Statistical Inspection Readiness Checklist

I. Overall Readiness

Statistical lead / data owner clearly identified
Full understanding of study design and primary/key secondary endpoints
Clear awareness of which analyses support regulatory decision-making
Clear distinction between primary, secondary, and exploratory analyses


II. Protocol and SAP Alignment

All analyses are pre-specified in the SAP
Final SAP approved before database lock
SAP version control is clear (dates, approvals, change history)
Any deviations from protocol or SAP are documented and justified
Post hoc analyses are clearly labeled as exploratory in the CSR

Typical inspector question:

Why was this analysis not pre-specified?


III. Data Traceability

Every key result can be traced back to source data
Clear linkage between ADaM and SDTM datasets
Data derivation rules are fully documented
Programming logic is consistent with data specifications
No “black-box” variables or undocumented calculations

Result → Program → ADaM → SDTM → CRF → Source Data


IV. Programming and Reproducibility

All statistical programs are under version control
Programs can be rerun to reproduce identical results
No manual editing of datasets or outputs
QC evidence available (double programming, independent review, validation)
Outputs are fully consistent with the CSR


V. Missing Data and Deviations

Missing data handling methods pre-specified in SAP
Methods align with ICH E9 / E9(R1) principles
Sensitivity analyses support the primary conclusions
Protocol deviations are clearly defined and categorized
Deviation handling is not outcome-driven


VI. Statistical Soundness

Statistical methods are appropriate for the study design
Assumptions are reasonable and explainable
Multiplicity control strategy clearly defined
Analysis populations (ITT, PP, SAF, etc.) clearly specified
No unnecessary complexity without scientific justification


VII. Documentation and Evidence

Protocol (all versions)
SAP (final and historical versions)
TFL shells
SDTM / ADaM specifications
Program inventory with version history
Audit trails and change logs


VIII. Inspection Interview Readiness

Able to explain the rationale for each key analysis
Able to clearly describe data sources and derivations
Distinguishes facts from interpretations
Answers based on documentation, not memory
Avoids ad hoc analyses or on-the-spot commitments


IX. Common Red Flags

SAP finalized after database lock
Unexplained discrepancies between SAP and results
Programs not reproducible
Undocumented data derivations
Modifying data or programs during inspection


X. Rapid Self-Check Questions


Summary

Inspection readiness for statisticians means that every result is reproducible, traceable, and scientifically justified—at any time.


 

 

Inspection Target

Possible Timing

Primary Purpose

Clinical trial sites

During trial conduct / Pre-Approval Inspection (PAI)

Data integrity and GCP compliance

Sponsor

IND / NDA stages

Oversight systems and accountability

CRO

Any stage

Vendor oversight and delegated responsibilities

Statistics / data systems

NDA / PAI

Reproducibility and data integrity

Manufacturing facilities

NDA review / Post-approval

GMP compliance

 


 

 

Inspection vs. Audit — Comparison Table

Dimension

Inspection

Audit

Conducted by

Regulatory authorities (e.g., FDA, NMPA, EMA)

Sponsor, Quality Assurance, or third-party auditors

Legal nature

Regulatory and enforcement activity

Quality management activity

Mandatory

Yes — cooperation is required

No — conducted by agreement or internal policy

Primary purpose

Determine regulatory compliance and impact on regulatory decisions

Identify risks and drive continuous improvement

Timing

Risk-based, during review, or triggered by signals

Planned, periodic, or risk-based

Scope

Focused on critical data, systems, and processes

Systematic review of processes and controls

Approach

Evidence-based, traceability-driven, result-oriented

Process-based, improvement-oriented

Notification

May be announced or unannounced

Typically pre-scheduled

Findings

Observations (e.g., FDA Form 483), inspection reports

Audit findings and internal observations

Consequences

May affect IND/NDA approval, licensing, or lead to enforcement actions

Leads to CAPA and internal corrective actions

Negotiability of outcome

No

Yes

Refusal allowed

No

Yes


Key takeaway

An audit is performed to prevent inspection failures; an inspection is the ultimate regulatory test of audit effectiveness.