ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 IND Application for an Investigational Drug: Investigational New Drug Application Guidance and Template for Drugs Products ICTR Navigators July 23, 2011 Version 3.0 Page 1 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products 1.0 Table of Contents Section 1.0 Table of Contents 2.0 Abbreviations: 3.0 FDA Websites: 4.0 Introduction: 5.0 Guidance and Instructions: 5.1 Template Comments 5.2 Regulations and Guidance documents 5.3 Number of Copies to be submitted 5.4 Application Header and Footer 5.5 Binding 5.6 FDA, CDER Mailing Address 5.7 Website Address Hyperlinks 5.8 Questions and Additional Information Contact 6.0 Application Template Guidance: 2.0 IND CFR FDA CDER CBER CDRH CMC GCP GLP GMP BLA NDA PMA IDE 3.0 Version 3.0 Page 2 2 2 3 4 4 4 4 4 4 6 6 6 7 Abbreviations Investigational New Drug Code of Federal Regulations U.S. Food and Drug Administration Center for Drug Evaluation and Research Center for Biologics Evaluation and Research Center for Devices and Radiological Health Chemistry, Manufacturing, and Controls Good Clinical Practices Good Laboratory Practices Good Manufacturing Practices Biologic License Application New Drug Application Pre-Market Application Investigational Device Exemption FDA Websites A list of several FDA websites containing useful information for investigators using an investigational drug product is provided below. It is strongly suggested that these websites be reviewed before submitting an IND application to the FDA. FDA Forms website: http://www.fda.gov/aboutfda/reportsmanualsforms/forms/default.htm FDA Title 21 Regulations Search Engine (e.g., IND regulations 21CRF312) website: http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm FDA Running Clinical Trials website: http://www.fda.gov/ScienceResearch/SpecialTopics/RunningClinicalTrials/default.htm Page 2 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 FDA – CDER Investigational New Drug (IND) Application website: http://www.fda.gov/Drugs/DevelopmentApprovalProcess/HowDrugsareDevelopedandApproved/ApprovalAp plications/InvestigationalNewDrugINDApplication/default.htm FDA - Sponsor-Investigator IND website http://www.fda.gov/Drugs/DevelopmentApprovalProcess/HowDrugsareDevelopedandApproved/ApprovalAp plications/InvestigationalNewDrugINDApplication/ucm071098.htm FDA – CDER Drug Guidance documents: http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm FDA- Formal Meetings Between the FDA and Sponsors or Applicants (pre-IND, Phase 2, etc…): http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM153222.pdf FDA - CDER PRE-IND Consultation Contacts http://www.fda.gov/downloads/Drugs/DevelopmentApprovalProcess/HowDrugsareDevelopedandApproved/ ApprovalApplications/InvestigationalNewDrugINDApplication/Overview/UCM166356.pdf 4.0 Introduction Introduction: The enclosed information is intended to provide a general process overview and a template for an Investigational New Drug (IND) application submission for drug products reviewed by the FDA Center for Drug Evaluation Research (CDER). The document is written from the perspective that the person submitting the IND application is a Sponsor-Investigator. A Sponsor-Investigator is someone who is both 1) responsible for initiating the studies conducted with the investigational drug product and 2) who conducts the studies. The contents of this document are based on the FDA regulations governing investigational drugs, 21CFR312, FDA guidance documents, and personal experience. However, each drug product and associated clinical trials may have unique features or circumstances that are not addressed by this document or the reference guidance documents cited herein. In such cases, the Sponsor-Investigator should consult with the ICTR-DDRS and are strongly encouraged to request a pre-IND meeting with the FDA. A guidance and template for a pre-IND meeting request is available through the ICTRDDRS. While there are numerous regulations, guidance documents and other references pertaining to IND applications for drug products, those provided in this document are those most commonly used and/or most widely applicable. The following references will give the Sponsor-Investigator a general overview of the basic IND application content and format. FDA Regulation - 21CRF312 Subpart B--Investigational New Drug Application (IND): http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?CFRPart=312&showFR=1&subp artNode=21:5.0.1.1.3.2 FDA Guidance - Content and Format of Investigational New Drug Applications (INDs) for Phase 1 Studies of Drugs, Including Well-Characterized, Therapeutic, Biotechnology-derived Products: http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm071597.pdf Page 3 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products 5.0 Version 3.0 Guidance and Instructions 5.1 Template Comments The enclosed template guidance is a suggested format based on federal regulations, guidance documents, and previous experience. Within each section of the application template are references to applicable FDA regulations, web addresses to FDA guidance documents, comments/instructions, web addresses to FDA forms, and suggested formatting and/or language. These instructions outline what should be included or inserted into a particular section and may also address special considerations. As this is a basic template and each IND is unique, best judgment should be used concerning the information to be included in the submisison. The sponsor-investigator may use this format or adapt it as appropriate for the particular investigational product being evaluated. Each section of the application should begin on new page because as you see in the binding instructions, you should use index tabs to mark each section of the application. Thus, each section in this document starts on a new page. A blank template with just the cover letter, title page, and suggested section headings and subheadings is available for download at the DDRS website. 5.2 Regulations and Guidance documents Throughout this document are a number references to regulations and guidance documents. These references have been included to provide the Sponsor-Investigator with direction and guidance when completing an IND application. The references will not address every situation that may be encountered. If the applicant has questions after reviewing the references provided, they should contact the ICTR Research Navigators for assistance and/or request a pre-IND meeting with the FDA. 5.3 Number of Copies to be submitted One original copy and two photocopies of the IND application must be sent with the initial submission. Of note: Once the FDA receives the application and begins the review process, they may ask for additional desk copies. 5.4 Application Header and Footer The following is the suggested format of document headers and footers to be used with the initial IND submission. Note: Headers and footers are not included in the template and must be inserted manually and may be modified as appropriate. Header: [Left Hand Side] IND Application Date: [INSERT DATE] [INSERT Drug Product Name] [Right Hand Side] IND Number: pending Serial Number: [1571 Serial #] Footer: [Left Hand Side] John Hopkins University [INSERT: Sponsor-Investigator Name] Confidential and Proprietary [Right Hand Side] Page [##] 5.5 Binding If a project manager has been assigned to the IND application being prepared for submission or if contact information is available for a project manager within the Office/Division that will review the IND application, it is suggested that the Sponsor-Investigator contact the project manager to review how the IND materials should be bound. If a project manager has not yet been assigned to the IND, general guidelines for binding a paper IND application being submitted to CDER are provided below. The below binding guidance is the Page 4 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 information posted at the FDA’s website entitled “FDA IND, NDA, ANDA, or Drug Master File Binders” and located at following web address: http://www.fda.gov/Drugs/DevelopmentApprovalProcess/FormsSubmissionRequirements/DrugMasterFil esDMFs/ucm073080.htm IND submissions that are received loose or which are inadequately bound may be returned to the Sponsor-Investigator for proper binding and resubmission which can significantly delay the FDA review process. If the Sponsor-Investigator chooses to use a different type of binder than suggested, the binders should be labeled as suggested below. 1. FDA CDER Guidance Recommendations: a. Archive - Red POLYETHYLENE BINDER (or ACCO Executive Red Stock Number 25079 or Smead Red Stock Number 81752 or similar type*) i. Front (flat size) - 248 x 292mm (9-3/4 x 11-1/2") ii. Back (flat size) - 248 x 305mm (9-3/4 x 12") (size includes 13 mm (1/2") lip at top) 1. Must be high impact linear plastic (matte finish or similar) - Must be able to withstand temperatures up to 150 degrees - Material should have a surface smooth enough to allow printing with a complete bonding of ink to the surface after a minimum of one hour drying time - Should be free from streaks, blisters, scratches and mottling . Binder weight MUST be .023-.025 gauge - Ink color MUST be BLACK b. Duplicate (or First Review Copy) - Green PAPER BINDER (or ACCO Green Stock Number 25076 or similar type *) i. Front (flat size) - 267 x 292mm (10-1/2 x 11-1/2") ii. Back (flat size) - 267 x 305mm (10-1/2 x 12") (size includes 13mm (1/2") lip at top) 1. Binder MUST be of 11-point plate rope stock of extra heavy weight - Ink color MUST be BLACK c. Second and additional review copies - Orange PAPER BINDER ( or ACCO Tangerine Stock Number 25977 or Smead Orange Stock Number 81652 or similar type or any color except Green or Red.* ) i. Same specifications as the Duplicate Copy 2. Identification of binders a. Required on front folder in a clear, sharp, permanent-type print in BLACK ink Permanent adhesive labels may be used in a clear, sharp print - Printing must withstand a "Scotch Tape Test" which consists of pressing a strip of "Scotch" tape firmly on the printed area and removing - There should be NO transfer of the printed area on the tape b. Binders are identified with the following label: VOLUME __________________ NOTICE OF CLAIMED INVESTIGATIONAL EXEMPTION FOR A NEW DRUG IND. NO._____(For the initial submission of the new application leave blank)_____ SPONSOR NAME NAME OF DRUG This submission: VOL._____OF______VOLS. Page 5 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 3. Additional Information: a. If submissions are received loose or are inadequately bound, they may be returned to the sponsor or applicant for further handling and processing. If the submission is returned, the submission will be date-stamped when resubmitted adequately bound. b. If the application is sent in boxes, “Banker Boxes” should be used. 4. Information about ACCO Folders: Note: The vendor information listed below is provided as an example of where these items may be purchased and is not intended as an endorsement of the vendor or a mandatory vendor to be used to purchase the folders. a. Red (ACCO USA, Executive Red, #25079) – used for archive (original copy) i. Example Vendor 1. Office Depot: http://www.officedepot.com/a/products/193664/Acco-Presstex-60percentRecycled-Binder-Side/ b. Green (ACCO USA, Green, #25076) – used for 1st review copy i. Example Vendor 1. Office Depot: http://www.officedepot.com/a/products/193623/Acco-Presstex-60percentRecycled-Binder-Side/ c. Light Blue (ACCO USA, #25072) – used for 2nd review copy NOTE: The FDA requests “Tangerine or Orange” binders, but these can be very difficult to find. In the Navigators’ experience, the FDA will accept these light blue binders in place of the tangerine/orange requested. i. Example Vendor 1. Office Depot: http://www.officedepot.com/a/products/102905/Acco-Presstex-60percentRecycled-Binder-Side/ 5.6 FDA, CDER Mailing Address Central Document Room Center for Drug Evaluation and Research Food and Drug Administration 5901-B Ammendale Rd. Beltsville, MD 20705-1266 5.7 Website Address Hyperlinks All hyperlinks to websites included in this document are operational as of the date of this version. If any non-functional hyperlinks are identified in this document, please contact the ICTR Research Navigators via the contact information below so that the links may be updated. 5.8 Questions and Additional Information Contact For questions regarding any of the information presented or use of the template, please contact the ICTR Research Navigators at ICTR_Navigators@jhmi.edu or via telephone at 410-955-8120 or 410614-5383. Page 6 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products 6.0 Application Template Guidance: Application Section Cover Letter Cover Page Section 1: Form FDA 1571 Section 2: Table of Contents Section 3: Introductory Statement Section 4: General Investigational Plan Section 5: Investigator’s Brochure Section 6: Protocol Section 7: Chemistry, Manufacturing, and Controls Section 8: Pharmacology and toxicology Section 9: Previous human experience Section 10: Additional Information Section 11: Relevant Information Section 12: Bibliography Section 13: Appendices Page 7 of 39 Page 8 9 10 11 14 16 18 19 28 32 34 35 37 38 39 Version 3.0 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Cover Letter [INSTRUCTIONS: The suggested format for the cover letter that accompanies the IND application may be found below. If the Sponsor-Investigator has already had a pre-IND meeting with the FDA, then the pre-IND number and meeting date should be referenced in the cover letter.] [INSERT: Sponsor-Investigator letterhead or address] [INSERT: DATE] Food and Drug Administration Center for Drug Evaluation and Research Central Document Room 5901-B Ammendale Rd. Beltsville, MD 20705-1266 RE: New IND Application Submission Dear Reviewers, Pursuant to 21 CFR 312, I am submitting an original, Sponsor-Investigator Investigational New Drug (IND) application. The IND is being submitted to [INSERT: Supply short description of experimental treatment/drug and protocol]. [INSERT: If pre-IND meeting was held, then insert text referencing the pre-IND (PIND) number and the date of meeting.] [INSTRUCTIONS FOR ACCO BINDERS: Use the following text if submitting the application in ACCO binders, per above guidance information. “Enclosed are the original application (red binders), first copy of the application (green binders), and the second copy (light blue binders).”] If you have any questions about the material included in this IND, please do not hesitate to contact me at [INSERT: phone number of Sponsor-Investigator], by email at [INSERT: email address of Sponsor-Investigator], or by fax at [INSERT: Sponsor-Investigator fax] any time during your review. [COMMENT: If there is another person designated to interact with the FDA on behalf of the SponsorInvestigator, then state “{INSERT: name} is authorized to interact with the FDA on my behalf and {INSERT: name‟s} contact information is {INSERT: phone, email, and fax}.”] Thank you in advance for your consideration. Sincerely, [INSERT: Sponsor-Investigator Name] [INSERT: Title] [INSERT: Affiliation] Enclosure: Page 8 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Cover Page [COMMENTS: A suggested format for the title page to the IND application is provided below.] Investigational New Drug Application DATE IND Application Title: Drug Product: Serial Number: Sponsor-Investigator: Name and Contact Information Page 9 of 39 ICTR DDRS: Sponsor-Investigator IND Guidance and Template for Drugs Version 3.0 Section 1: Form FDA 1571 [SECTION INTRODUCTION: The requirements for this section of the IND application are provided below. NOTE: Some of the information included may not be applicable to all IND applications. General instructions and comments on the format and content of this section of the IND application, along with a list of guidance documents and additional regulation references, are provided. Within each subheading of this section are additional instructions, comments, suggested text, web addresses for forms, web addresses for specific guidance documents, and/or regulations.] [Regulatory Reference: 21CFR312.23(a)(1)- Cover sheet (Form FDA-1571) An FDA Form 1571 is a required cover sheet for the application containing the following: (i) The name, address, and telephone number of the sponsor, the date of the application, and the name of the investigational new drug. (ii) Identification of the phase or phases of the clinical investigation to be conducted. (iii) A commitment not to begin clinical investigations until an IND covering the investigations is in effect. (iv) A commitment that an Institutional Review Board (IRB) that complies with the requirements set forth in part 56 will be responsible for the initial and continuing review and approval of each of the studies in the proposed clinical investigation and that the investigator will report to the IRB proposed changes in the research activity in accordance with the requirements of part 56. (v) A commitment to conduct the investigation in accordance with all other applicable regulatory requirements. (vi)The name and title of the person responsible for monitoring the conduct and progress of the clinical investigations. (vii) The name(s) and title(s) of the person(s) responsible under 312.32 for review and evaluation of information relevant to the safety of the drug. (viii) If a sponsor [Sponsor-Investigator] has transferred any obligations for the conduct of any clinical study to a contract research organization a statement containing the name and address of the contract research organization, identification of the clinical study, and a listing of the obligations transferred. If all obligations governing the conduct of the study have been transferred, a general statement of this transfer--in lieu of a listing of the specific obligations transferred--may be submitted. (ix) The signature of the sponsor [Sponsor-Investigator] or the sponsor's [Sponsor-Investigator‟s] authorized representative. If the person signing the application does not reside or have a place of business within the United States, the IND is required to contain the name and address of, and be countersigned by, an attorney, agent, or other authorized official who resides or maintains a place of business within the United States. 1. Form FDA 1571 [INSERT TEXT: “Please see the signed and dated Form FDA 1571 next.”] [WEB ADDRESS TO FDA FORM AND FORM INSTRUCTIONS FDA form 1571: http://www.fda.gov/downloads/AboutFDA/ReportsManualsForms/Forms/UCM083533.pdf Instructions for form 1571: http://www.fda.gov/Drugs/DevelopmentApprovalProcess/HowDrugsareDevelopedandApproved/ApprovalAp plications/InvestigationalNewDrugINDApplication/ucm071098.htm#form1571] Page 10 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 2: Table of Contents [SECTION INTRODUCTION: The requirements for this section of the IND application are provided below. NOTE: Some of the information included may not be applicable to all IND applications. General instructions and comments on the format and content of this section of the IND application, along with a list of guidance documents and additional regulation references, are provided. Within each subheading of this section are additional instructions, comments, suggested text, web addresses for forms, web addresses for specific guidance documents, and/or regulations.] [Regulatory Reference: 21CFR312.23(a)(2)- Table of Contents.] [INSTRUCTIONS: The IND Table of Contents must list all sections of the application broken down by volume and section number. Additionally, the Table of Contents should include a list of tables, figures, and attachments found within the application. The Table of Contents should be accurate and easy to follow so that the FDA reviewers can find the sections they need to review quickly and easily. Before submitting the IND application, double check to make certain that the Table of Contents matches the content, title, page numbers, and volumes, of the final version of the IND application.] [COMMENT: The Table of Contents below is provided as an example and is based on the requirements set forth in 21CFR312.23 – IND content and format, found at: http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?fr=312.23. Changes may be made to the Table of Contents provided based on the needs of individual IND applications.] 2.0 Table of Application Contents Volume 1 Section 1.0 FDA Form 1571 Title 2.0 Table of Contents 3.0 3.1 3.1.1 3.1.2 3.1.3 3.1.4 3.1.5 3.1.6 3.2 3.3 Introductory statement Brief Introductory Statement Drug Name Pharmacological Class Structural Formula Formulation of Dosage Form Route of Administration Broad Objectives & Planned Duration of the Proposed Clinical Investigations Brief Summary of Previous Human Experience Withdrawn From Investigation or Marketing in any Country 4.0 4.1 4.1.1 General investigational plan Rationale Rationale for Drug Page 11 of 39 Page ICTR DDRS: IND Application Guidance and Template for Drug Products 4.1.2 4.2 4.3 4.4 4.5 4.6 Rationale for Study Indications to be Studied the First Year General Approach to be Followed in Evaluating the Drug Clinical Trials to be Conducted First Year Estimated Number of Subjects to be Given the Drug in First Year Anticipated Risks of Particular Severity or Seriousness 5.0 Investigator’s brochure 6.0 6.1 6.2 Protocol Objectives and Purpose of Study Principal Investigator, Sub-investigators, Research Facilities, and Institutional Review Boards. Patient Selection and Estimated Number to be Studied Description of Study Design Drug Dosing – Method, Maximum Dose, and Duration of Exposure Observations and Measurements Made to Fulfill Study Objectives Procedures to Monitor Drug Effects in Human Subjects and Minimize Risks Clinical Trial Registration 6.3 6.4 6.5 6.6 6.7 6.8 Volume 2 Section Title 7.0 Chemistry, Manufacturing, and Controls 7.1 Introduction: Statement of Risk 7.2 Drug Substance 7.3 Drug Product 7.4 Placebo 7.5 Labeling 7.6 Claim for Categorical Exclusion for Environmental Assessment 8.0 8.1 8.2 Pharmacology and toxicology data Pharmacology and drug disposition Toxicology 9.0 Previous human experience 10.0 10.1 10.2 10.3 10.4 Additional information Drug dependence and abuse potential Radioactive drugs Pediatric studies Other information 11.0 Relevant Information 12.0 Bibliography 13.0 Appendices Page 12 of 39 Version 3.0 Page ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 LIST OF TABLES Volume # Section Title Page Title Page Table 1 Table 2 Table 3 Volume # Section Table 4 Table 6 Table 7 Table 8 Table 9 Table 10 LIST OF FIGURES Volume # Section Title Page Title Page Title Page Title Page Figure 1 Figure 2 Figure 3 Volume # Section Figure 4 Figure 5 List of Attachments Volume # Section Attachment 1 Attachment 2 Volume # Section Attachment 3 Attachment 4 Page 13 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 3: Introductory Statement [SECTION INTRODUCTION: The requirements for this section of the IND application are provided below. NOTE: Some of the information included may not be applicable to all IND applications. General instructions and comments on the format and content of this section of the IND application, along with a list of guidance documents and additional regulation references, are provided. Within each subheading of this section are additional instructions, comments, suggested text, web addresses for forms, web addresses for specific guidance documents, and/or regulations.] [REGULATORY REFERENCE: 21CFR312.23(a)(3)(i-iii) (3)Introductory statement and general investigational plan (i) A brief introductory statement giving the name of the drug and all active ingredients, the drug's pharmacological class, the structural formula of the drug (if known), the formulation of the dosage form(s) to be used, the route of administration, and the broad objectives and planned duration of the proposed clinical investigation(s). (ii) A brief summary of previous human experience with the drug, with reference to other IND's if pertinent, and to investigational or marketing experience in other countries that may be relevant to the safety of the proposed clinical investigation(s). (iii) If the drug has been withdrawn from investigation or marketing in any country for any reason related to safety or effectiveness, identification of the country(ies) where the drug was withdrawn and the reasons for the withdrawal.] 3.0 Introduction 3.1 Introductory Statement [INSTRUCTIONS FOR 3.1 TO 3.1.6 A brief introductory statement including the name of the investigational drug and all active ingredients, the drug's pharmacological class, the structural formula of the drug (if known), the formulation of the dosage form(s) to be used, the route of administration, and the broad objectives and planned duration of the proposed clinical investigation(s)should be provided here. If a particular heading provided below is not applicable or the information is not known/available at the time of the IND submission, then state “not applicable” or provide an explanation stating that the information is not known or available.] [NOTES: If submitting an Exploratory IND (eIND), a statement must be included in this section indicating that the application is an eIND. See FDA eIND guidance for more information. o FDA eIND Guidance: http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm078933.pdf If a pre-IND meeting was already held with the FDA, the pre-IND number, meeting date, and outcomes should be referenced here.] 3.1.1 Drug Name and all Active Ingredients [ADDITIONAL INSTRUCTIONS: List all known names of the investigational drug including, but not Page 14 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 limited to, the proprietary name, generic name, chemical name, and any other names of the drug.] 3.1.2 Pharmacological Class [INSTRUCTIONS: Insert description of pharmacological class. If not known, explain why it is not known.] 3.1.3 Structural and Chemical Formula [INSTRUCTIONS: Insert both the chemical and structural formula of the final drug product. If not known, explain why it is not known.] 3.1.4 Formulation of Dosage Form [INSTRUCTIONS: Insert a succinct description of the formulation including dosage amounts of each active ingredients of the drug product.] 3.1.5 Route of Administration [INSTRUCTIONS: Insert a description of the route of administration.] 3.1.6 Broad Objectives and Planned Duration of the Proposed Clinical Investigation(s). [INSTRUCTIONS: Provide description of the objectives of the clinical investigation(s) being proposed as part of this application and how long you expect the investigation(s) (clinical trial) to last. If more than one is being proposed, then insert appropriate subheading so the FDA can clearly distinguish what information pertains to which trial.] 3.2 Brief Summary of Previous Human Experience [INSTRUCTIONS: A brief summary of previous human experience with the drug, with reference to other IND's if pertinent, and to investigational or marketing experience in other countries that may be relevant to the safety of the proposed clinical investigation(s) should be provided here. This should be a high-level summary of the information provided in Section 9 – Previous Human Experience.] 3.3 Withdrawn From Investigation or Marketing in any Country [INSTRUCTIONS: If the drug has been withdrawn from investigation or marketing in any country for any reason related to safety or effectiveness, identification of the country(ies) where the drug was withdrawn and the reasons for the withdrawal should be provided here.] Page 15 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 4: General Investigational Plan [SECTION INTRODUCTION: The requirements for this section of the IND application are provided below. NOTE: Some of the information included may not be applicable to all IND applications. General instructions and comments on the format and content of this section of the IND application, along with a list of guidance documents and additional regulation references, are provided. Within each subheading of this section are additional instructions, comments, suggested text, web addresses for forms, web addresses for specific guidance documents, and/or regulations.] [REGULATORY REFERENCE: 21CFR312.23(a)(3)(iv)A brief description of the overall plan for investigating the drug product for the following year should be provided here. The plan should include the following: (a) the rationale for the drug or the research study; (b) the indication(s) to be studied; (c) the general approach to be followed in evaluating the drug; (d) the kinds of clinical trials to be conducted in the first year following the submission (if plans are not developed for the entire year, the sponsor should so indicate); (e) the estimated number of patients to be given the drug in those studies; and (f) any risks of particular severity or seriousness anticipated on the basis of the toxicological data in animals or prior studies in humans with the drug or related drugs.] 4.0 General investigational plan [INSTRUCTIONS: In this section, provide a brief overview of the investigational plan for the first year the drug is being studied. Be sure to include/address the information requested in each of the subsections of section 4.] 4.1 Rationale for Drug and Study [INSTRUCTIONS: In this section, state the rationale for using the investigational drug and/or conducting the research study. Include background information on the science that supports the use of the investigational drug and/or the research study. Note: This information can either be split into two sections, as illustrated here (4.1.1. and 4.1.2., or included all together under 4.1). Use your best judgment as to which style is more appropriate for your application.] 4.1.1 Rationale for Drug [INSTRUCTIONS: See above instructions for 4.1.] 4.1.2 Rationale for Study [INSTRUCTIONS: See above instructions for 4.1.] 4.2 Indications to be Studied the First Year [INSTRUCTIONS: State the indication(s) to be studied during the first year of the IND here.] 4.3 General Approach to be Followed in Evaluating the Drug Page 16 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 [INSTRUCTIONS: State the general approach to be followed in evaluating the drug here.] 4.4 Clinical Trials to be Conducted First Year [INSTRUCTIONS: Provide an overview of the clinical trial(s) that are planned to be conducted during the first year of the IND here. If the plans are not yet developed for the first year of the IND, indicate this here.] 4.5 Estimated Number of Subjects to be Given the Drug in First Year [INSTRUCTIONS: Provide an estimate of the number of total participants to be given the investigational drug in the proposed clinical trial(s) to be conducted during the first year of the IND. If the drug is to be given to multiple populations, i.e., healthy volunteers and patient populations, be sure to provide an estimate for each individual population.] 4.6 Anticipated Risks of Particular Severity or Seriousness [INSTRUCTIONS: Provide an overview of all risks of particular severity or seriousness anticipated on the basis of the toxicological data in animals and/or prior studies with the investigational drug or related drugs in humans here. Also include any study procedures that carry anticipated risks of particular severity or seriousness in this section.] Page 17 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 5: Investigator’s Brochure [SECTION INTRODUCTION: The requirements for this section of the IND application are provided below. NOTE: Some of the information included may not be applicable to all IND applications. General instructions and comments on the format and content of this section of the IND application, along with a list of guidance documents and additional regulation references, are provided. Within each subheading of this section are additional instructions, comments, suggested text, web addresses for forms, web addresses for specific guidance documents, and/or regulations.] [REGULATORY REFERENCE: 21CFR312.23(a)(5) - Investigator's brochure. If required under 312.55, a copy of the investigator's brochure, containing the following information: (i) A brief description of the drug substance and the formulation, including the structural formula, if known. (ii) A summary of the pharmacological and toxicological effects of the drug in animals and, to the extent known, in humans. (iii) A summary of the pharmacokinetics and biological disposition of the drug in animals and, if known, in humans. (iv) A summary of information relating to safety and effectiveness in humans obtained from prior clinical studies. (Reprints of published articles on such studies may be appended when useful.) (v) A description of possible risks and side effects to be anticipated on the basis of prior experience with the drug under investigation or with related drugs, and of precautions or special monitoring to be done as part of the investigational use of the drug.] Investigator’s brochure 5.0 [INSTRUCTIONS: If an early phase trial is being conducted at a single center, then an investigator brochure (IB) is not necessary. If no IB is included in the IND application, provide a brief explanation for FDA reviewers as to why. If studying an approved drug that has a package insert, change the section heading to “Package Insert” and place the package insert information here. A number of package inserts are available for download at http://dailymed.nlm.nih.gov/. The package insert needs to be from the manufacturer of the drug that will be supplying the drug for the study. If there is an IB, insert text after stating “Please see next the Investigator‟s Brochure” and then insert the IB.] Page 18 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 6: Protocol [SECTION INTRODUCTION: The requirements for this section of the IND application are provided below. NOTE: Some of the information included may not be applicable to all IND applications. General instructions and comments on the format and content of this section of the IND application, along with a list of guidance documents and additional regulation references, are provided. Within each subheading of this section are additional instructions, comments, suggested text, web addresses for forms, web addresses for specific guidance documents, and/or regulations.] [REGULATORY REFERENCE: 21CFR312.23(a)(6) (6)Protocols. (i) A protocol for each planned study. (Protocols for studies not submitted initially in the IND should be submitted in accordance with 312.30(a).) In general, protocols for Phase 1 studies may be less detailed and more flexible than protocols for Phase 2 and 3 studies. Phase 1 protocols should be directed primarily at providing an outline of the investigation--an estimate of the number of patients to be involved, a description of safety exclusions, and a description of the dosing plan including duration, dose, or method to be used in determining dose--and should specify in detail only those elements of the study that are critical to safety, such as necessary monitoring of vital signs and blood chemistries. Modifications of the experimental design of Phase 1 studies that do not affect critical safety assessments are required to be reported to FDA only in the annual report. (ii) In Phases 2 and 3, detailed protocols describing all aspects of the study should be submitted. A protocol for a Phase 2 or 3 investigation should be designed in such a way that, if the sponsor anticipates that some deviation from the study design may become necessary as the investigation progresses, alternatives or contingencies to provide for such deviation are built into the protocols at the outset. For example, a protocol for a controlled short-term study might include a plan for an early crossover of non-responders to an alternative therapy. (iii) A protocol is required to contain the following, with the specific elements and detail of the protocol reflecting the above distinctions depending on the phase of study: (a) A statement of the objectives and purpose of the study. (b) The name and address and a statement of the qualifications (curriculum vitae or other statement of qualifications) of each investigator, and the name of each sub-investigator (e.g., research fellow, resident) working under the supervision of the investigator; the name and address of the research facilities to be used; and the name and address of each reviewing Institutional Review Board. {NOTE: - FDA Form 1572 and CVs} (c) The criteria for patient selection and for exclusion of patients and an estimate of the number of patients to be studied. (d) A description of the design of the study, including the kind of control group to be used, if any, and a description of methods to be used to minimize bias on the part of subjects, investigators, and analysts. (e) The method for determining the dose(s) to be administered, the planned maximum dosage, and the duration of individual patient exposure to the drug. (f) A description of the observations and measurements to be made to fulfill the objectives of the study. (g) A description of clinical procedures, laboratory tests, or other measures to be taken to monitor the Page 19 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 effects of the drug in human subjects and to minimize risk.] [COMMENTS: This section of the application may be written in a number of different formats. Regardless of the format chosen, the information listed in the regulatory reference above and itemized in the template to follow must be provided. If the Sponsor-Investigator is using the JHM IRB eFormA, it is strongly suggested that the eIRB application in its entirety be submitted with in this section. This is suggested because the eIRB application contains information that is not included in the eFormA which should be submitted. If the eIRB application is submitted, the appropriate subheading in this section or in the appendices should be added. Finally, if the protocol being submitted with the IND application is already IRB approved, the Sponsor-Investigator should include the IRB approval letter with the IND application and the appropriate subheading in this section or in the appendices should be added. [FORMATS: In the suggested format below, the applicant provides a high level summary of the requested information and references the FDA reviewers to a full version of the documents (e.g., protocol, eIRB application, consent, IRB approval letter) located in the appendices, including the page number of document in which the information can be found. This format is suggested as it provides the FDA reviewers an „easy to read‟ overview of the requested information as well as specific references to full documents. Note: The instructions in the heading below also indicate the information to be provided to the FDA regardless of the chosen format. An alternate format starts with the „6.0 Protocol‟ heading, followed by subheadings „6.1 Protocol‟, „6.2 Consent‟, „6.3 Investigator and Facilities Data‟, and „6.4 Clinical Trial Registration‟. The Sponsor-Investigator should include additional subheading under each of the above as appropriate to the documents being submitted. The suggested format below illustrates appropriate subheadings (e.g. “6.1.1. Protocol/eFormA”, “6.1.2 eIRB application”, “6.1.3 IRB approval”, “6.3.1 Form FDA 1572”, “6.3.2. Sponsor-Investigator CV”, etc…) which may be used with this alternate format. After each subheading, the applicant should insert the appropriate document.] [FDA GUIDANCE DOCUMENTS: Below are web addresses for a number of FDA guidance document sites that may be useful with regard to choice of study design and drafting the protocol. FDA Guidance Documents on Clinical Pharmacology: http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm064982.htm FDA Guidance Documents on Clinical / Medical: http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm064981.htm FDA Guidance Documents on Biopharmaceutics: http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm064964.htm FDA Guidance Documents on Drug Safety: http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm064993.htm FDA Guidance Documents on International Conference on Harmonisation – Efficacy: http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm065004.htm] 6.0 Protocol(s) [INSTRUCTIONS: If providing a high-level summary of the information listed below, it is suggested Page 20 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 that the Sponsor-Investigator include the suggested text. Additionally, under each of the headings in Section 6, the Sponsor-Investigator should cross-reference the appendix and page number where the full version or actual document(s) can be found.] [SUGGESTED TEXT: “Please see below a brief overview of the required information for this section including cross references to the full versions of the documents in which this information can be found.” OR “Please see next the protocol.”] 6.1 Objectives and Purpose of Study [INSTRUCTIONS: Provide a brief statement of the objectives and purpose of the study here.] 6.2 Investigator and Facilities Data [INSTRUCTIONS: Needed here are the name, address, and a statement of the qualifications (curriculum vitae or other statement of qualifications) of each investigator as well as the name of each sub-investigator (e.g., research fellow, resident) working under the supervision of the investigator. Also needed are the name(s) and address(es) of the research facility(ies) to be used as well as the name and address of each reviewing Institutional Review Board (IRB). The information needed for this section is provided to the FDA on the FDA Form 1572 (see below for additional guidance) along with copies of the Sponsor-Investigator‟s CV, medical license, and financial disclosure forms (FDA Form 3454 and FDA Form 3455; see below for additional guidance). While not required, the Sponsor-Investigator may also provide copies of the CVs, medical or other professional licenses (if applicable), and financial disclosure forms (FDA Form 3454 and FDA Form 3455) for all subinvestigators listed in Box 6 of the 1572. If the Sponsor-Investigator chooses not provide the subinvestigators‟ information in the application, the applicant MUST maintain copies of this documentation in their IND regulatory binder. Additional guidance on the completion of the FDA forms for this section as well the website where fillable PDF forms can be found are provided below. The FDA forms, CVs, and licenses may either 1) be placed after the appropriate subheading in this section or 2) placed in the appendices.] 6.2.1 Form FDA 1572 [1572 INSTRUCTIONS and GUIDANCE: Please review the FDA 1572 FAQs guidance document before completing the 1572. Both the FAQs and FDA Form 1572 may be downloaded from the following websites: Form FDA 1572: http://www.fda.gov/downloads/AboutFDA/ReportsManualsForms/Forms/UCM074728.pdf FDA Guidance on 1572 (FAQs): http://www.fda.gov/downloads/RegulatoryInformation/Guidances/UCM214282.pdf] [SUGGESTED TEXT: “Please see the signed and dated FDA Form 1572 on the next page.” OR “Please see the signed and dated FDA Form 1572 in appendix ##.”] 6.2.2 Sponsor-Investigator Page 21 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 [SUGGESTED TEXT: “The Sponsor-Investigator‟s CV and Medical License may be found on the next page.” OR “Please see the Investigator‟s CV and Medical License in appendix ##.”] 6.2.3 Subinvestigator(s) [SUGGESTED TEXT: “The CVs and medical licenses (if applicable) of the following subinvestigators may be found on the next page.” OR “Please see the subinvestigators‟ CVs and medical licenses (if applicable) in appendix ##.”] [COMMENT: Provide a list of subinvestigators in the order that the CVs and licenses appear and place the documents after this subheading or if you may place the documents in the appendices.] [EXAMPLE TEXT (May be used here or in appendix): “The CVs and licenses (if applicable) of the subinvestigators listed below may be found on the next page. John L Doe, MD, PhD Lisa M. Name, PhD Thomas Y. Doe, RN, MSN”] 6.2.3 Disclosure of Financial Interests [Regulatory reference: 21CFR54 Sec. 54.1 Purpose. (a) The Food and Drug Administration (FDA) evaluates clinical studies submitted in marketing applications, required by law, for new human drugs and biological products and marketing applications and reclassification petitions for medical devices. (b) The agency reviews data generated in these clinical studies to determine whether the applications are approvable under the statutory requirements. FDA may consider clinical studies inadequate and the data inadequate if, among other things, appropriate steps have not been taken in the design, conduct, reporting, and analysis of the studies to minimize bias. One potential source of bias in clinical studies is a financial interest of the clinical investigator in the outcome of the study because of the way payment is arranged (e.g., a royalty) or because the investigator has a proprietary interest in the product (e.g., a patent) or because the investigator has an equity interest in the sponsor of the covered study. This section and conforming regulations require an applicant whose submission relies in part on clinical data to disclose certain financial arrangements between sponsor(s) of the covered studies and the clinical investigators and certain interests of the clinical investigators in the product under study or in the sponsor of the covered studies. FDA will use this information, in conjunction with information about the design and purpose of the study, as well as information obtained through on-site inspections, in the agency's assessment of the reliability of the data. Sec. 54.2 Definitions. For the purposes of this part: (a)Compensation affected by the outcome of clinical studies means compensation that could be higher for a favorable outcome than for an unfavorable outcome, such as compensation that is explicitly greater for a favorable result or compensation to the investigator in the form of an equity interest in the sponsor of a covered study or in the form of compensation tied to sales of the product, such as a royalty interest. (b)Significant equity interest in the sponsor of a covered study means any ownership interest, stock options, or other financial interest whose value cannot be readily determined through reference to public prices (generally, interests in a nonpublicly traded corporation), or any equity interest in a publicly traded corporation that exceeds $50,000 during the time the clinical investigator is carrying out the study and for 1 year following completion of the study. (c)Proprietary interest in the tested product means property or other financial interest in the product including, but not limited to, a patent, trademark, copyright or licensing agreement. (d)Clinical investigator means only a listed or identified investigator or subinvestigator who is directly involved in the treatment or evaluation of research subjects. The term also includes the spouse and each dependent child of the Page 22 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 investigator. (e)Covered clinical study means any study of a drug or device in humans submitted in a marketing application or reclassification petition subject to this part that the applicant or FDA relies on to establish that the product is effective (including studies that show equivalence to an effective product) or any study in which a single investigator makes a significant contribution to the demonstration of safety. This would, in general, not include phase l tolerance studies or pharmacokinetic studies, most clinical pharmacology studies (unless they are critical to an efficacy determination), large open safety studies conducted at multiple sites, treatment protocols, and parallel track protocols. An applicant may consult with FDA as to which clinical studies constitute "covered clinical studies" for purposes of complying with financial disclosure requirements. (f)Significant payments of other sorts means payments made by the sponsor of a covered study to the investigator or the institution to support activities of the investigator that have a monetary value of more than $25,000, exclusive of the costs of conducting the clinical study or other clinical studies, (e.g., a grant to fund ongoing research, compensation in the form of equipment or retainers for ongoing consultation or honoraria) during the time the clinical investigator is carrying out the study and for 1 year following the completion of the study. (g)Applicant means the party who submits a marketing application to FDA for approval of a drug, device, or biologic product. The applicant is responsible for submitting the appropriate certification and disclosure statements required in this part. (h)Sponsor of the covered clinical study means the party supporting a particular study at the time it was carried out. Sec. 54.3 Scope. The requirements in this part apply to any applicant who submits a marketing application for a human drug, biological product, or device and who submits covered clinical studies. The applicant is responsible for making the appropriate certification or disclosure statement where the applicant either contracted with one or more clinical investigators to conduct the studies or submitted studies conducted by others not under contract to the applicant. Sec. 54.4 Certification and disclosure requirements. For purposes of this part, an applicant must submit a list of all clinical investigators who conducted covered clinical studies to determine whether the applicant's product meets FDA's marketing requirements, identifying those clinical investigators who are full-time or part-time employees of the sponsor of each covered study. The applicant must also completely and accurately disclose or certify information concerning the financial interests of a clinical investigator who is not a full-time or part-time employee of the sponsor for each covered clinical study. Clinical investigators subject to investigational new drug or investigational device exemption regulations must provide the sponsor of the study with sufficient accurate information needed to allow subsequent disclosure or certification. The applicant is required to submit for each clinical investigator who participates in a covered study, either a certification that none of the financial arrangements described in 54.2 exist, or disclose the nature of those arrangements to the agency. Where the applicant acts with due diligence to obtain the information required in this section but is unable to do so, the applicant shall certify that despite the applicant's due diligence in attempting to obtain the information, the applicant was unable to obtain the information and shall include the reason. (a) The applicant (of an application submitted under sections 505, 506, 510(k), 513, or 515 of the Federal Food, Drug, and Cosmetic Act, or section 351 of the Public Health Service Act) that relies in whole or in part on clinical studies shall submit, for each clinical investigator who participated in a covered clinical study, either a certification described in paragraph (a)(1) of this section or a disclosure statement described in paragraph (a)(3) of this section. (1) Certification: The applicant covered by this section shall submit for all clinical investigators (as defined in 54.2(d)), to whom the certification applies, a completed Form FDA 3454 attesting to the absence of financial interests and arrangements described in paragraph (a)(3) of this section. The form shall be dated and signed by the chief financial officer or other responsible corporate official or representative. (2) If the certification covers less than all covered clinical data in the application, the applicant shall include in the certification a list of the studies covered by this certification. (3) Disclosure Statement: For any clinical investigator defined in 54.2(d) for whom the applicant does not submit the certification described in paragraph (a)(1) of this section, the applicant shall submit a completed Form FDA 3455 disclosing completely and accurately the following: (i) Any financial arrangement entered into between the sponsor of the covered study and the clinical investigator involved in the conduct of a covered clinical trial, whereby the value of the compensation to the clinical investigator for conducting the study could be influenced by the outcome of the study; (ii) Any significant payments of other sorts from the sponsor of the covered study, such as a grant to fund ongoing Page 23 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 research, compensation in the form of equipment, retainer for ongoing consultation, or honoraria; (iii) Any proprietary interest in the tested product held by any clinical investigator involved in a study; (iv) Any significant equity interest in the sponsor of the covered study held by any clinical investigator involved in any clinical study; and (v) Any steps taken to minimize the potential for bias resulting from any of the disclosed arrangements, interests, or payments. (b) The clinical investigator shall provide to the sponsor of the covered study sufficient accurate financial information to allow the sponsor to submit complete and accurate certification or disclosure statements as required in paragraph (a) of this section. The investigator shall promptly update this information if any relevant changes occur in the course of the investigation or for 1 year following completion of the study. (c) Refusal to file application. FDA may refuse to file any marketing application described in paragraph (a) of this section that does not contain the information required by this section or a certification by the applicant that the applicant has acted with due diligence to obtain the information but was unable to do so and stating the reason. Sec. 54.5 Agency evaluation of financial interests. (a)Evaluation of disclosure statement. FDA will evaluate the information disclosed under 54.4(a)(2) about each covered clinical study in an application to determine the impact of any disclosed financial interests on the reliability of the study. FDA may consider both the size and nature of a disclosed financial interest (including the potential increase in the value of the interest if the product is approved) and steps that have been taken to minimize the potential for bias. (b)Effect of study design. In assessing the potential of an investigator's financial interests to bias a study, FDA will take into account the design and purpose of the study. Study designs that utilize such approaches as multiple investigators (most of whom do not have a disclosable interest), blinding, objective endpoints, or measurement of endpoints by someone other than the investigator may adequately protect against any bias created by a disclosable financial interest. (c)Agency actions to ensure reliability of data. If FDA determines that the financial interests of any clinical investigator raise a serious question about the integrity of the data, FDA will take any action it deems necessary to ensure the reliability of the data including: (1) Initiating agency audits of the data derived from the clinical investigator in question; (2) Requesting that the applicant submit further analyses of data, e.g., to evaluate the effect of the clinical investigator's data on overall study outcome; (3) Requesting that the applicant conduct additional independent studies to confirm the results of the questioned study; and (4) Refusing to treat the covered clinical study as providing data that can be the basis for an agency action. Sec. 54.6 Recordkeeping and record retention. (a)Financial records of clinical investigators to be retained. An applicant who has submitted a marketing application containing covered clinical studies shall keep on file certain information pertaining to the financial interests of clinical investigators who conducted studies on which the application relies and who are not full or part-time employees of the applicant, as follows: (1) Complete records showing any financial interest or arrangement as described in 54.4(a)(3)(i) paid to such clinical investigators by the sponsor of the covered study. (2) Complete records showing significant payments of other sorts, as described in 54.4(a)(3)(ii), made by the sponsor of the covered clinical study to the clinical investigator. (3) Complete records showing any financial interests held by clinical investigators as set forth in 54.4(a)(3)(iii) and (a)(3)(iv). (b)Requirements for maintenance of clinical investigators' financial records. (1) For any application submitted for a covered product, an applicant shall retain records as described in paragraph (a) of this section for 2 years after the date of approval of the application. (2) The person maintaining these records shall, upon request from any properly authorized officer or employee of FDA, at reasonable times, permit such officer or employee to have access to and copy and verify these records. Page 24 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 [COMMENT: The Sponsor-Investigator must have documentation on file for each investigator and subinvestigator who is involved in the clinical trial(s) under this IND which states whether or not the individual has any type of financial interest which could be perceived as potentially influencing the outcome. This documentation must be maintained in the IND regulatory files and updated as needed.] [GUIDANCE DOCUMENTS: The FDA, NIH, and JHU have guidance documents concerning financial conflicts of interest which should be reviewed in order to verify that the Sponsor-Investigator and project team are in compliance. Web addresses for these guidance document websites are listed below. Guidance Documents: FDA Guidances: o Current Guidance dated 2001 http://www.fda.gov/RegulatoryInformation/Guidances/ucm126832.htm o Draft Guidance Dated May 2011 http://www.fda.gov/downloads/RegulatoryInformation/Guidances/UCM256525.pdf HHS-OHRP Guidance: http://www.hhs.gov/ohrp/policy/fguid.pdf JHM IRB Guidance: http://www.hopkinsmedicine.org/institutional_review_board/guidelines_policies/organization_policies/10 3_11.html JHU Conflict of Interest Policy: http://jhuresearch.jhu.edu/Policy_onConflict_of_Interest.pdf JHU Research Administration – Conflict of Interest website: http://jhuresearch.jhu.edu/compliance-conflict.htm 6.2.3.1 Form FDA 3454 [FORM FDA 3454 INSTRUCTIONS/COMMENTS: The Form FDA 3454 provides documentation to the FDA that the Sponsor-Investigator, other clinical investigator(s), and/or subinvestigator(s) DO NOT have any financial interests that may influence the outcome of the study. Form FDA 3454: http://www.fda.gov/downloads/AboutFDA/ReportsManualsForms/Forms/UCM048304.pdf] [SUGGESTED TEXT: “The completed Form FDA 3454 may be found on the next page.” OR “Please see the completed Form FDA 3454 in appendix ##.”] 6.2.3.2 Form FDA 3455 [COMMENT: Reportable Disclosures: If the Sponsor-Investigator, other clinical investigator(s), and/or subinvestigator(s) have any financial conflict of interest(s) that is/are being managed per JHU policies, each conflicted individual must complete and submit a Form FDA 3455 with attached copy of the conflict management plan with the IND application. If this is not applicable, then delete this section and delete from table of contents. Page 25 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 No Reportable Disclosures: The DDRS has been informed that during FDA inspections/audits, the FDA has cited investigators for not having a completed Form FDA 3455 as part of the IND‟s regulatory documentation. Therefore, even if there are no reportable disclosures, any time a Form FDA 3454 is being submitted a Form FDA 3455 should also be submitted. When completing the Form FDA 3455, all sections of the form should be completed except you do not check off any of the boxes describing reportable financial disclosures.] [Form FDA 3455: http://www.fda.gov/downloads/AboutFDA/ReportsManualsForms/Forms/UCM048310.pdf] [SUGGESTED TEXT: “The Sponsor-Investigator has completed Form FDA 3455 which may be found on the next page.” OR “Please see the Form FDA 3455 for the Sponsor-Investigator in appendix ##.”] 6.3 Patient Selection and Estimated Number to be Studied [INSTRUCTIONS: Provide a brief description of the criteria for patient selection and for exclusion of patients as well as an estimate of the number of patients to be studied for the entire proposed trial here.] 6.4 Description of Study Design [INSTRUCTIONS: Provide a brief description of the design of the proposed study, including the type of control group to be used, if any, and a description of methods to be used to minimize bias on the part of subjects, investigators, and analysts here.] 6.5 Drug Dosing – Method, Maximum Dose, and Duration of Exposure: [INSTRUCTIONS: Provide a brief description of the method for determining the dose(s) of investigational drug to be administered, the planned maximum dosage, and the duration of individual patient exposure to the investigational drug here]. 6.6 Observations and Measurements Made to Fulfill Study Objectives [INSTRUCTIONS: Provide a brief description of the observations and measurements to be made to fulfill the objectives of the study here.] 6.7 Procedures to Monitor Drug Effects in Human Subjects and Minimize Risks [INSTRUCTIONS: Provide a brief description of the clinical procedures, laboratory tests, or other measures to be taken to monitor the effects of the investigational drug in human subjects and to minimize risk here.] [COMMENT: This is the data safety monitoring plan.] 6.8 Clinical Trial Registration [COMMENTS: Per Title VIII of the Food and Drug Administration Amendments Act of 2007 or FDAAA (U.S. Public Law 110-85) clinical trial registration and reporting requirements, all applicable trials must be registered at clinicaltrials.gov, and results reported as required. As part of this requirement, the FDA created the Form FDA 3674 to certify compliance with registration of trials. Below are a number of resources that provide additional guidance and information concerning this requirement. If the Sponsor-Investigator needs additional guidance, please contact the ICTR Research Navigators. Even Page 26 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 if the protocol being submitted is not required to be registered at ClinicalTrials.gov, the SponsorInvestigator must check the appropriate box in section 9 of the form and submit the Form FDA 3674, entitled „Certification of Compliance, under 42 U.S.C § 282(j)(5)(B), with Requirements of ClinicalTrials.gov Data Bank (42 U.S.C § 282(j))‟, with the IND application.] [GUIDANCE/INFORMATION RESOURCES FOR TRIAL REGISTRATION: FDA Guidance Document on registering trials on ClinicalTrials.gov: http://www.fda.gov/RegulatoryInformation/Guidances/ucm125335.htm Clinicaltrials.gov Protocol Registration System Information Website http://prsinfo.clinicaltrials.gov/fdaaa.html. NIH Grantees Clinicaltrials.gov and FDAAA Policy Site http://grants.nih.gov/ClinicalTrials_fdaaa/ JHM IRB Policy and Guideline o Organizational Policy http://www.hopkinsmedicine.org/institutional_review_board/guidelines_policies/organization_policies /103_25.html o Guideline http://www.hopkinsmedicine.org/institutional_review_board/guidelines_policies/guidelines/clinical_tri als.html] [FORM FDA 3674 website to download PDF fillable form: http://www.fda.gov/downloads/AboutFDA/ReportsManualsForms/Forms/UCM048364.pdf] [Form FDA 3674 instructions website: http://www.fda.gov/Drugs/DevelopmentApprovalProcess/HowDrugsareDevelopedandApproved/Approva lApplications/InvestigationalNewDrugINDApplication/ucm071098.htm#form3674] 6.8.1 Form FDA 3674 [SUGGESTED TEXT: “The signed and dated Form FDA 3674 can be found on the next page.” OR “Please see the signed and dated Form FDA 3674 in appendix ##.”] Page 27 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 7: Chemistry, Manufacturing, and Controls (CMC) [SECTION INTRODUCTION: The requirements for this section of the IND application are provided below. NOTE: Some of the information included may not be applicable to all IND applications. General instructions and comments on the format and content of this section of the IND application, along with a list of guidance documents and additional regulation references, are provided. Within each subheading of this section are additional instructions, comments, suggested text, web addresses for forms, web addresses for specific guidance documents, and/or regulations. This section must be written by a person or organization familiar with the manufacture of drug products. If the drug product is a FDA approved product and not being adulterated for the proposed clinical trials, then this section may not be needed. If you are not certain if this section is needed, then you should consult with a Navigator or the FDA before submitting the IND application.] [REGULATORY REFERENCE: 21CFR312.23(a)(7): (i) As appropriate for the particular investigations covered by the IND, a section describing the composition, manufacture, and control of the drug substance and the drug product. Although in each phase of the investigation sufficient information is required to be submitted to assure the proper identification, quality, purity, and strength of the investigational drug, the amount of information needed to make that assurance will vary with the phase of the investigation, the proposed duration of the investigation, the dosage form, and the amount of information otherwise available. FDA recognizes that modifications to the method of preparation of the new drug substance and dosage form and changes in the dosage form itself are likely as the investigation progresses. Therefore, the emphasis in an initial Phase 1 submission should generally be placed on the identification and control of the raw materials and the new drug substance. Final specifications for the drug substance and drug product are not expected until the end of the investigational process. (ii) It should be emphasized that the amount of information to be submitted depends upon the scope of the proposed clinical investigation. For example, although stability data are required in all phases of the IND to demonstrate that the new drug substance and drug product are within acceptable chemical and physical limits for the planned duration of the proposed clinical investigation, if very short-term tests are proposed, the supporting stability data can be correspondingly limited. (iii) As drug development proceeds and as the scale or production is changed from the pilot-scale production appropriate for the limited initial clinical investigations to the larger-scale production needed for expanded clinical trials, the sponsor should submit information amendments to supplement the initial information submitted on the chemistry, manufacturing, and control processes with information appropriate to the expanded scope of the investigation. (iv) Reflecting the distinctions described in this paragraph (a)(7), and based on the phase(s) to be studied, the submission is required to contain the following: (a) Drug substance. A description of the drug substance, including its physical, chemical, or biological characteristics; the name and address of its manufacturer; the general method of preparation of the drug substance; the acceptable limits and analytical methods used to assure the identity, strength, quality, and purity of the drug substance; and information sufficient to support stability of the drug substance during the toxicological studies and the planned clinical studies. Reference to the current edition of the United States Pharmacopeia--National Formulary may satisfy relevant requirements in this Page 28 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 paragraph. (b) Drug product. A list of all components, which may include reasonable alternatives for inactive compounds, used in the manufacture of the investigational drug product, including both those components intended to appear in the drug product and those which may not appear but which are used in the manufacturing process, and, where applicable, the quantitative composition of the investigational drug product, including any reasonable variations that may be expected during the investigational stage; the name and address of the drug product manufacturer; a brief general description of the manufacturing and packaging procedure as appropriate for the product; the acceptable limits and analytical methods used to assure the identity, strength, quality, and purity of the drug product; and information sufficient to assure the product's stability during the planned clinical studies. Reference to the current edition of the United States Pharmacopeia--National Formulary may satisfy certain requirements in this paragraph. (c) A brief general description of the composition, manufacture, and control of any placebo used in a controlled clinical trial. (d) Labeling. A copy of all labels and labeling to be provided to each investigator. (e) Environmental analysis requirements. A claim for categorical exclusion under 25.30 or 25.31 or an environmental assessment under 25.40.] [GUIDANCE DOCUMENTS: Web addresses for various guidance documents concerning the CMC are listed below. FDA Guidance Document - Chemistry, Manufacturing, and Controls (CMC) http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm064979.htm FDA Guidance Documents - CMC - Microbiology (Chemistry, Manufacturing, and Controls) http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm064983.htm FDA Guidance Documents - Current Good Manufacturing Practices (CGMPs)/Compliance http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm064971.htm FDA Guidance Documents - International Conference on Harmonisation – Quality http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm065005.htm FDA Guidance Document - Exploratory IND Guidance Document http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM078933.pd f [ADDITIONAL REGULATIONS APPLICABLE TO CMC: 21CFR210 - CURRENT GOOD MANUFACTURING PRACTICE IN MANUFACTURING, PROCESSING, PACKING, OR HOLDING OF DRUGS; GENERAL http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?CFRPart=210&showFR=1 21CFR211 - CURRENT GOOD MANUFACTURING PRACTICE FOR FINISHED PHARMACEUTICALS http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?CFRPart=211&showFR=1 21CRF25 - ENVIRONMENTAL IMPACT CONSIDERATIONS http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?CFRPart=25] [GENERAL COMMENTS: For all phases of clinical trials (per 21CFR 312.23): Page 29 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 1. Sufficient information must be submitted to assure proper identification, quality, purity, and strength of the investigational drug. 2. Stability data is required at all phases of the trial. However, scope of data depends on the phase of the investigation (i.e. limited data for very short-term studies) 3. When drug manufacturing shifts from smaller to larger scale production, any changes in the manufacturing process must be submitted as information amendments to the IND. 4. If submitting a Phase 1 study, the following guidance should be reviewed: CGMP for Phase 1 Investigational Drugs: http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070273.pdf] 7. Chemistry, Manufacturing, and Control Data 7.1 Introduction: Statement of Risk [INSTRUCTIONS: A statement whether or not chemistry of either the investigational drug or drug product or the manufacturing of either moiety presents any risk should be included here. A description of any chemistry and/or manufacturing differences between the drug proposed for use in proposed trial and that used in animal toxicology trials must be included here. 7.2 Drug Substance [INSTRUCTIONS: Provide the following information for the Drug Substance Description: a. b. c. d. Description including physical, chemical, and/or biological characteristics Name and address of manufacturer Description of manufacturing processes that should include flow diagram Description Acceptable limits and analytical methods to demonstrate identity, strength, quality and purity including copy of COA (Validation data and established specifications may only be required for some well characterized biotechnology products) e. Description stability data and test methods to obtain data during toxicologic studies and proposed trial planned trial. f. References to US Pharmacopeia-National Formulary may be made to supply requested information] 7.3 Drug Product [INSTRUCTIONS: Provide the following information for the Drug Product Description: a. List of all components including reasonable substitutes for inactive compounds which do or do not appear in final drug product b. Quantitative composition of the drug product including any reasonable or anticipated variations during the manufacture c. Name and address of manufacturer d. Written and diagrammatic descriptions of the manufacturing process including sterilization processes where applicable and packaging procedures e. Brief description of test methods used to show identity, strength, quality and purity, including copy of COA for clinical batch (Assessment of bioactivity and preliminary specifications may be required for some well characterized biotechnology products) Page 30 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products f. Version 3.0 Description of stability data and test methods to obtain data in the drug's final packaging during toxicologic studies and proposed trial.] 7.4 Placebo [INSTRUCTIONS: Provide a brief diagrammatic, tabular, and written description of the composition, manufacture, and control of any placebo used in the proposed trial here.] 7.5 Labeling [INSTRUCTIONS: Provide a copy of all investigational drug and/or placebo labels to be used here.] 7.6 Claim for Categorical Exclusion for Environmental Assessment [INSTRUCTIONS: A statement regarding whether or not the investigational drug product qualifies for a categorical exclusion from or the submission of an environmental assessment per 21CFR312.23(a)(7)(iv)(e) belongs here. Usually, for an IND, a claim for categorical exclusion is requested under 21CFR25.30 or 21CFR25.31 or an environmental assessment under 21CFR25.40. Below are the web address for all regulations for 21CFR25.30, 21CFR25.31, and 21CFR25.40. 21CFR25.30: http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?fr=25.30 21CRF25.31: http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?fr=25.31 21CFR25.40: http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?fr=25.40] Page 31 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 8: Pharmacology and toxicology [SECTION INTRODUCTION: The requirements for this section of the IND application are provided below. NOTE: Some of the information included may not be applicable to all IND applications. General instructions and comments on the format and content of this section of the IND application, along with a list of guidance documents and additional regulation references, are provided. Within each subheading of this section are additional instructions, comments, suggested text, web addresses for forms, web addresses for specific guidance documents, and/or regulations.] [REGULATORY REFERENCE: 21CFR312.23(a)(8) – Pharmacology and toxicology information:- Adequate information about pharmacological and toxicological studies of the drug involving laboratory animals or in vitro, on the basis of which the sponsor has concluded that it is reasonably safe to conduct the proposed clinical investigations. The kind, duration, and scope of animal and other tests required varies with the duration and nature of the proposed clinical investigations. Guidance documents are available from FDA that describe ways in which these requirements may be met. Such information is required to include the identification and qualifications of the individuals who evaluated the results of such studies and concluded that it is reasonably safe to begin the proposed investigations and a statement of where the investigations were conducted and where the records are available for inspection. As drug development proceeds, the sponsor is required to submit informational amendments, as appropriate, with additional information pertinent to safety. (i) A section describing the pharmacological effects and mechanism(s) of action of the drug in animals, and information on the absorption, distribution, metabolism, and excretion of the drug, if known. (ii)(a) An integrated summary of the toxicological effects of the drug in animals and in vitro. Depending on the nature of the drug and the phase of the investigation, the description is to include the results of acute, subacute, and chronic toxicity tests; tests of the drug's effects on reproduction and the developing fetus; any special toxicity test related to the drug's particular mode of administration or conditions of use (e.g., inhalation, dermal, or ocular toxicology); and any in vitro studies intended to evaluate drug toxicity. (ii)(b) For each toxicology study that is intended primarily to support the safety of the proposed clinical investigation, a full tabulation of data suitable for detailed review. (iii) For each nonclinical laboratory study subject to the good laboratory practice regulations under part 58, a statement that the study was conducted in compliance with the good laboratory practice regulations in part 58, or, if the study was not conducted in compliance with those regulations, a brief statement of the reason for the noncompliance. [INSTRUCTIONS: Under each of the following headings are listed the requirements for this section as per the regulatory reference cited above. If this information is provided as a report from the vendor who performed the nonclinical studies, it is suggested that a high level summary be provided below and the vendor‟s reports placed in the appendix. After each summary/description of nonclinical testing, be certain to indicate whether or not the testing was performed in compliance with Good Laboratory Practices (GLP). If the testing was performed by a vendor, please indicate whether or not a certificate of GLP compliance is being provided and crossreference the certificate‟s location in the IND application. If the testing was not performed in compliance with GLP, provide a statement here describing why the testing was not performed in compliance with GLP. The web address for FDA GLP regulations is provided below. Page 32 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Additionally, a list of web addresses for guidance documents that describe the various requirements and options for nonclinical safety testing are also provided below.] [GLP FDA REGULATIONS: For more information concerning Good Laboratory Practice, please see the regulations at the following website: http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?CFRPart=58&showFR=1] [GUIDANCE DOCUMENTS: Below are web addresses for various guidance documents concerning nonclinical safety testing: FDA list of International Conference on Harmonisation – Safety Guidance Documents: http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm065007.htm FDA Pharm / Tox Guidance Documents: http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm065014.htm Exploratory IND Guidance Document: http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM078933.pdf Q & A - Content and Format of INDs for Phase 1 Studies of Drugs, Including Well-Characterized, Therapeutic, Biotechnology-Derived Products (Answers questions concerning Pharmacology and Toxicology): http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm078928.pdf 8. Pharmacology and toxicology information 8.1 Pharmacology and drug disposition [INSTRUCTIONS: Describe the pharmacological effects and mechanism(s) of action of the investigational drug in animals, and information on the absorption, distribution, metabolism, and excretion of the drug (if known) here.] 8.2 Toxicology [INSTRUCTIONS: Provide an integrated summary of the toxicological effects of the investigational drug in animals and in vitro. Depending on the nature of the investigational drug and the phase of the investigation, the description should include the results of acute, subacute, and chronic toxicity tests; tests of the drug's effects on reproduction and the developing fetus; any special toxicity testing related to the drug's particular mode of administration or conditions of use (e.g., inhalation, dermal, or ocular toxicology); and any in vitro studies intended to evaluate drug toxicity here. For each toxicology study that is primarily intended to support the safety of the proposed clinical investigation, a full tabulation of data suitable for detailed review should be included here.] Page 33 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 9: Previous human experience [SECTION INTRODUCTION: The requirements for this section of the IND application are provided below. NOTE: Some of the information included may not be applicable to all IND applications. General instructions and comments on the format and content of this section of the IND application, along with a list of guidance documents and additional regulation references, are provided. Within each subheading of this section are additional instructions, comments, suggested text, web addresses for forms, web addresses for specific guidance documents, and/or regulations.] [REGULATORY REFERENCE: 21CFR312.23(a)(9) – Previous human experience with the investigational drug. A summary of previous human experience known to the applicant, if any, with the investigational drug. The information is required to include the following: (i) If the investigational drug has been investigated or marketed previously, either in the United States or other countries, detailed information about such experience that is relevant to the safety of the proposed investigation or to the investigation's rationale. If the drug has been the subject of controlled trials, detailed information on such trials that is relevant to an assessment of the drug's effectiveness for the proposed investigational use(s) should also be provided. Any published material that is relevant to the safety of the proposed investigation or to an assessment of the drug's effectiveness for its proposed investigational use should be provided in full. Published material that is less directly relevant may be supplied by a bibliography. (ii) If the drug is a combination of drugs previously investigated or marketed, the information required under paragraph (a)(9)(i) of this section should be provided for each active drug component. However, if any component in such combination is subject to an approved marketing application or is otherwise lawfully marketed in the United States, the sponsor is not required to submit published material concerning that active drug component unless such material relates directly to the proposed investigational use (including publications relevant to component-component interaction). (iii) If the drug has been marketed outside the United States, a list of the countries in which the drug has been marketed and a list of the countries in which the drug has been withdrawn from marketing for reasons potentially related to safety or effectiveness. 9. Previous human experience with the investigational drug [INSTRUCTIONS: Provide the information requested per the above regulatory requirements. Insert subheadings as needed per the information provided. If there is no data on previous human experience with the investigational drug, then insert text stating that there is no previous human experience here.] Page 34 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 10: Additional Information [SECTION INTRODUCTION: The requirements for this section of the IND application are provided below. NOTE: Some of the information included may not be applicable to all IND applications. General instructions and comments on the format and content of this section of the IND application, along with a list of guidance documents and additional regulation references, are provided. Within each subheading of this section are additional instructions, comments, suggested text, web addresses for forms, web addresses for specific guidance documents, and/or regulations.] [REGULATORY REFERENCE: 21CFR312.23(a)(10) - Additional information. In certain IND applications, as described below, information about special topics may be needed. Such information should be submitted in this section as follows:] (i) Drug dependence and abuse potential. If the drug is a psychotropic substance or otherwise has abuse potential, a section describing relevant clinical studies and experience and studies in test animals.] (ii) Radioactive drugs. If the drug is a radioactive drug, sufficient data from animal or human studies to allow a reasonable calculation of radiation-absorbed dose to the whole body and critical organs upon administration to a human subject. Phase 1 studies of radioactive drugs must include studies which will obtain sufficient data for dosimetry calculations.] (iii) Pediatric studies. Plans for assessing pediatric safety and effectiveness.] (iii) Other information. A brief statement of any other information that would aid evaluation of the proposed clinical investigations with respect to their safety or their design and potential as controlled clinical trials to support marketing of the drug.] [INSTRUCTIONS: Under each heading below are listed the regulatory requirements per the above regulatory reference. Note: Each section should be addressed and, if not applicable, state “not applicable” and provide an explanation as to why it does not apply here.] 10. Additional information 10.1 Drug dependence and abuse potential [INSTRUCTIONS: Drug dependence and abuse potential. If the investigational drug is a psychotropic substance or has other abuse potential, a section describing relevant clinical studies and experience and studies in test animals should be included here. Below is web address for an FDA draft guidance on the assessment of abuse potentials.] [FDA DRAFT Guidance: Assessment of Abuse Potential of Drugs: http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM198650.pdf] 10.2 Radioactive drugs [INSTRUCTIONS: If this application is for an investigational radioactive drug, please discuss the placement of information within the application with the Research Navigators. For more information on radioactive drugs, please review information available at the FDA‟s Medical Imaging and Drug Development website (provided below).] Page 35 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 [FDA Medical Imaging and Drug Development website: http://www.fda.gov/Drugs/DevelopmentApprovalProcess/DevelopmentResources/ucm092895.htm] 10.3 Pediatric studies [INSTRUCTIONS: Describe the plans for assessing pediatric safety and effectiveness here. If there are not plans to assess pediatric safety and effectiveness, explain why here. The FDA site on Pediatric Drug Development has more information on pediatric safety and effectiveness assessment and their web address is provided below. [FDA website on Pediatric Drug Development: http://www.fda.gov/Drugs/DevelopmentApprovalProcess/DevelopmentResources/ucm049867.htm] 10.4 Other information [INSTRUCTIONS: Provide any additional information here which you believe will add to the FDA review of this IND application.] Page 36 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 11: Relevant Information [SECTION INSTRUCTIONS: Per regulatory requirements, include in this section any relevant information requested by the FDA that may be needed for the review of this IND application.] [REGULATORY REFERENCE: 21CFR312.23(a)(10) - Relevant information. If requested by FDA, any other relevant information needed for review of the application.] 11.0 Relevant Information [INSTRUCTIONS: Per the section instructions and regulatory reference, provide any relevant information the FDA requested be submitted with the application. If the FDA did not make such a request, then either remove this section or insert text stating the FDA did not request relevant information be submitted with this application.] Page 37 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 12: Bibliography [SECTION INSTRUCTIONS: Provide a list of references cited in the IND application here. Note: The bibliographical information may instead be provided after each of the above IND application sections. If the Sponsor-Investigator chooses to do this, delete this section here and from the table of contents.] 12. Bibliography [INSTRUCTIONS: Insert bibliography/literature cited.] Page 38 of 39 ICTR DDRS: IND Application Guidance and Template for Drug Products Version 3.0 Section 13: Appendices [SECTION INSTRUCTIONS: Provide a list of the appendices in order of appearance in the sections of the IND application. Before each appendix, include a cover page describing the document(s) that will be found in that appendix.] [ADDITIONAL INSTRUCTIONS - Copies of selected papers referenced in the IND application: While not required, it is strongly suggested that the Sponsor-Investigator provide copies of key papers that are referenced in the body of the IND application. Providing copies of any key papers will make it easier for the FDA reviewers to access the papers if they want more information. As with the other Appendices, include a cover page with this appendix, listing in order of appearance the citations for the papers being submitted with the IND application.] 13. Appendices Page 39 of 39