This SOP describes how [SITE NAME] confirms that each person working on clinical research is qualified by education, training and experience for their tasks, what training they complete and when, how competency is checked, and how qualification and training records are kept so they can be shown to sponsors, IRBs and inspectors.
2. Scope
This SOP applies to all investigators, staff, contractors and per diem or agency staff who perform research tasks at any [SITE NAME] location. It covers the staff qualification file, required training, protocol and SOP training, system training, shipping training, competency checks and training records. Onboarding steps outside training are in SOP-102 Site Organization, Roles and Staff Responsibilities. Delegation of study tasks is in SOP-302 Delegation of Authority.
Follow the protocol, sponsor or IRB requirement where it is stricter than this SOP (for example, a sponsor that requires GCP refresher training more often, or a CV signed within the last year).
3. Responsibilities
Role
Responsibilities
Quality Lead
Owns the training program. Sets role-based curricula, tracks due dates and expiry, keeps or audits qualification files, runs competency checks or assigns qualified assessors, and reports overdue items to the Site Director.
Site Director
Provides time and funding for training. Stops a person from working on tasks for which their training or license has lapsed.
Principal Investigator (PI)
Makes sure each person delegated a study task is qualified and trained on the protocol before delegation. Conducts or oversees protocol training for the PI's studies. Confirms competency for clinical tasks.
Lead CRC
Delivers or arranges protocol, amendment and study-system training for assigned studies and records it.
Regulatory Coordinator
Files study-required qualification documents (CVs, licenses, GCP certificates, training records) in the ISF or sends them to the sponsor, and tracks sponsor-specific requirements.
All Research Staff
Keep their CV, license and certifications current. Complete assigned training by the due date. Do not perform a task until trained and delegated. Report license actions or lapses immediately.
4. Definitions
Term
Definition
Qualification File
The set of records showing that a staff member is qualified for their research role, kept for each person (F-103-02 Staff Qualification File Checklist).
Training Record
A record showing who was trained, on what (with document version), when, by whom or by what method, and the trainee's acknowledgment.
Role-Based Curriculum
The list of training a person must complete for their role, set by the Quality Lead.
Protocol Training
Training on a study's protocol, amendments, manuals and the trainee's delegated tasks, given before the person performs those tasks.
Competency Check
Direct observation or other test showing that a person can perform a task correctly, recorded with the assessor's name and date.
GCP Training
Training on Good Clinical Practice that covers ICH E6 and applicable FDA regulations.
TransCelerate Mutual Recognition
A program in which TransCelerate member sponsors accept GCP training from providers whose courses meet TransCelerate's published minimum criteria.
Hazmat Employee
A person who, in the course of employment, prepares hazardous materials for transport, including packaging, marking, labeling and signing shipping papers (49 CFR 171.8).
5. Procedure
5.1 Role-based curricula
5.1.1
The Quality Lead sets a role-based curriculum for each role on F-102-01 Site Organization Chart and Role Assignment Record. Each curriculum lists the training in 5.3 to 5.8 that applies, the frequency and the due date rule.
5.1.2
The Quality Lead updates curricula when an SOP is issued or revised (SOP-100 Writing, Approving and Controlling SOPs), when a role changes, and when a regulation or sponsor requirement changes.
5.2 Qualification file
5.2.1
The Quality Lead (or a delegate) opens a qualification file for each person on hire and completes F-103-02 Staff Qualification File Checklist. The file holds, as applicable to the role:
current CV or biosketch, signed and dated by the person, showing education, research experience and current position at [SITE NAME]
signed role description (SOP-102)
copy of each professional license or certification required for the role (for example, MD/DO, NP, PA, RN, LPN, pharmacist, phlebotomy, medical assistant), with primary-source verification from the issuing board's website, printed or saved with the date checked
DEA registration and any [STATE] controlled-substance registration for investigators who prescribe, dispense or order controlled substances
results of exclusion and debarment checks (5.2.3)
GCP training certificate (5.3)
human subjects protection training, when required (5.4)
HIPAA and privacy training record
bloodborne pathogens training for staff with occupational exposure, as required by OSHA (29 CFR 1910.1030)
basic or advanced life support certification where the role or protocol requires it
IATA and DOT shipping training for hazmat employees (5.7)
SOP training acknowledgments (F-100-02 SOP Training Acknowledgment)
the staff member's F-103-01 Staff Training Log
signed confidentiality agreement and onboarding checklist (SOP-102)
5.2.2
Staff update their CV at least every [DEFAULT: 2 years], and sooner when their position, license or research role changes, and sign and date each version. The Regulatory Coordinator sends updated CVs to sponsors when a study requires it.
5.2.3
Before hire and at least [DEFAULT: annually] after, the Quality Lead screens each person against the FDA Debarment List, the FDA Clinical Investigators Disqualification Proceedings list and the HHS OIG List of Excluded Individuals/Entities, plus any added lists chosen under SOP-704. The lists, frequency, recording and handling of a possible match follow SOP-704 Research Misconduct and Fraud Reporting, section 5.7. The result is filed in the qualification file and tracked on F-103-02.
5.2.4
The Quality Lead tracks expiry dates for licenses, registrations and certifications and reminds the staff member at least [DEFAULT: 60 calendar days] before expiry. A person whose required license or certification lapses stops performing tasks that depend on it the same day. The PI removes or suspends the related delegation (SOP-302) until renewal is verified.
5.2.5
Staff report any license restriction, disciplinary action, or exclusion to the Site Director immediately. The Site Director and PI assess the effect on current studies and whether sponsors and the IRB must be told.
5.2.6
Qualification files are confidential personnel records. Copies that a sponsor needs for the ISF (CV, license, GCP certificate) are filed by the Regulatory Coordinator under SOP-204 Essential Documents and the Investigator Site File. Personal data not needed by the sponsor (home address, license numbers beyond what the sponsor requests, date of birth) is redacted before sending.
5.3 GCP training
5.3.1
Each person on a delegation log completes GCP training before performing any delegated study task.
5.3.2
The site accepts GCP training from a course that meets the TransCelerate GCP minimum criteria for mutual recognition, or another course the sponsor accepts. The certificate shows the person's name, course title, completion date and provider.
5.3.3
Staff complete GCP refresher training at least every [DEFAULT: 3 years]. No regulation sets a GCP refresher interval; 3 years is the interval most sponsors accept. A sponsor may require a shorter interval for its studies.
5.3.4
Staff whose current GCP certificate was earned on an ICH E6(R2)-based course complete an ICH E6(R3) update course within [DEFAULT: 6 months of this SOP's effective date] or at their next refresher, whichever comes first.
5.3.5
Investigators and staff on device studies complete device GCP content covering 21 CFR 812 and ISO 14155 when the sponsor requires it or when the site has active device studies.
5.4 Human subjects protection training
5.4.1
Staff complete human subjects protection (HSP) training when required by the reviewing IRB, the sponsor, or the terms of federal funding (for example, NIH-funded research under 45 CFR 46). Many GCP courses include HSP content; the Quality Lead confirms whether a separate course is needed for each study.
5.4.2
HSP refresher frequency follows the requirement that triggered it, or [DEFAULT: every 3 years] if none is stated.
5.5 SOP training
5.5.1
Staff complete training on each SOP in their curriculum before performing the tasks it covers, and before the effective date of each new or revised SOP (SOP-100). Training is recorded on F-100-02 and summarized on F-103-01.
5.5.2
Initial SOP training for a new hire is complete before the person works without supervision on the related tasks. Supervised work during training is recorded on F-103-01 with the supervisor's name.
5.6 Protocol training
5.6.1
The PI or Lead CRC trains each person on the protocol before the PI delegates study tasks to them. Training covers the protocol sections relevant to the person's tasks, the IB or device information as relevant, study manuals (laboratory, pharmacy, imaging), the consent form for staff who will obtain consent, safety reporting requirements, and the person's delegated tasks (ICH E6(R3) Annex 1, 2.3.2).
5.6.2
Sponsor-led training (site initiation visit, investigator meeting, web training) counts as protocol training when attendance or completion is documented. The Regulatory Coordinator files the sponsor's training record or the site's attendance record in the ISF.
5.6.3
Staff complete training on each protocol amendment, revised manual or new consent form version before carrying out the changed procedures. Training is recorded on F-103-01 or the sponsor's training log, with the document version.
5.6.4
Training is proportionate: a person needs study-specific training only on tasks that go beyond their usual training and experience, or that the protocol performs differently from routine practice.
5.6.5
The PI signs the delegation log for a task only after protocol training for that task is recorded (SOP-302).
5.7 Shipping training (IATA and DOT)
5.7.1
The site treats any staff member who classifies, packages, marks, labels or signs for shipments of UN3373 Biological Substance Category B specimens, dry ice (UN1845) or other dangerous goods as a hazmat employee for training purposes. DOT's formal training rule (49 CFR 172.704) applies to dry ice and other hazmat shipments; for Category B shipments DOT requires that the shipper know the packaging requirements (49 CFR 173.199(e)); IATA requires training for anyone preparing dangerous goods for air transport. Training everyone who ships to both standards is site practice.
5.7.2
Hazmat employees complete:
DOT hazmat training covering general awareness, function-specific, safety and security awareness content, within 90 days of starting the function (working only under direct supervision of a trained employee until then) and repeated at least every 3 years (49 CFR 172.704)
IATA Dangerous Goods Regulations training for air shipments, repeated within 24 months of the previous training
5.7.3
A staff member who has not completed this training does not package or sign for dangerous goods shipments independently. The Quality Lead records completion on F-103-01 and in the shipper training matrix kept under SOP-311, and keeps the certificate in the qualification file. Shipping procedure is in SOP-311 Biological Specimen Collection, Processing and Shipping.
5.7.4
The employer must keep a DOT training record for each hazmat employee that shows name, completion date, a description or copy of the training materials, the trainer's name and address, and certification that the person was trained and tested, covering the preceding 3 years and kept for 90 days after the person stops hazmat work (49 CFR 172.704(d)).
5.8 System training
5.8.1
Staff complete training on each computerized system before they receive access (ICH E6(R3) Annex 1, 4.3.2):
sponsor systems (EDC, IRT, eCOA, ePRO, safety portals, imaging upload): the sponsor's or vendor's training, with the completion certificate or record filed in the ISF
site systems (eRegulatory, CTMS, EMR, temperature monitoring, eConsent if site-deployed): training by the System Owner or vendor, recorded on F-103-01
5.8.2
Staff repeat system training when the system has a major change that affects how they use it, or when the sponsor requires it.
5.8.3
Access requests and removals are recorded under SOP-102 and SOP-401 Computerized Systems and Electronic Records.
5.9 Competency checks
5.9.1
The Quality Lead lists the tasks that need a documented competency check in each role-based curriculum. At minimum:
obtaining informed consent: the new consenter is observed by an experienced consenter or investigator for at least [DEFAULT: 2] consent discussions before obtaining consent alone
phlebotomy and specimen processing (including centrifugation, aliquoting, labeling and freezing)
vital signs and ECG acquisition per protocol specifications
IP preparation, dispensing and accountability
protocol-required rating scales, when the sponsor requires rater certification (the sponsor's certificate is the record)
5.9.2
The assessor is a person already qualified in the task. The assessor records the task, the result (competent or needs retraining), the date and their signature on F-103-01.
5.9.3
The Quality Lead or PI orders retraining and a repeat competency check when a deviation, monitoring finding, audit finding or CAPA points to a training gap (SOP-703 Corrective and Preventive Action (CAPA)). The retraining is recorded on F-103-01 and linked to the CAPA number.
5.10 Training records
5.10.1
Every training event is recorded on F-103-01 Staff Training Log or on a sponsor training log, or in a training system that captures the same information. Each record shows:
trainee name
topic and document identifier with version (SOP number and version, protocol number and amendment number)
date
method (read and acknowledge, instructor-led, web course, observation)
trainer or provider
trainee signature or electronic acknowledgment
5.10.2
Certificates from external courses are kept in the qualification file. Study-specific training records are filed in the ISF.
5.10.3
Training records are written at the time of training. Late entries are dated when made and explain the delay.
5.10.4
Electronic training records and signatures meet SOP-401 requirements.
5.11 Review and readiness
5.11.1
The Quality Lead reviews each qualification file against F-103-02 at hire, when the person is added to a new study, and at least [DEFAULT: annually].
5.11.2
Before each sponsor site qualification visit, site initiation visit and inspection, the Regulatory Coordinator confirms that the CV, license and GCP certificate for each person on the study's delegation log are current and filed in the ISF.
5.11.3
The Quality Lead reports overdue training and expiring credentials to the Site Director at least [DEFAULT: monthly].
5.11.4
Qualification files and training records are kept for at least the retention period of every study the person worked on (SOP-402 Record Retention, Archiving and Destruction), and are not destroyed when the person leaves.
6. Related Forms and SOPs
F-100-02 SOP Training Acknowledgment
F-102-01 Site Organization Chart and Role Assignment Record
F-103-01 Staff Training Log
F-103-02 Staff Qualification File Checklist
F-302-01 Delegation of Authority Log
F-904-01 Shared Staff Assignment and Credentialing Log (Model N only)
Appendix B Central and Site Responsibility Matrix (Model N only)
SOP-100 Writing, Approving and Controlling SOPs
SOP-102 Site Organization, Roles and Staff Responsibilities
SOP-204 Essential Documents and the Investigator Site File
SOP-302 Delegation of Authority
SOP-311 Biological Specimen Collection, Processing and Shipping
SOP-401 Computerized Systems and Electronic Records
SOP-402 Record Retention, Archiving and Destruction
SOP-703 Corrective and Preventive Action (CAPA)
SOP-704 Research Misconduct and Fraud Reporting
SOP-904 Shared Staff, Cross-Site Coverage and Central Services (Model N only)
7. References
Reference
Title
ICH E6(R3) Principle 5
Clinical trials should be designed and conducted by qualified individuals
ICH E6(R3) Annex 1, 2.1
Investigator: Qualifications and Training
ICH E6(R3) Annex 1, 2.3.2
Investigator: Responsibilities (qualified and informed delegates; proportionate training)
ICH E6(R3) Annex 1, 4.3.2
Computerised Systems: Training
ICH E6(R3) Appendix C
Essential Records: qualification documents and trial-specific training records
21 CFR 312.53(c)
Form FDA 1572 (investigator qualifications)
21 CFR 812.43(c)
Investigator agreements (CV and relevant experience)
Training requirements for shippers of dangerous goods by air
29 CFR 1910.1030
Occupational Safety and Health: Bloodborne Pathogens
45 CFR 164.530(b)
HIPAA Privacy Rule: workforce training
21 CFR 1301
DEA registration of manufacturers, distributors and dispensers of controlled substances
TransCelerate BioPharma
GCP Training Mutual Recognition: minimum criteria
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.