SOP-102

Site Organization, Roles and Staff Responsibilities

Number
SOP-102
Category
Governance and Quality System
Edition
Reference Edition 1.3
Approx. pages
11

[YELLOW] the site fills in. [DEFAULT: green] a value the site may keep or change.

On this page

1. Purpose

This SOP describes how [SITE NAME] documents its organization and reporting lines, defines research roles, manages combined roles at a small site without losing needed independence, organizes work across multiple locations, and brings staff on and off the research team, including granting and removing system access.

2. Scope

This SOP applies to all employees, contractors, per diem and agency staff who perform research activities at any [SITE NAME] location. It covers site-level organization. Study-level assignment of tasks is covered by SOP-302 Delegation of Authority. Qualification and training records are covered by SOP-103 Staff Qualification, Training and Training Records.

Follow the protocol, sponsor or IRB requirement where it is stricter than this SOP.

3. Responsibilities

RoleResponsibilities
Site DirectorOwns the organization chart and role assignments. Approves hires, role changes and combined roles. Names a lead for each location. Makes sure each critical role has a backup. Starts and signs off onboarding and offboarding.
Quality LeadReviews combined roles against the independence limits in 5.3. Assigns role-based SOP training curricula. Checks onboarding and offboarding records during internal QC.
Principal Investigator (PI)Confirms staff assigned to the PI's studies are suitable before delegation. Supervises study activities at each location used for the PI's studies.
Regulatory CoordinatorRecords staff changes in the study records against the 1572 or investigator agreement (SOP-101, 5.2.5), and updates the delegation log and IRB records when staff join, change role or leave. Notifies sponsors of staff changes. Requests and confirms revocation of sponsor system access for departing staff (5.7.5).
Lead CRC / CRCHands over open study tasks when a team member leaves. Tells the Regulatory Coordinator which sponsor systems a departing person uses on the CRC's studies.
System Owner (named per system on F-401-01)Grants, changes and removes access to the site's computerized systems and records each change.
All Research StaffWork within their assigned role. Report changes in license, certification or availability. Complete offboarding steps before leaving.
Network Office (Model N only)Keeps the network organization chart and the network role descriptions. Performs the central activities Appendix B assigns to it. In N-Affiliated, directs member site staff only as the network or affiliation agreement allows.
Network Executive (Model N only)Leads the Network Office (SOP-900). Approves the operating variant and F-900-02 with the Network Quality Committee and provides resources for the network quality system.
Network Quality Committee (Model N only)Approves network SOPs, F-900-02 and changes to Appendix B, and conducts network management review (SOP-900).
Network Quality Lead (Model N only)Owns the network SOP system, network QA audits and CAPA trending across member sites. Reviews combined network and site roles against 5.3 and 5.9.
Network Regulatory Lead (Model N only)Leads central IRB submissions, the central eRegulatory system and reliance agreements, as Appendix B assigns.
Network Contracts and Finance Lead (Model N only)Leads master agreements, CTAs, budgets, coverage analysis and invoicing, as Appendix B assigns.
Network Clinical Operations Lead (Model N only)Leads study allocation, member site performance and deployment of shared staff.
Network Privacy Officer (Model N only)The Privacy Officer (SOP-400) designated by the Network Office. Records the network's HIPAA structure, maintains F-905-01 and approves each new cross-entity data flow in N-Integrated; in N-Affiliated, records each flow after the disclosing entity's Privacy Officer approves it. Coordinates privacy incidents that involve more than one entity (SOP-905). May be the Network Quality Lead.
Network Security Officer (Model N only)The Security Officer (SOP-400) designated by the Network Office for shared systems. Owns technical safeguards for shared systems, including separation of each site's data (SOP-905). May be the Network Privacy Officer.
Network Training Lead (Model N only, optional)Runs the central training program. May be the Network Quality Lead.
Network Medical Director (Model N only, optional)Provides physician oversight and advice across PIs. Does not take over any PI's investigator duties.

4. Definitions

TermDefinition
Organization ChartA dated chart showing the legal entity, its locations, the people in each research role, reporting lines and named backups.
Role DescriptionA written description of a research role's duties, required qualifications and reporting line.
Combined RoleOne person holding two or more of the standard roles in this SOP library (for example, Site Director and Quality Lead).
Critical RoleA role whose absence would stop participant safety reporting, IP management, regulatory submissions or investigator oversight: PI, Sub-I, IP Manager, Regulatory Coordinator, CRC for an active study.
LocationAny physical address where [SITE NAME] conducts study procedures, stores IP or keeps study records.
Location LeadThe person named by the Site Director as the day-to-day contact for research at one location.
Impartial WitnessA person independent of the trial, who cannot be unfairly influenced by people involved with the trial, who attends the consent process when the participant or legally authorized representative cannot read, or as required for the short form process (ICH E6(R3) Glossary; SOP-301).
OnboardingThe steps that make a new or transferring staff member qualified, trained and authorized to perform research tasks.
OffboardingThe steps that end a staff member's research authority and access when they leave the site or a study.
Operating ModelModel S (single site) or Model N (a Network Office plus member sites; N-Integrated or N-Affiliated), recorded on F-900-02 under SOP-100.
Network OfficeIn Model N, the central organization collectively, including the network roles in Section 3.
Member SiteIn Model N, a site that conducts studies under the network SOP library. In N-Affiliated, each member site is a separate legal entity with its own employees.
Site Quality LeadIn Model N, the person at a member site who performs the Quality Lead duties that Appendix B leaves with the site. Where Appendix B assigns all quality duties centrally, the site has no Site Quality Lead and the Network Quality Lead performs them.
Shared StaffIn Model N, staff who work at more than one member site or for the Network Office and a member site (SOP-904).

5. Procedure

5.1 Organization chart

5.1.1
The Site Director maintains the site organization chart on F-102-01 Site Organization Chart and Role Assignment Record. The chart shows:
  • legal entity name and each location address
  • Site Director, Quality Lead, each PI and Sub-I, Regulatory Coordinator, each CRC and Lead CRC, Research Pharmacist or IP Manager, Finance / Contracts Lead and Recruitment Specialist (if used)
  • reporting lines
  • the named backup for each critical role
  • the Location Lead for each location
  • each combined role and the independence controls applied (5.3)
5.1.2
The Site Director updates F-102-01 within [DEFAULT: 10 business days] of any change in people, roles or locations, and reviews it at least [DEFAULT: annually] even if nothing has changed. Each version is dated and signed by the Site Director. Superseded versions are kept.
5.1.3
The Regulatory Coordinator provides the current organization chart for sponsor site qualification visits, audits and inspections on request.

5.2 Role descriptions

5.2.1
The Site Director keeps a written role description for each role used at the site, based on the standard roles in this library. Each role description states duties, required education, license or certification, required training, the person the role reports to, and the backup role.
5.2.2
Summary of standard research roles:
  • Principal Investigator (PI): responsible for study conduct, participant safety and data reliability at the site (SOP-101 Roles and Responsibilities of the Principal Investigator)
  • Sub-Investigator (Sub-I): licensed professional who performs significant trial procedures or makes important trial decisions under PI oversight, and covers for the PI
  • Site Director: business and operations lead; staffing, budgets, facilities, contracts; may also be a PI
  • Quality Lead: SOP system, training program, QC, internal audit, CAPA, inspection readiness
  • Regulatory Coordinator: IRB submissions, ISF and essential records, 1572 and financial disclosure collection, regulatory correspondence
  • Lead CRC: day-to-day coordination of an assigned study; first contact for the sponsor monitor
  • Clinical Research Coordinator (CRC): screening, consent (when delegated), visits, source, EDC entry, query resolution, scheduling
  • Research Pharmacist or IP Manager: IP receipt, storage, temperature monitoring, dispensing, accountability and returns
  • Finance / Contracts Lead: CDAs, CTAs, budgets, invoicing, participant payments
  • Recruitment Specialist: outreach, pre-screening and advertising within IRB-approved materials
  • clinical support staff (for example, phlebotomists, medical assistants, nurses): perform delegated clinical procedures within their license or certification
5.2.3
Each staff member signs and dates their role description at hire and when it changes. The signed copy is kept in the staff qualification file (SOP-103).
5.2.4
A role description does not authorize study tasks. Study tasks are authorized only through the delegation log (SOP-302).

5.3 Combined roles and independence limits

5.3.1
At a small site one person may hold more than one role. The Site Director records each combined role on F-102-01. The Quality Lead reviews each combination against 5.3.2 before it starts.
5.3.2
The following limits apply regardless of site size:
  • No one performs QC or audit of their own work. When the Quality Lead also performs study work (for example, as Regulatory Coordinator or CRC), another trained person or an external reviewer QCs that work (SOP-700 Internal Quality Control and Quality Assurance Audits).
  • No one is the sole approver of an SOP they wrote (SOP-100 Writing, Approving and Controlling SOPs).
  • When the protocol requires unblinded staff (for example, an unblinded pharmacist or IP Manager), those staff do not perform blinded assessments, efficacy ratings or AE causality assessments for that study, and do not share treatment information with blinded staff (SOP-305 Randomization, Blinding and Emergency Unblinding). The PI assigns blinded and unblinded roles on the delegation log (SOP-305, 5.1.2).
  • Protocol-required independent raters or assessors do not take on other tasks the protocol says would compromise their independence.
  • An impartial witness for consent is not a member of the study team for that study (SOP-301 Informed Consent Process and Documentation).
  • A person with a significant financial interest in a study's sponsor or product follows the management plan set under SOP-104 Conflict of Interest and Financial Disclosure.
  • The person who approves participant payments does not also reconcile the payment records for the same study (SOP-310 Participant Payments and Reimbursement).
  • When the Site Director is also the Quality Lead, a Quality Lead review, approval or CAPA closure that concerns the Site Director's own work or decisions is done by the PI or, where the PI is the same person, by the independent reviewer named in the Site decision below.
5.3.3
When the PI is also the Site Director or an owner of [SITE NAME], business decisions (enrollment targets, study selection, staffing) must not override the PI's medical judgment on eligibility, safety or withdrawal. The Quality Lead checks eligibility and safety decisions on these studies during routine QC.
5.3.3.1
Where the owner, PI and Site Director are the same person, that person's conflicts of interest (SOP-104) and any review, approval or CAPA closure of that person's own work or decisions go to the independent reviewer named in the Site decision under 5.3.2. The independent reviewer records each review on the record the relevant SOP names (for example F-104-01 or F-703-01).
5.3.4
Each critical role has a named, trained backup recorded on F-102-01. The backup is on the delegation log for the tasks they would cover before they cover them.

5.4 Multiple locations

5.4.1
Before any study activity takes place at a location, the Regulatory Coordinator confirms:
  • the location is listed on the 1572 (Section 3) or in the device investigator records where the sponsor requires
  • the reviewing IRB has approved or been notified of the location as its policy requires
  • the sponsor has approved the location
  • a CLIA certificate covering any testing done at that location is current (SOP-312 Equipment Calibration and Maintenance; Local Laboratory Requirements)
5.4.2
The Site Director names a Location Lead for each location and records them on F-102-01.
5.4.3
Each location that stores IP has its own storage area, temperature monitoring and accountability records, or a documented transfer process between locations approved by the sponsor (SOP-304 Investigational Product Management).
5.4.4
Each location keeps its own emergency equipment, equipment calibration records and emergency contact list (SOP-705 Business Continuity and Emergency Preparedness).
5.4.5
The PI supervises study activity at each location used for the PI's studies. The PI or a Sub-I is on site or immediately reachable when study procedures that need investigator involvement take place.
5.4.6
The Regulatory Coordinator keeps a record of where essential records and source for each study are held, by location (ICH E6(R3) Appendix C, C.2.4; SOP-204 Essential Documents and the Investigator Site File).
5.4.7
Within one investigator site, staff who work across locations are on the delegation log once per study, not once per location, unless the sponsor requires otherwise.

5.5 Onboarding

5.5.1
The Site Director starts F-102-02 Staff Onboarding and Offboarding Checklist on or before the start date. The checklist covers 5.5.2 to 5.5.8.
5.5.2
Before the start date, or on the first day, the staff member:
  • signs the role description
  • signs a confidentiality agreement covering participant information and sponsor confidential information
  • provides the documents for the qualification file (SOP-103)
5.5.3
Before the staff member performs any research task, the Quality Lead (or delegate) completes and records the license verification and the debarment, disqualification and exclusion screening described in SOP-103 and SOP-704 Research Misconduct and Fraud Reporting.
5.5.4
The Quality Lead assigns the role-based training curriculum (SOP-103), including HIPAA and privacy training, GCP training and the SOPs for the role. The staff member completes required training before performing the related tasks.
5.5.5
Each System Owner grants access to site systems (for example, eRegulatory, CTMS, EMR, temperature monitoring, shared drives) only after the role is confirmed and system training is done. Each grant is recorded on F-401-01 Computerized System Inventory and Access Log with the access level and date (SOP-401 Computerized Systems and Electronic Records). Shared log-ins are not used.
5.5.6
For sponsor systems (EDC, IRT, eCOA, safety portals, sponsor eReg), the Regulatory Coordinator requests access through the sponsor or its vendor after the staff member is on the delegation log for the related task. The Regulatory Coordinator records the request and grant on F-401-01.
5.5.7
Before the staff member performs any study task, the Lead CRC or PI completes protocol training (SOP-103) and the PI signs the delegation log (SOP-302). If the person is a Sub-I, the Regulatory Coordinator notifies the sponsor so the 1572 information or investigator records can be updated, and notifies the IRB where the IRB requires it.
5.5.8
Keys, badges, alarm codes and access to IP storage or controlled-substance storage are issued only as the role requires and are recorded on F-102-02.
5.5.9
The Site Director and the staff member sign F-102-02 when onboarding is complete. The checklist is filed in the staff qualification file.

5.6 Role changes

5.6.1
When a staff member changes role or location, the Site Director updates F-102-01 and the role description. The Quality Lead assigns any added training. System Owners and the CRC adjust site and sponsor system access to match the new role and record the change on F-401-01. The PI updates the delegation log for each affected study.

5.7 Offboarding

5.7.1
When a staff member gives notice, or the Site Director decides to end employment or a contract, the Site Director starts the offboarding section of F-102-02 the same day.
5.7.2
Before the last working day, the Lead CRC for each affected study arranges handover of open tasks to a named person:
  • pending data entry and open queries
  • AE and SAE follow-up and any pending safety reports
  • pending investigator signatures (for departing investigators, PI review of the outstanding items in SOP-101, 5.13.5)
  • scheduled participant visits and calls
  • IP accountability reconciliation for any IP the person managed
5.7.3
The departing staff member completes and signs their outstanding source entries and corrections before leaving. Entries cannot be made in the person's name after access is removed.
5.7.4
Each System Owner removes the person's access to site systems on [DEFAULT: the last working day] and records removal on F-401-01. For an involuntary departure, access is removed at or before the time the person is told.
5.7.5
The Regulatory Coordinator asks the sponsor or its vendor to revoke access to each sponsor system on [DEFAULT: the same business day] that the person leaves or comes off the study (SOP-401), keeps the request and confirmation, and records the request on F-401-01 (ICH E6(R3) Annex 1, 2.12.10(b)). The Regulatory Coordinator follows up until revocation is confirmed.
5.7.6
The Site Director collects keys and badges, and changes codes or combinations for any area the person could open, including IP and controlled-substance storage, and records this on F-102-02.
5.7.7
The Regulatory Coordinator enters the end date on the delegation log for each study and the PI initials and dates it (SOP-302, 5.6.3). The Regulatory Coordinator records the change in the study records, tells the sponsor (a new signed 1572 is needed only as SOP-101, 5.2.5 sets out) and notifies the IRB where the IRB requires notice of personnel changes. If the departing person is the PI, SOP-101, 5.13.5 applies.
5.7.8
The person's qualification file and training records are kept, not destroyed, for the retention period of the studies they worked on (SOP-402 Record Retention, Archiving and Destruction).
5.7.9
The Site Director signs F-102-02 when every offboarding item is complete. The Quality Lead checks a sample of completed offboarding checklists against F-401-01 during internal QC.

5.8 Contractors, agency and per diem staff

5.8.1
Contractors and agency or per diem staff who perform study tasks are qualified, trained, delegated and offboarded the same way as employees under this SOP and SOP-103.
5.8.2
When an agency or company supplies the staff, the Site Director puts a written agreement in place under SOP-105 Oversight of Service Providers and Vendors that covers confidentiality, qualification documents, training and notice when staff change.

5.9 Network roles and site roles (Model N only)

This section applies only in Model N. Model S sites skip it.

5.9.1
The Network Office records on F-900-02 and in Appendix B Central and Site Responsibility Matrix which activities each network role performs and which stay with member sites (Appendix B, SOP-102 rows). Site roles keep their names and duties for every activity Appendix B leaves with the site.
5.9.2
Site roles relate to network roles as follows:
  • Quality Lead: becomes the Site Quality Lead, who handles site QC, site training records, site SOP deviations and local addenda, and reports to the Network Quality Lead for network SOPs, network audits and CAPA trending. Where Appendix B assigns all quality duties centrally, the Network Quality Lead performs them and the site names a contact for quality matters.
  • Regulatory Coordinator: files and maintains the site ISF and site-specific submissions; the Network Regulatory Lead prepares central IRB submissions, keeps the central eRegulatory system and handles reliance agreements where Appendix B assigns them.
  • Finance / Contracts Lead: handles site invoiceables, site reconciliation and participant payments; the Network Contracts and Finance Lead handles master agreements, CTAs, budgets and coverage analysis where Appendix B assigns them.
  • Privacy Officer and Security Officer (SOP-400): keep the site's HIPAA duties for the site's own records; the Network Privacy Officer and Network Security Officer handle cross-entity data flows, shared systems and multi-entity incidents (SOP-905).
  • Site Director: keeps responsibility for site staffing, facilities and operations, and works with the Network Clinical Operations Lead on study allocation and shared staff.
  • PI and Sub-I: keep every investigator duty for their studies at their site (SOP-101). The Network Medical Director may advise PIs and review clinical quality across sites but does not sign for, delegate for or overrule a PI on eligibility, safety, consent or IP decisions.
5.9.3
No network role takes over an investigator's regulatory duties. The PI at each member site stays the investigator of record (21 CFR 312.60; 21 CFR 812.100; ICH E6(R3) Annex 1, 2.3).
5.9.4
N-Affiliated: the Network Office directs member site employees only as the network or affiliation agreement allows. Where a network role needs a site employee to act (for example, to correct a QA finding), the request goes to the Site Director, who assigns the work. Escalation when a site does not act follows SOP-903.
  • F-102-01 Site Organization Chart and Role Assignment Record
  • F-102-02 Staff Onboarding and Offboarding Checklist
  • F-302-01 Delegation of Authority Log
  • F-401-01 Computerized System Inventory and Access Log
  • F-900-02 Network Operating Model and Appendix B Adoption Record (Model N only)
  • F-904-01 Shared Staff Assignment and Credentialing Log (Model N only)
  • F-905-01 Cross-Entity Data Flow Register (Model N only)
  • Appendix B Central and Site Responsibility Matrix (Model N only)
  • SOP-100 Writing, Approving and Controlling SOPs
  • SOP-101 Roles and Responsibilities of the Principal Investigator
  • SOP-103 Staff Qualification, Training and Training Records
  • SOP-104 Conflict of Interest and Financial Disclosure
  • SOP-105 Oversight of Service Providers and Vendors
  • SOP-204 Essential Documents and the Investigator Site File
  • SOP-301 Informed Consent Process and Documentation
  • SOP-302 Delegation of Authority
  • SOP-304 Investigational Product Management
  • SOP-305 Randomization, Blinding and Emergency Unblinding
  • SOP-310 Participant Payments and Reimbursement
  • SOP-312 Equipment Calibration and Maintenance; Local Laboratory Requirements
  • SOP-400 Participant Privacy and HIPAA in Research
  • SOP-401 Computerized Systems and Electronic Records
  • SOP-402 Record Retention, Archiving and Destruction
  • SOP-700 Internal Quality Control and Quality Assurance Audits
  • SOP-704 Research Misconduct and Fraud Reporting
  • SOP-705 Business Continuity and Emergency Preparedness
  • SOP-900 Network Governance, SOP Hierarchy and Local Addenda (Model N only)
  • SOP-903 Network Oversight of Member Sites (Metrics, Central QA, Escalation) (Model N only)
  • SOP-904 Shared Staff, Cross-Site Coverage and Central Services (Model N only)
  • SOP-905 Network Data, Systems, Privacy and Records Across Sites (Model N only)

7. References

ReferenceTitle
ICH E6(R3) Principles 5 and 10Qualified individuals; roles and responsibilities clear and documented
ICH E6(R3) Annex 1, 2.2 and 2.3Resources; Responsibilities (delegation and oversight)
ICH E6(R3) Annex 1, 2.12.10Records: computerized system access for investigator and sponsor systems
ICH E6(R3) Annex 1, 4.3.8Computerised Systems: User Management
ICH E6(R3) Appendix C, C.2.4Management of Essential Records: record of where essential records are located
21 CFR 312.53(c)Form FDA 1572 (research facilities, Sub-Is)
21 CFR 312.60; 21 CFR 812.100General responsibilities of investigators
21 CFR 11Electronic Records; Electronic Signatures
42 CFR 493Laboratory Requirements (CLIA)
45 CFR 164.308(a)(3)HIPAA Security Rule: workforce security, including termination procedures
FDA Guidance (Oct 2024)Electronic Systems, Electronic Records, and Electronic Signatures in Clinical Investigations: Questions and Answers

Independent Site SOP Library. Licensed CC BY-NC 4.0 by the American Institute for Medical Research (AIMR), with added permission for any site's internal use (license terms). Not legal advice: each adopting site confirms state law, IRB and sponsor requirements with its own counsel and owns every step it approves.