The FDA held a meeting on March 21, 2005 soliciting opinions about how adverse events
should be reported to Institutional Review Boards (IRBs).
Some of the testimony provided to FDA can be found on the FDA website and in various spots
on the Internet, mostly in PDF format.
This is something I have been interested in, but have not had the time to work up the
details. It seems to me that any system for reporting adverse events has to have information
about the accrual of patients into the study. Here's a simple graph that shows the entry and
exit times in a research study. It's not exactly a study of adverse events reports per se,
but the example is close enough that I can use to illustrate the general concepts.

The accrual rate appears to be more or less constant, though some patients appear to stay
in the study for only a short period of time. In this example, the treatment being studied is
peritoneal dialysis, and patients can leave the study when they get a kidney transplant or
when they die.
You can get a more accurate picture of the accrual rate by looking at the date gaps, the
number of days between successive recruiting of patients. So if the first patient is
recruited on January 2 and the second on January 16, the date gap is 14, meaning that you had
to wait two weeks between patients. The date gaps for entry times in this study are
23 0 28 61 7 85 97 45
163 55
120 81 37 94 18 195 10 19 119 31
189 39 32 39 23 36 41 126 1 48
4 41 47 175 27 50 83 95 109 13
4 294 4 124 29 242 4 7 55 28
73 38 10
The average number of days between recruitment is 64.5 days, which tells you that a new
patient enrolls about every other month. You could detect whether patient accrual is slowing
by looking at the trend in date gaps.

An upward trend would imply that recruitment is slowing down, since you have to wait an
increasing amount of time between successive patients. In this particular example, there is
no obvious trend.
Now although it is important to track the rate at which we are accruing patients, the
value of this type of display is far more important when you look at adverse event reports.
The following graph shows rates of infection for these patients. Each vertical line
represents a separate infection event.

There looks to be some evidence that infection rates are slowing down over the past few
years. You can look at the date gaps for this data as well.
40 180 138 98 60 28 365 14 33 14
23 76 144 5 44 4 14 19 136 128
11 6 6 19 39 0 20 59
32 5
38 99 363 573 8 130 109 2
The first and second infections occurred 40 days apart, and the last two infections
occurred two days apart. A plot of these date gaps is instructive.

Notice several dry spells when we waited a year or more between successive infection
events. Notice also in the middle of the plot where it seems like new infections were popping
up left and right, sometimes less than a week apart.
The tricky things about these graphs is recognizing what shift and trends are trivial and
which are important. Some variation is to be expected, but when you see 363 days between
infections followed by another 573 days between infections, you might suspect that something
is going on. The large date gaps early in the process also have a possible explanation.
Patient recruitment started out slowly and only after two years did the number of patients in
the study tend to stabilize (in other words, the rate at which patients entered the study was
matched by the rate at which patients left the study).
There are other important issues, such as monitoring the rate at which patients drop out
of a study that also lend themselves well to an approach like this.
I believe that a statistical control chart should be used with data like this to determine
when the process of producing infections (or any adverse event) has changed. It turns out
that the management of these patients did indeed change in the middle of the study, and there
is some evidence that this led to a lowering of the infection rates.
A statistical control chart would apply well established rules (eight consecutive points
on the same side of the center line, or one point outside the 3 sigma limits) to determine
when the process demands attention.
I want to examine issues such as the use of log transformations on charts like these, how
best to handle multiple events on a singe day, and how best to adjust for the varying number
of patients being studied, as well as the tendency for some adverse events to occur more
frequently the longer the patient is under study.
Previous weblog entries on this topic:
Further reading
-
Clarifying adverse drug events: a clinician's guide to terminology, documentation, and
reporting. Nebeker JR, Barach P, Samore MH. Ann Intern Med 2004: 140(10); 795-801.
[Medline] [Abstract]
[PDF]
This web page was written and was last modified on
09/24/2007.