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03/22/15 1
Investigational New Drug
Application (INDA)
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INTRODUCTION
REGULATORY ASPECT
TYPE OF IND
REQUIERMENT IND
CONTENT OF IND
IND AMENDMENT
ANNUAL REPORT OF IND
CONCLUSION
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WHAT I WILL TELL
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What is INDA
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General introductionGeneral introduction
this data and information is generated and this data and information is generated and
gathered from three broad areas:gathered from three broad areas:
Animal P’cology & Toxicology studiesAnimal P’cology & Toxicology studies
Manufacturing informationManufacturing information
Clinical Protocols & Investigator Clinical Protocols & Investigator
InformationInformation
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The regulations in 21 CFR 312 cover procedures
and requirements for Investigational New Drug
Applications (INDs)
These regulations define the roles and
responsibilities of FDA reviewers, IND sponsors,
and clinical investigators
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Regulation
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Sponsor
A sponsor is an individual, company, institution, or
organization that takes responsibility for and
initiates a clinical study (21 CFR 312.3(b), 312.50)
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Definitions
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A sponsor is responsible for:
Selecting qualified investigators
Ensuring study monitoring
Maintaining an effective IND, and
Ensuring AE risk information is provided to the FDA
and investigators
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Sponsor
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Investigator
An investigator is an individual under whose
immediate direction the study drug is
administered or dispensed. If a team is
involved, the leader is the investigator; other
team members are sub-investigators
(21 CFR 312(b), 312.60)
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Definitions
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Sponsor-Investigator
A sponsor-investigator is an individual
who both initiates and conducts a study
and under whose immediate direction the
study drug is administered or dispensed.
This person must follow the requirements
pertaining to a sponsor and those
pertaining to an investigator
(21 CFR 312(b))
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Definitions
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IND Requirements
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1.Commercial IND
2.Emergency use IND
3.Treatment IND
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TYPE OF IND
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To focus FDA’s attention during early phase
of clinical research on assuring the safety of
human test subjects.
To provide sponsors with a greater measure
of flexibility in conducting Phase 1 trials.
To facilitate consultation between FDA &
sponsors, especially after there is an
indication that the new drug is safe and
efficacious in humans.
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Objective
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Cover Sheet (Form FDA 1571)
Table of Contents
Introductory Statement & General investigational
plan
Investigator’s Brochure
Protocols
Chemistry, Manufacturing & Control Information
Previous Human Experience with the Investigational
Drug
Additional Information
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IND Content Requirements
21 CFR 312.23
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The form is provided for basic information
like name of drug, submission date, sponsor
identification, phase of proposed clinical
investigation, sponsor commitments,
identification of clinical monitor and safety
evaluator, information regarding transfer of
responsibilities to a contract research
organization.
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Cover Sheet (form FDA
1571)
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Drug Name
®
IND table of contents
Item title volume/page
Introductory statement &
general investigational plan…
(i) Introductory statement….
(ii) summary of previous human experience
with drug…….
(iii) If the drug has been withdrawn from
Investigation/Marketing……
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Table of Contents
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iv) iv) General Investigational Plan…..General Investigational Plan…..
5 Investigator’s Brochure…….5 Investigator’s Brochure…….
6 Protocol……..6 Protocol……..
7 Chemistry, Manufacturing & Control 7 Chemistry, Manufacturing & Control
Information…Information…
(a) Drug substance…………(a) Drug substance…………
(b) Drug Product…………….(b) Drug Product…………….
(c) Placebo (if applicable)…(c) Placebo (if applicable)…
(d) Labeling…………………….(d) Labeling…………………….
(e) Environmental Analysis ….(e) Environmental Analysis ….
8 Pharmacology & Toxicology 8 Pharmacology & Toxicology
Information…….Information…….
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9)Previous Human Experience with the
Investigational Drug…….
(i) Summary of Previous Human Experience….
(ii) If the drug is a combination of drug
previously investigated/marketed…….
(iii) If the drug has been marketed outside the
United States……
10 Additional Information (as applicable for
radioactive drugs or drugs with dependence or
abuse potential)….
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It consists of four subsections:
1
st
subsection: (introductory statement)
Name of drug
P’cological Class
Structural formula
Route of administration
Broad objectives
Planned duration of the proposed clinical
investigation
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Introductory Statement & General
Investigational Plan:
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2
nd
subsection:
Brief summary of any previous human
experience with the drug, including
investigational or marketing experience in other
countries
3
rd
subsection:
It is a statement as to whether or not the drug
has been withdrawn from investigation or
marketing in any country for any reason of
safety or efficacy
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4
th
subsection:
Brief description of overall investigational plan for
drug during the following year like: Indications to be
studied, kinds of clinical trials to be conducted in
first year
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Sponsor must provide to all clinical
investigators, not required for sponsor
investigators (21 CFR 312.55). It must
include:
Brief product description
Pharm/tox summaries
Previous human experience
Description of anticipated risk and any special
monitoring needs
Updates as appropriate
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Investigator’s Brochure (IB)
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Drug Name®
Investigator's Brochure
Table of contents
Page
Introduction……………………..
Chemistry……………………….
Physical Properties……
How Supplied…………….
Pharmacology………………….
Specific Effect Studies…
General Studies………….
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Safety/Efficacy Overview
Safety…………………………..
Efficacy………………………..
Possible Risks and Side Effects…
References………………………….
03/22/15 26www.PharmInfopedia.com
Phase 1 protocol provides an outline of
investigation by specifying information
such as estimated number of test
subjects, inclusion/exclusion criteria and
dosing plan
Phase 2 and Phase 3 protocols are detailed,
describing all aspects of the studies, such
that any deviation in a design if required, it
can be established in the protocol from
the beginning.
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5 Protocols
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All the protocols are required to contain the
following elements:
Statement of the objectives and purpose of the study
Patient inclusion/exclusion criteria
Estimate of number of patients to be studied
Description of study design
Dosing information including planned maximum
dosage and duration of individual patient exposure to
the Drug
Description of the observations and measurements
planned to fulfill the study objectives
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Emphasis in Phase I is on identification and
control of raw materials and new drug substance,
including information on any placebo as well
Even for Phase I, need enough information to
assess safety
Extent of expected information increases as drug
development proceeds
Throughout product development, good
documentation of all manufacturing and testing
steps is essential
Deficiencies in CMC information can result in
clinical hold
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CMC Information
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Previous human experience needs to be included (if
applicable)
Additional information such as pre-IND meeting
minutes or critical references should be included as
well
Serial numbering of pages of an IND is required (21
CFR 312.23(11)(e)) as this facilitates reference if the
FDA has questions
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Other IND Items
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21 CFR 312.30
A new protocol
Safety or design related changes to an
existing protocol
New investigator (notification is required
within 30 days of being added)
These should be submitted to the FDA prior
to implementation
IRB approval is needed prior to
implementation
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IND Protocol
Amendments
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21 CFR 312.31
Information amendments advise the FDA of:
New tox, CMC or other technical information
Notice of discontinuance of a clinical study
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IND Information
Amendments
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If a sponsor notify any unexpected fatal / life
threatening experience associated with the use of the
drug requires to notify the FDA by telephone no
later than 3 working days after receipt of the
information, followed by a written report within 10
days.
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IND Safety Reports:
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21 CFR 312.33
To be submitted within 60 days of the
anniversary of “in effect” date
Include enrollment, demographic and
conduct status information for each study
Adverse event summaries (safety reports,
deaths, dropouts)
Drug action information
Preclinical study status information
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Annual Reports
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CMC change information
Revised/updated investigator brochure with
revisions described
Foreign marketing experience
Outstanding business with the FDA
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Annual Reports (cont’d)
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It is option of a sponsor to withdraw an IND at any
time without prejudice.
On withdrawn, sponsor must notify the FDA.
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Withdrawal of an IND
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Two major outcomes from the IND discussion
are:
30 days after an IND is submitted to the FDA, if the
sponsor has not heard anything from the FDA it
can be assumed that the drug is not on a clinical
hold and clinical trials may be started
The Investigator’s Brochure, which will be used
during that important first clinical study and in
every clinical study thereafter, acts as the approved
labeling for the drug while it is under an IND
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Conclusions
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1.www.fda.gov/cder/about/history/time1.htm
2.Remington the science and practice of pharmacy,
20th edition, Lippincott,Williams & Wilkins, page
no: 930-943
3. New Drug Approval Process: second Edition,
Revised and Expanded, edited by Richard A.
Guarino page no: 39-64, 243-263
4.www.fda.gov/cder/handbook/indbox.htm
5.www.fda.gov/cder/handbook/ndabox.htm
6.www.fda.gov
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List of references
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