fda course of action when it finds that essential elements of the study protocol are lacking

by Ms. Missouri Reichert IV 9 min read

When should I submit a clinical protocol to the FDA?

Clinical Protocol should be submitted for each planned clinical study or trial. An original IND application submission lacking a clinical protocol is considered incomplete. Protocols for ...

Are there any FDA guidance documents for product development and protocol writing?

In both Phase 2 and 3, CDER can impose a clinical hold if a study is unsafe (as in Phase 1), or if the protocol is clearly deficient in design in meeting its stated objectives.

What are the FDA requirements for sponsoring a clinical trial?

• Discuss the most common mistakes FDA finds during inspections ... corrective action, and classifies the inspection: ... Protocol Compliance - 2 • Identify study-specific procedures and at

Should the primary endpoint of investigational drug therapy measure the most important benefit?

II. BACKGROUND. Experience has shown that during the course of a clinical investigation, the sponsor of a study will want or need to make modifications to …

When was the FDA finalizing the format of PI?

Be informative and accurate and neither promotional in tone nor false or misleading. On January 24, 2006, the U.S. Food and Drug Administration (FDA) issued final regulations governing the content and format of PI for human prescription drugs.

What is the number to call for FDA advisory committee meetings?

For additional information about FDA advisory committee meetings, call 800-741-8138.

How long does it take to get a refusal to file NDA?

This decision must be forwarded within 60 calendar days after the NDA is initially received by CDER.

What is a surrogate endpoint?

A surrogate endpoint is a laboratory finding or physical sign that may not be a direct measurement of how a patient feels, functions, or survives, but is still considered likely to predict therapeutic benefit for the patient.

What is Accelerated Development Review?

Accelerated development/review ( Federal Register, April 15, 1992) is a highly specialized mechanism for speeding the development of drugs that promise significant benefit over existing therapy for serious or life-threatening illnesses for which no therapy exist s. This process incorporates several novel elements aimed at making sure ...

Why do drug companies use animal testing?

In animal testing, drug companies make every effort to use as few animals as possible and to ensure their humane and proper care. Generally, two or more species (one rodent, one non-rodent) are tested because a drug may affect one species differently from another. Animal testing is used to measure how much of a drug is absorbed into the blood, how it is broken down chemically in the body, the toxicity of the drug and its breakdown products (metabolites), and how quickly the drug and its metabolites are excreted from the body.

Is the drug application based on the NDA?

For decades, the regulation and control of new drugs in the United States has been based on the New Drug Application (NDA). Since 1938, every new drug has been the subject of an approved NDA before U.S. commercialization. The data gathered during the animal studies and human clinical trials of an Investigational New Drug (IND) become part of the NDA.

When is a change to a protocol considered?

Changes to the protocol are considered to occur when the sponsor notifies a clinical investigator that the change should be implemented in the protocol. For a sponsor-investigator study, the change to the protocol is considered to occur when the sponsor-investigator incorporates the change in the protocol.

What is 201A in FDAMA?

105-115), which amended the Federal Food, Drug and Cosmetic Act (the act) by adding section 520 (g) (6). This new section of the act establishes criteria that allow sponsors to make certain modifications to the investigational device, including manufacturing changes, and/or to the clinical protocol during the course of the clinical investigation without prior FDA approval.

What is prior approval for IDE?

Certain changes or modifications to a clinical investigation require submission of an IDE supplement and approval by FDA before implementation. Prior approval is required for changes to the device (including manufacturing changes) that constitute a change in the basic principles of operation or a significant change in design or changes that were not made in response to information gathered during the course of the investigation. Additionally, prior approval is required for changes to the investigational plan that affect the validity of the data resulting from the study, the risk to benefit relationship for subjects enrolled in the study, the scientific soundness of the investigation, or the rights, safety or welfare of subjects.

What is 520 G 6?

New section 520 (g) (6) of the act, however, required FDA to modify the IDE regulation to explicitly permit certain changes to the investigational device (including manufacturing changes) and to the clinical protocol during the course of the clinical investigation without agency approval of an IDE supplement.

What is an investigational plan?

According to § 812.25 Investigational Plan, the investigational plan includes the purpose of the study, the clinical protocol, a risk analysis, a description of the investigational device, monitoring procedures, labeling, informed consent materials, and institutional review board (IRB) information.

When was the IDE regulation amended?

The amendment to the IDE regulation was published in the Federal Register as a proposed rule on July 15, 1998 and as a final rule on November 23, 1998.

What is FDA 812.35?

As discussed above, new § 812.35 (a) provides for three approval/notification mechanisms for changes or modifications that may occur during the course of a clinical investigation. Below, the sponsor’s responsibilities in the various types of submissions and FDA’s actions on them are discussed.

What is 21 CFR Part 11?

The FDA's regulations related to electronic records and electronic signatures (21 CFR Part 11) is intended to: Allow the use of electronic documents and signatures in the regulatory process for drugs and devices. An academic medical center is selecting a new database system for clinical research.

What is a sponsor in a pacemaker?

A sponsor proposes research to evaluate reengineering a commercially available pacemaker. It is hoped that the new pacemaker will pose fewer risks to individuals when compared to the current commercially available product. How should this device be classified?