The Trial Master File (TMF) is the backbone of the clinical trial. It consists of essential documents which not only enable the conduct of a clinical trial, but also enable the evaluation of the quality of data produced.
One of the questions asked at the beginning of an inspection is: “Where and how are your documents stored?”. It is expected that all responsible parties know the location(s) of all paper/hybrid, and electronic documents that comprise the TMF. Most importantly, it is expected that the TMF is readily accessible and audit-ready.
The reality is…this is not always the case. In most cases, the TMF is often forgotten and becomes a disorganized “pile of files”. As a result, inspections can be extended for this reason.
In fact, MHRA stated that that 35% of inspections were extended and required extra days particularly due to critical findings of TMFs.
Three (3) critical findings and surefire ways a TMF can extend your inspection are:
1. Lack of Access – The majority of time, the full TMF is not readily available or accessible to inspectors causing a delay in document review.
2. Poor Indexing – Oftentimes, the person designated to the TMF has issues locating documents during inspections due to poor indexing.
3. Incomplete/Missing Files – This is self-explanatory. Files that are inaccurate, incomplete or missing/misfiled can certainly cause a delay. Furthermore, uploading last minute documents to the eTMF (electronic Trial Master File) is a red flag as inspectors can see the download date and time of each document.
Sounds familiar?
Well, this can all be prevented with proper planning, as noted in our article Planning for TMF Success, and effective QC measures as discussed in the following Trial Master File training sessions:
The “Audit-Ready” TMF: Concepts & Strategies (basic)
The “Audit-Ready” TMF: Tools &Techniques to effective QC Reviews (intermediate)- COMING SOON
The TMF Challenge: Part of the IRS (Inspection Readiness Survival) Series (advanced)-COMING SOON