Investigational New Drug Application (INDA)

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Investigational New Drug Application [INDA]

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Introduction

What is an IND ?

❖ An IND is a submission to the food and drug administration (FDA) requesting permission
to initiate a clinical study of a new drug product.

❖The Federal Food , Drug and Cosmetic act requires that drugs have an approved
marketing application before they can be shipped in interstate commerce.

❖The IND application allows a company to initiate and conduct clinical studies for their
new drug products.

❖The IND application provides the FDA with the data necessary to decide whether the new
drug and the proposed clinical trial pose a reasonable risk to the human subjects
participating in the study.

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What is an IND ?

▪ FDA's role in the development of a new drug begins when the drug's sponsor has screened
the new molecule for pharmacological activity and acute toxicity potential in animals, wants
to test its diagnostic or therapeutic potential in humans
▪ The molecule changes in legal status under the Federal Food, Drug, and Cosmetic Act and
becomes a new drug subject to specific requirements of the drug regulatory system
▪ Drug is to be the subjected to an approved marketing application before it is transported or
distributed across state lines
▪ IND- notice of claimed investigational exemption for a new drug must be filed with
regulatory body.

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Importance of INDA

❖ An IND is required any time I want to conduct a clinical trial of an unapproved drug.
❖ An IND would be required to conduct a clinical trail if the drug is
❖ a new chemical entity , not approved for the indication under investigation in a new
dosage form.
❖ Being administered at a new dosage level.
❖ in combination with another drug and the combination is not approved.
❖ All clinical studies where a new drug is administered to human subjects , regardless
of whether the drug will be commercially developed , require an IND.

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When you don’t need an IND

❖ An IND is not required to conduct a study if the drug :

❑ It is not intended for human subjects , but is intended for in vivo testing or lab
research animals (non clinical studies).
❑ It is an approved drug and the study is within its approved indication for use.

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TYPES OF IND
⚫ Investigator IND
o Submitted by a physician who both initiates and conducts an investigation, and under
whose immediate direction the investigational drug is administered or dispensed.
o Physician might submit a research IND to propose studying an unapproved drug, or an
approved product for a new indication or in a new patient population

⚫ Emergency Use IND


o Allows FDA to authorize use of an experimental drug in an emergency situation
o Does not allow time for submission of an IND in accordance with 21CFR , Sec. 312.23 or
Sec. 312.34

⚫ Treatment IND
o Submitted for experimental drugs showing promise in clinical testing for serious or
immediately life-threatening conditions while the final clinical work is conducted and the
FDA review takes place

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CLASSIFICATION OF IND

⚫ Commercial

o Permits sponsor to collect data on clinical safety and effectiveness needed for
application for marketing in the form of NDA

⚫ Research (non-commercial)

o Permits the sponsor to use drug in research to obtain advanced scientific


knowledge of new drug
o No plan to market the product

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CONTENT OF IND
In three broad areas:
⚫ Animal Pharmacology and Toxicology Studies –
o An assessment as to whether the product is reasonably safe for initial testing
in humans
o Any previous experience with the drug in humans
⚫ Manufacturing Information
o composition, manufacturer, stability, and controls used for manufacturing the
drug
⚫ Clinical Protocols and Investigator Information
o Commitments to obtain informed consent from the research subjects, to
obtain review of the study by an institutional review board (IRB), and to
adhere to the investigational new drug regulations.

Once the IND is submitted, the sponsor must wait 30 days before
initiating any clinical trials. During this time, FDA has an
opportunity to review the IND for safety to assure that research
subjects will not be subjected to unreasonable risk
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FORMAT OF INDA
A. Cover sheet (Form FDA-1571)
o Name, address, telephone of sponsor
o Identification of phases
o Commitment not to begin CT until IND approval
o Commitment by IRB- Form 56
o Commitment for conducting CT- accordance with regulations
o Name, title – Monitor
o Name, title – person(s) for reviewing
o Name, Address of CRO, if any
o Signature of sponsor
B. Table of contents
C. Introductory statement & general investigational plan
D. Investigators brochure
E. Study protocol
F. Investigator facilities & IRB data
G. Chemistry manufacturing & control data
H.Pharmacology & toxicology data I.
P19r-e06v-2i0o1u6 s human experience 9
Resources For IND Applications
• Pre-Investigational New Drug Application (IND) Consultation Program
o Offered by CDER (Center for Drug Evaluation and Research) to foster early
communications between sponsors and new drug review divisions in order to
provide guidance on the data necessary to warrant IND submission.

• Guidance Documents for INDs


o documents are prepared for FDA review staff and applicants/sponsors to provide
guidelines to the processing, content, and evaluation/approval of applications and
also to the design, production, manufacturing, and testing of regulated products

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GUIDANCE DOCUMENTS
For The Complete List Of CDER Guidance, Please See The Guidance
Index
⚫ Safety Reporting Requirements for INDs and BE/BA Studies
⚫ CGMP for Phase 1 Investigational Drugs
⚫ Exploratory IND Studies
⚫ Content and Format of Investigational New Drug Applications (INDs) for Phase 1 Studies of
Drugs, Including Well Characterized, Therapeutic, Biotechnology-Derived Products
⚫ Q & A - Content and Format of INDs for Phase 1 Studies of Drugs, Including Well-
Characterized, Therapeutic, Biotechnology-Derived Products
⚫ Bioavailability and Bioequivalence Studies for Orally Administered Drug Products
⚫ IND Exemptions for Studies of Lawfully Marketed Drug or Biological Products for the
Treatment of Cancer
⚫ Guideline for Drug Master Files
A Drug Master File (DMF) is a submission to the Food and Drug Administration (FDA) that
may be used to provide confidential detailed information about facilities, processes, or
articles used in the manufacturing, processing, packaging, and storing of one or more human
drugs.
⚫ Required Specifications for FDA's IND, NDA, and ANDA Drug Master File Binders
⚫ Immunotoxicology Evaluation of Investigational New Drugs

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Laws, regulations, Policies, Procedures
• The Federal Food, Drug, and Cosmetic Act is the basic food and drug law of the U.S
The law is intended to assure consumers that foods are pure and wholesome, safe to
eat, and produced under sanitary conditions; that drugs and devices are safe and
effective for their intended uses; that cosmetics are safe and made from appropriate
ingredients; and that all labeling and packaging is truthful, informative, and not
deceptive.

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Laws, regulations, Policies, Procedures
• Code Of Federal Regulations (CFR)
o The final regulations published in the Federal Register (daily published record of proposed rules,
final rules, meeting notices, etc.) are collected in the CFR.
o The CFR is divided into 50 titles that represent broad areas subject to Federal regulations.
o The FDA's portion of the CFR interprets the The Federal Food, Drug, and Cosmetic Act and related
statutes. Section 21 of the CFR contains most regulations pertaining to food and drugs.

21CFR Part 312 Investigational New Drug Application


INDA and NDA Applications for FDA Approval to
21CFR Part 314
Market a New Drug (New Drug Approval)
21CFR Part 316 Orphan Drugs
21CFR Part 58 Good Lab Practice for Nonclinical Laboratory
[Animal] Studies
21CFR Part 50 Protection of Human Subjects

21CFR Part 56 Institutional Review Boards

21CFR Part 201 Drug Labeling


21CFR Part 54 Financial Disclosure by Clinical Investigators

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Laws, regulations, Policies, Procedures
• CDER's Manual of Policies and Procedures (MaPPs)

MaPPS are approved instructions for internal practices and procedures followed by
CDER staff to help standardize the new drug review process and other activities.

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INDA Review Process

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DRUG DEVELOPMENT PROCESS

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New Drug Development and Review Process
Steps from Test Tube to New Drug Application Review

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Phases of clinical testing

Phase Number of Length Purpose Percent


patients successfully
completing
Phase 1 20-100 Several months Mainly safety
67
Phase 2 Up to several Several months Some short-
hundred to two years term safety but
45
mainly
effectiveness
Phase 3 Several hundred 1-4 years Safety,
to several effectiveness,
5-10
thousand dosage

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Clinical Trials
▪ 10-15 years from lab to US patients
▪ Only 1 in 5000 compounds make it to human testing
▪ Only 1 in 5 tested in humans is approved
▪ Testing Phases in Humans
▪ DISCOVERY
▪ Phase I RESEARCH
▪ Phase II DEVELOPMENT
▪ Phase III CLINICAL STUDIES
▪ Phase IV MEDICINE APPROVED

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Introductory statement

▪ Description of the investigational drug


▪ All active ingredients
▪ Drug’s pharmacological classification
▪ Structural formula
▪ Route of administration
▪ Summary of previous human experience
▪ Formulation of dosage forms
▪ Objective and planned duration of proposed clinical investigation.

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Investigational plan

▪ Description of clinical studies planned for the experimental drug


▪ Purpose of the study
▪ Indication to be studied
▪ Types of trials to be initiated
1. Number of study subjects
2. Risks involved

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INVESTIGATORS BROCHURE

▪ Structural formula of drug.


▪ Summary of pharmacological , toxicological , pharmacokinetic effects
in animals.
▪ Safety and efficacy
▪ Purpose of study
▪ Dose / dose frequency
▪ Monitoring procedures

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Clinical protocol
▪ A clinical protocol describes how a particular clinical trial is to be
conducted.

▪ It describes
✓ the objectives of study
✓the trial design
✓ how subjects are selected
✓ how the trial is to be carried out

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▪ It should contain the following elements:

✓ A statement of the objective and purpose of study.


✓Name , address and qualification of each investigator participating in
the study.
✓Name and address of each clinical site.
✓Study subject inclusion and exclusion criteria.
✓Estimate of the number of subjects to be enrolled in the study.

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Chemistry, manufacturing and Control Data

▪ Determines the adequacy of methods used to manufacture and assay


investigational compound
▪ Safety concerns
▪ Describe drug substances
▪ Method of preparation
✓ Reagent and solvents
✓Acceptable limits and analytical methods to ensure quality and purity
of drug.

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Pharmacological and Toxicology data :
▪ Pharmacology and drug disposition
▪ Integrated toxicology summary

Previous human exposure :

▪ Marketed (foreign) or previously tested in humans.

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FDA Review of The INDA
▪ Once the ind is stamped as received ,it is sent to the review division
within CDER.
▪ On arrival at the review division , it is critically evaluated by several
reviewers of
✓ Chemisty
✓ Biopharmaceutics
✓ Medical
✓ Stastistics
✓ Microbiology
✓ Pharmacology /toxicology sections

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▪ All these areas review the data submitted with the primary purpose to
ensure safety of the individual enrolled in th e study.
▪ Once an IND is submitted,the study can’t be initiated until a period of
30 days.
▪ If there are any major issues relating to the safety of the volunteers in
the proposed study , the FDA can institute a clinical hold.

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INDA Annual reports
▪ Sponsors should submit an annual report that provides the FDA with a
brief update on the progress of all investigations included in the IND.

▪ It should contain the following:


✓ Individual study information.
✓ Summary of the study.
✓Listing of any significant foreign marketing developments with the
drug e.g. approval in another country.

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