21 CFR 312 Flashcards
IND regulations typically do not apply to investigations with lawfully marketed drugs which are being studied for purposes other than supporting a change in labeling or a change in advertising, so long as the study complies with IRB & consent regulations & does not significantly increase risks or decreaseacceptability of risks. TRUE OR FALSE?
true
Some clinical investigations involving an in vitro diagnostic biologic product may be exempt from the IND regulations if it is used only to confirm a diagnosis made by another medically established diagnostic
product or procedure. TRUE OR FALSE?
true
Clinical research on blood grouping serum, reagent RBC & anti-human globulin are generally exempt from
the FDA’s IND regulation. TRUE OR FALSE?
true
Clinical Investigations involving placebos may be exempted from the IND regulations if the investigation does not otherwise require the submission of an IND application. TRUE OR FALSE?
true
Use of a marketed drug or biologic product for an unlabeled indication in practice of medicine is not subject to IND regulations. TRUE OR FALSE?
true
Researchers planning an investigation may contact the FDA to obtain guidance on the applicability of the IND regulations to a particular study. TRUE OR FALSE?
true
What is the definition of a “contract research organization” according to FDA’s IND regulations?
A person working with the sponsor as an independent contractor who assumes one or more of the obligations of the sponsor.
What type of products are generally subject to IND
regulations?
- Investigational new drugs
- Biological products used in vitro for diagnostic
purposes that are to be used in a clinical
investigation.
What statement must the label of all investigational
drugs bear?
“Caution: New Drug - Limited by Federal (or United States) Law to Investigational Use.”
What are the labeling requirements for investigational drugs with respect to safety or effectiveness of the product?
The label can bear no misleading statement & shall not represent that the drug is safe or effective for the
purposes for which it is being investigated.
A promotional claim is acceptable on investigational drug supply labeling, provided the claim was previously
approved by FDA. TRUE OR FALSE?
False. Promotional claims may not appear on investigational drug supply label.
Investigational drugs may be commercially distributed or test-marketed by sponsor or investigators. TRUE OR FALSE?
false
Sponsors are prohibited from unduly prolonging clinical investigations, once adequate data has been generated
to support a marketing application. TRUE OR FALSE?
true
Describe the FDA requirement for charging for Investigational drugs under an IND.
Charging for Investigational drugs under an IND is not permitted without prior written approval from FDA. Written explanation of why charges are necessary & not a normal cost of doing business is required.
Charging a reasonable amount for investigational drugs under a treatment IND is permissible provided certain criteria are met & there is no commercialization or promotion involved. TRUE OR FALSE?
true
The FDA may withdraw authorization to charge for an investigational drug. TRUE OR FALSE?
true
Sponsor may request waivers of the IND requirements from FDA. TRUE OR FALSE?
true
Filing an IND application with the FDA is required prior to commencing any clinical investigation with an investigational new drug. TRUE OR FALSE?
true
Filing a separate IND with the FDA is required if a sponsor elects to conduct investigations involving waiver of informed consent in emergency research. TRUE OR FALSE?
true
A sponsor must receive written approval from the FDA, prior to beginning emergency research being conducted with waiver of consent. TRUE OR FALSE?
true
How much time does the FDA have to provide a sponsor with written approval to proceed with an IND that involves waiver from ICF due to emergency conditions?
30 days
Name three phases of a clinical investigation for a
previously untested drug?
Phase 1
Phase 2
Phase 3
A study of normal volunteers designed to evaluate the metabolic & pharmacologic actions of a drug with increasing doses would be considered as what phase of investigation?
Phase 1
When several hundred to several thousand subjects are in a study, what phase is the clinical investigation
typically in?
Phase 3
What phase of clinical investigation includes a study that evaluates structure-activity relationships or
mechanism of action in humans?
phase 1
Controlled trials evaluating the effectiveness of multiple doses of a drug in patients would be considered as what phase of investigation?
phase 2
What phase of a study typically evaluates the pharmacokinetics of a drug in normal volunteers?
phase 1
Studies which provide an overall evaluation of a drug & an adequate basis for physician labeling would be
considered as what phase of the investigation?
phase 3
What are the FDA’s primary objectives when reviewing an IND regarding the various phases of investigation?
Phase 1: focus is on safety assessment.
Phase 2 & 3: Focus is on safety & effectiveness & to help assure scientific evaluation.
All phases: Assure the rights & safety of subjects.
Name at least two factors that determine the amount of information that must be submitted in an IND.
- Novelty of the drug.
- Extent to which the drug has been previously studied.
- Known or suspected risks.
- Particular developmental phase.
What should be the main focus of an initial IND submission?
The general investigational plan & the protocols for specific human studies.
What FDA form specifies the content & order of an IND submission?
FDA form 1571
FDA form 1571 requires the names & titles of two persons with specific functions. Who are they?
- The person responsible for monitoring the conduct & progress of the evaluation
- The person responsible for review & evaluation of safety information for the drug.
The FDA form 1571 contains a statement that an IRB that complies with the requirements of 21 CFR 56 will
be responsible for review of all studies conducted under
IND. TRUE OR FALSE?
true
Obligations transferred by a sponsor to CROs are always submitted as an information amendment to an IND, rather then being included in the original IND application. TRUE OR FALSE?
false
Foreign clinical experience with a drug must be submitted in an original IND application. TRUE OR
FALSE?
true
Name at least four elements required in the general investigational plan of an original IND application .
- Rationale for the drug or study.
- Indications.
- General evaluation approach.
- Types of trials to be conducted in the first year.
- Estimated number of patients to be studied in the first year.
- Any anticipated risks of particular severity or seriousness.
The Investigator Brochure is a required component of an original IND submission. TRUE OR FALSE?
true
Describe the relative level of detail required for Phase 1 protocol vs. Phase 2 & Phase 3 protocols.
Phase 1 may be less detailed & more flexible than Phase 2 & 3
Phase 1 should outline the plan, specific number of patients, describe safety measures & include dosing plan
Phase 2-3 should be very detailed & will generally not permit unanticipated protocol changes.
List at least four required sections in a clinical protocol for a study conducted under an IND.
- Objectives & purpose.
- Name, address & qualifications of investigators &
of the reviewing IRB - Inclusion/exclusion criteria.
- Study design
- Dosing information.
- Planned observations & measurements.
- Clinical procedures to evaluate safety.
Name three of the five required content elements in the chemistry, manufacturing, & control section of an original IND application.
- The drug substance.
- The drug product.
- Placebo composition if applicable.
- Labeling.
- Environmental analysis requirements.
The pharmacology & toxicology section of an IND
application requires the names & qualifications of the
individuals who performed what tasks?
Those who evaluates the result of the pre-clinical
studies & concluded it was reasonably safe to begin the
proposed clinical investigations
Results of pre-clinical studies on abuse potential & drug
dependence are required in the original IND application
for which classes of drugs?
Psychotropic substance or any other drug with abuse
potential.
What are the FDA’s requirements for translation &
inclusion of documents in an IND application which are
not in English?
A complete English translation must be included as well
as a copy of the original publication in the foreign
language.
Name three categories of protocol amendments which
require a sponsor to update the original IND
application.
- New Protocols
- Changes in a protocol.
- New investigators.
How soon does a sponsor have to submit a new investigator amendment to an IND?
30 days following the addition of the investigator.
Give an example of the type of information required to
be filed as an information amendment to an original
IND application.
- New technical information such as toxicology or
chemistry. - Reports regarding discontinuation of a clinical
Investigation.
What is the FDA’s preferred filing frequency for
information amendments by sponsor?
At intervals of 30 days.
What is the FDA’s definition of the term “associated
with the use of the drug” with respect to the evaluation
of adverse experience.
What is the FDA’s definition of the term “associated
with the use of the drug” with respect to the evaluation
of adverse experience.
What type of experiences does the FDA classify as
serious adverse drug experiences in clinical trials?
Serious adverse drug experiences include:
1. Any event that results in death.
2. A life-threatening drug experience,
3. In patient hospitalization or prolongation thereof.
4. A significant or persistent disability
5. Congenital anomaly or birth defect.
6. Important medical events may also be serious
events.
What is the FDA’s definition of disability, as it relates to
serious adverse drug experience?
A substantial disruption of a person’s ability to conduct
normal life functions.
What is the FDA criterion which classified an adverse
drug experience as unexpected?
Any adverse experience, the specificity or severity of
which is not consistent with the IB, or other designated
document when an IB is not required.
Sponsor are required to maintain an ongoing review of
safety information from which sources?
- Any foreign or domestic source including clinical,
epidemiological & animal investigations. - Commercial marketing experience
- Scientific literature reports & unpublished scientific papers .
- Reports from foreign regulatory authorities not
previously reported to the FDA.
Who must be notified, via an IND safety report, of
serious, unexpected adverse experiences that are
associated with the use of the drug?
FDA & all investigators conducting studies under the
IND.
What is the time requirement for filing IND safety
reports with the FDA?
As soon as possible & never later than fifteen calendar
days after the sponsor’s initial receipt of the
information.
How soon must the FDA be notified of a fatal or life-threatening
adverse experience which is associated
with use of a drug?
By telephone or facsimile transmission, no later than
seven calendar days after sponsor receipt of the
information, followed by written report no later than 15
calendar days after initial receipt of the information by
the sponsor.
For purposes of filing IND safety reports with FDA,
what is the definition of a “life threatening event?”
The patient was at immediate risk of death from the
reaction as it occurred.
Who must approve modifications on the reporting
format or frequency of IND safety reports prior to a
sponsor deviating from the regulations ?
- The director of the new drug review division of
either the Center for rug Evaluation & Research
(CDER) - The Center for Biologics Evaluation & Research
(CBER).
For marketed drugs, a sponsor is not required to file
IND safety report for events which are from non-clinical
trial sources. TRUE or FALSE?
true
When are sponsors required to file follow-up
information for IND safety reports?
As soon as the relevant information is available.
If a sponsor evaluates an adverse experience &
determines that it is reportable as an IND safety
report, but it was not originally reported as such, how
long does the sponsor have to report the event as an
IND safety report?
As soon as possible ,but in no event later than 15
calendar days after the determination is made.
If a sponsor submits an IND safety report, it is
assumed by FDA that the drug caused or contributed to
the event, unless it is specifically denied by the
sponsor. TRUE OR FALSE?
false
What is the time frame in which a sponsor must file an
annual report ?
Within 60 days of the anniversary date that the IND
went into effect.
Name at least three elements required to be reported
for each individual study reported in an IND annual report.
- Study Title, identifier & purpose, description of
patient population & completion status. - Total number of subjects
initially planned for inclusion,
entered to date
who completed as planned
dropped for any reason. - Brief description of any interim or final analysis
results, if available.
Name at least two specific clinical adverse experience
summary items required in an IND annual report.
- Most frequent & most serious adverse experience
by body system. - IND safety reports submitted within the past year.
- List of subjects who died with cause of death.
- List of subjects who dropped due to an adverse
experience.
Summary information for clinical trials activity within
the past year is required in the IND annual report,
while results of pre-clinical studies are not. TRUE OR
FALSE?
false
A revised copy of an Investigator Brochure in an IND
annual report must accompanied by what additional
information?
A description of revisions.