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In December 2025, FDA released two final guidance documents focused on safety reporting in clinical research, replacing earlier FDA guidance issued in 2009 and 2012.
Key Takeaways
Reportable Information
Under FDA regulations, the following safety reports must be treated as unanticipated problems involving risks to subjects or others and therefore require IRB review. Other events not listed may be included in periodic reports such as the annual IND report.
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Serious and unexpected suspected adverse reaction2
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Findings from other clinical studies suggesting significant risk in humans exposed to the drug2
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Animal or in vitro findings suggesting human risk2
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Increased rate of occurrence of serious suspected adverse reactions2
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All serious adverse events in IND-exempt bioavailability / bioequivalence studies3
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All unanticipated adverse device effects4
Resources
1 HRP-103 Investigator Manual
2 21 CFR 312.32(c)(1)
3 21 CFR 320.31(d)(3)
4 21 CFR 812.150(a)(1)
Reporting a Problem
Protocol Event Table
HRP-001 SOP – Definitions
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