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Familiarize Yourself with Applicable Regulations: Stay updated on the relevant regulations and guidelines that govern clinical research, including FDA regulations, International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH) guidelines, and local regulatory requirements. Understand the specific regulations that apply to your study, such as those related to investigational new drugs (IND) or investigational device exemptions (IDE).
Obtain Institutional Review Board (IRB) Approval: IRBs play a crucial role in ensuring the protection of human subjects in research. Before initiating a clinical trial, obtain IRB approval by submitting a detailed study protocol, informed consent documents, and other required materials. IRBs review the study's scientific merit, ethical considerations, and compliance with regulations.
Investigational New Drug (IND) or Investigational Device Exemption (IDE) Application: If your clinical research involves the use of investigational drugs or devices, you may need to submit an IND or IDE application to the FDA. These applications provide detailed information on the investigational product, its safety, efficacy, manufacturing processes, and proposed study design.
Good Clinical Practice (GCP) Guidelines: GCP guidelines provide a framework for the conduct of clinical research to ensure data integrity and participant protection. Adhere to GCP principles, including informed consent, protocol adherence, accurate documentation, and appropriate monitoring and reporting of adverse events.
Adverse Event Reporting: Monitor and report adverse events occurring during the study promptly. Follow the FDA's requirements for safety reporting, including expedited reporting of serious and unexpected adverse events. Maintain accurate and complete records of adverse events and their follow-up actions.
Data Integrity and Documentation: Ensure the integrity, accuracy, and traceability of study data. Implement robust data management practices, including proper documentation, source data verification, and secure storage of study documents. Follow regulatory requirements for data retention, including archiving study records for the required period.
Audits and Inspections: Be prepared for audits and inspections by regulatory agencies. Maintain organized and easily accessible study documentation, including study protocols, informed consent forms, case report forms, and correspondence with IRBs and regulatory agencies. Cooperate with auditors or inspectors and address any identified deficiencies or findings promptly.
INTRODUCTION
IND TYPES
IND CATEGORIES
THE IND APPLICATION MUST CONTAIN INFORMATION IN THREE BROAD AREA
THE REGULATORY ENVIRONMENT AND FDA ROLE
LIST OF IMPORTANT SECTIONS
GENERAL PRINCIPLES
INVESTIGATIONAL NEW DRUG GUIDANCE AND PLANNING
FDA FORM 1571
FDA FORM 1572
FDA FORM 3674
SUBMITTING AN IND
FOLLOWING RECEIPT OF IND BY THE FDA
RESPONDING TO A CLINICAL HOLD
REGULATORY REQUIREMENTS FOR AN IND DURING STUDY AND AT COMPLETION
PROTOCOL AMENDMENTS (21 CFR 312.30)
INFORMATION AMENDMENTS (21 CFR 312.31)
SAFETY REPORTS (21 CFR 312.32)
ANNUAL REPORTS (21 CFR 312.33)
WITHDRAWAL, TERMINATION, AND INACTIVATION
MONITORING RESPONSIBILITIES FOR SPONSOR-INVESTIGATORS
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2. INTRODUCTION
Liaisonmeans
CommunicationorCooperation
The FDA is one of our nation’s oldest consumer protection agencies.
FDA is a public health agency, charged with protecting American consumers by enforcingthe
Federal Food, Drug, and Cosmetic Act and several related public healthlaws.
There is approximately 9,000 employees who monitor the manufacture, import, transport,
storage, and sale of about $1 trillion worth of products each year.
These employees are located in district and local offices in 157 cities across the country.
2
4. Inspections and Legal Sanctions
The investigators and inspectors visit more than 16,000 facilities a year, seeing that products
are made correctly and labeled truthfully.
They collect about 80,000 domestic and imported product samples for examination by FDA
scientists or for label checks.
If a company is found violating any of the laws, the FDA can encourage the firm to correctthe
problem voluntarily or to recall a faulty product from the market.
When a company cannot or will not voluntarily correct a public health problem with one of its
products, the FDA has legal sanctions it can bring to bear.
4
5. Scientific Expertise
The scientific evidence needed to back up the FDA’s legal cases is prepared by the agency’s
2,100 scientists, including 900 chemists and 300 microbiologists.
Some of these scientists analyze samples and others review test results submitted by companies
seeking agency approval for drugs, vaccines, food additives, coloring agents, and medical
devices.
The agency must determine that the new drug produces the benefits it is supposed to without
causing side effects that would outweigh those benefits.
5
6. Product Safety
The agency’s scientists test samples to see if any substances, such as pesticide residues, are
present in unacceptable amounts.
If contaminants are identified, the FDA takes correctiveaction.
The safety of the nation’s blood supply is another FDA responsibility. The agency’s
investigators routinely examine blood bank operations, from record-keeping to testingfor
contaminants.
Cosmetic safety also comes under the FDA’s jurisdiction. The agency can have unsafe
cosmetics removed from the market.
6
7. FDA DIVISIONS
Center for Drug Evaluation and Research
Center for VeterinaryMedicine
National Center for Toxicological Research
CDER
7
CBER Center for Biologics Evaluation and Research
CDRH Center for Devices and Radiologic Health
CFSAN Center of Food Safety and Applied Nutrition
CVM
NCTR
8. CENTER FOR DRUG EVALUATION AND
RESEARCH
CDER’s mission is to ensure that safe and effective prescription, non-prescription and generic
drugs are available to the people as quickly as possible.
CDER fulfills its mission by overseeing the clinical research, development, manufacture, and
marketing of drugs.
As of August 2003, there are 15 review divisions within CDER that are responsiblefor
reviewing all INDs, NDAs, and chemistry and efficacy supplemental applications.
CDER ensures that drug labeling, drug information for patients, and drug promotion are
truthful, helpful, and not misleading.
8
9. Promote public health by ensuring the availability of safe and effective drugs: Promote
patient and health professional awareness of drug benefits and risks through effective
communication of drug information.
Protect public health by promoting the safe use of marketed drugs: Oversee drug
promotion and marketing to help ensure that marketed drug labeling and advertising are
truthful and not misleading.
Protect public health by ensuring the quality and integrity of marketed drug products.
9
FUNDAMENTAL GOALS ANDOBJECTIVES
11. The Office of Pharmaceutical Science (OPS) is an integral part of CDER’s new and generic
drug product application review process.
The goal of OPS is to help establish common approaches to the manufacture and formulation
of drugs among pharmaceutical manufacturers.
OPS has four main offices:
Office of Generic Drugs
Office of New Drug Chemistry
Office of Clinical Pharmacology and
Biopharmaceutics
Office of Testing and Research
11
12. CONTACTS WITH THE FDA
One of CDER’s primary goals is to work collaboratively and cooperatively with industry, to
improve the drug development and review process.
It also strives to provide consumers and health care providers with drug information that is vital
for improving the public health.
The various means of communicating with the CDER are:
Consumer/Industry Inquiries.
Industry/FDAInquiries.
FDA/Industry Meetings.
12
13. Consumer/Industry Inquiries
To enhance the communications aspect of this process, the Center created the Division of
Communications Management (DCM).
This division enhances information exchange, strategic communications planning, and the
development of communications products and initiatives.
The Division of Communications Management works to ensure that pharmaceutical industry
representatives, health care professionals, government officials, and consumers have easy and
open access to information and are educated about the drug regulation process and the benefits
and risks of drugs.
13
14. There are a number of ways consumers and industry representatives can communicate with the
Center or get reliable, current, and up-to-date information from it.
The newest and easiest method for getting information is the Center’s world
wide web homepage at http://www.fad.gov/cder.
For more specific or complex drug inquiries, individuals may telephone the
Drug Information Branch or send an electronic mail.
For specific inquiries from industry, CDER’s Compendia Operations
14
15. Industry/FDA Inquiries
All meetings with the FDA are held at the pleasure of the agency and should be requested
judiciously.
Project managers , are responsible for coordinating FDA/industry meetings.
If a meeting with the FDA is deemed necessary, the first step is to telephone the project
manager assigned to the firm’s IND or NDA.
The need for a meeting should be explained, a statement about the general topic of the meeting
should be described, and an idea of when the meeting is needed should be offered.
15
16. The project manager will likely return the call and indicate if a meeting will be granted.
If the answer is positive, a confirmatory letter from the firm should be sent to the appropriate
division.
The document should include the fact that the meeting has been granted and what the date for
the meeting will be.
The names and titles of those representatives of the sponsor who will be attending the meeting,
and the proposed agenda are provided.
16
17. FDA/Industry Meetings
There are three types or categories of meeting that industry can request to the agency.
They are typically known as Type A, B, or C meetings.
• Most important.
• To dispute issues that arise during new drug development, or to
resolve clinical holds that the FDA has deemed necessary.
• These meetings are usually scheduled 30 days from FDAs receipt of a
written request for a meeting.
TYPEA
17
18. • Usually occur for a pre-ind, an end of phase 1 (EOP1), an end of
phase 2 (EOP2), a pre phase 3, or a pre-nda or BLA. All of these
meetings will be honored by the FDA.
• Usually scheduled 60 days from the time the agency received the
written request.
TYPE B
• Any other meeting not falling into type Aor B meetings.
• These are meetings that pertain to the review of human drug
applications.
• These meetings are usually scheduled within 75 days of the
agency’s of the written request.
TYPE C
18
19. Pre-IND/Preclinical Meetings
Prior to clinical studies, the sponsor needs to demonstrate evidence that the compound is
biologically active.
Preclinical meetings are occasionally conducted with the appropriate division that would
review the IND or the drug marketing application, and these meetings are typically requested
by the sponsor of a drug.
Meetings at such an early stage in the process are sometimes useful for open discussion about
testing phases, data requirements, and any scientific issues that may need to be resolved prior
to IND submission.
19
20. End-of-Phase 2 Meeting (EOP2)
The primary focus of “end-of-phase 2” meetings is to determine whether it is safe to begin
phase 3 testing.
This is also the time to plan protocols for phase 3 human studies and to discuss and identify
any additional information that may be required to support the submission of an NDA.
These meetings avoid unnecessary expenditures of time and money because data requirements
have been clarified.
One month before the end-of-phase 2 meeting, the sponsor should submit the background
information and summary protocols for phase 3 studies.
20
21. Pre-NDA Meetings
The purpose of a pre-NDA meeting is to discuss the presentation of data (both paperand
electronic) in support of the application.
The information provided at the meeting by the sponsor includes:
A summary of clinical studies to be submitted in the NDA.
The proposed format for organizing the submission, including methods for
presenting the data.
Other information that needs to be discussed.
21
22. Advisory Committee Meetings
Advisory committees have been established to advise and make recommendations on issues
related to the agency’s regulatory responsibilities.
The primary role of FDA advisory committees is to provide independent expert scientific
advice to the agency, and to help make sound decisions based on the reasonable application of
good science.
The committees are advisory in nature, and final decisions are made by the FDA.
Advisory committee meetings can be very advantageous to sponsors who are filing an NDAfor
similar drug categories.
22
23. FDA INITIATIVES TO SPEED UPDRUG
APPROVAL PROCESS
The FDA has instituted several programs designed to hasten the drug approval processfor
effective drugs.
The FDA pathways to swift new drug approval are:
Accelerated Development/Review
Program
Treatment IND
FDA Guidance Documents/Guideline
23
24. Accelerated Development/Review Program
Accelerated development/review is a highly specialized mechanism for speeding the
development of drugs that promise significant benefit over existing therapy for serious or life-
threatening illnesses.
This process incorporates several novel elements aimed at making sure that rapid development
and review are balanced by safeguards to protect both the patient and the integrity of the
regulatory process.
24
25. Treatment IND
Treatment INDs are used to make promising new drugs available to desperately ill patients as
early in the drug development process as possible.
The FDA will permit an investigational drug to be used under a treatment IND if there is
preliminary evidence of drug efficacy and the drug is intended to treat a serious or life-
threatening disease.
Treatment INDs are made available to patients before general marketing begins, typically
during phase 3 studies.
Treatment INDs also allow the FDA to obtain additional data on the drug’s safetyand
effectiveness. 25
26. FDA Guidance Documents/Guidelines
A regulatory professional must be aware of the guidance documents that the FDA hasmade
available to assist industry to understand expectations regarding drug development and the
approval process.
The website providing the complete list of FDA guidance's is updated almostdaily.
The FDA comprehensive list of all guidance's available is found on the internet.
26
27. FREEDOM OF INFORMATIONACT
(FOIA)
Freedom of information is another important way in which regulatory personnel may readily
obtain information from the FDA.
The FDA has published a guidance handbook intended to facilitate requests for bothpublic
information and records not originally prepared for distribution by the FDA.
This handbook has been updated in response to the Electronic Freedom of InformationAct
(FOIA) amendments of 1996
27
28. Obtaining Information Through the FOI
The Freedom of Information Act allows anyone to request copies of records not normally
prepared for public distribution.
It pertains to existing records only and does not require agencies to create new recordsto
comply with a request.
It also does not require agencies to collect information they do not have or to do researchor
analyze data for a requestor.
In addition, FOI requests must be specific enough to permit an FDA employee who is familiar
with the subject matter to locate records in a reasonable period.
28
29. How to Make an FOI Request
All FOI requests must be in writing and should include the following information:
Requestor’s name, address, and telephone number.
A description of the records.
Separate requests should be submitted for each firm or product involved.
A statement concerning willingness to pay fees, including any limitations.
All FOI requests must be in writing. The FDA does not accept FOI requests sent byemail.
29
30. Fees
Requestors under FOIA may have to pay fees covering some or all of the costs of processing
their request.
Requestors may want to include the maximum dollar amount they are willing to pay.
If the fees exceed the maximum amount stated, FDA will contact the requestor before filling
the request.
Requestors are generally billed for fees after their requests have been processed.
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31. SUMMARY
All dealings with the FDA or other regulatory agencies for that matter must be wellconceived
and adequately planned.
Without knowledge, conception, planning, and an understanding of how the other half works,
significant delays in drug approval frequently and painfully occur.
Whether the regulatory goal is to speed the approval process for a new product or to keep a
product on the market, the firm must know how bet to work with the FDA.
31