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Investigational New Drug Application 21 CFR Part 312 A Review for OCRA US RAC Study Group September 2005 Ginger Clasby, MS Promedica International [email protected] 714-799-1617 x 25 IND Application About the Regulation • Provides procedures for use of investigational new drugs • Exempts products from premarketing approval requirements: – Registration, listing, interstate distribution – Labeling – GMPs • Applies to most studies to determine drug safety & effectiveness When IND Application is Not Required Clinical Study Situations • Drug legally marketed for indicated use – Study not intended to support new indication or significant labeling change – Study not intended to support significant change in advertising – Study doesn’t involve change in route of admin, dosage, or use that significantly increases patient risks • IVD biological for confirmatory diagnostic procedure • Intended for tests of in vitro or lab research animals • Placebo products “Treatment” IND When Used • Drug intended to treat or diagnose serious or lifethreatening condition • No satisfactory alternative available • Controlled clinical trials in progress under IND – Or when trials completed & FDA review of request to market is pending • Sponsor actively pursuing device marketing approval with FDA “Emergency Use” IND When Used • Need FDA authorization to use experimental drug in an emergency situation that does not allow time for submission of an IND in accordance with 21 CFR Part 312 • May be used for patients ineligible per existing study protocol(s), or if approved study protocol does not exist IND Application Product Labeling Requirements • Immediate package must be labeled: – “Caution: New Drug – Limited by Federal (or United States) law to investigational use” • No false or misleading statements • No representation that drug is safe or effective for indicated use IND Application Promotion & Charging for Investigational Drugs • No representation that drug is safe or effective for indicated use • No commercial distribution or test marketing • No prolongation of study • Prior written approval from FDA required to “charge” for drug, unless being used under “treatment” IND IND Application Clinical Study Phases • Phase 1 – first time in human – Small number of healthy volunteers – Closely monitored – focus on safety • Phase 2 – controlled studies to evaluate effectiveness – Small number of subjects with condition to be treated – Closely monitored – focus on efficacy (& safety) • Phase 3 – expanded controlled & uncontrolled studies – Large number of subjects with condition to be treated – Focus on efficacy (& safety) IND Application Contents Administrative Details • Sponsor responsibility • Submit original & 2 copies of application • FDA notifies Sponsor in writing of date application is received • IND in effect 30 days after FDA receipt of application, unless FDA notifies Sponsor otherwise IND Review/Approval FDA’s Considerations • Subject safety & welfare • Rendered 30 days of FDA receipt – Only disapproval or early approval is rendered in writing • Clinical hold may be ordered if: – Sponsor fails to comply with applicable regulations – Sponsor is non-responsive to requests for add’l info – Subject risks outweigh benefits – Unreasonable to proceed due to inadequacy of investigational plan, manufacturing or monitoring Clinical Holds To Delay/Suspend A Study • Phase I clinical holds – Subject safety concerns • Phase II & III clinical holds – Concerns about safety or efficacy • Treatment IND clinical holds – Alternative treatment drug now commercially available – Sponsor not diligently pursuing marketing approval – Administrative oversights by Sponsor IND Application Contents An Overview • Cover sheet/application form (Form FDA-1571) • Table of contents • Introductory statement • General investigational plan • Investigator brochure • Protocol(s) • Chemistry, manufacturing & control info IND Application Contents An Overview • Pharmacology & toxicology info • Previous human experience with drug • Add’l info as required: – Drug dependence/abuse potential – Radioactive drugs – Pediatric studies • Add’l info as requested by FDA IND Application Contents Application Form - FDA 1571 • Required for initial IND & all subsequent submissions • Provides basic info about Sponsor & submission contents • Must be signed & dated – Obligates Sponsor to comply with laws & regs IND Application Contents Introductory Statement • Drug name, structure, pharmacological class, development history, foreign testing IND Application Contents General Investigational Plan • Summary of studies anticipated in first year • Study rationale IND Application Contents Investigator Brochure • Package insert • Early versions contain more pre-clinical data • Later versions more heavily weighted with clinical data IND Application Contents Protocol(s) • Must include at least the initial protocol • Phase I – protocol outline: – No. subjects planned – Eligibility requirements – Dosing – Safety assessments • Phase II & III – detailed protocols IND Application Contents Chemistry, Manufacturing & Controls • Manufacturing process • Raw materials & finished product testing • May refer to drug master file or previous application IND Application Contents Pharmacology & Toxicology • Non-clinical study summaries of pharmacological & toxicological effects IND Application Contents Previous Human Experience • Foreign trials • Data from other INDs, NDAs IND Application Contents Additional Info • Other relevant info • Minutes of FDA meetings • Copies of referenced materials • Address issues re: possible drug abuse, dependence, radioactivity, etc. IND Amendments Necessary When: • New protocol introduced • Changes made to protocol that may affect: – Scientific soundness of study – Rights, safety or welfare of study subjects • Addition of new study investigators (FDA Form 1572) • New/revised information not related to protocol – New pharmacology, toxicology, chemistry, clinical info – Discontinuance of a study IND Safety Reports FDA Form 3500A • Any unexpected, serious adverse experience associated with drug use – 15 calendar days • Any finding from animal studies suggesting significant risk for human subjects – 15 calendar days • Any unexpected fatal or life-threatening experience associated with drug use – 7 calendar days IND Annual Reports When Required • Due within 60 days of IND anniversary • Individual study information • Summary information for all studies, including: – Summary of safety results & significant changes in product manufacturing, pre-clinical study status – General investigational plan for upcoming year – Any Investigator Brochure revisions – Significant Ph I protocol modifications – Significant foreign marketing developments during prior year – Log of outstanding business IND Review/Approval FDA Meetings • Pre-IND Submission – Facilitates planning for IND • End of Phase II – Facilitates planning for later studies • Pre-NDA or Pre-BLA – Facilitates preparation & review of NDA or BLA Sponsors & Investigators Responsibilities • Similar to 21 CFR 812 IRB Responsibilities • As identified in 21 CFR 50, 56 IND Regulation Reference Documents & Links (www.fda.gov/cder) • CDER Guidance: IND Application Process (interactive session) http://www.fda.gov/cder/regulatory/applications/ind_page_1.htm IND Regulation Reference Documents & Links (www.fda.gov/cder) • FDA Guidance for Financial Disclosure by Clinical Investigators • FDA Guidance for IRBs & Clinical Investigators • FDA Guidance for Monitoring Clinical Investigations • FDA/ORA Compliance Program Guidance for Bioresearch Monitoring of Clinical Investigations