‘Objectionable Conditions’ Found at Dentist’s Clinical Site

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A 9/18-10/16/14 FDA inspection found objectionable conditions at a clinical site operated by Dr. William Domb in Upland, CA, who was sponsor/investigator of the significant risk clinical study entitled “Expectations for IRB Research Associations and Oxygen/Ozone Simplified and Suggested Research Treatment Protocols: A Historical Review of Current Trends of Dental Colleagues.” A just-released 3/24/15 Warning Letter says the inspection was conducted under a program designed to ensure that data and information contained in requests for IDEs, PMAs, and 510(k)s are scientifically valid and accurate. An additional program objective is to ensure that human subjects are protected from undue hazard or risk during scientific investigations. Specific violations noted in the letter were: 

  •          failing to submit an IDE application to FDA and obtain approval of the IDE from the agency and an institutional review board before allowing subjects to participate in the investigation of a significant risk device;
  •          failing to prepare an adequate investigational plan;
  •          failing to select investigators qualified by education and experience and failing to obtain signed agreements from participating investigators;
  •          failing to ensure that informed consent was obtained; and
  •          failing to ensure proper monitoring of the investigation.

FDA says Domb’s responses to the inspection observations were inadequate. He was told to provide documentation of additional actions he has taken or will take to correct the violations and to prevent their recurrence, with projected completion dates and a plan for monitoring the corrective actions’ effectiveness.

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