Misha Regulatory Affairs
Misha Regulatory Affairs
Misha Regulatory Affairs
The non-clinical (or pre-clinical) development phase primarily
aims to identify which candidate therapy has the greatest
probability of success, assess its safety, and build solid scientific
foundations before transition to the clinical development phase.
The main goals of preclinical studies are to determine a starting,
safe dose for first in human study and assess potential toxicity of
the product, which typically include new medical
devices, prescription drugs, and diagnostics.
Also , during the non clinical development phase the candidate
compound should meet non-medical objectives, including
defining the intellectual property rights and making enough
medicinal products available for clinical trials.
THE STUDIES OF NON CLINICAL
DEVELOPMENT ARE PERFORMED
1. COMMERCIAL INDs
• These are applications that are submitted primarily by the companies to obtain marketing approval for a new product.
2. NON-COMMERCIAL INDs
• These INDs are filed for noncommercial research.
THESE ARE:
INVESTIGATOR’S IND- It is submitted by a physician who both initiates & conducts an investigation and who also
administered & dispenses the IP.
EMERGENCY USE IND- This IND allows FDA to allow the use of an experimental drug in an emergency situation
that does not allow submission of an IND in accordance with 21 CFR Sec321.23 or Sec312.34.
TREATMENT IND- Also called expanded access IND, it may be submitted for experimental drugs showing promise
in clinical testing of serious and immediately life threatening conditions while in final clinical work is conducted and
the FDA review takes place.
CRITERIA FOR IND APPLICATION
• A new indication
• Change in the approved route
of administration or dosage
level.
• Change in the approved
patient population.
• Significant change in the
promotion of an approved
drug.
IND PROCESS IN INDIA
NEW DRUG APPLICATION (NDA)
The NDA is the vehicle through which the drug sponsors formally propose FDA or DCGI to approve a
new investigational drug for sale & marketing after phase IIIA pivot trials.
The official definition of new drug is in Sec 201(p) of Federal drug, food & cosmetics act as;
Any new drug, the composition of which is such that it is not recognized among experts qualified by
scientific training as safe and effective foe use under prescribed, recommended or suggested conditions.
Any drug the composition of which is such that it as a result of investigations to determine safety &
efficacy for use has become recognized, but which has not, otherwise in such investigations been used
to a material extent.
The following letter codes describes the review priority of the drug;-
• S- STANDARD REVIEW: for drugs similar to currently available drugs.
• P- PRIORITY REVIEW: for drugs that represent significant advances over existing treatments.
CLASSIFICATION OF DRUGS IN
NDA
CENTER OF DRUG EVALUATION AND RESEARCH (CDER) classifies new drug applications
according to the type of drug being submitted & its intended use:-
a) New molecular entity
b) New salt of previously approved drug
c) New formulation of previously approved drug
d) New combination of two or more drugs
e) Already marketed drug product- duplication (i.e., new manufacturer)
f) New indication for already marketed drug
g) Already marketed drug product
PROCESS OF NDA
ABBREVIATED NEW DRUG
APPLICATION (ANDA)
Generic drug applications are referred to abbreviated new drug applications.
Pharmaceutical companies must admit ANDAs & receive FDAs approval before marketing new generic drugs according to
21CFR 314.105(d).
Once ANDA is approved, an applicant can manufacture & market generic drug to provide safe, effective and low cost
alternative of innovator drug product to the public.
Generic drugs are termed ‘abbreviated’ as they are not required to include preclinical and clinical data to establish safety and
efficacy. They must scientifically demonstrate bioequivalence to innovator (brand name) drug.
A generic drug is comparable to innovator drug I dosage form, strength, route of administration, quality, performance and
intended use.
One of the ways to demonstrate bioequivalence is to measure the time taken by generic drug to reach blood stream in 24-36
healthy volunteers. The time and amount of active ingredients in the blood stream should be comparable to those of
innovators drugs.
Use of bioequivalence as base for approving generic drug products was established in 1984, also known as WAXMAN-
HATCH ACT. It is because of this act that generic drugs are cheaper without conducting costly and duplicative clinical trials.
PROCESS OF ANDA
NDA & ANDA
INVESTIGATOR’S BROCHURE
The IB is a compilation of the clinical & non clinical data on the investigational products that are relevant
to study of the products in human subjects.
PURPOSE:
• Its purpose is to provide information to the investigators and others involved in the trials such as the dose,
dose interval/frequency, method of administration and safety monitoring procedure.
• The IB also provides insight to support the clinical management of the study subject during the course of
the clinical trials.
• The information should be presented in a concise and simple manner.
• IB enables a clinician or potential investigator to understand it and make his/her own unbiased risk
assessment of the appropriateness to the proposed trial. For this reason, a medically qualified person
should generally participate in the editing of an IB.
GENERAL CONSIDERATIONS
TITLE PAGE
1. Sponsor name
2. The identity of each investigational product
3. The release date
4. Confidential statement
CONFIDENTIALITY STATEMENT
The sponsor may wish to include a statement instructing the investigator to treat the IB as a confidential document
for the sole information and use of the investigator’s team and the IRB/IEC.
The investigator brochure should include:
1. Table of contents
2. Summary
3. Introduction
4. Description of IB
5. Non clinical studies
6. Effects in human
7. Summary of data & guidance for the investigator.
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