable regulatory requirements, and signed and dated by both the sponsor/sponsor’s representative and the PI to document the their agreement to the protocol. If the protocol is not signed and dated by both parties, a corresponding declaration that is signed and dated by both must be submitted to the LMHRA with the application.

National Research Ethics Board of Liberia

The LBR-32 requires the following elements to be included in the research protocol template submission:

• Specific aims
• Background and significance of research
• Research locations and collaborating sites
• Study team
• Study design
• Recruitment methods
• Consent process
• HIPAA privacy protections
• Vulnerable populations
• Risks
• Benefits
• Participant privacy
• Data confidentiality
• Data/statistical analysis plan
• Costs and compensation
• Sharing study results
• Research related injuries
• Reportable events
• Regulatory compliance
• Data or specimen banking (repositories)
• Clinical trials
• Device, if applicable
• Drug/biologic

National Research Ethics Board of Liberia/Atlantic Center for Research and Evaluation Institutional Review Board

Per the NatResHlthPlcy, Liberian ECs including the NREB and the ACRE IRB, should structure the research protocol according to the follow format:

• Title
• Investigators’/researchers’ information including contact addresses
• Abstract/summary
• Background/Introduction
• Aims and objectives
• Study design and methods
• Data collection, management, and analysis
• Study administration and ethical issues
• Resource requirements
• Study plan
• Supervision
• Dissemination and outcome

For more details, see Annex 2 of the NatResHlthPlcy.

Atlantic Center for Research and Evaluation Institutional Review Board

According to the G-ACRE-IRB, the clinical research protocol should contain the elements included in the ACRE IRB submission form (see Article XXV in the G-ACRE-IRB). The initial protocol submission should also contain:

• Original protocol (including cover sheet, abstract, and research section including the Human Subjects Section)
• Application letter
• ICF and/or assent form
• Sample questions survey
• Investigator(s) CVs
• Qualification of study site(s)
• Protocol budget
• Copy of ACRE IRB approval, if available
• Study design
• Study participation, including informed consent procedures and content/language and participant information sheet content (See also the Documentation Requirements section)

Note: Per the G-ACRE-IRB, for regular renewal or interim modification reviews of a protocol, PIs should attach current consent document(s) and include instruments ONLY if changes are being proposed (Article XXV (Section 25.02) in the G-ACRE-IRB).

Regulatory Authority Requirements

National Drug Authority

As per the NDPA-CTReg, the G-CTConduct, the NGHRP, UGA-39, and UGA-1, the following documentation must be submitted to the National Drug Authority (NDA) in a clinical trial application (Note: Each of the items listed below will not necessarily be found in all sources, which provide overlapping and unique elements):

• Proof of payment of the prescribed fees
• Applications for import and/or export of biological materials (if required)
• Application Form for Clinical Trial (See Form 29 in Schedule 1 of the NDPA-CTReg, Appendix I of the G-CTConduct, or UGA-39)
• Trial protocol (See Schedule 2 of the NDPA-CTReg)
• Investigator’s Brochure (See UGA-4 or Schedule 2 of the NDPA-CTReg)
• If the investigational product (IP) is unregistered, a dossier following the Format for Investigational Medicinal Product Dossier (See Schedule 2 of the NDPA-CTReg)
• Phytochemical analysis report and microbiological contamination report, where the clinical trial is for an herbal medicinal product
• Participant Information Leaflet and informed consent form, which must be approved by the ethics committee (EC) (research ethics committee (REC) in Uganda)
• Certificate of Good Manufacturing Practice (GMP) of the IP or other evidence of manufacturing quality, safety, and consistency
• GMP certificate of the facility where the drug was manufactured
• Package insert(s)/product information leaflet for the comparator and concomitant medications
• Certificate of GMP of the placebo, if appropriate
• Evidence of accreditation of the designated laboratories or other evidence of Good Laboratory Practice (GLP) and assay validation
• Insurance certificate specific for the trial sourced from a local provider or in consultation with the NDA (valid evidence of insurance for the participants by a local insurance company and of professional indemnity for the principal investigator (PI))
• Signed and completed declarations by all investigators (See UGA-16 or Form 31 in Schedule 1 of the NDPA-CTReg)
• Approval of ECs for the protocol
• Uganda National Council for Science and Technology (UNCST) approval
• Authorization of the clinical trial from the country of origin, if applicable
• Full, legible copies of key, peer-reviewed published articles supporting the application
• Relevant published literature on the drug
• Sample of the label for the IP
• Letter of authorization from the manufacturer/product owner (See UGA-18 or Form 30 in Schedule 1 of the NDPA-CTReg)
• Pharmaceutical data on dosage form (See UGA-14)
• Duly signed declaration of the monitor (See UGA-17 or Form 32 in Schedule 1 of the NDPA-CTReg)
• Clinical trial agreement between the sponsor and the PI
• Duly signed declaration by the sponsor and PI of funds of the clinical trial (See UGA-15 or Form 33 in Schedule 1 of the NDPA-CTReg)
• Other supporting documents and any other requirement, as may be determined by the NDA

See Appendix II of the G-CTConduct and UGA-1 for the clinical trial application checklist.

The C-InstitutionCert further indicates that clinical trial certificates will not be issued without submission of a valid certificate of suitability of the premises supplying drugs within the respective institutions.

Applicants may apply for renewal of a clinical trial approval using the form found in Appendix VIII of the G-CTConduct or on the NDA website at UGA-32. See Appendix VI of the G-CTConduct for the Checklist for Application for Authorization of Renewal of Conduct of a Clinical Trial, and UGA-2 for a related clinical trial application screening renewal form.

As per the NDPA-CTReg, an application to amend the conditions of a clinical trial must use Form 35, and an application for additional investigators, additional clinical trial sites, or for change of the investigators must use Form 36 in Schedule 1 of the NDPA-CTReg or UGA-13.

According to the G-CTConduct, an application for amendment of the conditions of a clinical trial can also be found in Appendix III of the G-CTConduct and on the NDA website at UGA-19. The amendment application must be accompanied by a cover letter signed by the applicant together with required supporting documentation, including a submission of the protocol amendment in tracked changes, a clean copy clearly indicating the protocol version number, valid evidence of payment of amendment fees, and ethical approval of the proposed amendment. See the NDPA-CTReg, G-CTConduct, and UGA-19 for more detailed amendment application content requirements. See Appendix V of the G-CTConduct or UGA-22 for the amendments screening form.

Uganda National Council for Science and Technology

As per the NGHRP and UGA-20, the following documents must be submitted to the UNCST (Note: Each of the items listed below will not necessarily be found in both sources, which provide overlapping and unique elements):

• Approved protocol by an accredited EC, including an approval letter and a summary from the meeting that approved the study
• Research forms
• A letter of introduction or recommendation from the affiliated institution in Uganda (for foreign investigators only). The letter should mention the names of the foreign investigators and it should be addressed to the UNCST Executive Secretary
• An administrative clearance letter from the head of the institution where the research is going to be conducted, addressed to the PI and/or the UNCST Executive Secretary
• Admission letter for academic research (applies to only East African students)
• Curriculum vitaes (CVs) for each investigator, dated and signed or initialed on each page
• Proof of payment of research administration and clearance fees for the study

As stated in the NGHRP, investigators must file a copy of the NDA certificate authorizing the importation and/or use of the trial drug in Uganda with the UNCST. See the NGHRP and UGA-20 for detailed application requirements.

Ethics Committee Requirements

The NGHRP further indicates that all ECs must develop standard operating procedures for submission of protocols and other requirements. However, at a minimum, the requirements must include:

• Research protocol with version and date
• A site-specific implementation plan for multi-site/multicenter studies
• Study instruments such as questionnaires, case report forms, videos, flip charts, data abstraction forms, and any other data collection tools or forms
• Samples of trial drugs
• Informed consent documents in English and relevant local language (where applicable)
• Data sharing and use agreement (where applicable)
• Material transfer agreement (where applicable)
• Evidence that the investigator(s) and team are appropriately qualified, experienced and, where applicable, licensed, and have adequate facilities for the safe and efficient conduct of research
• For foreign investigators, copies of work permits (where applicable)

As stated in the NGHRP, investigators must file a copy of the NDA certificate authorizing the importation and/or use of the trial drug in Uganda with the relevant EC.

Clinical Protocol

As delineated in Schedule 2 of the NDPA-CTReg and UGA-12, the clinical protocol submitted to the NDA should contain the following information (Note: Each of the items listed below will not necessarily be found in both sources, which provide overlapping and unique elements):

• General information (trial identification; contact information of sponsor, monitor, sponsor’s medical expert, and qualified physician; name and title of investigator(s); name(s) and address(es) of clinical trial laboratory(ies) and other medical and/or technical department(s)/institutions involved in the trial; etc.)
• Background information (product name, dosage form, description of population to be studied, etc.)
• Trial objectives and purpose
• Trial design
• Selection and withdrawal of participants
• Treatment profile
• Trial parameters
• Assessment of efficacy
• Assessment of safety
• Operational aspects
• Adverse event reporting methods
• Evaluation of results, including statistics
• Direct access to source data/documents
• Quality control and quality assurance
• Description of ethical considerations relating to the trial
• Data handling and recordkeeping
• Financing and insurance, if not addressed in a separate agreement
• Publication policy, if not addressed in a separate agreement
• Supplements/appendices

For detailed information on these elements, please refer to the NDPA-CTReg and UGA-12.

The NGHRP indicates that the research protocol, with version and date, submitted to an EC should include the title and list of investigators, summary/abstract, background to the study, problem statement, significance, justification, objectives, literature review, methodology, workplan, dissemination plan, community engagement plan, data sharing and ownership (where applicable), environmental impact assessment (where applicable), budget, and references/bibliography. See Annex IV of the NGHRP for a list of items to be considered for inclusion in a protocol.

Overview

According to the LibCTReg and the G-LibClinTrial, the National Research Ethics Board of Liberia (NREB) and the Liberia Medicines and Health Products Regulatory Authority (LMHRA) reviews may be conducted in parallel. However, per the G-LibClinTrial and the G-NREB, the LMHRA will only issue final approval once NREB approval is obtained.

Regulatory Authority Approval

The LibCTReg and the G-LibClinTrial state that the LMHRA must inform an applicant in writing about the outcome of an assessment of a clinical trial application within a maximum of 45 working days for pharmaceutical investigational products (IPs); 60 working days for biological and biotechnology IPs; and 90 working days for genetically modified organisms. However, the G-LibClinTrial also indicates that the LMHRA must inform the applicant within a maximum of 60 working days.

As indicated in the LibCTReg and the G-LibClinTrial, upon receipt of a clinical trial application, the LMHRA screens the application package for completeness and must inform the applicant in writing about the validity of the application or the formal grounds for non-acceptance of the application within 10 working days of application receipt. If applicable, the applicant, in turn, must address formal grounds for non-acceptance within 10 working days. These timelines exclude time taken for the applicant to respond to queries from the LMHRA during the review and decision process. If changes are required and the applicant fails to modify the application within a maximum of 30 working days, the application will be rejected.

Additionally, the G-LibClinTrial further notes that if the LMHRA requires changes to the application, and the applicant fails to modify the application within a maximum of 90 days, the application will be rejected.

As explained in the G-LibClinTrial, upon approval of the application, the LMHRA must issue a clinical trial certificate to the applicant that includes the LMHRA clinical trial number. The clinical trial certificate may contain conditions required by the LMHRA with respect to the conduct or reporting of the trial. If the application is rejected, the applicant can submit a written appeal to the LMHRA’s Managing Director within 60 days of receipt of the rejection notice.

Per the G-LibClinTrial, in the case of expedited clinical trial application reviews, the LMHRA will review the application within no more than 14 working days for approved products and within 21 days for new products.

Additionally, per the G-LibClinTrial, the LMHRA must respond to any substantial clinical trial amendment within 20 calendar days upon receipt of the written decision from the NREB.

Ethics Committee Approval

Note: Per LBR-38, the NREB has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

National Research Ethics Board of Liberia

Pursuant to the G-NREB, principal investigators (PIs) are required to submit new research protocols no later than one (1) month prior to the next bi-monthly board meeting. The NREB should notify PIs in writing of its decision within two (2) weeks following a board meeting, where applicable, following a complete review of the protocols. The G-NREB does not specify an approval expiration date.

The G-NREB explains that for protocol amendments, the NREB Secretariat, in consultation with the Chair, will make a determination regarding the type of review (full board review or expedited based on the risk) and will notify the investigator within three (3) weeks upon submission per the board’s decision. Expedited reviews must take no more than three (3) weeks, and if any committee member raises a concern about a protocol that was expedited, the protocol must undergo a full board review.

Refer to the G-NREB for additional information on the various submission types that may be submitted to the board and their corresponding review and approval processes.

Atlantic Center for Research and Evaluation Institutional Review Board

As specified in the G-ACRE-IRB, PIs are required to submit all application materials to the ACRE IRB four (4) weeks in advance of the date that a decision is requested. In the case of full review studies, submission is required four (4) weeks prior to the next scheduled ACRE IRB meeting. The ACRE IRB will convene a special meeting, if necessary, to accommodate the PI’s compliance with an external funding deadline; however, submission is required four (4) weeks prior to the special meeting date.

No timeline of review is specified for the ACRE IRB’s review. However, the G-ACRE-IRB states that the clinical research protocol and accompanying documents are approved as they are submitted. Approval will commence on the day the study is approved and will expire within a defined time period based on a risk assessment and regulations. If specific conditions are stipulated in the approval letter, those conditions must be met by the designated date or approval may be withdrawn.

The G-ACRE-IRB states that the ACRE IRB must also review and approve any clinical research protocol amendments prior to those changes being implemented. The clinical research protocol submission is reviewed either via expedited procedures (for minor changes) or via full board review (for all other changes). Refer to the G-ACRE-IRB for clinical research protocol amendment documentation submission and procedural requirements.

Overview

The NGHRP states that research approval must be obtained from the institutional ethics committee (EC) (research ethics committee (REC) in Uganda) and/or National Biosafety Committee (NBC), as applicable, prior to approval and registration with the Uganda National Council for Science and Technology (UNCST). Per the NDPA-CTReg, proof of institutional EC approval must also be submitted in a clinical trial application to the National Drug Authority (NDA). However, the G-TrialsGCP indicates that parallel submissions may be made to the NDA and the UNCST. In that instance, the NDA would not make a final decision until after the trial receives ethical clearance. NDA approval will be dependent on receipt of the protocol’s approval by the institutional EC in consultation with the UNCST. As per the NGHRP, Joint Scientific and Ethical Review (JoSER) involving the UNCST, the Uganda National Health Research Organisation (UNHRO), the NDA, and the EC, as applicable, is also available for research that involves a novel technology, product, study design, or intervention that addresses a public health need or/and emergency (see the Scope of Assessment section for more information on JoSER).

Regulatory Authority Approval

National Drug Authority

Per the G-CTConduct, NDA reviews for clinical trials are performed following a first-in first-out principle, except for clinical trials conducted in public health emergencies such as disease outbreaks, which may be exempted.

According to UGA-24, the NDA will screen and acknowledge receipt of a clinical trial application within 10 working days and reach a decision on the application within 50 working days. The G-CTConduct further specifies that the total processing time for a new clinical trial application routine review is 60 working days. Fast track reviews, under which a regulatory decision is given to the applicant within 15 or 30 working days, are applicable for certain clinical trial applications. See the Scope of Assessment section for more information.

The G-CTConduct states that the NDA may request supplementary information or documentation when appropriate, which should be submitted within the stated timeline, usually four (4) weeks. The NDA secretariat may grant additional time to provide information upon request by the applicant on a case-by-case basis. If the requested information is not submitted, the application will be archived within 50 working days. The application will need to be resubmitted for review. If the NDA, on its own initiative, makes amendments to the conditions for conducting a clinical trial for safety reasons or the scientific validity of the clinical trial, the NDA will give 15 calendar days’ notice to the sponsor or the principal investigator (PI) and request submittal of a written response to the proposed amendments.

Additionally, according to UGA-24, the NDA conducts annual reviews of ongoing trials within 20 working days and reviews amendments of clinical trial authorization within 20 working days. Per the G-CTConduct, the NDA review timelines published on UGA-24 do not include the time taken by the applicant to respond to any NDA requests for additional information. A stop-clock mechanism is applied each time the NDA requests additional information.

See Appendices X and XI of the G-CTConduct for the Service Delivery Timelines for Submitted Documents by the Authority and for the Clinical Trial Process Flow, respectively.

Uganda National Council for Science and Technology

According to the NGHRP, the UNCST registration process is normally completed within 10 working days.

Joint Scientific and Ethical Review

The G-JoSER states that the national regulatory agencies (NRAs) (the NDA, the UNHRO, and the UNCST) and the EC will pre-screen a request for JoSER and notify the applicant within three (3) working days. For accepted applications, the UNCST, in collaboration with the NRAs, will identify subject matter experts and interested parties and notify them about the review meeting within three (3) working days. Following the identification of reviewers, a joint review meeting will be convened by the UNCST within 10 calendar days.

The G-JoSER indicates that the UNCST will submit a consolidated list of comments from the joint review within three (3) days after a convened meeting. The PI must submit a formal response to the comments received at the JoSER and then submit a cover letter with required documentation to the local EC for review. The EC will convene a meeting to review the responses within five (5) working days and decide whether to approve or reject the proposal. Following EC approval, the PI must submit the approved documents to the UNCST, and submit them in parallel to the NDA (where necessary). The UNCST, in collaboration with the UNHRO, will review the documentation for completeness within two (2) working days, after which a research permit may be issued. The NDA will review the clinical trial application and provide a regulatory decision within five (5) working days, after which a certificate may be issued.

According to the G-JoSER, an investigator who is dissatisfied with a JoSER or an EC decision may appeal to the UNCST Executive Secretary within 15 days of the date of receipt of the decision.

Ethics Committee Approval

Per the G-TrialsGCP and the NGHRP, an applicant must also submit the clinical trial protocol for review and approval by a UNCST-accredited institutional EC. As indicated in the NGHRP, the EC is required to review a clinical protocol within 60 calendar days from the date of its receipt. In the case of an annual continuing review, the EC must maintain the same anniversary date of approval for any given protocol. Review outcomes must be communicated to the applicant within 14 calendar days of the EC’s review.

The NGHRP states that an investigator may request a fast track/speedy review of a protocol, for which the EC meeting and voting will be done within 14 calendar days after submission of the protocol. The expedited EC review process, for research involving no more than minimal risk or for minor changes in certain previously approved research protocols, must be done within 21 calendar days. For studies that are eligible for exemption from EC review, the EC chairperson will screen the application to ensure that the protocol satisfies the requirements and grant exemption within seven (7) working days, as applicable. For more information on the aforementioned EC review processes, see the Scope of Review section and the NGHRP.

Overview

In accordance with the LMHRA-Act, the LibCTReg, and the G-LibClinTrial, a clinical trial can only commence after the sponsor or the representative receives authorization from the Liberia Medicines and Health Products Regulatory Authority (LMHRA). The LibCTReg and the G-LibClinTrial further state that the sponsor, the legal representative, the principal investigator (PI), or the sponsor-investigator must obtain written permission from the National Research Ethics Board of Liberia (NREB). In addition, per the G-LibClinTrial, the appointed PI must provide proof of residency in Liberia in the clinical trial application submission package.

As per the G-LibClinTrial, the sponsor or the representative is required to obtain LMHRA approval for the clinical trial before the import of an investigational product (IP) to be used in the trial is authorized. However, parallel submission is permitted for approval of the clinical trial and the IP import permit if the import permit application is included in the clinical trial application submission package.

In addition, per the LibCTReg, the applicant must inform the LMHRA in writing of the exact clinical trial commencement date (i.e., first patient first visit). If the trial does not begin within 90 calendar days from issuance of the clinical trial certificate, the applicant must show cause for the failure to commence as scheduled and solicit issuance of a new clinical trial certificate. Pursuant to Part VIII of the LMHRA-Act, the LibCTReg delineates that failure to inform the LMHRA of the commencement, or not starting the clinical trial within this period, will have regulatory implications including, but not limited to, the payment of administrative charges for the re-issuance of the clinical trial certificate on its expiration.

The LibCTReg also states that the sponsor, the investigator, and all of the persons involved in the clinical trial must fulfill the requirements of good clinical practice in accordance with the International Council for Harmonisation’s Guideline for Good Clinical Practice E6(R2) (LBR-8) and the World Health Organization (WHO)'s Guidelines for Good Clinical Practice (GCP) for Trials on Pharmaceutical Products (LBR-25), as determined by the LMHRA. The G-LibClinTrial further specifies that the LMHRA has adopted LBR-8 for use along with the LMHRA guidelines.

Clinical Trial Agreement

While a formal clinical trial agreement is not an official requirement, the G-LibClinTrial states that the protocol should contain a statement that the trial will be conducted in compliance with the protocol, LBR-8, and the applicable regulatory requirements. The protocol should also be signed and dated by both the sponsor or the representative and the PI to document the investigator’s and the sponsor’s agreement to the protocol. If the protocol is not signed and dated by both parties, a corresponding declaration, signed and dated by both, must be provided to the LMHRA with the application.

Clinical Trial Registration

As delineated in the LibCTReg, the sponsor or the sponsor-investigator must register all clinical trials with a public international database. The G-LibClinTrial further specifies that the LMHRA requires the sponsor or the representative to provide proof of registration with the Pan African Clinical Trials Registry (PACTR) (LBR-36) or another WHO Primary Registry (LBR-35).

Overview

According to the NDPA-CTReg, the G-CTConduct, the NGHRP, and the G-TrialsGCP, institutional ethics committee (EC) (research ethics committee (REC) in Uganda) approval, National Drug Authority (NDA) approval, and Uganda National Council for Science and Technology (UNCST) registration are mandatory before a study may commence.

The UNHRO-Act indicates that the Uganda National Health Research Organisation (UNHRO), in collaboration with the UNCST, conducts a scientific and ethical review of all health research protocols for approval. According to the NGHRP, the UNCST consults the UNHRO, where applicable, on identified health protocols. The research follows established research regulatory processes, and final research clearance and registration is carried out by the UNCST.

The G-CTConduct and the NDPA-CTReg indicate that following the NDA’s approval of the clinical trial application, the applicant is also required to obtain a permit from the NDA to import investigational products (IPs) approved for the clinical trial. See the Manufacturing & Import section for more information on IP import permit requirements.

The NGHRP requires that investigators make reasonable efforts to involve community stakeholders in the research process, where appropriate, right from the inception of research to post research period. As stated in the G-TrialsGCP, research intended to be carried out at the community level (e.g., vaccine trials) should ideally ensure adequate consultation with civil society organizations that may exist within affected communities at all phases of the trial. Sponsors are encouraged to establish Community Advisory Groups/Community Advisory Boards (CAGs/CABs), which act as liaisons between the investigator and the community. Additionally, per the NGCER, community engagement is an opportunity for communities to participate in the design and conduct of research, and enhances the relevance, ownership, and applicability of research findings.

See the G-TrialsGCP for more information on CAGs/CABs. See the NGHRP and the NGCER for detailed UNCST guidance on community engagement.

Clinical Trial Agreement

As delineated in the NDPA-CTReg and the G-CTConduct, before the trial begins, the sponsor must sign a clinical trial agreement with the principal investigator (PI).

According to the G-TrialsGCP, if the sponsor decides to use a contract research organization (CRO) to conduct the trial, the transferred duties should be specified in writing and evidence of a mutual agreement must be provided. The sponsor is responsible for securing agreement from all involved parties to ensure direct access to all trial related sites, source data/documents, and reports for the purpose of monitoring and auditing by the sponsor, and inspection by domestic and foreign regulatory authorities. A signed agreement between involved parties (such as the PI/institution and sponsor; the PI/institution and CRO; and the sponsor and CRO), is considered an essential document before a clinical trial can commence.

Per the G-TrialsGCP, the sponsor should obtain the investigator's agreement to:

• Conduct the trial in compliance with the G-TrialsGCP, the principles of good clinical practice (GCP), the requirements of the NDA, and the protocol agreed upon by the sponsor and given approval by the relevant EC
• Comply with procedures for data recording/reporting
• Permit monitoring, auditing, and inspection
• Retain the trial-related essential documents until the sponsor informs the investigator/institution that these documents are no longer needed

Clinical Trial Registration

The G-CTConduct states that clinical trial registration with a publicly accessible clinical trial registry is a requirement for all industry-funded trials in Uganda. Details of registration should be provided with the clinical trial application. It also states that clinical trials conducted in Uganda must be registered with the Pan African Clinical Trials Registry (UGA-35) and any other publicly accessible clinical trials registry recognized by the World Health Organization (WHO). The respective number should be submitted upon application. Additionally, the NDA maintains a clinical trials register (see UGA-36) that details all clinical trials that have received a regulatory decision. This includes information on clinical trial applications that are authorized, suspended, rejected, terminated, and completed.

As stated in the NGHRP, the investigator must prospectively register clinical trials in a publicly available registry at the UNCST.

Note: Per LBR-38, the National Research Ethics Board of Liberia (NREB) has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

Safety Reporting Definitions

According to the LibCTReg, the LibPVReg, and the G-LibPVSys, the following definitions provide a basis for a common understanding of Liberia’s safety reporting requirements (Note: Each of the items listed below will not necessarily be found in all sources, which provide overlapping and unique elements):

• Adverse Event (or Adverse Experience) (AE) – Any untoward medical occurrence in a participant to whom a medicinal product has been administered, including occurrences which are not necessarily caused by or related to that product, or any abnormal sign (e.g., any abnormal physical exam or laboratory finding), symptom, or disease, that is temporally associated with the participant’s involvement in the research; AEs encompass both physical and psychological harms
• Adverse Drug Reaction (ADR) – Any noxious and unintended responses in a participant to an investigational medicinal product which is related to any dose administered to that participant. A causal relationship between a medicinal product and an adverse event is at least a reasonable possibility (i.e., the relationship cannot be ruled out)
• Serious Adverse Event (SAE) or Serious Adverse Drug Reaction (SADR) – Any untoward medical occurrence that at any dose: results in death, is life threatening, requires hospitalization or prolongation of existing hospitalization, results in persistent or significant disability/incapacity, is a congenital anomaly/birth defect, or may jeopardize the participant’s health and may require medical or surgical intervention based upon appropriate medical judgment (e.g., the development of drug dependency or drug abuse). A causal relationship between a medicinal product and an adverse event is at least a reasonable possibility, i.e., the relationship cannot be ruled out
• Unexpected Adverse Drug Reaction – An adverse reaction where the nature or severity is inconsistent with the applicable product information (e.g., Investigator's Brochure for an unapproved investigational product (IP) or package insert/summary of product characteristics for an approved product)

Safety Reporting Requirements

Per the LibCTReg and the G-LibClinTrial, the principal investigator (PI) or the sponsor should report any SAEs/SADRs suspected to be related to the IP immediately, and in any event, no later than three (3) calendar days after becoming aware of the event, to the Liberia Medicines and Health Products Regulatory Authority (LMHRA) and the NREB. However, per the LibCTReg, in the case of death, all SAEs must be reported within 24 hours. Per the G-LibClinTrial, in the case of multicenter trials involving clinical trial sites both within and outside of Liberia, the PI or sponsor must submit all SAEs/SADRs deemed to be related to the IP within 15 calendar days to the LMHRA and the NREB. The PI or the sponsor is also required to indicate the timelines allocated for related investigations.

In addition, the LibPVReg provides the following serious adverse reaction reporting timelines:

• All serious adverse reactions associated with the use of a product must be reported on an expedited basis as soon as possible, but not later than 15 calendar days of initial receipt of the minimum required information. If all the information needed is not available within 15 days, the applicant should submit an initial report containing at least the minimum required data elements (i.e., patient details, suspected product details, reaction details, and the reporter details) in order to meet the expedited reporting timeframes. A follow-up report containing more detailed information should be submitted later as soon as this becomes available
• Every serious suspected adverse reaction occurring in all post-marketing studies of which the manufacturer is aware must be reported to the LMHRA on an expedited basis

However, the LibPVReg also states that the reporting of SAEs and serious unexpected adverse drug reactions (SUSARs) occurring during clinical trials must comply with the requirements stipulated under the LibCTReg.

The G-LibPVSys also notes that all SUSARs occurring in Liberian post-authorization safety studies, of which the local representative or marketing authorization holder (MAH) is aware and includes the design and conduct of company-sponsored, post-marketing surveillance studies (i.e., Phase IV clinical trials), should be reported within seven (7) days.

Investigator Responsibilities

Pursuant to the LibPVReg, for fatal or life-threatening, unexpected events during clinical development, the PI is required to alert the LMHRA as soon as possible but not later than seven (7) calendar days after first knowledge. If a case qualifies, the PI should subsequently submit a complete report as soon as possible within eight (8) additional calendar days.

The G-NREB indicates that investigators are required to submit a report to the NREB for all AEs, except those resulting in death, within seven (7) calendar days. Investigator(s) must report all deaths that are possibly, probably, or definitely related to the study within 24 hours to the NREB.

Other events that must be reported to the NREB include the following:

• Unanticipated problems involving risks to participants or others
• Non-compliance (including major protocol deviations and non-compliance unrelated to a protocol deviation)
• New information that might affect the willingness of participants to enroll or continue to participate in the study

For studies other than clinical trials that use the ACRE IRB, the G-ACRE-IRB states that the investigator must promptly report any unanticipated problems to the ACRE IRB in accordance with the following guidelines:

• Unanticipated problems that are SAEs must be reported to the ACRE IRB within five (5) business days of the investigator becoming aware of the event. The board strongly recommends that a preliminary report be submitted by the investigator within 48 hours of learning of the SAE with a formal follow-up report submitted within the above timeline
• Any other unanticipated problem should be reported to the ACRE IRB within two (2) weeks of the investigator becoming aware of the problem. The board strongly recommends that a preliminary report be submitted by the investigator within five (5) business days of learning of the unanticipated problem with a formal follow-up report submitted within the above timeline

See the G-ACRE-IRB for additional details on the information the investigator should provide.

Sponsor Responsibilities

As explained in the LibPVReg, AEs/ADRs, AEs following Immunization (AEFI) of a vaccine or biological product, fatal or life-threatening AEs of special interest (AESIs), and unexpected ADRs that occur during clinical investigations qualify for very rapid reporting. The sponsor must notify regulatory agencies (e.g., by telephone, facsimile transmission, or in writing) as soon as possible but no later than seven (7) calendar days after first knowledge that a case qualifies, followed by as complete a report as possible within eight (8) additional calendar days. The healthcare facilities, public health programs, manufacturers, MAHs, or any other designated person is required to report AEs/ADRs which include the following to the LMHRA:

• All suspected ADRs resulting from prescription and non-prescription medicinal products
• Unexpected reactions, regardless of their nature or severity, whether or not consistent with product information or labelling
• All ADRs regardless of whether or not the product was used in accordance with the product information provided by the company marketing the product
• All AEs following immunization or use of a biological product
• A serious reaction, whether expected or not
• ADRs in a special field of interest including drug abuse and drug use in pregnancy and during lactation
• ADRs occurring from overdose or medication errors

See the LibPVReg for additional reporting requirements.

Per the LibPVReg, a case initially classified as a non-expedited report, would qualify for expedited reporting upon receipt of follow-up information that indicates the case should be re-classified. The reporting timeframe begins again upon receipt of any medically relevant information for a previously reported case.

Other Safety Reports

Per the LibPVReg, every sponsor and MAH is required to submit an annual Development Safety Update Report (DSUR) to the LMHRA for drugs under development, including marketed drugs under further study. A single DSUR must be prepared for each IP with data pertinent to all dosage forms and strengths, all indications, and all patient populations under study with the IP, wherever feasible. If this is not possible, an explanation should be provided in the introduction section of the DSUR. If more than one sponsor is involved in drug development, a single DSUR can be submitted. The DSUR must provide safety information from all ongoing clinical trials and other studies that the sponsor is conducting or has completed during the review period, including the following:

• Clinical trials using an IP (e.g., human pharmacology, therapeutic exploratory, and therapeutic confirmatory trials (Phase I to III))
• Clinical trials conducted using marketed drugs in approved indications such as therapeutic use trials (Phase IV)
• Therapeutic use of an IP
• Clinical trials conducted to support changes in the manufacturing process of medicinal products
• Any significant other findings pertinent to the safety of the IP

Form Completion & Delivery Requirements

Liberia Medicines and Health Products Regulatory Authority

As per the G-LibClinTrial, all SAEs/SADRs and SUSARs must be reported on the LMHRA’s Suspected Adverse Drug Reaction Reporting Form (Annex 3 in the G-LibClinTrial). In addition, the LibPVReg states that medication errors arising during routine clinical practice must be reported to the LMHRA. The MAHs, healthcare providers, and public health programs must also notify the LMHRA of any reports of unusual failure in efficacy using the Suspected Adverse Drug Reaction Reporting Form. Additionally, patients or consumers may report any suspected ADR/AE associated with the use of a product immediately to the nearest health facility, healthcare provider, or directly to the LMHRA using the Suspected Adverse Drug Reaction Reporting Form.

Atlantic Center for Research and Evaluation Institutional Review Board

Per LBR-28, since all clinical trials protocols submitted to the ACRE IRB are referred to the NREB for review, all AEs/ADRs and SAEs/SADRs are only sent to the NREB. Safety reports for clinical research protocols other than clinical trials should be sent to the ACRE IRB.

National Research Ethics Board of Liberia

No information is available on NREB safety reporting forms and delivery requirements.

Safety Reporting Definitions

In accordance with the NDPA-CTReg, the NDPA-PVReg, the NDPA-PVRegAmdt, the G-CTConduct, the NGHRP, and the G-TrialsGCP, the following definitions provide a basis for a common understanding of Uganda’s safety reporting requirements (Note: Each of the items listed below will not necessarily be found in all sources, which provide overlapping and unique elements):

• Adverse Event (AE) – Any untoward medical occurrence in a research participant who is administered an investigational product (IP), and which does not necessarily have a causal relationship with this treatment
• Adverse Drug Reaction (ADR) – All noxious and unintended responses to a medicinal product related to any dose
• Serious Adverse Event (SAE) – Any untoward medical occurrence that at any dose: results in death, is life-threatening, requires inpatient hospitalization or prolongation of existing hospitalization, results in persistent or significant disability/incapacity, or results in a congenital anomaly/birth defect
• Unexpected Adverse Drug Reaction – An adverse reaction, the nature or severity of which is not consistent with the applicable product information (e.g., Investigator's Brochure for an unapproved IP)

Safety Reporting Requirements

Investigator Responsibilities

As per the NDPA-CTReg and the G-TrialsGCP, the principal investigator (PI) must report all SAEs to the sponsor within 48 hours of first knowledge. The report must identify each participant by an assigned number. When the SAE results in a participant’s death, the PI must supply the sponsor, the National Drug Authority (NDA), and the institutional ethics committee (EC) (research ethics committee (REC) in Uganda) with any additional information requested.

The NGHRP states that the investigator must properly document the occurrence of SAEs or unexpected events, as well as their management. The investigator must also identify, manage, and promptly report SAEs to the EC and the NDA with a notification to the UNCST. All SAEs, SUSARs, and unexpected events of greater than moderate severity must be reported to the local EC, and to the NDA if appropriate, as soon as possible and no later than seven (7) calendar days of awareness. A detailed report of the applicable event must be submitted within seven (7) calendar days from the date it is reported to the EC. A notification of these events must be made to the UNCST, and a final report must be submitted to the local EC, UNCST, and NDA, if appropriate, after resolution of the event. SAEs and actions taken to ensure the safety of research participants must also be reported by the investigator to the EC, research partners, and sponsor.

As set forth in the NDPA-CTReg, the PI must record and report to the sponsor any suspected unexpected serious adverse reaction (SUSAR) that occurs during the course of the trial.

According to the NGHRP, all other reportable events must be reported to the EC and the UNCST as soon as possible, but no later than 14 calendar days. Other reportable events may include notifiable diseases, criminal acts, injury, social harm, economic harm, psychological harm, deaths and life-threatening events in studies, and any other events deemed reportable by the law and the investigator. See the NGHRP for more information on other reportable events.

Sponsor Responsibilities

According to the G-TrialsGCP, the sponsor is responsible for the ongoing safety evaluation of the IP(s). The sponsor should promptly notify all concerned investigator(s), the NDA, and the EC in writing of findings that could adversely affect the safety of participants, impact the conduct of the trial, or alter the EC's approval to continue the trial. Study participants should also be informed of any new information that could adversely affect their safety. Per the NGHRP, the sponsor must also ensure the timely reporting and management of AEs.

The NDPA-CTReg and the G-TrialsGCP state that the sponsor should keep detailed records of the trial-related AEs/ADRs reported by the PI.

The G-CTConduct delineates that the sponsor (or the PI, when delegated) must report all SAEs to the NDA as soon as possible, but no later than seven (7) calendar days upon receiving notice of the event. Additional follow up information must be made available to the NDA as soon as possible, but in any case, no later than 15 calendar days. However, the G-TrialsGCP indicates that the PI is responsible for the aforementioned reporting of SAEs to the NDA.

In addition, according to the G-TrialsGCP, the sponsor should expedite the reporting of all AEs/ADRs that are both serious and unexpected to all concerned investigator(s)/institutions(s), EC(s), and to the NDA. The expedited reporting should occur within the timeframe and format specified by the NDA. Serious and unexpected AEs/ADRs suspected to be related to the IP(s) should be reported to the relevant EC as soon as possible. If the study is multicenter, the sponsor should ensure that all serious and unexpected AEs/ADRs that occur in other study sites are also reported within 15 calendar days of becoming aware of them.

As set forth in the NDPA-CTReg, the sponsor and the PI must also take appropriate safety measures to protect participants against any immediate hazards to their health and safety. When safety measures are taken, the sponsor must, within three (3) working days, provide written notice to the NDA of this action and the reasons why this action was taken.

As set forth in the NDPA-CTReg, the sponsor or their appointed representative must report any SUSARs within seven (7) days of first knowledge to the NDA and the Uganda National Council for Science and Technology (UNCST), or a UNCST-accredited EC.

The G-CTConduct further specifies that the sponsor (or the PI, when delegated) must report all SUSARs to the NDA as soon as possible, but no later than seven (7) calendar days of becoming aware of the event. If the initial report is not complete within the seven (7) days, a completed report should be submitted within 15 calendar days of the initial report. SUSAR reports originating from other studies using the same IP internationally must be submitted as soon as possible, but no later than 15 calendar days following notification of the PI by the sponsor.

However, the G-TrialsGCP indicates that the sponsor should report any SUSARs to the NDA within 15 calendar days of becoming aware of the event. The initial reports should be followed promptly by detailed, written follow-up reports after investigations have been completed, no later than 15 calendar days of becoming aware of the event.

According to the NDPA-CTReg and the G-TrialsGCP, the sponsor should also inform the PI of any SUSARs which occur during the course of another trial for which the sponsor is responsible, where the reaction relates to the IP used in the trial. The NDA should maintain a record of all IP-related SUSARs reported to the authority.

Form Completion & Delivery Requirements

Per UGA-44, clinical trial sponsors can submit AE reports to the NDA via email to clinicaltrials@nda.or.ug. The Council for International Organizations of Medical Sciences (CIOMS) form (UGA-8) may be used.

Note: Per LBR-38, the National Research Ethics Board of Liberia (NREB) has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

Interim and Annual Progress Reports

Liberia Medicines and Health Products Regulatory Authority

Pursuant to the LibCTReg, the applicant must submit to the Liberia Medicines and Health Products Regulatory Authority (LMHRA) and the NREB progress reports containing safety updates and duly signed and authenticated Data and Safety Monitoring Board (DSMB) reports, as specified in the corresponding clinical trial guidelines. As specified in the G-LibClinTrial, the applicant must provide a progress report at least annually on the clinical trial to the LMHRA, unless otherwise stipulated in the clinical trial certificate. The report should contain recruitment status, safety updates, and DSMB reports, as well as an update on the use and results collected on biological samples exported out of Liberia, if applicable.

National Research Ethics Board of Liberia

As indicated in the G-NREB, for continuing review submissions, PIs must submit review reports to the NREB Secretariat at least eight (8) weeks prior to the approved protocol’s expiration. See LBR-6 for the NREB Continuing Review Form. Additionally, according to LBR-38, the NREB is also using LBR-24 for continuing review, for annual reports, and as a final report to close a study.

Per the G-LibClinTrial and the G-NREB, research in Liberia should comply with the International Council for Harmonisation's (ICH)’s Guideline for Good Clinical Practice E6(R2) (LBR-8). Refer to LBR-8 for additional progress reporting guidance.

Atlantic Center for Research and Evaluation Institutional Review Board

For clinical research studies using the ACRE IRB, the G-ACRE-IRB requires the principal investigator(s) (PIs) to submit progress reports (also referred to as continuing review submissions in Liberia) to the ACRE IRB. If no work was conducted on a study during the last approval period, the PIs should explain why (e.g., too busy with other projects; a delay in funding; or unable to hire a graduate student to work on the project). If the PI(s) are closing the study, a copy of any publications or manuscripts resulting from the study should be attached.

See the G-ACRE-IRB for details on the required documentation to submit a continuing review to the ACRE IRB.

Final Report

Liberia Medicines and Health Products Regulatory Authority

The LibCTReg states that the applicant is required to submit a final clinical trial summary report to the LMHRA. As per the LibCTReg and the G-LibClinTrial, the applicant must notify the LMHRA within 30 business days from the end of a clinical trial. Per the G-LibClinTrial, the end of the trial definition should be documented in the clinical trial protocol.

The LibCTReg and the G-LibClinTrial also indicate that the applicant must submit a closeout report with a copy of the LMHRA-issued disposal certificate to the LMHRA. The G-LibClinTrial specifies this report should be submitted within 90 days from completion of the clinical trial. (See Annex 5 of the G-LibClinTrial for closeout report form).

In addition, per the LibCTReg and the G-LibClinTrial, the applicant must submit a comprehensive end of study report conforming to the ICH’s Structure and Content of Clinical Study Reports (E3) (LBR-37) guidelines, within one (1) year from the trial’s completion.

Per the LibCTReg and the G-LibClinTrial, the end of study report must also contain any AEs reported by the PIs.

National Research Ethics Board

The LibCTReg states that the applicant is required to submit a final clinical trial summary report to the NREB. The applicant must also notify the NREB within 30 business days from the end of a clinical trial.

Additionally, per the LibCTReg, the PI must also inform the NREB of any AEs as part of the end of study report.

The LibCTReg further specifies that the applicant must submit a comprehensive end of study report to the NREB conforming to the LBR-37 guidelines, within one (1) year from the trial’s completion.

According to LBR-38, the NREB is using LBR-24 for continuing review, for annual reports, and as a final report to close a study.

Atlantic Center for Research and Evaluation Institutional Review Board

Per the G-ACRE-IRB, PI(s) should complete Section 12 (Disposition of Project) of the ACRE IRB Submission Form (Section 25.02 in Article XXV of the G-ACRE-IRB) for the final ACRE IRB review. For the board’s purposes, the project has ended when there is no further participant enrollment, intervention(s), or data collection, and the remaining data are either de-identified or maintained with safeguards. The PI(s) should use this section to describe the disposition of the project and its data and to provide a brief summary of their findings.

Interim and Annual Progress Reports

As per the G-TrialsGCP, the principal investigator (PI) is obliged to submit progress reports as required by the sponsor, the institutional ethics committees (ECs) (research ethics committees (RECs) in Uganda), the Uganda National Council for Science and Technology (UNCST), and the National Drug Authority (NDA). These reports should contain information on:

• How the study is progressing
• The number of participants included in relation to the number screened and the target sample size
• The number of dropouts and withdrawals
• Adverse events
• If the planned time schedule is still appropriate

The format and frequency of reporting is as prescribed by the relevant authorities.

The NDPA-CTReg and the G-CTConduct also state that the NDA may request the sponsor to submit an interim report. See Schedule 2 of the NDPA-CTReg or UGA-6 for the format of the clinical trial report.

As stated in the NGHRP, the PI must notify the EC (and the collaborating organization’s EC and the UNCST, where applicable) in the annual report of any minor deviations to the protocol.

Final Report

The NGHRP states that the sponsor is responsible for approving a final study report, regardless of whether the trial has been completed. Additionally, a standard operating procedure for study closure and a budgetary provision for end of study are required.

The NDPA-CTReg and the G-TrialsGCP require the sponsor to inform the NDA in writing of the conclusion of the trial within 90 days, using the format of the clinical trial report in Schedule 2 of the NDPA-CTReg. However, according to the G-CTConduct, either the sponsor or PI must notify the NDA upon conclusion of a trial within 90 calendar days using the format conforming to the International Council for Harmonisation (ICH)’s Harmonised Tripartite Guideline: Structure and Content of Clinical Study Reports (E3) (UGA-38). This notification must be accompanied by:

• The final soft and hard copies of the clinical trial report as specified
• A comprehensive summary of the essential findings of the trial
• Evidence of destruction or shipment of remaining investigational products or any other course of action approved by the sponsor

As stated in the G-CTConduct, the definition of the end of the study will be as defined by the specific study protocol. The NDA requires that the PI submit an end of study notification according to the end as defined in the study protocol. End of trial reports will be submitted once the trial data can answer the study endpoints. The NDA defines the end of the trial as a time when the trial ends and end points are available.

The G-TrialsGCP further indicates that upon completion of the trial, the investigator, where applicable, should inform the institution. The investigator/institution should provide the EC with a summary of the trial’s outcome and furnish the regulatory authorities with any reports required. All aspects (statistical and clinical) of the protocol should be integrated in order to obtain a final study report that is entirely consistent with the study data generated. Essential elements in the presentation of the results include:

• Baseline comparisons between the treatment groups
• The number of participants actually randomized into the study by treatment group and the number of participants excluded from any of the analyses, by reason and by treatment group
• Major efficacy and safety results by treatment group in the form of tables, graphs, test variables, and statistical parameters, as appropriate
• An assessment of between-group differences with confidence intervals

An account must be made of missing, unused, or spurious data during statistical analyses. All omissions of this type must be documented to enable review.

As stated in the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with LMHRA guidelines. Per LibCTReg, the sponsor is defined as an individual, company, institution, or organization that takes responsibility for the initiation, management, and/or financing of a clinical trial.

LibCTReg also defines a sponsor-investigator as an individual who both initiates and conducts an investigation, alone or with others, and under whose immediate direction the investigational product is administered or dispensed. The term does not include any person other than an individual. The obligations of a sponsor-investigator include both those of a sponsor and those of an investigator.

In addition, per the LibCTReg, the sponsor may hire a contract research organization (CRO) (commercial, academic, or other) to perform one (1) or more of the sponsor’s trial-related duties and functions. See LBR-8 for additional guidance on sponsor responsibilities.

As defined in the NDPA-CTReg, the G-CTConduct, the G-GMPAnnexes, and the G-TrialsGCP, a sponsor is the person, company, institution, or organization that takes responsibility for the initiation, management, or financing of a clinical trial. The NGHRP specifically assigns responsibility to the sponsor for providing all the necessary financial support to initiate and complete a research study.

The NDPA-CTReg also specifies that in order to submit a clinical trial application, the sponsor must be one (1) of the following:

• The drug patent holder
• A licensed person (a pharmacist)
• The drug manufacturer
• An agent of the drug patent holder or the drug manufacturer

As stated in the G-TrialsGCP, a sponsor may transfer any or all of the sponsor's trial-related duties and functions to a contract research organization (CRO), but the ultimate responsibility for the quality and integrity of the trial data always rests with the sponsor. The CRO must have the required skills, experience, and competencies to safely conduct clinical trials. Any trial-related duty and function that is transferred to and assumed by a CRO should be specified in writing and evidence of a mutual agreement provided. The sponsor should ensure oversight of any trial-related duties and functions carried out on the sponsor’s behalf, including trial-related duties and functions that are subcontracted to another party by the sponsor's contracted CRO(s). Any trial-related duties and functions not specifically transferred to and assumed by a CRO are retained by the sponsor.

Per the NDPA-CTReg, a local company in Uganda may act as an agent in the clinical trial for a foreign sponsor.

Overview

According to the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with LMHRA guidelines. Refer to LBR-8 for additional guidance on sponsor site/investigator selection requirements.

As stated in the G-LibClinTrial, all investigators must be trained in good clinical practice (GCP), as documented by the provision of training certificates that are no more than three (3) years old at the time of application. Any other training or experience from previous clinical trials and patient care, as needed for the conduct of the trial, must be provided for the investigators to prove their qualifications. The principal investigators (PIs) should have acted as a PI, or at least as an investigator, in at least one (1) prior clinical trial and must provide proof of residency in Liberia in the clinical trial application submission package. The LibCTReg further states that the trial is to be conducted in an appropriate facility by a suitably qualified investigator in a responsible manner and managed by an investigator who can provide evidence of sufficient experience in the conduct of clinical trials, as determined by the LMHRA.

Per the G-NREB, PIs are also required to be able to provide a current Certificate of Training in GCP for PIs, be qualified to undertake the particular study, and be knowledgeable in the values and tenets of ethical and regulatory principles and scientific method applications associated with conducting research in human participants.

In addition, the G-LibClinTrial requires the applicant to provide details of the site(s) where the clinical trial is to be conducted, along with a duly justified written statement on the suitability of the trial sites, adapted to the nature and use of the investigational product in the clinical trial application submission package. The statement should include a description of the suitability of facilities, equipment, human resources, and description of expertise, issued by the head of the clinic/institution at the trial site or by some other responsible person.

See also LBR-8 for information on sponsor agreements with investigators/institutions.

Foreign Sponsor Responsibilities

No information is currently available on foreign sponsor requirements.

Data and Safety Monitoring Board

As per the G-LibClinTrial, the sponsor or the representative should provide information on the composition of the Data and Safety Monitoring Board (DSMB) in the clinical trial application submission package. This information should include the list of members, the terms of reference, and the CVs of its members to justify their expertise as members of the DSMB.

See LBR-8 for additional DSMB guidance.

Multicenter Studies

See LBR-8 for guidance on sponsor requirements for multicenter clinical trials.

Overview

As per the NDPA-CTReg and the G-TrialsGCP, the sponsor oversees the selection of the investigator(s) and the institution(s) for the clinical trial. The G-CTConduct indicates that based on the clinical trial agreement between the sponsor and the principal investigator (PI), the National Drug Authority (NDA) will liaise with the in-country PI representing the sponsor regarding the application. The PI should be a Ugandan resident (local) and licensed by the relevant body in Uganda.

The G-TrialsGCP states that before entering an agreement with an investigator to conduct a trial, the sponsor should provide the investigator with the protocol and an up-to-date Investigator's Brochure (IB). The investigator should also be given sufficient time to review the protocol and the information provided. The PI/investigator(s) should be qualified by education, training, and experience to assume responsibility for the proper conduct of the trial, meet all the qualifications specified by the applicable regulatory requirement(s), and provide evidence of such qualifications through an up-to-date curriculum vitae and/or other relevant documentation requested by the sponsor, the accredited institutional ethics committee (EC) (research ethics committee (REC) in Uganda), and/or the NDA. The PI/investigator(s) should also be thoroughly familiar with the appropriate use of the investigational product(s) (IP(s)), as described in the protocol, current IB, product information, and other information sources provided by the sponsor. Furthermore, the PI/investigator(s) should be aware of, and comply with, good clinical practice (GCP) and the applicable regulatory requirements.

Per the NGHRP, initial face-to-face training before study commencement is encouraged. Research teams must receive training before initiation of study activities and undergo continued research ethics education at least once every three (3) years. An investigator must be qualified and licensed to carry out the study being proposed. Foreign investigators must have a valid work permit where applicable, especially when actively involved in the research implementation within Uganda. According to the NDPA-CTReg, an application for additional investigators, change of investigator, or additional clinical trial sites must be made using Form 36 in Schedule 1 of the NDPA-CTReg or using UGA-13. The application must be accompanied by evidence of ethical approval of the clinical trial protocol amendment, where applicable, and the prescribed fees.

As indicated in the NGHRP, the host institution is responsible for the provision of space and necessary facilities for research implementation, as well as for monitoring research progress as necessary. For new and emerging technologies, therapeutics, and designs, efforts must be made by the institution of affiliation for infrastructural capacity enhancement and professional development, which must be provided for in the protocol.

Foreign Sponsor Responsibilities

The NDPA-CTReg states that in the case of foreign sponsors, a local company in Uganda must submit a letter of authorization from the holder of the patent of the drug, licensed person, or manufacturer of the drug to be the agent in the clinical trial that is responsible for all matters pertaining to the NDA clinical trial certificate. See Form 30 in Schedule 1 of the NDPA-CTReg or UGA-18 for the letter of authorization, and Form 34 in Schedule 1 of the NDPA-CTReg for the clinical trial certificate.

Data and Safety Monitoring Board

According to the NGHRP and the G-TrialsGCP, the sponsor is responsible for establishing a Data and Safety Monitoring Board (DSMB) (also referred to as an Independent Data-Monitoring Committee (IDMC)) prior to the trial’s commencement. Per the NGHRP, the DSMB ensures that the study is conducted in accordance with the protocol provisions, ensures the safety of study participants, and preserves the integrity and credibility of the trial. A DSMB must be established before the commencement of an interventional study, and its charter must be submitted to the EC for review and approval. All Phase IIb and Phase III clinical trials must have a DSMB, and Phase I, Phase IIa, and other high risk noninterventional studies must have a safety monitoring plan. A Safety Monitoring Committee must be established for Phase I and Phase IIa of a clinical trial before the trial’s commencement and must be based on risk categorization of the study. Its composition must be submitted to the EC.

The G-TrialsGCP further indicates that a DSMB should have written operating procedures and maintain written records of all its meetings. A duly signed DSMB charter must be submitted to the NDA prior to recruitment of participants, and any decision not to create a DSMB should be clearly documented and justified in the protocol.

For additional details on DSMB establishment and functions, see 3.7.3 of the NGHRP.

Multicenter Studies

The G-TrialsGCP indicates that multicenter trials must adhere to all national regulatory requirements, ensuring consideration and adaptation of the local context into the general study design. The following should be considered regarding multicenter trials:

• Inclusion and exclusion criteria must be appropriate to consider local realities, as well as trial site-specific differences
• The informed consent procedure must be tailored to local conditions and informed consent forms translated into the local language submitted to the EC for approval
• Study design differences between the Ugandan site(s) and other sites must be fully explained, as well as differences between sites within Uganda Study extrapolations and conclusions should be relevant to the Ugandan context
• Where necessary, site investigators should develop site-specific standard operating procedures and/or a site implementation plan to guide the respective sites on protocol implementation

Per the G-TrialsGCP, for multicenter trials, the PI is responsible for appointing co-investigators that will be responsible for the various trial sites in Uganda. However, it is the responsibility of the sponsor to ensure all investigators conduct the trial in strict compliance with the approved protocol. In addition, the sponsor should ensure that:

• The case report forms (CRFs) are designed to capture the required data at all multicenter trial sites
• Investigator responsibilities are documented prior to the start of the trial
• All investigators are given instructions on following the protocol, complying with a uniform set of standards to assess clinical and laboratory findings, and completing the CRFs
• Communication between investigators at the various sites is facilitated

Insurance

As set forth in the LibCTReg and the G-LibClinTrial, the applicant should include documentation in the clinical trial application submission package to verify active clinical trial insurance that covers Phases I, II, and III; proof of professional indemnity (malpractice insurance); and proof of sponsor indemnification for investigators and the trial site. The LibCTReg also notes that an indemnity, in the form determined by the Liberia Medicines and Health Products Regulatory Authority (LMHRA), is to be signed by the participant to protect the LMHRA from liability related to an injury or an adverse event that may be sustained by a person, directly or indirectly, as a result of the conduct of the trial and that occurs or reveals itself at the time of the trial or subsequently. The LibCTReg further notes that any person(s), institution(s), corporate entity(ies), their designees, or legal representative(s) who fail to provide insurance coverage for prospective participants as required, and where bodily injury or substantial harm results in the course of the research, commits a first degree misdemeanor.

The G-LibClinTrial also specifies that a study insurance certificate and an indemnity provision should be current and valid for the full duration of the trial and follow-up period. If the validity is shorter, a written renewal commitment for the trial duration is required. The certificate should contain a reference to the clinical trial, the clinical trial protocol number, and the countries to which the insurance cover is extended. The insurance cover should be provided from an internationally recognized company. Additionally, the LibCTReg, requires an insurance policy to be in place to provide benefits in the event that a clinical trial participant suffers injury or death related to the study.

In addition, per the G-LibClinTrial, under certain circumstances, the LMHRA may accept an expedited application and review process for clinical trials (e.g., epidemics or other urgent public health interests requiring fast use of new medicines or health products and/or fast gathering of health product information). In the case of trials involving human participants, the applicant must provide proof of current, relevant, and appropriate study insurance for all participants, or professional indemnity insurance for investigators, as part of the application submission package to be sent to the LMHRA. Furthermore, as specified in the LibCTReg and the G-LibClinTrial, the LMHRA has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. See LBR-8 for additional sponsor insurance requirements.

Compensation

Injury or Death

Pursuant to Part VIII of the LMHRA-Act, the LibCTReg specifies that the principal investigator (PI) or organization is subject to an action of damages for any Serious Adverse Event (SAE)/Serious Adverse Drug Reaction (SADR) that is life-threatening, or results in persistent or significant disability/incapacity or congenital anomaly/birth defect, during the conduct of a clinical trial. Additionally, any SAE/SADR that is life-threatening or results in persistent or significant disability/incapacity, congenital anomaly/birth defect to a participant during the conduct of a clinical trial, subjects the PI or organization to an action of damages.

See LBR-8 for additional sponsor compensation requirements related to trial-related injuries.

Trial Participation

See LBR-8 for guidance on sponsor compensation requirements for trial participants.

Insurance

As set forth in the NDPA-CTReg and the G-TrialsGCP, the sponsor is responsible for providing insurance coverage for any unforeseen injury to research participants. The sponsor should provide indemnity for the investigator(s) against claims arising from the clinical trial, except for claims that arise from malpractice or negligence.

According to the NDPA-CTReg, the G-CTConduct, and the G-InsuranceCover, an insurance certificate must be provided to the National Drug Authority (NDA) that is specific to the trial for which the clinical trial application is being submitted. The G-CTConduct and the NDPA-CTReg also indicate that the clinical trial application must provide evidence that each member of the clinical trial team is covered by relevant malpractice insurance for the trial. The NGHRP states that medical treatment and compensation must be covered through the mandatory clinical trial insurance.

The G-InsuranceCover further states that the required insurance coverage for research participants in a specific trial at a given site must be obtained from a local insurance company that is registered and operating under law in Uganda. For additional details on the required elements of the insurance policy, see Section 7.0 of the G-InsuranceCover.

According to the G-TrialsGCP, the principal investigator (PI) is responsible for ensuring participants obtain their claim from the local insurance company in the event of any trial-related injury and/or resultant disability.

Compensation

Per the G-TrialsGCP, the sponsor must ensure that information on incentives offered to participants is included in the protocol and informed consent documents. If the study is multicenter, information on the incentives given at all the different trial sites must be provided. If the participating sites are multinational, then the differences in the incentives across the sites must also be explained.

According to the NGHRP, a care package for research participants must be prepared before initiation of a research study. Care and treatment for research participants must be provided with the ideal aim of providing the best proven intervention.

Injury or Death

In accordance with the NGHRP, the sponsor is responsible for participant compensation or indemnity in the event of trial-related injuries, disability, or death. The sponsor must ensure that participants who suffer any trial-related injuries receive free medical treatment for such injuries, and financial or other assistance that would compensate them equitably for any resulting impairment, disability, or handicap. The sponsor must provide care until complete cure or stabilization of a trial-related injury.

Additionally, the NGHRP, indicates that the investigator must refer all participants whose conditions may not be managed adequately within the expertise and licensure of the medical professionals at the study site, and/or where facilities or supplies at the study site do not allow adequate handling of the condition. The investigator and/or study sponsor must pay the cost of referral and management of the condition when a referral has been made for a trial-related injury or a serious adverse event (SAE) related to the study.

Per the NGHRP, a trial-related injury may be physical, social, economic, or psychological, and may be classified as follows:

• Definitely: When injury is directly caused by participation in a research study

• Probably: When injury is most likely explained by participation in a research study but when no definite proof of causality is evident

• Possibly: When explanation for injury is equally due to participation in a research study or other cause

• Unlikely: When injury is more likely explained by another cause other than participation in a research study
• Not related: When injury is clearly due to another cause other than participation in a research study

The NGHRP states that subject to applicable laws in Uganda, research participants will be entitled to compensation when they suffer injury classified as possibly, probably, or definitely related to their participation in the research. Before determination of relatedness, all adverse event (AE) care must be provided to the research participant at the study’s cost. The staff and clinical facilities where research will be conducted must be licensed/approved for patient care. The investigator must meet treatment costs for AEs that are deemed possibly, probably, and definitely related to the study intervention.

According to the NGHRP, research participants must not be asked to waive the right to compensation, and must retain legal rights to seek monetary compensation for research related injuries including settlements out of court. Any research regulatory body, institution, investigators, participant, or other stakeholder may initiate the compensation process. The Uganda National Council for Science and Technology (UNCST), Uganda National Health Research Organisation (UNHRO), research host institution, institution of affiliation, and sponsor must agree on an appropriate mechanism for arbitration.

Trial Participation

In the clinical trial application made to the NDA, the applicant must explain how the participant(s) will be compensated for their time and other inconveniences, in accordance with the G-CTConduct and the NDPA-CTReg.

In addition, per the NGHRP, participants must be compensated for inconveniences, effort, time spent, and expenses incurred while taking part in a study, such as travel costs, as deemed relevant by the institutional ethics committee (EC) (research ethics committee (REC) in Uganda) and the UNCST. Compensation can be in kind. Refreshments and meals are not compensation for research participation, but a welfare aspect for study participation. Research participants may also receive free medical services. The compensation or medical services must not be so out of proportion as to induce individuals to participate in the research. Incentives can be given, but must not be considered a research benefit and must not present undue inducement to potential participants, as determined by the EC.

According to the G-TrialsGCP, the sponsor must ensure that participants are reimbursed for all reasonable costs incurred by their participation in the trial.

Post-Trial Access

In accordance with the NGHRP, post research responsibilities must be considered at the conception of the research study, and they must have a dedicated section in the research protocol. The duration and sustainability of care and treatment for the participant after the study must be negotiated before initiation of the study. Sponsors are encouraged, but not obliged, to care and treat for chronic and relapsing illnesses. However, investigators and sponsors are obliged to manage SAEs/harm related to the study (including paying for associated costs thereof) until they are fully resolved or stabilized. Investigators must provide relevant follow up for participants for the duration as approved. Certain categories of interventions with potential long-term effects may require extended follow-up and monitoring for SAEs. These may include investigations involving genetically modified substances, gene therapy, and DNA-based compounds. The extended follow-up and monitoring period will be determined by the EC on a case-by-case basis. Children born by participants who become pregnant during a trial must receive follow-ups for a minimum of two (2) years.

Quality Assurance/Quality Control

As specified in the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation (ICH)'s Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. Refer to LBR-8 for guidance on sponsor responsibilities related to quality assurance (QA) and quality control (QC) systems throughout the conduct of the trial.

Monitoring Requirements

See LBR-8 for sponsor monitoring requirements.

Premature Study Termination/Suspension

Pursuant to the LibCTReg, if the trial is suspended or terminated before its purpose is achieved, the applicant must convey the reason(s) in writing to the LMHRA and the National Research Ethics Board of Liberia (NREB) within 10 working days, and all information must be provided as determined by the LMHRA. The G-LibClinTrial also states that the applicant must inform the LMHRA of a clinical trial suspension or premature termination of a clinical trial within 10 working days, and clearly explain the reasons for this decision. See also LBR-8 for additional guidance on sponsor requirements related to premature study terminations/suspensions.

Quality Assurance/Quality Control

The NDPA-CTReg states that the sponsor should maintain quality assurance and quality control systems for the conduct of clinical trials and for the generation of documentation, recording, and reporting of data. The G-TrialsGCP indicates that the sponsor is also responsible for implementing the systems with written standard operating procedures (SOPs) to ensure that trials are conducted and data are generated, documented (recorded), and reported in compliance with the protocol, good clinical practice (GCP), and the applicable regulatory requirement(s). Quality control should be applied to each stage of data handling to ensure that all data are reliable and have been processed correctly.

According to the G-TrialsGCP, the sponsor should implement a quality management system throughout all stages of the trial process, and should focus on the trial activities essential to ensuring participant protection and the reliability of trial results. The quality management system should use a risk-based approach including critical process and data identification, risk identification, risk evaluation, risk control, risk communication, risk review, and risk reporting. For additional details, see the G-TrialsGCP.

The NGHRP requires that all research institutions have in place a research integrity policy that provides a framework for compliance and designation of a research integrity officer in accordance with international and national applicable standards. Institutions must submit reports of all cases handled at the institutional level, and refer cases not adjudged to the Uganda National Council for Science and Technology (UNCST). See the NGHRP for more information on research integrity requirements.

As stated in the NGHRP, protocol violations and deviations should be avoided except for purposes of intervening when a participant’s life is in danger. When a violation or deviation occurs, the principal investigator (PI) must report to the institutional ethics committee (EC) (research ethics committees (RECs) in Uganda). For a violation and major deviation, notification to the EC (and the collaborating organization’s EC and the UNCST, where applicable), must be made by the PI within seven (7) calendar days of becoming aware of the event. For a minor deviation, notification to the EC (and the collaborating organization’s EC and the UNCST, where applicable), must be made by the PI in an annual report.

Monitoring Requirements

As per the G-TrialsGCP, the sponsor should ensure that the auditing of clinical trials/systems is conducted in accordance with the sponsor's written procedures on what to audit, how to audit, the frequency of audits, and the form and content of audit reports. The observations and findings of the auditor(s) should be documented and accessible to the EC and the National Drug Authority (NDA). The audit report should be submitted to the NDA if evidence of GCP or protocol non-compliance is found.

The G-TrialsGCP further states that in accordance with the NDPA-CTReg, the sponsor should appoint a monitor tasked with trial oversight and reporting on the progress of a study. The monitor should ideally have adequate medical, pharmaceutical, and scientific qualifications. The investigator(s) should accept the possibility of an audit or monitoring visit by an independent auditor appointed by the sponsor, and/or an inspection by the NDA, EC, or relevant local and international regulatory authorities.

Premature Study Termination/Suspension

Per the NDPA-CTReg, in the case of a sponsor-initiated clinical trial termination, the sponsor must notify the NDA within 15 days using the format specified in Schedule 2 of the NDPA-CTReg or UGA-5. The notification must give reasons for the termination, indicate the disposal process for the unused investigational product, and give the effective date of the termination. The G-CTConduct further requires that the sponsor provide evidence of notification to the EC of record and the UNCST.

According to the NGHRP, the investigator must notify the EC, the UNCST, and other relevant regulatory agencies in writing about early termination of the study and the reasons for the termination. The G-TrialsGCP further specifies that if a trial is prematurely terminated or suspended for any reason, the investigator should inform the participants, assure appropriate therapy and follow-up for the participants, and inform the NDA. Furthermore, if the investigator terminates or suspends a trial without prior agreement of the sponsor, the investigator should inform the institution where applicable, and the investigator/institution should inform the sponsor and the EC. The investigator should provide the sponsor and the EC with a detailed written explanation of the termination or suspension.

Note: Per LBR-38, the National Research Ethics Board of Liberia (NREB) has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

Electronic Data Processing System

As specified in the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation (ICH)'s Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. See LBR-8 for sponsor requirements when using electronic data processing systems.

Records Management

The G-LibClinTrial specifies that the principal investigator (PI) must keep an Investigator Site File (ISF), and the sponsor must keep a Trial Master File (TMF) containing essential documents relating to the clinical trial, which provide verification for the trial conduct and the quality of the data generated, taking into account all trial characteristics. The files must be readily available and directly accessible upon request from the LMHRA. The sponsor and the investigator must archive the contents of the TMF and ISF, respectively, for at least 25 years after the end of the trial including the medical files of study participants.

See also LBR-8 for additional sponsor requirements related to record management.

As per the G-LibClinTrial, data handling and recordkeeping should be conducted in conformity with the World Health Organization's Good Clinical Practice Guidelines (LBR-25) (refer to Section 8 for details).

Per the G-ACRE-IRB, for clinical research studies using the ACRE IRB, research records from a study must be retained by the investigator(s) for a period of no more than five (5) years following the closure date. If other regulations and policies apply to a particular protocol, then the duration of protocol retention is in accordance with the applicable regulations/policies. For detailed ACRE IRB recordkeeping requirements, refer to the G-ACRE-IRB.

The G-ACRE-IRB also specifies that although a research protocol has been closed, the investigator(s) should keep the data they have collected, including identifiable private data, in a manner consistent with the board-approved protocol and participant consent requirements. The investigator(s) must continue to honor any confidentiality protections applicable to the data. Refer to the Informed Consent topic for additional information on documentation requirements and research participant rights during the informed consent process.

Electronic Data Processing System

According to the G-TrialsGCP, the sponsor should utilize appropriately qualified individuals to supervise the overall conduct of the trial, handle the data, verify the data, conduct the statistical analyses, and prepare the trial reports. When using electronic trial data handling or remote electronic trial data systems, the sponsor should:

• Ensure and document that the electronic data processing system(s) conform(s) to the sponsor's established requirements for completeness, accuracy, reliability, and consistent intended performance
• Maintain standard operating procedures (SOPs) for using these systems
• Ensure that the systems are designed to permit data changes in such a way that the data changes are documented and that there is no deletion of entered data
• Maintain a security system that prevents unauthorized access to the data, and a list of the individuals who are authorized to make data changes
• Maintain adequate backup of the data
• Safeguard the blinding, if any
• Ensure the integrity of the data, including any data that describes the context, content, and structure

For additional details, see Section 4.8 of the G-TrialsGCP.

The G-TrialsGCP states that quality control should be applied to each stage of data handling to ensure that all data are reliable and have been processed correctly. The sponsor should base their approach to validation of electronic data processing systems on a risk assessment that takes into consideration the intended use of the system and the potential of the system to affect human participant protection and reliability of trial results. The sponsor should maintain a documented record of SOPs that guide a step-by-step retrospective assessment of data quality and study performance. These SOPs should cover system setup, installation, and use. The SOPs should also describe system validation and functionality testing, data collection and handling, system maintenance, system security measures, change control, data backup, recovery, contingency planning, and decommissioning. The responsibilities of the sponsor, investigator, and other parties with respect to the use of these computerized systems should be clear, and the users should be provided with training in their use.

According to the G-TrialsGCP, satisfactory maintenance and back-up procedures for computer databases must be provided. Case report forms (CRFs) should be designed to meet the specific data requirements set out in the study protocol. The effects of missing and inaccurate data should be minimized to maintain data quality. The system for routinely checking the data collection and entry throughout the course of the trial should be documented. Checks for validity and consistency of the database should be on separate items as well as on predetermined combinations of items in the CRFs. The SOP for data editing should ensure that any queries about data validation are brought to the attention of the investigators. Database lock should be done after completion of the validation and editing processes are documented.

As per the NGHRP, utilization of electronic data requires safeguards and compliance with national laws and policies. See Annex I of the NGHRP for the minimum requirements for the establishment of research E-Systems.

Additionally, the NGHRP indicates that certain procedures and controls are required for electronic documents systems when utilizing E-Informed Consent (eIC). The procedures are designed to ensure the authenticity, integrity, and confidentiality of electronic documents, and ensure that signers cannot claim the signed documents are not genuine. See the Documentation Requirements section and 5.8 of the NGHRP for more information on eIC.

The NGHRP states that before using artificial intelligence (AI) in research, the principal investigator (PI) must provide administrative clearance from the national body responsible for information systems and data protection prior to submission to the institutional ethics committee (EC) (research ethics committee (REC) in Uganda) and final registration and clearance by the Uganda National Council for Science and Technology (UNCST). See the NGHRP for additional guidance regarding the use of AI in research.

Records Management

The G-TrialsGCP and the G-CTConduct state that the sponsor and the PI are responsible for archiving and ensuring the safety of all trial-related documentation. Per the NDPA-CTReg, the sponsor must keep the records, documents, and information provided to the National Drug Authority (NDA) in the clinical trial application for unregistered investigational products (IPs) at the clinical trial site for 20 years following the trial's completion. Documentation for trials involving IPs to be registered should be kept for two (2) years after the registration of the IP. For an IP used in a clinical trial, the sponsor must, at the clinical trial site, maintain:

• The Investigator's Brochure (IB) for the IP and a record of the changes made to the IB, if any, including the rationale for each change
• A record of the adverse events (AEs) of the IP that occurred inside or outside Uganda, showing the indication for use and the dosage form of the IP at the time of the AE
• A record of the participants with their identifications and contacts
• A record of the shipment and receipt of the IP and where applicable, a record of the return of the IP or a record of the destruction of the IP, which must be in accordance with the prescribed process
• A copy of the protocol and consent forms

The G-CTConduct further states that the holder of the clinical trial certificate should inform the NDA in writing prior to destroying the documents. Documents may be stored in electronic (soft and scanned) or hard copies.

In addition, the G-TrialsGCP requires that if the sponsor discontinues the clinical development of an IP, the sponsor should maintain all sponsor-specific essential documents for at least two (2) years after formal discontinuation. The sponsor should inform the investigator(s)/institution(s) in writing of the need for record retention and should notify the investigator(s)/institution(s) in writing when the trial-related records are no longer needed.

The NGHRP notes that as part of the host institution’s responsibilities, all stakeholders must maintain adequate and accurate source documents through hard or electronic copies. Additionally, all research records must meet standards for source documentation practices: attributable, legible, contemporaneous, original, accurate, complete, consistent, and available.

According to the NGHRP, collaborating research partners must agree on appropriate data access and use rights before commencement of the study. Furthermore, a collaborating research partner must not transfer data to a third party without the written consent of the other partner. Investigators must also have mechanisms for ensuring privacy and confidentiality as stated in the NITA-U-PrivAct, and a copy of the data sets must be available for access by the local institution. Investigators must ensure that research records from which personal data have been obtained are available at the research site for at least 20 years after completion of a clinical trial, and at least five (5) years after completion for any other type of study. This must include hard and/or electronic copies. The mechanism of backup must be stated in the protocol, and a local server in-country must be used for storage and backup of the data. For more information on data protection and privacy requirements, see the Personal Data Protection section.

The NGHRP further requires that collaborating research partners negotiate data ownership and use in accordance with the institution of affiliation’s data use and ownership policies. Ownership of data must be clearly stated in the research protocol and Data Transfer and Use Agreements (DTAs), which must be reviewed and approved by the EC and the UNCST. See Annex III of the NGHRP for a DTA template.

Responsible Parties

No information is currently available related to responsible parties for personal data protection.

Data Protection

No information is currently available related to data protection.

Consent for Processing Personal Data

As stated in the LibCTReg, the clinical trial participant must be informed of the purpose and scope of the collection and use of personal data, especially medical data. The trial participant must be informed especially of the fact that, where necessary, the collected data should be:

• Kept available for inspection by the Liberia Medicines and Health Products Regulatory Authority (LMHRA) or for monitoring or auditing by the sponsor in order to verify the proper conduct of the clinical trial
• Be passed on to the sponsor and the LMHRA without disclosing the identity of the trial participant

The LibCTReg further notes that a declaration of consent to participate in a clinical trial can be revoked at any time in the presence of the investigator or a member of the investigating team, orally or in writing, without disadvantage to the trial participant. In the case of a revocation of consent, the study participant must decide whether their stored data may continue to be used.

Responsible Parties

As per the NITA-U-PrivAct, the data controller determines the purposes for and the manner in which personal data is processed or is to be processed. The “data processor” processes personal data on behalf of the data controller. Data controllers and processors must be registered with the Personal Data Protection Office (PDPO) of the National Information Technology Authority - Uganda (NITA-U). See the NITA-U-PrivAct, the NITA-U-PrivReg, and the PDPO-Note for detailed registration requirements.

Data Protection

As per the NITA-U-PrivAct, a data controller or processor must:

• Be accountable to the data subject for data collected, processed, held, or used
• Collect and process data fairly and lawfully
• Collect, process, use, or hold adequate, relevant, and not excessive or unnecessary personal data
• Retain personal data for the period authorized by law or for which the data is required
• Ensure quality of information collected, processed, used, or held
• Ensure transparency and participation of the data subject in the collection, processing, use, and holding of the personal data
• Observe security safeguards in respect of the data

The NITA-U-PrivReg indicates that every data collector, data processor, and data controller registered under the NITA-U-PrivReg must submit an annual report to the PDPO within 90 days after the end of every financial year. The report must contain a summary of all complaints received and the status of such complaints (including whether the complaint was resolved or is still pending), as well as all data breaches and the action taken to address such data breaches. See UGA-41 for a template of the annual report. See Part III of the NITA-U-PrivAct and NITA-U-PrivReg for detailed requirements on data processing, record retention, and processing of personal data outside Uganda.

Additionally, as per UGA-43, the PDPO launched a Data Protection and Privacy Compliance Toolkit to help organizations comply with NITA-U-PrivAct. The Toolkit is a comprehensive resource that includes practical tools, templates, and step-by-step guidance that organizations can use to assess their data protection practices, identify gaps, and take corrective actions. For more details and to access the toolkit, individuals should contact compliance@pdpo.go.ug.

According to the NGHRP, investigators must have mechanisms in place for ensuring safety, privacy, confidentiality, and proper disposal of research data, including electronic domains, such as anonymization delinking and/or strict custody of delinked identifiers. Data must be disposed of in a way that protects participant confidentiality. Disposal can be in the form of delinking, deleting, or destruction, and documents must be disposed of in a way that prevents reconstruction in an intelligible form. Request for disposal must be submitted to the institutional ethics committee (research ethics committee in Uganda) for approval with a notification to the Uganda National Council for Science and Technology (UNCST) prior to disposal of data.

For information on privacy and confidentiality requirements regarding open databases and digital migration, see the NGHRP.

Consent for Processing Personal Data

As delineated in the NITA-U-PrivAct, for the purposes of processing personal data, consent means any freely given, specific, informed, and unambiguous indication of the data subject’s wish which, by a statement or by a clear affirmative action, signifies agreement to the collection or processing of the data subject’s personal data.

According to the NITA-U-PrivAct, a data controller or data processor must obtain the consent of the data subject before collecting or processing personal data, and the data must be collected for a lawful, specific purpose. Unless otherwise provided under the NITA-U-PrivAct, a data subject has the right to object to the collection or processing of personal data at any time. See the NITA-U-PrivAct and NITA-U-PrivReg for detailed requirements on consent to data collection or processing, record retention, and processing of personal data outside Uganda.

The NITA-U-PrivAct and NITA-U-PrivReg further state that data subjects have a right to (Note: Each of the items listed below will not necessarily be found in both sources, which provide overlapping and unique elements):

• Request a data controller to give a description of the personal data held by the controller
• Prevent processing of personal data
• Appeal a decision to continue processing personal data
• Request a data controller to correct or delete personal data about the data subject that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully

See the NITA-U-PrivAct and NITA-U-PrivReg for more information on data subject rights.

Children

According to the NITA-U-PrivAct, personal data relating to children must not be collected or processed unless it is carried out with the prior consent of the parent/legal guardian; is necessary to comply with the law; or is for research or statistical purposes. The NITA-U-PrivReg further requires that every data collector, data processor, and data controller establish a system to determine the age of participants whose personal data is to be collected, processed, or stored, and where the data relates to a child, describe the manner of obtaining consent of a parent/legal guardian, where necessary.

Note: Per LBR-38, the National Research Ethics Board of Liberia (NREB) has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

Obtaining Consent

In accordance with the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. According to the G-ACRE-IRB and the G-NREB, the informed consent form (ICF) is viewed as an essential document that must be reviewed and approved by an ethics committee (EC).

As delineated in the LibCTReg, the trial participant should be informed of the nature, significance, and implications of the clinical trial and should provide a voluntary written informed consent. The trial participant or witness, if applicable, must be informed by an investigator, who is a healthcare professional or by a person designated by the investigator, and who is knowledgeable about the nature, significance, risks, and implications of the clinical trial, as well as about the participant’s right to withdraw from the clinical trial at any time. A generally comprehensible information sheet is to be handed out to the participant. The trial participant is also to be given the opportunity to have a counseling session with an investigator or a person designated by the investigator about the other conditions surrounding the conduct of the clinical trial.

The LibCTReg further notes that a declaration of consent to participate in a clinical trial can be revoked at any time in the presence of the investigator or a member of the investigating team, orally or in writing, without disadvantage to the trial participant. In the case of a revocation of consent, the study participant must decide whether their stored data may continue to be used. See also LBR-8 for additional consent guidelines.

Per the G-ACRE-IRB, the ACRE IRB must assess the research study to ensure the voluntary, non-coercive recruitment of research participants.

(See the Required Elements section for details on what should be included in the ACRE IRB and NREB forms. Refer to LBR-33 for the NREB Exempt Human Research Consent Script Form and LBR-34 for the NREB Short Consent Form.)

Re-Consent

Refer to LBR-8 for re-consent guidelines.

In addition, per the G-ACRE-IRB, in the case that ACRE IRB approval for a research protocol is reinstated, the ACRE IRB may require previously enrolled participants to re-consent.

Language Requirements

As stated in the G-LibClinTrial, all clinical trial application documentation must be submitted in English. If documents are written in another language, a certified translation is required.

Documenting Consent

As explained in the LibCTReg, if the trial participant is unable to read or write English, the informed consent should be obtained in the language the participant understands and in the presence of at least one (1) witness. The witness, who should be able to read and write English and understand the local language in which the trial participant is informed, should not be a member of the investigating team. The consent given by the trial participant must be documented in writing, dated, and signed by the witness and thumb printed by the trial participant.

LBR-34 also provides a sample NREB ICF for adults capable of consent. A witness must also be present during the consent process and must sign and date the ICF. The number of copies to be signed and distributed is not specified.

Waiver of Consent

No information is currently available from the LibCTReg, G-LibClinTrial, or G-NREB regarding clinical trial waivers.

As specified in the G-ACRE-IRB, to obtain a waiver or alteration of informed consent, the investigator must include the request (and provide justification for the waiver or alteration) in the protocol submission to the ACRE IRB. The request for waiver or alteration will be reviewed by the convened board, the ACRE IRB Chair, or the designated expedited reviewer. The ACRE IRB reviewer (Chair or designee) may approve the waiver or alteration of informed consent, if the board reviewer can establish that the research is to be conducted by or subject to the approval of state or local government officials and is designed to study, evaluate, or otherwise examine:

• Public benefit or service programs
• Procedures for obtaining benefits or services under those programs
• Possible changes in or alternatives to those programs or procedures, or
• Possible changes in methods or levels of payment for benefits or services under those programs

Per the G-ACRE-IRB, the ACRE IRB reviewer should also be able to ascertain that the research could not practicably be carried out without the waiver or alteration. In cases where the documentation requirement is waived, the IRB may require the investigator to provide participants with a written statement regarding the research, such as an information sheet, instead of an informed consent document.

Additionally, per the G-ACRE-IRB, the ACRE IRB reviewer may approve the waiver or alteration of informed consent, if the reviewer determines the following:

• The research involves no more than minimal risk to the participants
• The research could not practicably be conducted without the requested waiver or alteration
• If the research involves using identifiable private information or identifiable biospecimens, the research could not practicably be carried out without using such information or biospecimens in an identifiable format
• The waiver or alteration will not adversely affect the rights and welfare of the participants, and
• Whenever appropriate, the participants or legal representative/guardian will be provided with additional pertinent information after participation. The ACRE IRB reviewer will document the findings for waiver or alteration of informed consent. An alteration to informed consent may apply when conducting a study where there is deception or an incomplete disclosure (for example, studies that require deception because the study would be compromised if participants were told the true purpose)

In addition, the G-ACRE-IRB explains that a waiver of a signed ICF may be appropriate for some research studies such as survey or interview studies containing highly sensitive questions (e.g., health status, sexual practices, criminal behavior, etc.), or surveys containing non-sensitive information. To obtain a waiver of documented (signed) informed consent, the investigator must include the request (and provide justification for the waiver or alteration) in the protocol submission process. The request for waiver or alteration will be reviewed by the convened ACRE IRB, the Chair, or the designated expedited reviewer. The ACRE IRB reviewer will consider the investigator’s request and review the request to determine if:

• The only record linking the participant and the research would be the consent document, and the principal risk would be potential harm resulting from a breach of confidentiality
• The research presents no more than minimal risk of harm to participants and involves no procedures for which written consent is normally required outside of the research context
• The participants or legal representative/guardian are members of a distinct cultural group or community in which signing forms is not the norm, that the research presents no more than minimal risk of harm to participants, and provided that there is an appropriate alternative mechanism for documenting that informed consent was obtained. In cases where the documentation requirement is waived, the ACRE IRB may require the investigator to provide participants with a written statement regarding the research, such as an information sheet, instead of an informed consent document

Obtaining Consent

In all Ugandan clinical trials, a freely given informed consent is required to be obtained from each participant in accordance with the requirements set forth in the NGHRP and the G-TrialsGCP.

As per the NGHRP, the NDPA-CTReg, the G-CTConduct, and the G-TrialsGCP, the informed consent form (ICF) and the participant information leaflet are viewed as essential documents that must be reviewed and approved by an accredited institutional ethics committee (EC) (research ethics committee (REC) in Uganda) and provided to the National Drug Authority (NDA) with the clinical trial application. (See the Required Elements section for details on what should be included in the ICF.)

The G-TrialsGCP states that before informed consent may be obtained, the principal investigator (PI), or a person designated by the PI, should provide the participant or legal representative/guardian ample time and opportunity to inquire about details of the trial and to decide whether or not to participate in the trial. All questions about the trial should be answered to the satisfaction of the participant or legal representative/guardian. The NGHRP further indicates that seeking consent must be carried out under circumstances that provide the prospective research participant or legal representative/guardian sufficient opportunity to consider whether or not to participate, and that minimize the possibility of undue influence.

As stated in the NGHRP, an investigator must seek informed consent only after ascertaining that the prospective research participant has adequate understanding of the relevant facts and of the consequences of participation. The EC will require the investigator to administer a comprehension test (or test of understanding) to ensure that prospective research participants have acquired an adequate understanding of the relevant facts and of the consequences of participation.

Per the G-TrialsGCP, if a participant is unable to read or if the legal representative/guardian is unable to read, an impartial witness should be present during the entire informed consent discussion. The written ICF and any other written information to be provided to participants should be read and explained to the participant or legal representative/guardian. According to the NGHRP, the ICF must be read to illiterate prospective research participants in the presence of a literate witness. Verbal consent may be obtained in studies that present no more than minimal risk or in studies where for justifiable reasons written consent may not be feasible. ECs reserve the right to determine when verbal informed consent may be appropriate and acceptable.

Additionally, as stated in the G-TrialsGCP, the language used in the oral and written information about the trial, including the written ICF, should be as non-technical as practical and should be understandable to the participant or legal representative/guardian and the impartial witness, where applicable. Neither the PI, nor the trial staff, should coerce or unduly influence a participant to participate or to continue to participate in a trial. None of the oral and written information concerning the trial, including the written ICF, should contain any language that causes the participant or legal representative/guardian to waive or to appear to waive any legal rights, or that releases or appears to release the investigator, the institution, the sponsor, or their agents from liability for negligence and/or malpractice. The NGHRP adds that the investigator/designee must not interpret and must only read out or allow the potential/prospective participant to read the approved and stamped ICFs.

See the NGHRP and the G-TrialsGCP for detailed requirements for obtaining consent. Additionally, see the NGHRP for information on deferred, tiered, broad, and blanket consent.

Re-Consent

According to the G-TrialsGCP, the written ICF and any other written information to be provided to participants should be revised whenever important new information becomes available that may be relevant to the participant’s consent. Any revised written ICF and written information should receive the EC's approval/favorable opinion in advance of use. The participant or legal representative/guardian should be informed in a timely manner if new information becomes available that may be relevant to the participant’s willingness to continue participation in the trial. The communication of this information should be documented.

The NGHRP specifies that re-consent from participants must be obtained if there are changes in the conditions or procedures of the research or if new information becomes available that could affect the participant’s willingness to continue in the research. A surrogate/proxy must consent for a prospective participant who is unable to comprehend information for participation in the study. When the participant is able to comprehend, the participant must be re-consented to continue in the study.

Language Requirements

As per the NGHRP, the ICF should be provided in English and the relevant local language (where applicable). The G-TrialsGCP further indicates that for multicenter trials, the informed consent procedure must be tailored to local conditions, and ICFs must be translated into the local language and submitted to the EC for approval.

Documenting Consent

The G-TrialsGCP and the NGHRP state that prior to participation in the trial, the written ICF should be signed and personally dated by the participant or legal representative/guardian, and by the person who conducted the informed consent discussion.

The G-TrialsGCP delineates that the impartial witness for participants unable to read should sign and personally date the ICF, after the participant or legal representative/guardian has orally consented to the participation in the trial. If capable of doing so, the participant or legal representative/guardian should sign and personally date the ICF. By signing the ICF, the impartial witness attests that the information in the ICF and any other written information was accurately explained to, and apparently understood by, the participant or legal representative/guardian, and that informed consent was freely given.

According to the NGHRP, where the use of signed consent forms is not feasible, alternative viable methods like thumbprint must be employed.

The G-TrialsGCP and the NGHRP indicate that a copy of the signed ICF must be offered to the participant or legal representative/guardian prior to participation in the trial. The G-TrialsGCP further specifies that during the course of the trial, the participant or legal representative/guardian should receive a copy of the signed and dated consent form updates and a copy of any amendments to the written information provided to the participant.

As per the NGHRP, E-Informed Consent (eIC) must contain all the required components of informed consent. The use of eIC requires prior approval from the EC. The EC submission must also include the appropriate information materials, such as videos and web-based presentations. The investigator must demonstrate that the study population is able to comprehend and use E-consenting mechanisms. The copy of the eIC form provided to the participant may be in paper form, on an electronic storage device, or via email. If the copy includes one (1) or more hyperlinks to information on the Internet, the hyperlinks must be maintained and information must be accessible until study close-out. Measures for privacy and confidentiality of information must be available at the research entity. The EC and the Uganda National Council for Science and Technology (UNCST) must be granted access to records and reports made by the investigator, including site-specific versions of the eIC, materials submitted to the ECs, all amendments to the site-specific eICs, and all signed eICs. These must be available at the site, either in electronic or paper form. For more information on eIC documentation requirements, see the NGHRP.

Waiver of Consent

According to the NGHRP, an EC may waive some or all of the requirements for the investigator to obtain informed consent for some or all of the research participants if the EC determines that:

• The research study carries no more than minimal risk (risk that is no more than the risks encountered in daily life in a stable society)
• The research study could not practically be carried out without the waiver or alteration (whenever appropriate, the research participants will be provided with additional pertinent information after participation)
• Deception needs to be applied to achieve the objectives of the study
• The only record linking the research participant and the research study would be the ICF which would cause risk to the research participant resulting from a breach of confidentiality
• The human materials and data have been de-identified or anonymized

The NGHRP notes that many studies are carried out using data abstracted from clients’ records or other record sources, and the clients may not be reasonably available to provide informed consent. The investigator must request a waiver of consent from the EC to use such records for research. Relevant mechanisms must be put in place to ensure privacy and confidentiality in relation to identifiable data, including procedures such as anonymization and de-linking.

Note: Per LBR-38, the National Research Ethics Board of Liberia (NREB) has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

Liberia Medicines and Health Products Regulatory Authority

As specified in the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. Refer to LBR-8 for additional guidance on informed consent.

National Research Ethics Board of Liberia

The following elements are to be included in the NREB’s Exempt Human Research Consent Script Form (LBR-33) and the NREB Short Consent Form (LBR-34) respectively (Note: Each of the items listed below will not necessarily be found in both sources, which provide overlapping and unique elements):

• Statement indicating that the person is being asked to take part in a research study
• Research study purpose and the reason for participant’s eligibility to participate in study
• Duration of research study
• Participation is voluntary and participant may withdraw at any time
• Explanation of study-specific procedures and sample questions provided to participants
• Possible risks associated with participating in study
• Benefits to the participant or to others from participating in study
• Appropriate alternative procedures, or courses of treatment, if any
• Explanation of what is experimental vs. routine standard of care
• Statement regarding who will have access to the participant’s personal information
• Participant’s right to decline participating in any part of the study for any reason, their right to end participation at any time, and that refusal to participate will not be held against the participant
• Researcher’s contact information for any questions the participant may have prior to deciding to participate and throughout the participant’s involvement in the study

See LBR-33 and LBR-34 for additional details.

Per LBR-34, if applicable, the following information is also included in the NREB Short Consent Form:

• Whether the participant will get treated or paid if injured
• The possibility of unknown risks
• When the participant may be taken off the research study without the participant’s agreement
• Added costs from taking part in the study
• What will happen if the participant stops taking part
• Steps to safely stop taking part
• What new information will be shared with the participant
• The number of participants expected to take part in the study
• What happens to the participant’s collected data if the participant withdraws from the trial
• An explanation of the ClinicalTrials.gov (LBR-40) website

Atlantic Center for Research and Evaluation Institutional Review Board

The G-ACRE-IRB indicates that the principal investigator (PI) is responsible for preparing the informed consent form (ICF) and that the ICF should include the following statements or descriptions:

• The study involves research and an explanation of its purpose
• The expected duration of a participant’s involvement in the research
• A description of the procedures to be followed
• Identification of any experimental study procedures
• Any foreseeable risks or discomforts to the participant
• Any benefits to the subject or to others that may reasonably be expected from the research
• Alternative procedures or treatment that may be available to the participant, and if any, which might be advantageous to the participant
• A statement describing the extent to which, if any, confidentiality of records identifying the participant will be maintained
• A statement noting the possibility that the EC (or its designees) and the study sponsor may inspect the study records, if the research is sponsored by a funding source
• For research involving more than minimal risk, an explanation of compensation and/or medical treatment available to the participant, or to the participant’s family or dependents, in the event of a trial-related injury, and if injury occurs, what the medical treatments consist of, or where further information may be obtained
• The person(s) to contact for further information regarding the trial and the rights of research participants, and whom to contact in the event of research-related injury
• Participation is voluntary, the participant may withdraw at any time, and refusal to participate will not involve any penalty or loss of benefits, or reduction in the level of care to which the participant is otherwise entitled

In addition to the required elements listed above, per the G-ACRE-IRB, for research involving the collection of identifiable private information or identifiable biospecimens, one (1) of the following must be included in the informed consent:

• A statement that identifiers will be removed from the identifiable private information or identifiable biospecimens and that, after such removal, the information or biospecimens could be used for future research studies without additional informed consent from the participant or legal representative/guardian
• A statement that the participant's information or biospecimens collected as part of the research, even if identifiers are removed, will not be used or distributed for future research studies

See also the Consent for Specimen section for additional information on informed consent relating to specimens.

Based on the NGHRP and the G-TrialsGCP, the informed consent form (ICF) should include the following statements or descriptions, as applicable (Note: Each of the items listed below will not necessarily be found in both sources, which provide overlapping and unique elements):

• The study involves research and an explanation of its nature and purpose
• The procedures to be followed, including all invasive procedures
• The expected duration of the trial
• The trial treatment(s) and the probability for random assignment to each treatment (where appropriate)
• The participant's responsibilities
• Those aspects of the trial that are experimental
• Any reasonably foreseeable risks or discomforts to the participant (when applicable, to an embryo, fetus, or nursing infant), and whether the project involves more than minimal risk
• Where relevant, any benefits to the participant and/or their community that may be reasonably expected from the study, including potential benefits of commercial value; if no benefit is expected, the participant should also be made aware of this
• The alternative procedure(s) or course(s) of treatment that may be available to the participant, and their potential benefits and risks
• The extent, if any, to which the participant’s privacy and confidentiality will be maintained, including anonymization and de-identification of data and biological samples
• Allowed access by the sponsor, National Drug Authority (NDA), Uganda National Council for Science and Technology (UNCST), relevant institutional ethics committee (EC) (research ethics committee (REC) in Uganda), and/or other regulatory authority including international regulatory authorities (pending that they have received permission to do so from UNCST) to participant records
• The policy on compensation and/or medical treatment(s) available to the participant in the event of a trial-related injury within the framework of clinical trials insurance and where further information may be obtained
• Where applicable, a statement of how the investigator will provide or facilitate access to medical services to the participant
• The nature, form, and extent of compensation for participation (e.g., reimbursement for transport, time, effort, inconvenience, and refreshments)
• The identity of a sponsor and any potential conflict of interests
• A brief description of sponsors of the research study and the organizational affiliation of the investigators
• A contact name and number of the principal investigator and/or site investigator
• Names and contact details of individual(s) to be contacted at any time in case of questions about the research study, and/or about the participants’ rights and welfare
• The individual(s) obtaining informed consent must be able to communicate in a language understandable to the participant
• Participation is voluntary, the participant can withdraw from the study at any time, and withdrawal or refusal to participate will not involve any penalty or loss of benefits to which the participant is otherwise entitled
• A statement that participants will get feedback on findings and progress of the study, and that any new information that affects the study will be made available to research participants and/or their health care providers, including the participant’s willingness to continue participation
• The study has been approved by an accredited Ugandan-based EC
• A statement that a particular treatment or procedure may involve risks to the participant (or to the embryo or fetus, if the participant is or may become pregnant), which are currently unforeseeable
• The foreseeable circumstances and/or reasons under which the investigator may terminate participation in the trial, whether or not the participant consents to such termination
• Additional costs/expenses to the participant that may result from participation in the study
• The consequences of a participant’s decision to withdraw from the research and procedures for orderly withdrawal by the participant. Participants may withdraw at any time without further notice, and investigators must not follow up with participants who have withdrawn from the study
• The approximate number of participants in the research study
• For new and emerging technologies and innovations in treatment and/or intervention that have been shown to be efficacious, efforts for post-research access must be made
• If the research involves collecting human materials, participants must be provided with an explanation on how specimens will be managed at the end of the study. If samples will be stored for future use, a separate consent must be obtained
• That data and/or biological specimens may be used for commercial purposes and the extent to which the participants and/or their communities may benefit directly or indirectly
• Whether, when, and how any of the products or interventions proven by the study to be safe and effective will be made available to participants at the end of the study, and if the participants will be expected to pay for them

Compensation Disclosure

According to the G-TrialsGCP, the sponsor must ensure that information on incentives offered to participants is included in the informed consent documents. If the study is multicenter, information on the incentives given at all the different trial sites must be provided. If the participating sites are multinational, then the differences in the incentives across the sites must also be explained.

Note: Per LBR-38, the National Research Ethics Board of Liberia (NREB) has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

Overview

As specified in the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. The G-ACRE-IRB also complies with the Council for International Organizations of Medical Sciences (CIOMS)’ International Ethical Guidelines for Health-related Research Involving Humans (LBR-2) and the national ethical guidelines for research on human participants.

The G-ACRE-IRB states that a participant’s rights must also be clearly addressed in the informed consent form (ICF) and during the informed consent process.

The Right to Participate, Abstain, or Withdraw

As set forth in the G-ACRE-IRB, LBR-33, and LBR-34, the participant or legal representative/guardian should be informed that participation is voluntary, that the participant may withdraw from the research study at any time, and that refusal to participate will not involve any penalty or loss of benefits to which the participant is otherwise entitled.

The Right to Information

As per the G-ACRE-IRB, LBR-33, and LBR-34, a potential research participant or legal representative/guardian has the right to be informed about the nature and purpose of the research study, its anticipated duration, study procedures, any potential benefits or risks, any compensation for participation or injury/treatment, and any significant new information regarding the research study. (See the Required Elements section for a more detailed list.)

The Right to Privacy and Confidentiality

As per the G-ACRE-IRB, all participants must be afforded the right to privacy and confidentiality, and the ICF must provide a statement that recognizes this right.

The Right of Inquiry/Appeal

The G-ACRE-IRB, LBR-33, and LBR-34, state that the research participant or legal representative/guardian should be provided with contact information for the sponsor and the investigator(s) to address trial-related inquiries.

The Right to Safety and Welfare

The G-ACRE-IRB states that ethics committees review and approve all research proposals involving research participants with a view to safeguarding their dignity, rights, safety, and well-being. The goals of research, however important, should never be permitted to override the health and well-being of the participants.

(See the Required Elements and Vulnerable Populations sections for additional information regarding requirements for participant rights.)

Overview

The G-TrialsGCP states that in obtaining and documenting informed consent, the principal investigator (PI) or delegate should comply with the ethical principles that have their origin in the Declaration of Helsinki (UGA-27), the NGHRP, and the G-TrialsGCP. Additionally, in accordance with the NGHRP and the G-TrialsGCP, a participant’s rights must be clearly addressed in the informed consent form (ICF) and during the informed consent process.

See the Required Elements; Vulnerable Populations; Children/Minors; Pregnant Women, Fetuses & Neonates; Prisoners; and Mentally Impaired sections for additional information regarding requirements for participant rights.

The Right to Participate, Abstain, or Withdraw

As set forth in the NGHRP and the G-TrialsGCP, the participant or legal representative/guardian should be informed that participation is voluntary, that the participant may withdraw from the research study at any time, and that refusal to participate will not involve any penalty or loss of benefits to which the participant is otherwise entitled.

The Right to Information

According to the NGHRP and the G-TrialsGCP, a potential research participant or legal representative/guardian has the right to be informed about the nature and purpose of the research study, its anticipated duration, study procedures, any potential benefits or risks, any compensation for participation or injury/treatment, and any significant new information regarding the research study.

The Right to Privacy and Confidentiality

The NGHRP and the G-TrialsGCP indicate that all participants must be afforded the right to privacy and confidentiality, and the ICF must provide a statement that recognizes this right. It is the responsibility of the investigator(s) to safeguard the confidentiality of research data to protect the identity and records of research participants.

The Right of Inquiry/Appeal

As per the NGHRP and the G-TrialsGCP, the research participant or legal representative/guardian should be provided with contact information for the investigator(s) and the institutional ethics committee (EC) (research ethics committee (REC) in Uganda) to address trial-related inquiries in the event of any injury and/or to appeal against a violation of the participants’ rights.

The Right to Safety and Welfare

The NGHRP states that research and development, including scientific investigations involving humans as research participants, must be conducted for the benefit of communities without causing unnecessary harm or inconvenience and must not compromise the rights and welfare of participants. In order to protect the rights and welfare of participants, research must be conducted in accordance with the basic research ethics principles: respect for persons, beneficence, non-maleficence, and justice.

As set forth in the LibCTReg, in an emergency situation where consent cannot be obtained, treatment which is necessary without delay to save the life of the trial participant can be started immediately. Such situations must be defined by the Liberia Medicines and Health Products Regulatory Authority (LMHRA) and consent for continued participation must be obtained as soon as possible, and not later than the timeframe specified by the National Research Ethics Board of Liberia (NREB) for a given clinical trial. Additionally, in these cases, the LMHRA may apply an expedited application and review process for clinical trials and make exemptions to the documentation requirements for clinical trial application submissions.

The LibCTReg and the G-LibClinTrial further explain that the LMHRA has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. Refer to LBR-8 for additional guidelines on emergency consent requirements.

Per the G-LibClinTrial, examples of emergency situations are epidemics or other urgent public health interests that require fast utilization of new medicines or health products and/or fast gathering of information on products. Information provided to clinical trial participants about the process of obtaining consent must be included in the documents submitted to the LMHRA. Refer to 2.3 of the G-LibClinTrial for additional information on how to submit an expedited clinical trial application package.

The NGHRP allows the use of deferred consent in emergency clinical research where the participant or legal representative/guardian is incapable of providing informed consent. The participant must consent once the participant is able to comprehend the information provided, and relevant documentation of this instance(s) must be provided by the investigator. Deferred consent must be clearly justified by the investigator, and the institutional ethics committee (EC) (research ethics committee (REC) in Uganda) must give approval to the research procedure.

The G-TrialsGCP further states that in emergency situations, when prior consent of the participant is not possible, the consent of the legal representative/guardian, if present, should be requested. When prior consent of the participant is not possible and the legal representative/guardian is not available, enrollment of the participant should require measures that are described in the protocol and/or elsewhere, with documented approval by the EC, to protect the rights, safety, and well-being of the participant and to ensure compliance with applicable regulatory requirements. The participant or legal representative/guardian should be informed about the trial as soon as possible and provide consent to continue or other consent as appropriate, should this be requested.

Overview

The LibCTReg and the G-LibClinTrial explain that the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. Refer to LBR-8 for consent guidelines applicable to vulnerable populations.

Persons with Diseases

As indicated in the LibCTReg, in the case of a clinical trial involving a person of legal age who is suffering from a disease for which the investigational product (IP) is to be used, one (1) of the following conditions should be applied along with the general clinical trial requirements delineated in the LibCTReg:

• The use of the IP is indicated according to the findings of medical science in order to save the person's life
• The IP must be of direct benefit to the group of patients who are suffering from the same disease as this person

Persons Under Legal Disability

As set forth in the LibCTReg, “persons under legal disability” are defined as being under the same category as a minor in terms of the individual’s ability to grant consent, except that the person under disability may be above the age of consent (18 years), but may be too ill to participate in decisions regarding their own health. In this case, priority is not given to parents or next of kin to petition the Probate Court for Guardianship, but priority is given to any natural person who demonstrates best interest in the welfare of the disabled.

The LibCTReg further explains that a person under legal disability may participate in a trial, if their parents/legal guardians have been informed of the nature, significance, and implications of the clinical trial and have given a written voluntary informed consent. If the informed implication is grave, it may be necessary for the guardian to secure the permission from the Probate Court before granting consent, due to the fact that the Decree of Guardianship has a clause that the Court appointed guardian should not release the disabled person to any other body in which case their welfare will be put at peril. Otherwise, it can be argued that the appointed guardian has breached their fiduciary duty to the Court by releasing the disabled person to peril.

See the Children/Minors and Mentally Impaired sections for additional information about these vulnerable populations.

Overview

According to the NGHRP, additional safeguards must be included in a study to protect vulnerable populations. Vulnerable populations are characterized as groups or individuals who are incapable of protecting their interests due to insufficient power, intelligence, knowledge, education, resources, strength, or other requisite attributes. Those with a limited capacity or freedom to freely provide or decline consent may also be considered vulnerable. Vulnerable populations include children/minors, older persons, prisoners, the homeless, refugees, internally displaced persons, substance abusers, mentally and physically handicapped, armed forces personnel, terminally ill, pregnant women, fetuses, and minority groups. Characteristics that constitute vulnerability in such populations include one (1) or more of the following:

• Limited economic empowerment
• Conflict and post-conflict situations and inadequate protection of human rights
• Discrimination on the basis of health status
• Limited availability of health care and treatment options
• Communities in acute disaster and disease epidemics
• Communities that may criminalize certain behavior

As per the NGHRP and the G-TrialsGCP, vulnerable participants also include individuals whose willingness to volunteer in a clinical trial may be unduly influenced by the expectation, whether justified or not, of benefits associated with participation, or of a retaliatory response from senior members of a hierarchy in case of refusal to participate. The G-TrialsGCP adds that examples include members of a group with a hierarchical structure, such as medical, pharmacy, dental, and nursing students, subordinate hospital and laboratory personnel, employees of the pharmaceutical industry, workers in settings where research studies are conducted, members of the armed forces or police, and persons kept in detention.

The NGHRP states that there must be a provision for involvement of the community in the research process right from inception to post research period. Additionally, to protect vulnerable individuals or groups/communities, the institutional ethics committee (EC) (research ethics committee (REC) in Uganda) must ensure that:

• Selection of communities is justified by the research goals
• Research is responsive to the needs and priorities of the community where it is to be conducted
• Research can only be conducted in the group and with the individuals if the objectives of the research cannot be addressed using non-vulnerable groups and individuals
• Risk of participating in research is justified by anticipated benefits
• The intervention or procedure presents experiences that are commensurate with those inherent in their actual or expected medical, dental, psychological, social, or educational situations
• The intervention or procedure is likely to yield generalizable knowledge about the group or individual’s disorder or condition that is of vital importance for the understanding or amelioration of that disorder or condition
• ECs must co-opt a person knowledgeable about and that has experience working with the vulnerable group and/or individuals
• For pregnant women and fetuses, relevant studies on animals and non-pregnant individuals have been completed

The G-TrialsGCP further indicates that special protections for vulnerable populations can include:

• Allowing no more than minimal risks for procedures that offer no potential individual/direct benefits for participants
• Supplementing the participant’s agreement by the permission of family members, legal guardians, or other appropriate representatives
• Requiring that the research be carried out only when it is targeting conditions that affect these populations
• Safeguards can be designed to promote voluntary decision-making, limit the potential for confidentiality breaches, and otherwise work to protect the interests of those at increased risk of harm
• Appointment of advocates to the EC when such proposals for clinical trials on institutionalized individuals are under review

See the Children/Minors and Pregnant Women, Fetuses & Neonates sections for additional information about these vulnerable populations. See the NGHRP and the G-TrialsGCP for more examples of and details on vulnerable populations.

Note: Per LBR-38, the National Research Ethics Board of Liberia (NREB) has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

According to the LibCTReg and the G-NREB, Liberia defines children and minors as those persons under 18 years of age. The G-NREB also defines adolescents as those between the ages of 15 and 17.

The LibCTReg also states that the definition of a legal guardian or “legal representative of a minor” is based on the premise that a minor cannot grant consent or enter into an agreement. The interest of a minor must be firstly protected by the parents (the father, if the parents are married or the child is legitimized), or the mother of the child, if the parents are not married. Where there is no parent alive, especially the mother, if the child is not born out of wedlock or not legitimized, any next of kin, preferably the grandparents first, the siblings second, or any person with interest in the welfare of the child, may petition the Probate Court for Decree of Guardianship. A guardian must be authorized to give consent for the minor child. No institution can serve as guardian and give consent for research on the child. A guardian must be a natural person, not an institution.

Additionally, per the LibCTReg, a minor may participate in a trial if their parents/legal guardians have been informed of the nature, significance, and implications of the clinical trial and have given a written, voluntary informed consent. If the implication of the trial is grave, it may be necessary for the guardian to secure permission from the Probate Court before granting consent, due to the fact that the Decree of Guardianship contains a clause stating that the Court appointed guardian should not release the minor to any other body where their welfare will be put in peril. Otherwise, it can be argued that the appointed guardian has breached their fiduciary duty to the Court by releasing the minor or disabled to peril.

Also, as indicated in LibCTReg, in the case of a clinical trial on a minor who suffers or may suffer from a disease for which the investigational product (IP) is to be used, the following conditions should be applied:

• The use of the IP must be indicated according to the findings of medical science in order to save the life of the trial participant, to restore the participant to health, to alleviate suffering, or to prevent a disease
• The clinical trial must be of direct benefit to the group of patients suffering from the same disease as the trial participant
• The research must be absolutely necessary in order to confirm data obtained in clinical trials on other persons or by means of other research methods
• The research must relate to a clinical condition from which the minor concerned is suffering or may suffer
• The research may cause only minimal risk and minimal burden to the trial participant

LBR-34 provides a sample NREB informed consent form (ICF) for children that explains the parents’ or guardian’s signatures document their permission for the child to take part in a research study as well as their permission for the use and disclosure of the child’s protected health information. If a second parent’s signature is not obtained, the first parent or guardian needs to choose one (1) of the following options on the form to justify why this is not possible:

• The ethics committee (EC) has determined that the permission of one (1) parent is sufficient (this option is only listed on the form if it has been approved by the EC)
• Second parent is deceased
• Second parent is unknown
• Second parent is incompetent
• Second parent is not reasonably available
• Only one (1) parent has legal responsibility for the care and custody of the child

In addition, per LBR-34, an individual may provide permission as a guardian for a child only if that individual can provide a written document indicating that the individual is legally authorized to consent to the child’s general medical care and this documentation must be attached to the signed ICF. The EC must also approve the consent form, a witness must be present during the consent process, and the witness must sign and date the ICF.

As delineated in the G-ACRE-IRB, the ACRE IRB must classify research involving children into one (1) of four (4) categories and document its discussion of the risks and benefits of the research study in order to approve such research. The risk/benefit categories are as follows:

• When the ACRE IRB determines that the risk is no more than minimal to children in a study, it may approve the research only if adequate provisions are made for soliciting the assent of the children and the permission of their parents or legal guardians
• When the ACRE IRB determines that more than minimal risk to children is presented by a procedure that holds the prospect of direct benefit to an individual child, or by a monitoring procedure that is likely to contribute to the child’s well-being, the ACRE IRB may approve the research if it is established that: the risk is justified by the anticipated benefit to the children; the relation of the anticipated benefit to the risk is at least as favorable to the children as that presented by available alternative approaches; and adequate provisions are made for soliciting the assent of the children and permission of their parents or legal guardians
• When the ACRE IRB determines that the study presents more than minimal risk to children and does not hold out the prospect of direct benefit for the individual child, but is likely to contribute generalizable knowledge about the child’s disorder or condition, the board may approve the research if it established that: the risk represents a minor increase over minimal risk; the study intervention or procedure presents experiences to participants that are reasonably commensurate with those inherent in their actual or expected medical, dental, psychological, social, or educational situations; the intervention or procedure is likely to yield generalizable knowledge about the participants’ disorder or condition that is of vital importance for the understanding or improvement of the participants’ disorder or condition; and adequate provisions are made for soliciting the assent of the children and permission of their parents or legal guardians
• When the ACRE IRB determines that the research does not meet the requirements in any of the above three (3) categories, the board may only approve the research if it finds that the study presents a reasonable opportunity to further the understanding, prevention, or alleviation of a serious problem affecting the health or welfare of children

The G-ACRE-IRB further states that the ACRE IRB should ensure that adequate permissions are made for soliciting the permission of each child’s parent/legal guardian. The following provisions are used depending on the category of research:

• Research not involving greater than minimal risk to children: Where parental permission is to be obtained, the ACRE IRB may suggest that the permission of one (1) parent is sufficient for research not involving greater than minimal risk
• Research involving greater than minimal risk but presenting the prospect of direct benefit to the individual child: Where parental permission is to be obtained, the board may suggest that the permission of one (1) parent is sufficient for research involving greater than minimal risk but presenting the prospect of direct benefit to the individual participants
• Research involving greater than minimal risk and no prospect of direct benefit to the individual child, but likely to yield generalizable knowledge about the child’s disorder or condition: When the research is approved under this category, both parents must give their permission unless one (1) parent is deceased, unknown, incompetent, not reasonably available, or when only one (1) parent has legal responsibility for the care and custody of the child

If the ACRE IRB determines that a research study is designed for a participant population for which approval from the parents and/or legal guardian(s) or representative(s) is not reasonably required to protect the participants (e.g., neglected or abused children), the G-ACRE-IRB indicates that the consent requirements may be waived. In order to protect the rights and welfare of children in a research study, the board should consider the involvement of a court appointed guardian.

Assent Requirements

Per the LibCTReg, an assent form must be signed, and, if possible, dated by the minor. Similarly, per the G-LibClinTrial, when the research participant is a minor, the investigator must obtain assent from the child/minor. The G-NREB also indicates that both written parental consent and assent forms should be completed for children less than 18 years of age. Per LBR-34, the child’s assent should also be attained unless this can be justified by one (1) of the following reasons:

• The EC determined that assent of the child was not a requirement
• The capability of the child is so limited that the child cannot reasonably be consulted

According to LBR-34, the EC must approve the assent form, a witness must be present during the consent process, and the witness must sign and date the ICF.

As indicated in the G-ACRE-IRB, for research reviewed and approved by the ACRE IRB, adequate provisions for the assent of children include the following:

• Children capable of assenting: After the ACRE IRB determines that a child is capable of assenting, the proposed research procedures should be explained to the child in a language that is appropriate to the age, experience, maturity, and condition of the child and should include any discomforts and inconveniences the child may experience if the child agrees to participate in the study
• The option to withdraw: As they are in the developmental stage, children should be asked if they do or do not wish to participate in the research, especially where the research does not involve interventions likely to be of benefit to the participants but that they will be volunteers for the benefit of others
• The signing of assent or consent: When an assent requirement is established, the investigator or the designee and the child (when appropriate) will sign the study consent form. When it is inappropriate for the child to sign the form (due to age or ability), the board requires that the document be signed by the investigator (or the designee) and the parent/legal guardian

Per the G-ACRE-IRB, the ACRE IRB may determine that assent may be waived if the capability of some or all of the children is so limited that they cannot reasonably be consulted; or the intervention or procedure involved in the research has a direct benefit to the health or well-being of the children and is available only in the context of the research. In such instances, a child’s dissent which should normally be respected, may be overruled by the child’s parents at the discretion of the board (for example, when a research study involves providing experimental therapies for life-threatening diseases, such as Ebola Virus Disease, severe COVID-19, or cancer, parents may wish to try anything to help their children, even with the likelihood of success being uncertain). If the child is a mature adolescent, the child’s wishes should be respected.

The NGHRP and the G-CTChldrnWmn define a child as a person below the age of 18.

According to the G-CTChldrnWmn, data supporting the conduct of a clinical trial involving children should demonstrate that the benefit to the population outweighs the risk. For interventions or procedures that have no potential individual benefits for children:

• The risks must be minimized and no more than minimal;
• The purpose of the research must be to obtain knowledge relevant to the particular health needs of the population;
• The social value of the research for the children is compelling, and the research cannot be conducted in any other population; and
• Any research-related risk is the least possible for achieving the objectives of the research

Assent Requirements

The NGHRP requires assent to participate in research from all children aged eight (8) to 17. A researcher intending to conduct research involving children must obtain informed consent from the parents/legal guardians. However, the child’s assent or dissent takes precedence over the parent’s/legal guardian’s consent. For research involving more than minimal risk, parental consent must be sought from both parents of a child unless one (1) of the parents is reasonably unavailable. If the parents/legal guardians of the child cannot be reasonably traced, and the child needs to participate in research, the investigator must apply to a court for an order to waive the consent requirement.

According to the NGHRP, the assent forms must be in a language that is comprehensible by an eight (8) year old. Where applicable, relevant illustrations of the study procedures may be used. The investigator must ensure continued adequacy of the informed consent process, and obtain re-consent from participants, including consent for continued storage of samples, when they attain the age of majority (18 years).

The G-CTChldrnWmn further indicates that for pediatric studies, adequate provisions should be made for soliciting the assent of the children and permission of their parents/legal guardians. Investigators should provide an understandable age-specific informed assent and information sheet for children.

Note: Per LBR-38, the National Research Ethics Board of Liberia (NREB) has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

As set forth in the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. Refer to LBR-8 for additional guidance on informed consent applicable to embryos, fetuses, and nursing infants.

As stated in the G-ACRE-IRB, for clinical research studies using the ACRE IRB, pregnant women or fetuses may be involved in research if all the following conditions are met:

• Where scientifically appropriate, preclinical studies, including studies on pregnant animals, and clinical studies, including studies on non-pregnant women, have been conducted and provide data for assessing potential risks to pregnant women and fetuses
• The risk to the fetus is caused solely by the interventions or procedures considered directly beneficial for the woman or the fetus; or, if there is no such prospect of specific benefit, the risk to the fetus is not greater than minimal and the purpose of the research is for the development of important biomedical knowledge which cannot be obtained by any other means
• Any risk is the least possible for achieving the objectives of the research
• Consent is obtained in accordance with the informed consent provisions in the G-ACRE-IRB if the research holds out the prospect of direct benefit to a pregnant woman; the prospect of a direct benefit both to the pregnant woman and the fetus, or no prospect of benefit to either the woman or the fetus when risk to the fetus is not greater than minimal; and the purpose of the research is the development of important biomedical knowledge that cannot be obtained by any other means
• If the research holds the prospect of direct benefit solely to the fetus, then the consent of the pregnant woman and the father is obtained in accordance with the informed consent provisions in the G-ACRE-IRB, except that the father’s consent need not be obtained if he is unable to consent due to unavailability, incompetence, or temporary incapacity, or, the pregnancy resulted from rape or incest (close relationship)
• Each person providing consent is fully informed regarding the foreseeable impact of the research on the fetus and/or resultant child
• For children who are pregnant, assent and permission are obtained in accordance with the provisions for children indicated in this guideline
• No inducements, monetary or otherwise, will be offered to terminate a pregnancy
• Individuals engaged in the research will have no part in any decisions as to the timing, method, or procedures used to terminate a pregnancy
• Individuals engaged in the research will have no part in determining the viability of a fetus

The G-CTChldrnWmn states that data supporting the conduct of a clinical trial involving pregnant/lactating women should demonstrate that the benefit to the population outweighs the risk. For interventions or procedures that have no potential individual benefits for pregnant/lactating women:

• The risks must be minimized and no more than minimal;
• The purpose of the research must be to obtain knowledge relevant to the particular health needs of the population;
• The social value of the research for the pregnant/lactating women is compelling, and the research cannot be conducted in any other population; and
• Any research-related risk is the least possible for achieving the objectives of the research

According to the G-CTChldrnWmn, legally valid consent should be obtained from the participant or spouse as appropriate and in line with the NGHRP. The NGHRP indicates that for interventional research involving pregnant women, informed consent must be obtained from both the mother and father of the fetus. However, the father's consent is not required if: (i) the purpose of the study is primarily to meet the mother's health needs; (ii) the father's identity and/or whereabouts are unknown; (iii) the father is not reasonably available; (iv) the pregnancy resulted from rape or incest; and (v) the father is incompetent to give consent.

The G-CTChldrnWmn further indicates that for clinical trials involving pregnant women that have the potential for harm to the fetus, the participant should be informed about the potential risks, and research should be conducted only after assessing that the benefits (to the mother or fetus, as appropriate) outweigh the risk involved, and with informed consent of the participants.

(See the Required Elements section for general informed consent form requirements.)

Note: Per LBR-38, the National Research Ethics Board of Liberia (NREB) has sole responsibility to review all clinical trial protocols in Liberia. Per LBR-28, due to a Memorandum of Understanding (MOU) between the NREB and the Atlantic Center for Research and Evaluation Institutional Review Board (ACRE IRB) in 2022, all clinical trial protocols submitted to the ACRE IRB are referred to the NREB. Therefore, the information and requirements from the G-ACRE-IRB described in the ClinRegs Liberia profile only apply to human participants research other than clinical trials.

Pursuant to the G-ACRE-IRB, for clinical research studies using the ACRE IRB, due to the vulnerability of prisoners, research involving prisoners should be reviewed by a fully convened ACRE IRB. Per the G-ACRE-IRB, the ACRE IRB may only approve research projects involving prisoners if the research falls under one (1) of the following categories:

• Study of possible causes, effects, and processes of incarceration, and of criminal behavior, provided that the study presents no more than minimal risk or inconvenience to the participant
• Study of prisons as institutional structures or of prisoners as incarcerated persons, provided that the study presents no more than minimal risk and no more than inconvenience to the participants
• Research on conditions particularly affecting prisoners as a class
• Research on practices that are intended and have the probability of improving the health or well-being of the participants

In addition, per the G-ACRE-IRB, the ACRE IRB must review research involving prisoners and approve such research only if it finds that:

• The risks involved in the research are commensurate with risks that would be accepted by non-prisoner volunteers
• Procedures for the selection of participants within the prison are fair to all prisoners, and free of arbitrary interference by prison authorities or prisoners. Other than the investigator’s justification to the ACRE IRB, the use of other procedures, and the selection of control participants from the available prisoner population for a particular research study should be randomly done
• The information is presented in a language that is understandable to the participant population
• There is adequate assurance that parole boards will not take into account a prisoner’s participation, withdrawal, or lack of participation in the research in making decisions regarding parole, and each prisoner is clearly informed in advance that their participation, withdrawal, or lack of participation in the research will have no effect on their parole
• The ACRE IRB should ensure that adequate provisions are made where there will be a follow-up examination or care of participants after the end of their participation, considering the variable lengths of individual prisoners’ sentences, and informing participants of this information

The G-TrialsGCP states that residents of prisons are often considered vulnerable because in a confined setting, they have few options and are denied certain freedoms that non-institutionalized persons enjoy. Some individuals with this characteristic may also have diminished capacity to consent and therefore require additional protections for participants who lack decisional capacity. Institutional ethics committees (ECs) (research ethics committees (RECs) in Uganda) must review the need for special protection of the rights and welfare of these vulnerable populations and include protections when necessary.

As set forth in the LibCTReg, “persons under legal disability” is defined as being under the same category as a minor in terms of the individual’s ability to grant consent, except that the person under disability may be above the age of consent (18 years) even though the person may lack the mental capacity to reason properly and grant consent. In this case, priority is not given to parents or next of kin to petition the Probate Court for Guardianship, but priority is given to any natural person who demonstrates the best interest in the welfare of the disabled.

The LibCTReg further explains that a person under legal disability may participate in a trial, if their parents/legal guardians have been informed of the nature, significance, and implications of the clinical trial and have given a written voluntary informed consent. If the informed implication is grave, it may be necessary for the guardian to secure permission from the Probate Court before granting consent, due to the fact that the Decree of Guardianship has a clause that the court-appointed guardian should not release the disabled person to any other body where their welfare will be put at peril. Otherwise, it can be argued that the appointed guardian has breached their fiduciary duty to the court by releasing the disabled person to peril.

Also, as indicated in LibCTReg, in the case of a clinical trial on a person of legal age who is incapable of comprehending the nature, significance, and implications of a clinical trial and of determining their will in light of these facts, and who is also suffering from a disease which is to be treated by the investigational product (IP), the following conditions should be applied:

• The use of the IP must be indicated, according to the findings of medical science, in order to save the life of the trial participant, to restore the participant to health, or to alleviate suffering
• The research must relate directly to a life-threatening or to a highly debilitating clinical condition suffered by the trial participant, and the clinical trial may involve as little burden and other foreseeable risks as possible for the trial participant. Both the degree of burden and the risk threshold must be defined specifically in the trial protocol and monitored constantly by the investigator. The clinical trial may only be conducted if there is a justified expectation that the benefits of using the IP for the trial participant outweigh the risks
• Consent should be given by the legal representative/guardian after the participant has been duly informed per the general clinical trial requirements in LibCTReg
• The research must be absolutely necessary for the confirmation of data obtained from clinical trials conducted on persons capable of granting informed consent or by means of other research methods
• With the exception of adequate compensation, no advantages may be granted

Additionally, as per the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines.

LBR-34 provides a sample National Research Ethics Board of Liberia (NREB) informed consent form (ICF) for adults unable to consent, which explains that the signature of the legally authorized representative documents their permission for the participant named in the ICF to take part in this research study, as well as their permission for the use and disclosure of the participant’s protected health information. The participant’s assent should also be attained unless this can be justified by one (1) of the following reasons:

• The EC determined that assent of the participant was not a requirement
• The capability of the participant is so limited that the participant cannot reasonably be consulted

The previously listed options are only available if they have been approved by the ethics committee. A witness must also be present during the consent process and the witness must sign and date the ICF.

The G-TrialsGCP states that residents of mental institutions are often considered vulnerable because in a confined setting, they have few options and are denied certain freedoms that non-institutionalized persons enjoy. Some individuals with this characteristic may also have diminished capacity to consent and therefore require additional protections for participants who lack decisional capacity. Institutional ethics committees (ECs) (research ethics committees (RECs) in Uganda) must review the need for special protection of the rights and welfare of these vulnerable populations and include protections when necessary.

The NGHRP requires assent to participate in research from mentally incapacitated individuals in accordance with their evolving capacity. Assent of an individual incapable of self-determination is obtained after consent from the legal representative/guardian. The individual’s dissent takes precedence over consent by the legal representative/guardian.

Per the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. Refer to LBR-8 for detailed investigational product guidelines and definitions.

As delineated in LibCTReg, an investigational product (IP) is defined as a pharmaceutical form of an active ingredient or placebo being tested or used as a reference in a clinical trial. This includes a product with a marketing authorization when it is used or assembled (formulated or packaged) in a different way from the approved form, when used for an unapproved indication, or when used to gain further information about an approved use. In Liberia, IPs are referred to as investigational medicinal products (IMPs).

As delineated in the NGHRP, the NDPA-CTReg, the G-CTConduct, the G-GMPAnnexes, and the G-TrialsGCP, an investigational product (IP) (also referred to as an investigational medicinal product (IMP) in Uganda) is defined as a pharmaceutical form of an active ingredient or a placebo being tested or used as a reference in a clinical trial. Per the NDPA-CTReg, the G-CTConduct, the G-GMPAnnexes, and the G-TrialsGCP, an IP includes a product with registration when used or assembled (formulated or packaged) in a way different from the approved form; when used for an unapproved indication; or when used to gain further information about an approved use.

Manufacturing

As set forth in the LMHRA-Act, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) is responsible for issuing licenses or permits for premises and personnel to engage in the manufacture of medicinal products in Liberia. The LibCTReg also states that investigational products (IPs) for clinical trials must be manufactured according to internationally accepted good manufacturing practice (GMP) principles.

Per the LibCTReg and the G-LibClinTrial, the LMHRA has also adopted the International Council for Harmonisation (ICH)'s Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. Refer to LBR-8 for additional IP guidelines. Per LBR-29, the World Health Organization’s (WHO) GMP Guidelines for IPs (LBR-26) and the International Council for Harmonisation (ICH) Harmonised Tripartite GMP Guide for Active Pharmaceutical Ingredients (LBR-9) must also be complied with during the IP manufacturing process.

As explained in G-Inspec-PMS, where pharmaceutical factories have not yet established validated manufacturing processes for pharmaceuticals for use in clinical trials, or have not yet established comprehensive manufacturing control standards, the factories must establish written operational procedures and keep detailed and accurate records for each batch of products manufactured, and each batch of raw material used. Batch manufacturing records must be kept until clinical trials are completed, or until at least two (2) years after the product is completed, whichever period is longer. Additionally, where pharmaceutical factories produce biopharmaceuticals or biotechnology products for use in clinical trials, impurities caused by virus inactivation/removal or other organisms may not exceed the limits imposed on other similar products on the market; where operational procedures for said products have not yet been validated, quality control tests must be performed.

Import

As set forth in the LMHRA-Act, the LibCTReg, and the G-LibClinTrial, the LMHRA is also responsible for issuing licenses or permits for the import/export of medicinal products in Liberia. Pursuant to the G-Inspec-PMS and the LibCTReg, authorization must be obtained from the LMHRA for the importation of medicines to be used in clinical trials. Per LBR-30, the Clinical Trials Unit within the LMHRA’s Pharmacovigilance & Clinical Trials Department is responsible for reviewing importation permits for IPs that are required for the conduct of clinical trials. Per LibCTReg, the LMHRA Managing Director is responsible for receiving application requests to obtain an import permit.

According to the LibCTReg and the G-LibClinTrial, the import permit application must contain the following information and documentation:

• Name and address of the sponsor, the sponsor’s legal representative, or the sponsor-investigator (both physical and postal)
• Principal investigator’s name, address (both physical and postal), and contact details (e.g., phone number and email)
• The clinical trial for which the application is made
• The planned clinical trial sites and the planned number of participants at the sites
• IP(s) description by name or code, strength, and dosage form
• IP(s) unit of issue, total quantity, batch number, manufacture, and expiry dates
• Sample labels of the primary and secondary containers
• Planned return of unused IP(s) to sponsor or destruction at the clinical trial site
• Manufacturer name and address

The LibCTReg also notes that an application letter should be sent to the LMHRA Managing Director along with the required documentation.

In addition, per G-LibClinTrial, a parallel submission for approval of the clinical trial and the import permit application is possible. In this case, the import permit application can be included in the clinical trial application package.

The G-LibClinTrial further explains that if the IP(s), health products, or any auxiliary medicinal product must be imported, the clinical trial must be approved by the LMHRA before the import can be authorized. IPs may only be imported if they are not locally available, or if the need for importation is otherwise justified. The justification must be stated in the import permit application letter.

Please note: Liberia is party to the Nagoya Protocol on Access and Benefit-sharing (LBR-3), which may have implications for studies of IPs developed using certain non-human genetic resources (e.g., plants, animals, and microbes). For more information, see LBR-17.

Manufacturing

According to the NDPA-CTReg, the G-CTConduct, and the G-TrialsGCP, the National Drug Authority (NDA) is responsible for authorizing the manufacture of investigational products (IPs) in Uganda. The NDA will only approve the manufacture of an IP after approval of the clinical trial application. The NDPA-CTReg indicates that if the IP is to be manufactured in Uganda, the holder of the clinical trial certificate must apply to the NDA for a manufacturing license.

Uganda follows the G-GMPMedicinal, the G-GMP-APIs, and the G-GMPAnnexes for good manufacturing practice (GMP), which were adopted from Pharmaceutical Inspection Co-operation Scheme (PIC/S) guidance. Per the G-GMPMedicinal, the holder of the NDA’s manufacturing authorization must manufacture IPs to ensure that they are fit for their intended use; comply with the requirements of the clinical trial authorization; and do not place participants at risk due to inadequate safety, quality, or efficacy. The G-GMPAnnexes further states that for manufacturers to be able to apply and comply with GMP for IPs, cooperation between manufacturers and sponsors of clinical trials is required. This cooperation should be described in a technical agreement between the sponsor and manufacturer.

The G-GMP-APIs indicates that when manufacturing active pharmaceutical ingredients (APIs) for use in clinical trials, process and test procedures should be flexible to provide for changes as knowledge of the process increases and clinical testing of a drug product progresses from pre-clinical stages through clinical stages. Once drug development reaches the stage where the API is produced for use in IPs, manufacturers should ensure that APIs are manufactured in suitable facilities using appropriate production and control procedures to ensure the quality of the API. Additionally, the manufacture of APIs for use in clinical trials should be documented in laboratory notebooks, batch records, or by other appropriate means.

See the G-GMPMedicinal, the G-GMP-APIs, and the G-GMPAnnexes for more detailed manufacturing requirements.

Import

The NDA is responsible for authorizing the import of IPs. The NDPA-CTReg and the G-CTConduct state that prior to IP import or manufacture, the sponsor or principal investigator (PI) must be granted a clinical trial certificate by the NDA. According to the NDPA-CTReg, the holder of the clinical trial certificate must then apply for a permit to import the IP approved for the trial.

According to the G-VerImprtExprt, an application for an import verification certificate under extraordinary circumstances (which include clinical trials approved by the NDA) must be submitted electronically to the NDA. UGA-44 indicates that the NDA receives all applications for import authorization through the NDA integrated Regulatory Information Management System (iRIMS) (UGA-40). (Note: The G-VerImprtExprt refers the user to a different management system that is no longer in use. Therefore, the G-VerImprtExprt may not reflect the current iRIMS application process.)

Please note: Uganda is party to the Nagoya Protocol on Access and Benefit-sharing (UGA-3), which may have implications for studies of IPs developed using certain non-human genetic resources (e.g., plants, animals, and microbes). For more information, see UGA-21.

Investigator’s Brochure

Per the LibCTReg and the G-LibClinTrial, the Liberia Medicines and Health Products Regulatory Authority (LMHRA) has adopted the International Council for Harmonisation's Guideline for Good Clinical Practice E6(R2) (LBR-8) for use along with the LMHRA guidelines. Refer to LBR-8 for sponsor requirements related to compiling the investigator’s brochure (IB).

Quality Management

Per the G-LibClinTrial, the Good Manufacturing Practice (GMP) certificate issued by the national regulatory authority of the country where the investigational product (IP) is manufactured must be included in the clinical trial application submission package, if applicable. If necessary, the certificate must be translated into English.

According to LBR-29, the sponsor or the representative must also ensure that the products are manufactured in accordance with the WHO’s GMP Guidelines for Investigational Products (LBR-26) and the ICH Harmonised Tripartite Good Manufacturing Practice Guide for Active Pharmaceutical Ingredients (LBR-9).

See also LBR-8 for additional sponsor guidance on quality management requirements. (See Product Management section for additional information on sponsor requirements).

Investigator's Brochure

In accordance with the NDPA-CTReg, the sponsor is responsible for updating the Investigator’s Brochure (IB), which is a compilation of the clinical and non-clinical data on the investigational product(s) (IPs). The G-TrialsGCP further indicates that the IB should be reviewed at least annually and revised as necessary in compliance with a sponsor's written procedures. Relevant new information may be so important that it should be communicated to the investigator(s), and possibly to the institutional ethics committee(s) (ECs) (research ethics committees (RECs) in Uganda) and/or regulatory authorities, before it is included in a revised IB.

According to the G-TrialsGCP, the sponsor is generally responsible for ensuring that an up-to-date IB is made available to the investigator(s), and the investigators are responsible for providing the up-to-date IB to the responsible ECs and the National Drug Authority (NDA). In the case of an investigator sponsored trial, the sponsor-investigator should determine whether a brochure is available from the commercial manufacturer. If the IP is provided by the sponsor-investigator, then the sponsor-investigator should provide the necessary information to the trial personnel. In cases where preparation of a formal IB is impractical, the sponsor-investigator should provide, as a substitute, an expanded background information section in the trial protocol that contains the minimum current information described in this guideline.

The G-TrialsGCP, the NDPA-CTReg, and UGA-4 require the IB to provide coverage for the following areas:

• Physical, chemical, and pharmaceutical properties and formulation parameters
• Non-clinical studies (pharmacology, pharmacokinetics, toxicology, and metabolism profiles)
• Effects of IP in humans (pharmacokinetics, metabolism, and pharmacodynamics; safety and efficacy; regulatory and post-marketing experiences)
• Summary of data and guidance for the investigator(s)

See Section 7.3 of the G-TrialsGCP for detailed content descriptions, and UGA-4 or Schedule 2 of the NDPA-CTReg for the format of the IB.