Quality Management Manual
Transcription
Quality Management Manual
Quality Management Manual Version: …1…………………………………………………….. Date Created: …30.07.2013…………………………………………………….. …………………………………………………………….. Date of last review: Date of next review: …30.07.2014…………………………………………………….. Name of Author: Stephen McQuaid Signature of Author: Authorised by: Jacqueline James Signature: 1 Contents Abbreviations ........................................................................................................... 4 Introduction .............................................................................................................. 5 Section 1: Organisation and Quality Management System .................................. 6 Organisation and management .............................................................................. 6 NIB Operational Committee .................................................................................... 6 The NIB Steering Committee .................................................................................. 6 Ethics, Governance and HTA Advisory Group ........................................................ 7 Information Technology and Data Management Committee ................................... 8 Biosampling and Quality Assurance Committee (BQAC) ....................................... 8 Quality Policy .......................................................................................................... 9 Quality Management System .................................................................................. 9 Quality Objectives and Plans .................................................................................. 9 Quality Manager ..................................................................................................... 9 Quality Manual ........................................................................................................ 9 Document and version control ................................................................................ 9 Section 2: Governance .......................................................................................... 10 Ethical Approval .................................................................................................... 10 HTA permission .................................................................................................... 10 Sponsorship arrangements ................................................................................... 10 Research Governance arrangements ................................................................... 10 Access Policy ....................................................................................................... 11 Material Transfer Agreement ................................................................................ 11 Section 3: Personnel .............................................................................................. 11 Professional Direction ........................................................................................... 11 Staffing ................................................................................................................. 11 Training, competence and staff development ....................................................... 12 Job descriptions and contracts ............................................................................. 12 Staff meetings ....................................................................................................... 12 Staff training and education .................................................................................. 12 Section 4: Communications .................................................................................. 13 Internal communication......................................................................................... 13 External communication ....................................................................................... 13 Communication with patients and donors ............................................................. 13 Clinically relevant findings .................................................................................... 13 Communication with researchers.......................................................................... 13 Stakeholder feedback ........................................................................................... 14 Section 5: Premises and Environment ................................................................. 14 Premises and environment ................................................................................... 14 Facilities for staff ................................................................................................... 14 Facilities for patients ............................................................................................. 14 Facilities for storage.............................................................................................. 14 Health and safety .................................................................................................. 15 Risk Assessments ................................................................................................ 15 Equipment ........................................................................................................... 15 Section 6: Evaluation and quality assurance ...................................................... 15 Evaluation ............................................................................................................. 15 2 Complaints ............................................................................................................ 15 Anomalies and non-conformities .......................................................................... 15 Section 7: Resources ............................................................................................. 16 Procurement ......................................................................................................... 16 Subcontracting ...................................................................................................... 17 Section 8: Handling of Samples ............................................................................ 17 Consent ................................................................................................................ 17 Traceability ........................................................................................................... 17 Samples ................................................................................................................ 17 Sample collection.................................................................................................. 17 Transport of samples ............................................................................................ 17 Selection and release of samples to researchers ................................................. 18 Quality control of samples .................................................................................... 18 Proficiency testing................................................................................................. 18 Disposal of samples.............................................................................................. 18 Section 9: Handling Data ....................................................................................... 18 Data ...................................................................................................................... 18 Data protection ..................................................................................................... 18 Data Security ........................................................................................................ 18 Data quality ........................................................................................................... 19 Return of research data ........................................................................................ 19 3 Abbreviations BHSCT Belfast Health and Social Care Trust BQAC Biosampling & Quality Assurance Committee CCRCB Centre for Cancer Research and Cell Biology COSHH Control of Substances Hazardous to Health CPA Clinical Pathology Accreditation CR-UK Cancer Research UK DHSSPS Department of Health, Social Services and Patient Safety DNA Deoxyribonucleic acid HSC R & D Health and Social Care Research and Development HTA Human Tissue Authority MTA Material Transfer Agreement NHS National Health Service NIB Northern Ireland Biobank NICR Northern Ireland Cancer Registry NICTC Northern Ireland Cancer Trials Centre NI- MPL Northern Ireland Molecular Pathology Laboratory NICRCF Northern Ireland Cancer Research Consumer Forum QMS Quality Management System QUB Queen’s University Belfast RNA Ribonucleic acid SOP Standard Operating Procedure TMA Tissue Microarray 4 Introduction This quality manual outlines the practices and procedures which govern the collection, processing, storage and distribution of human tissue and associated biosamples within the Northern Ireland Biobank (NIB). It exists as part of the Quality Management System (QMS) of the NIB. Objectives of the quality manual: - To meet the requirements of the Human Tissue Act (2004) and the Human Tissue Authority (HTA) Codes of Practice To comply with local regulatory requirements To provide information for NIB staff, NIB users and Accreditation bodies 5 Section 1: Organisation and Quality Management System Organisation and management NIB Operational Committee NIB Operational Team meet approximately every two months as the NIB Operational Committee. These meetings are chaired either by the NIB Scientific Director or Deputy Scientific Director. The meetings provide a forum for staff to feedback experiences and to guide best practices and future developments. The NIB Steering Committee The NIB steering committee is currently chaired by the Belfast Health Social Care Trust (BHSCT) Director of Research and Development and meets at least twice a year to oversee the good practices of the NIB on an ongoing basis. The terms of reference of this committee are as follows:6 - - To ensure, as much as possible, that the NIB develops in line with the recommendations set out in the NI Biobanking Advisory Group Report. To assess if sponsorship, governance and legal requirements are in place that satisfy local and national requirements. To agree and support the operational procedures put in place for the biosample and data collections. To assess and monitor the development of the NIB Information Technology infrastructure, to ensure it is fit for purpose and can interface appropriately with relevant parts of the Health and Social Care/Department of Health and Social Services and Public Safety (DHSSPS), Northern Ireland Cancer Registry (NICR) and other databases as appropriate and to ensure compatibility with national and international activities for sample and data collection. To agree and monitor the conditions under which researchers are given access to the biological samples and data in the biobank. To monitor the use of allocated funds for the NIB. To assess the impact of the biobank on BHSCT and Queens University Belfast (QUB) in relation to costs. To evaluate promotional activities of the NIB and agree an effective communication plan. To consider and agree future developmental phases of the NIB, including feasibility for a regional collection of samples and related data. Membership of the NIB Steering Committee is usually for three years, renewable for a further two. As the NIB becomes more established, it is hoped to extend the membership to include service users, lay persons and representatives of patients and survivorship. Currently it comprises:- Director of Research & Development, Belfast Health & Social Care Trust (Chair) Scientific Director of Northern Ireland Biobank Deputy Director, HSC Research and Development Division, Public Health Agency Director of the Northern Ireland Cancer Trials Centre (NICTC), BHSCT Director, Northern Ireland Cancer Registry Director, Centre for Cancer Research & Cell Biology (CCRCB), Queens University Belfast Professor of Molecular Pathology, Centre for Cancer Research & Cell Biology, QUB Clinical Lead for Tissue Pathology, Belfast Health & Social Care Trust Senior academic representation from the QUB Centre for Public Health and the Centre for Infection & Immunity Senior academic representation from the Biomedical Sciences Research Institute of the University of Ulster. Ethics, Governance and HTA Advisory Group These advisors assist and advise the Scientific Director on matters relating to research governance, ethics and HTA compliance. Membership of the group includes the Scientific Director and is approved by the NIB Steering Committee. The group meets as required at the request of the NIB Scientific Director. 7 Information Technology and Data Management Committee This committee oversees the development of the information management system designed to track the collection, storage and distribution of anonymised tissue samples. This Committee is chaired by the CCRCB Professor of Bioimaging and Bioinformatics and includes representation from PathXL, the IT company awarded the tender to develop the NIB IMS. IT and Data Management Committee Membership: - NIB Lead for IT and Data Management NIB Scientific Director NIB Deputy Scientific Director NIB Administrator NIB Clinical Research Nurses NIB Digital Pathology Technician PathXL Project Manager PathXL Senior Software Developer Biosampling and Quality Assurance Committee (BQAC) This committee meets approximately every two months and deals with the practical aspects of sampling and all quality assurance issues associated with samples in the tumour collection. It is chaired by the NIB Deputy Director. NIB is closely integrated with BHSCT Tissue Pathology at the Royal Victoria and the Belfast City Hospital. This committee is critical for the success of biobanking and key NHS personnel responsible for HTA documentation and standard operating procedures relating to CPA accreditation of the NHS laboratories are involved. Six consultant histopathologists are supported through the Belfast CR-UK Centre and facilitate the biobanking workflow within Tissue Pathology and NI-MPL. The BQAC oversees the production of Standard Operating Procedures (SOPs) for all activities relating to NIB. BQAC Committee membership: - NI Deputy Scientific Director and Quality Manager (chair) Senior Biomedical Scientists BHSCT Tissue Pathology Representation from BHSCT Consultant ‘CR-UK funded’ pathologists NIB Biomedical Scientists NI-Molecular Pathology Laboratory Biomedical Scientists BHSCT Tissue Pathology Archivist Quality Lead for BHSCT Tissue Pathology NIB Clinical Research Nurse NIB Digital Pathology Technician NIB Administrator 8 Quality Policy NIB is committed to the creation of a resource to facilitate high calibre translational research through the organised collection of biological samples linked with welldefined clinical and pathological data. The NIB will: Operate a quality management system to achieve continual quality improvement Continually review and improve the NIB quality management system Ensure that the needs and requirements of users are met Ensure all NIB personnel are familiar with the contents of the quality manual, procedures relevant to their work and this quality policy Comply with all relevant regulatory, health and safety and environmental legislation Comply with the standards required by relevant accreditation bodies This quality policy will be periodically reviewed to ensure its continuing suitability Quality Management System The components of the NIB QMS are described throughout this manual. NIB Standard Operating Procedures which support the QMS Quality Objectives and Plans are located on the NIB website at www.nibiobank.org other support documents can be found on the QUB NI-MPL shared drive. The NIB quality objectives and plans for forthcoming year are discussed and planned at the NIB Steering Committee. Staff receive feedback via the Operational Team Meetings. Quality Manager There is a designated Quality Lead (Chair of BQAC) for the NIB who is responsible for implementing and maintaining the NIB quality management system. Quality Manual The quality manual is maintained by the NIB Administrator. It is reviewed and updated yearly or as required by operational changes and changes are communicated to relevant personnel by the NIB Administrator. Document and version control All documents relevant to the QMS of the NIB are reviewed and updated regularly or as required. See SOP Admin 03 (Creation, Amendment, Retention and Destruction of NIB Documentation). 9 Section 2: Governance The NIB is governed by the principles of transparency and accountability; it functions within a strict regulatory framework and is compliant with the research governance requirements of the two main stakeholders, namely Queen’s University Belfast and Belfast Health and Social Care Trust. Ethical Approval NIB has generic ethics approval which was awarded by a recognized research committee from the Office for Research Ethics Committees in Northern Ireland (reference 11/NI/0013). The approval covers the prospective collection, storage and distribution of a targeted collection of malignant tissues and related biosamples for cancer focused research. The NIB also has approval in place to collect samples of tissues and blood from individuals with premalignant or potentially malignant conditions. Furthermore NIB has OREC (NI) approval to access and distribute for research anonymised samples from the BHSCT laboratory archives. This includes samples from the archives of tissue pathology, cytopathology, haematology and molecular diagnostics. All amendments to the original application must be OREC NI approved. HTA Licencing Arrangements The NIB is integrated within the NI-MPL, based in the QUB Centre for Cancer Research and Cell Biology as a facility to store human samples for future research under the QUB HTA Research licence (HTA licensing number 12044). The HTA is aware that NIB samples stored in CCRCB are under the responsibility of the QUB HTA Research licence DI. The existing BHSCT Pathology HTA licence arrangements ensures all HTA regulations are followed by NHS pathology for the storage of tissue for as yet undefined research. The BHSCT pathology HTA licence (HTA licensing number 12278) also facilitates the temporary storage of NIB prospectively-collected frozen samples on the RVH site prior to batch transfers to the long-term storage facility in CCRCB. Sponsorship arrangements Queen’s University Belfast and The Belfast Health and Social Care Trust are joint sponsors of the Northern Ireland Biobank. In line with the requirements of both institutions the NIB staff are trained in the principles of Good Clinical Practice and have completed appropriate training on the Human Tissue Act 2004. Research Governance arrangements The NIB has worked with the Research Office of BHSCT and the Research Governance Office of QUB to ensure a robust infrastructure is in place which operates with a clear understanding of responsibility. The NIB works closely with the Research Office of BHSCT and the Research Governance Office of QUB to ensure there is appropriate tracking of all required documents for each application. Audits of the application work flow are carried out by senior NIB personnel. Decisions regarding access to the samples in the NIB are impartial and members of the 10 scientific review team will be asked to agree to the principles of non-disclosure. Independent-peer review is carried out by NIB for the majority of applications prior to the release of samples. In some instances, the Scientific Director may make a decision to release samples on the basis of proven, relevant peer-reviewed grant income, for example for research council funded projects. Access Policy The NIB has an access policy which adheres to the over-arching access policies of the Confederation of Cancer Biobanks. Material Transfer Agreement An overarching Material Transfer Agreement (MTA) between the provider organisation (BHSCT) and the recipient organisation (QUB) is in place which encompasses all movements of materials from BHSCT to the NIB. Release of tissues to researchers for a funded, scientifically approved project is subject to a QUB-Recipient MTA for use of the samples and this incorporates the terms from the BHSCT-QUB MTA. The MTA forms part of the “application request for use of the samples”. The Chief Investigator and the University’s Designated Individual (DI) are required to sign the MTA once the application to request the use of the samples has been approved and before any samples are released. Section 3: Personnel Professional Direction The Scientific Director professionally leads the NIB. Staffing The NIB Director, Deputy Director and Administrator regularly reviews the workload and staffing of the NIB to ensure the service is delivered by appropriately trained and qualified staff: NIB staff include: - Scientific Director Deputy Director & Quality Lead Administrator IT and Data Management Lead Clinical Research Nurses Biomedical Scientists Medical Laboratory Assistants Digital Pathology Technician 11 Training, competence and staff development It is recognized that records of professional qualifications and/or training will be maintained by the employing organization. The NIB maintains a central record of biobank-specific training procedures which are documented and reviewed regularly. This includes: - Induction for new NIB staff members Training staff in skills specific to their job according to NIB SOPs NIB competency framework document which is signed off by appropriately trained NIB/NI-MPL personnel A documented and reviewed approach to staff appraisal with annual review of training needs and personal development plan. Professional behaviour NIB staff who have access to donor identities and/or donor identifiable data are bound by the confidentiality policy of BHSCT. Non NHS contracted staff (who all have honorary contracts with the BHSCT) working within the NI-MPL are supervised by NIB personnel for any work they carry out on behalf of the NIB. Job descriptions and contracts Job descriptions are held within individual training files or available from personnel departments of the NIB stakeholder organizations. Staff meetings Please refer to Section 1: Organisation and Quality Management System for information on staff meetings Staff training and education NIB staff are encouraged to have a training/Continuing Professional Development folder which includes records of: - Personal details, CV, professional memberships Work based activities Evidence of attendance at training and development courses Evidence of mandatory training Competency document as appropriate 12 Section 4: Communications Internal communication Internal communication amongst NIB staff is maintained through: - Regular NIB meetings (Refer to Section 1) - Dissemination of minutes - Email External communication External communication is maintained through: - NIB webpage NIB annual report Updates in the CCRCB Bulletin A number of joint academic and clinical roles are in place within the NIB to help engage clinical staff and facilitate mutual understanding of biobanking. Promotion of the NIB and biobanking is also achieved by attendance/presentation of NIB staff at conferences and events. Communication with patients and donors The NIB has established links with the Northern Ireland Cancer Research Consumer Forum (NICRCF) for lay input into information produced for donors. This involvement in future will extend to representation on the NIB Steering Committee (See Section 1) Information about accrual numbers and published research studies using NIB samples is made available to donors via the NIB annual report and the NIB webpage. Clinically relevant findings Prior to consent, potential donors are informed that no attempt will be made by the NIB to trace research results back to individual patients. Communication with researchers The NIB is developing a web-based biosample catalogue to provide information on the types and numbers of samples held. This will be integrated into the official NIB webpage. The NIB is also displayed on the CCB portal, CCRCB webpage and the NI-MPL webpage. 13 Stakeholder feedback On or shortly after a project end date, researchers will be required to submit a short end of project report on the progress of their study. NIB welcomes feedback via the NIB Administrator. Section 5: Premises and Environment Premises and environment The NIB main storage facilities are located within the Northern Ireland Molecular Pathology Laboratory in the basement of CCRCB, Queen’s University Belfast. Tissue is collected via the BHSCT Tissue Pathology Laboratories at the Royal Victoria Hospital and Belfast City Hospital. Blood collected in the Royal Victoria Hospital site is processed in the basement laboratory of the Centre for Public Health, Institute of Pathology. Blood collected in the Belfast City Hospital site is processed in the NICTC laboratory in the Northern Ireland Regional Cancer Centre or in the NIMPL in CCRCB. Facilities for staff The NIB has adequate facilities for staff within these buildings. Facilities for patients There is no requirement for facilities for patients other than as visitors to the Centre. Facilities for storage The NIB’s permanent storage facility is in the basement of CCRCB. Access to this facility is by electronic pass card / key pad access and is restricted to authorised individuals only. Visitors are accompanied by authorised personnel at all times. The NIB has temporary storage facilities in the Institute of Clinical Sciences B Building, Royal Victoria Hospital, and in the laboratory of the NICTC, Belfast City Hospital. Access to both facilities is restricted to authorized personnel. NIB freezers and refrigerators are located in air conditioned rooms. Freezers and refrigerators are subject to continuous temperature monitoring with remote alarms to mobile phones and email of designated personnel. Freezer status can also be monitored online. Back up freezer storage is available on both sites. Patient consent forms are held in the Northern Ireland Clinical Trials Centre based . . Access to this facility is by electronic pass card and is restricted to authorised individuals only. Visitors are accompanied by authorised personnel at all times. 14 Health and Safety The NIB complies with relevant Health and Safety policies and procedures of the BHSCT and QUB. Risk Assessments Risks are assessed for both the tissue sample and the tissue handler and are reviewed every 2 years. Risk Assessment documents are cross referenced in appropriate SOPs. Equipment All equipment calibration, validation logs and service contracts are maintained by the different lab managers in different sites (BHSCT Tissue Pathology laboratories, NICTC laboratory, NI-MPL). Section 6: Evaluation and quality assurance Evaluation Evaluation of the NIB is achieved through: - Horizontal and vertical, internal and external audits. Please refer to Admin 06 SOP for Audit and Quality Control - Reports from accreditation bodies - End of project reports - Reporting and management of anomalies and non-conformities - Annual management review Results or feedback from evaluation activities are discussed at either the Operational Committee or the Biosampling and Quality Assurance Committee meetings and reported in the NIB annual report. Complaints Please refer to Admin SOP 05 -Complaints Anomalies and non-conformities The NIB has procedures in place for the reporting, management and review of anomalies and non-conformities. Please refer to Admin 02 SOP for Incident Reporting. 15 Section 7: Resources The NIB storage facility is located within the Northern Ireland Molecular Pathology Laboratory in a purpose-built area in the basement of the CCRCB, QUB. Funding for the NIB is a syndicate of three partners. The Health and Social Care Research and Development Division of the Public Health Agency (HSC R & D Division) awarded a five year grant to support the day to day running costs and the majority of the staffing costs (2010-2015) Cancer Research-UK has provided funds as part of the Belfast CR-UK Centre initiative to enhance the research infrastructure within the BHSCT Tissue Pathology departments to facilitate sample accrual and molecular typing. The Friends of the Cancer Centre has provided funds for the creation of the Information Management System and for the purchase of a MacroPath Imaging System. NIB operates a modest cost recovery model. NIB facilitates BHSCT in the retrieval of costs from researchers for the acquisition and transfer of samples from the BHSCT laboratory archives to the NIB storage area. Resources subsequently created by NIB/NI-MPL staff using samples retrieved from the Tissue Pathology Archive (eg for the creation of TMAs, extraction of DNA, RNA etc) and distributed by NIB to researchers are also associated with a modest cost recovery model in order to subsidize further activities within the NIB. An environment is being created in Belfast where science is rapidly developing and where the conventional model for biomarker discovery and validation is changing. This model provides ‘fit for purpose’ biosamples of high-level quality within a regulated framework. NIB works closely with the Northern Ireland Molecular Pathology Laboratory (NI-MPL) to provide an end to end sample collection and analytical framework for all researchers in Northern Ireland and beyond. The Scientific Director meets regularly with the chief funder (HSC R & D Division) to review and amend financial plans, as required and to plan ahead for the continued financial viability of the Biobank. The Scientific Director will also explore other sources of funding from charities and other appropriate sources such as the EU. In the event that NIB is no longer funded, contingency plans would be drawn up in consultation with the Confederation of Cancer Biobanks to transfer accrued samples to an appropriately accredited biobank. Procurement NIB operates under the auspices of BHSCT and QUB with regard to the procurement of items of capital expenditure. 16 Subcontracting Services subcontracted out by the NIB are undertaken by approved subcontractors in line with QUB or BHSCT policies. Section 8: Handling of Samples Consent Consent for donation to the NIB is undertaken using ethically approved NIB consent forms and patient information sheets. Please refer to Donor 01 SOP for Informed Consent for Patients with Solid Tumours and Donor 03 SOP for Informed Consent for Patients with Haematlogical Malignancies Patients are given the opportunity to withdraw their consent from the NIB. Please refer to Donor 02 SOP for Withdrawal of Consent. Traceability The NIB has a dedicated Information Management System which conforms to 21CFR11 guidelines for secure access and date/time/user tracking of changes to the system and meets HTA requirements for traceability of samples. This allows each sample to have a unique identifier number, to be registered against a collection protocol, to have a record of significant events and to identify where any sample is at any time (including release of samples to researchers). Please refer to IT01 SOP for Data Entry,Sample 07 Transfer and Tracking of Prospectively Collected, PatientConsented samples from NHS to NIB(CCRCB) and Sample 06 Retrieval of samples from BHSCT Tissue Pathology Archives and Transfer to NIB. Samples The NIB has ethical approval to collect surplus tissue for research at the time of diagnostic sampling, and in addition has approvals in place to retrieve and distribute anonymised samples from the BHSCT laboratory archives. The NIB is developing a procedure for the adoption of investigator led tissue samples from clinical trials including hosting of clinical trials from multiple sites. Sample collection For prospective sample collection protocols please refer to disease specific sample SOPs. Transport of samples For the internal transport of prospectively collected samples within the NIB and its host organisations please refer to NIB Risk AssessmentsRA01 and RA02) 17 For transport of NIB samples outside the NIB and its host organizations, please refer to Sample 11–SOP for Packaging and Transport of Samples Selection and release of samples to researchers See NIB Access Policy Quality control of samples Please see Admin 06 SOP for Audit and Quality Control Proficiency testing The NIB and/or laboratories used by the NIB participate are subject to relevant internal and external quality assurance testing. Disposal of samples Disposal of samples is undertaken according to the HTA Code of Practice 5: Disposal of Human Tissue. NIB Samples for disposal follow the procedures within CCRCB and the NI-MPL – see NI-MPL-SOP-0036-Waste Disposal-E1A (QUB S drive). Section 9: Handling Data Data Hard copies of the NIB pathologist’s reporting proformas are held by the NIB Biomedical Scientists based in the Tissue Pathology laboratories. The data is inputed directly into the NIB IMS by NHS-employed NIB staff for all prospectively collected tissue samples For associated clinical data, please refer to SOP on Admin 04 Data Collection, Storage and Dissemination. Data protection The NIB operates within the requirements of law ie Data Protection Act and the Belfast Health & Social Care Trust (BHSCT) policies for data access. Linkage of clinico-pathological data to biosamples samples held within the NIB for subsequent distribution in an anonymised form to researchers has been approved by the Office of the Data Guardian of the BHSCT. A service level agreement has been formalized with the Northern Ireland Cancer Registry to facilitate this linkage of relevant clinical and pathological data. Data Security Access to the NIB IMS is by individual logins for authorised personnel only. Levels of permission are approved by the NIB Senior Management Team and arranged via 18 the NIB Administrator. The IMS incorporates a robust back-up procedure in the event of a failure which may result in loss of live electronic data. Please refer to IT SOPs for further information. Data quality - Regular audits of the IMS are undertaken to identify missing data or fields which are not completed correctly. Please refer to Admin 06 SOP for Audit and Quality Control Return of research data See Access Policy 19