Everything you need to know about an investigational new drug (IND) application is listed on the FDA website, click here. Consider this your textbook.
Below left is the law governing the IND. Because new drugs have the potential to kill, as well as cure, some drugs are carefully regulated. These regulated drugs include prescription drugs for diseases, and some over-the-counter drugs. Drugs not regulated by this act and these procedures include topical cosmetics, tattoo inks, nutitional supplements. Bullets, which are designed to go into bodies and change their physiologies, are not regulated by this act. Some inhaled drugs are, but not tobacco.
Below right, an excerpt from the FDA site. All IND applications are not handled in the same way.
[Code of Federal Regulations]
[Title 21, Volume 5]
[Revised as of April 1, 2012]
TITLE 21--FOOD AND DRUGS
CHAPTER I--FOOD AND DRUG ADMINISTRATIONDEPARTMENT OF HEALTH AND HUMAN SERVICES
(a)Progress reports. The investigator shall furnish all reports to the sponsor of the drug who is responsible for collecting and evaluating the results obtained. The sponsor is required under 312.33 to submit annual reports to FDA on the progress of the clinical investigations.
(b)Safety reports. An investigator must immediately report to the sponsor any serious adverse event, whether or not considered drug related, including those listed in the protocol or investigator brochure and must include an assessment of whether there is a reasonable possibility that the drug caused the event. Study endpoints that are serious adverse events (e.g., all-cause mortality) must be reported in accordance with the protocol unless there is evidence suggesting a causal relationship between the drug and the event (e.g., death from anaphylaxis). In that case, the investigator must immediately report the event to the sponsor. The investigator must record nonserious adverse events and report them to the sponsor according to the timetable for reporting specified in the protocol.
(c)Final report. An investigator shall provide the sponsor with an adequate report shortly after completion of the investigator's participation in the investigation.
(d)Financial disclosure reports. The clinical investigator shall provide the sponsor with sufficient accurate financial information to allow an applicant to submit complete and accurate certification or disclosure statements as required under part 54 of this chapter. The clinical investigator shall promptly update this information if any relevant changes occur during the course of the investigation and for 1 year following the completion of the study.[52 FR 8831, Mar. 19, 1987, as amended at 52 FR 23031, June 17, 1987; 63 FR 5252, Feb. 2, 1998; 67 FR 9586, Mar. 4, 2002; 75 FR 59963, Sept. 29, 2010]
3 IND types:
-Investigator IND submitted by a physician who 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.
-Emergency Use IND allows the FDA to authorize use of an experimental drug in an emergency situation that does not allow time for submission of an IND in accordance with 21CFR , Sec. 312.23 or Sec. 312.34. It is also used for patients who do not meet the criteria of an existing study protocol, or if an approved study protocol does not exist.
-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.
The 2 IND categories:- Commercial or Research (non-commercial)
The IND application must have:
- Animal Pharmacology and Toxicology Studies
- Preclinical data to permit an assessment as to whether the product is reasonably safe for initial testing in humans. Also included are any previous experience with the drug in humans (often foreign use).
- Manufacturing Information - 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.
-Clinical Protocols and Investigator Information
-Detailed protocols for proposed clinical studies to assess whether the initial-phase trials will expose subjects to unnecessary risks.
-Also, information on the qualifications of clinical investigators--professionals (generally physicians) who oversee the administration of the experimental compound--to assess whether they are qualified to fulfill their clinical trial duties.
-Finally, 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.
An Investigator Brochure is a continually updated document, it is a log of everything that has been done with the drug in the lab, in the clinic and in the general population after the drug has been marketed.
FDA guidance explaining what an Investigator Brochure is and what it should have in it, click here.
More IND resources, including links to Patents and Trade Office. You are going to need patent protection for your exciting new antibiotic, click here
Prepare a summary of an Investigator Brochure for our Lake Mbezi antibiotic
a. Make up a generic name
b. Make up a document giving you patent protection for your exciting new drug by finding a patent for an antibiotic. Make sure you record which drug or drug you are copying.
c. Make up microbiology studies. Do this from a literature search at NLM Pubmed and copy studies done for other drugs. Make sure you record the references of drugs you are copying.
d. Make up toxicology studies. Similarly, from a literature search.
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