What is Investigational New Drug Application?

Investigational New Drug Application (IND)

• After preclinical studies, an Investigative New drug application is required before clinical trials can be initiated.
• In the US, federal law requires that a drug be the subject of an approved marketing application before it is transported or distributed across state lines.
• Because a sponsor will probably want to ship the investigational drug to clinical investigators in many states, it must seek an exemption from that legal requirement.
• IND is the means through which a sponsor obtains an exemption from the FDA.
• An Investigational New Drug Application (IND) is a request for Food and Drug Administration (FDA) authorization to administer an investigational drug to humans. Such authorization must be secured prior to interstate shipment and administration of any new drug that is not the subject of an approved new drug application.
• IND regulations are contained in Title 21, Code of Federal Regulations, Part 312. Copies of the regulations, and further guidance regarding IND procedures.

Types of Investigational New Drug Application (IND)

1. Investigator IND

Submitted by a physician who both initiates and conducts an investigation, and under whose immediate direction the investigational drug is administered or dispensed.

A 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.

2. Emergency Use IND

• Allows the FDA to authorize the use of an experimental drug in an emergency situation that does not allow time for submission of an IND in accordance with 21 CFR, Sec. 312.23 or Sec. 312.34.
• Also for patients who do not meet the criteria of an existing study protocol,
• or if an approved study protocol does not exist.

3. Treatment IND

• Treatment IND is 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.

There are two IND categories

1. Commercial
2. Research (Non-Commercial)

The IND application must contain information in three broad areas:

1. Animal Pharmacology and Toxicology Studies:

• Preclinical data permits an assessment as to whether the product is reasonably safe for initial testing in humans. Also included is any previous experience with the drug in humans (often foreign use).

2. Manufacturing Information:

• Information pertaining to the composition, manufacturer, stability, and controls used for manufacturing the drug substance and the drug product. This information is assessed to ensure that the company can adequately produce and supply consistent batches of the drug.

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3. Clinical Protocols and Investigator Information

• Detailed protocols for proposed clinical studies to assess whether the initial phase trials will expose subjects to unnecessary risks.
• Information on the qualifications of clinical investigators-professionals (generally physicians) who oversee the administration of the experimental compound
• Commitments to obtain informed consent from the research subjects, to obtain a review of the study by an institutional review board (IRB), and to adhere to the investigational new drug regulations.

Resources for IND Applications

1. Pre-IND Consultation Program

• Center for Drug /valuation and Research(CDER)'s Pre-Investigational New Drug Application (IND) Consultation Program fosters early communications between sponsors and new drug review divisions to provide guidance on the data necessary to warrant IND submission.

2. Guidance Documents for INDs

• Guidance documents represent the Agency's current thinking on a particular subject.
• Provide FDA review staff and applicants/sponsors with guidelines for the processing, content, and evaluation/approval of applications and also for the design, production, manufacturing, and testing of regulated products.
• Establish policies intended to achieve consistency in the Agency's regulatory approach and establish inspection and enforcement procedures.
• Are not regulations or laws, they are not enforceable, either through administrative actions or through the courts.
• An alternative approach may be used if it satisfies the requirements of the applicable statute, regulations, or both.

Guidance documents to help prepare INDs include

• 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. Provides description of required sections of an application.
• Q & A: Content and Format of INDs for Phase 1 Studies of Drugs, Including Well-Characterized, Therapeutic, Biotechnology-Derived Products. This guidance is intended to clarify when sponsors should submit final, quality-assured toxicology reports and/or update the Agency on any changes in findings since the submission of non1quality1assured reports or reports based on non-quality-1assured data.
• Bioavailability and Bioequivalence Studies for Orally Administered Drug Products - This guidance should be useful for applicants planning to Conduct bioavailability (BA) and bi0equivalenCe (BE) studies during the IND period for an NDA, BE studies intended for submission in an ANDA, and BE studies Conducted in the post-approval period for Certain Changes in both NDAs and ANDAs.
• 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 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.

Immunotoxicology Evaluation of Investigational New Drugs 

This guidance makes recommendations to sponsors of INDs on

1. The parameters that should be routinely assessed in toxicology studies to determine the effects of a drug on immune function.
2. When additional immunotoxicity studies should be conducted.
3. When additional mechanistic information Could help Characterize the significance of a given drug's effect on the immune system

Laws, Regulations, Policies and Procedures

• The mission of the FDA is to enforce laws enacted by the U.S. Congress and regulations established by the Agency to protect the Consumer's health, safety, and pocketbook. 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.

Code of Federal Regulations (CFR)

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

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