Clinical Investigation in Animals

Abstract

The Code of Federal Regulations Part 511 addresses the requirements for new animal drugs for investigational use. In 1977, the Food and Drug Administration proposed new rules for the conduct of clinical trials. Although these are only proposed regulations, the FDA uses them as guidelines when conducting audits of clinical investigators. These proposed Good Clinical Practice Regulations have resulted in an improvement in the manner animal clinical studies are now conducted. We feel the results have been positive for all concerned, the public, sponsor and the Food and Drug Administration.     

美国药品标识监管体系研究

目的：通过研究和分析美国药品说明书和标签监管体系,重点阐述现有监管制度上的环节要求,以期为完善我国药品说明书和标签监管体系提供较为全面的参考和借鉴,进一步提高用药安全水平。方法：采用非接触性研究中的内容分析方法,广泛查询FDA及美国联邦政府的官方网站、中国知网数据库等,收集整理与美国标识监管体系相关的资料,包括法律文件8个、指南36个及50余个FDA官网网页资料和报告文件等。结果与结论：围绕上市前、上市后和信息公开管理,并通过不断修订加强法律法规,美国药品标识逐步形成了法律、法规及指南3个层面的逻辑清晰的完整监管体系。我国药品说明书和标签监管体系建设工作相差明显,应尽快建立我国药品说明书和标签功能定位监管认识的新视角,完善上市前、上市后和信息公开管理制度机制,抓住《药品管理法》修订的契机,系统性安排药品说明书和标签立法工作计划,开展全国调研,为全面规范药品说明书和标签管理提供科学保障。     

A Conputerized System for Monitoring and Accounting of Investigational Drug Supplies in a Multi-Center Clinical Trial

Abstract

In any clinical trial involving investigational drugs, federal regulations require accurate and adequate drug accounting. In addition, it is advantageous to monitor individual patient compliance for its relationship to response to therapy, adverse reactions, etc. Accomplishing these objectives can be very time consuming, especially when there are multiple participating centers.

A computer system has been designed to meet these needs and was tested on a investigational drug supplies used in a multicenter clinical trials. The computer generated reports, which can be easily developed by a supporting statistical and data processing center are helpful in monitoring drug supplies at field stations and in achieving compliance with federal regulations. Sponsors of clinical trials, especially physicians, could use CDAS to assist in assuming the drug accountability responsibilities of a multicenter clinical trial.

To develop a CDAS similar to the one just described which can be used to monitor and verify the usage of all drug supplies used in a clinical trial, the sponsor must:

1) Identify each dispensible unit with a number (i.e. bottle number)

2) Package all drug supplies in patient kits.

3) Collect the appropriate drug accountability data on clinic visit forms

4) Supplement the study master file with appropriate drug shipping data, lot numbers and expiration dates.

The goal of any CDAS should be to monitor and account for all investigational drug supplies. Otherwise many of the problems identified by the FDA, such as lost drugs or laxity in drug accountability, may go undetected.     

Preparing the Nda Summary: How to,How Not to and why

Abstract

The four parts of this presentation are: 1) some practical advice on preparing an NDA Optional Expanded Summary and Evaluation (summary); 2) a look at the NDA regulations as guidelines rather than as detailed instructions; 3) comments from FDA reviewers on common shortcomings in summaries and some insight into the FDA reviewer's job, and 4) a look at how the proposed new regulations would affect the preparation of a summary.

Presented at the annual meeting of the Associates of Clinical Pharmacology, March 1, 1984, at the Sheraton El Conquistador Hotel, in Tucson, AZ.     

同情用药制度对我国罕见病患者用药可及性研究

目的：基于国内罕见病患者用药可及性现状,剖析国外同情用药的制度体系及实施成效,深入分析同情用药制度对国内罕见病患者的用药可及性问题,并提出贴合国内罕见病患者同情用药制度落实的细则。方法：查阅美国FDA发布的法规政策、技术指南、相关统计数据及文献资料,对美国同情用药的使用类别、申请及审批流程、费用支付方式等内容进行分析。结果与结论：美国已具备较为完善的同情用药制度体系,该制度在我国的建立或将成为国内罕见病患者用药可及的一条新路径,在一定程度上能够提高国内罕见病患者的用药可及性。     

Clinical research: regulatory issues.

The regulatory issues faced by institutions performing clinical research are described. Many institutions do not have on staff an expert who understands the regulatory issues involved in managing investigational new drug research and who knows the institution's obligations under the federal rules. Because pharmacists understand the FDA regulations that apply to the management of drugs in clinical research, institutions are asking pharmacists to expand their role and manage clinical research offices. Many authorities govern various aspects of investigational drug research. FDA has published regulations for good clinical practice (GCP), and the International Conference on Harmonisation is developing an international standard for the proper management of clinical trials. The guidelines published by the Joint Commission on Accreditation of Healthcare Organizations aim to protect patients who are in the institution to receive health care and also participate in clinical trials. The Social Security Administration Acts specifically state that only items and services that are reasonable and necessary for the diagnosis and treatment of injury or disease can be billed to the government; research-related billings are excluded from coverage. Proper management of drug research is crucial to the success of a research program that is integrated with patient care.     

Current Thoughts on Crossover Designs

Abstract

In this paper a historical perspective will be developed regarding the use by drug sponsors of crossover designs in clinical trials in reference to new drug application (NDA) submissions to FDA and FDA's concerns with these designs. From the standpoint of drug sponsors, drug researchers and FDA statistical reviewers the possible impact of a report by the former Biometric and Epidemiological Methodology Advisory Committee (BEMAC) of the FDA and of recommendations contained in 22 FDA clinical guidelines on the matter of crossover designs will be discussed. Additionally, current experience gained from the FDA's statistical evaluation of crossover designs will be briefly presented and some constructive suggestions will be made to guide drug sponsors and drug researchers regarding the use of crossover designs in clinical trials.     

Regulatory overview: protection of human subjects--IRBS and informed consent.

The Food and Drug Administration (FDA) regulations on Institutional Review Boards (IRBs) and Informed Consent (IC) were published on January 27, 1981 and became operational on July 27, 1981. The historical development of these regulations began in August 1978 when the FDA proposed standards for IRBs. During the comment period, the National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research submitted its report and recommendations on IRBs and informed consent. In its report, the National Commission recommended revision of the Department of Health and Human Services (DHHS) regulations and one uniform standard for IRBs. On August 14, 1979, the FDA withdrew the 1978 proposal and published a revised proposal that it had developed in conjunction with the DHHS in response to the recommendations made by the National Commission. Following consideration of the comments received on the 1979 proposal, the new regulations were published as final. I would like to discuss how these regulations relate to the FDA's mandate and regulatory responsibilities, to the work of IRBs, and to the protection of human subjects involved in the FDA-regulated research. I will also mention the FDA's internal organization to deal with IRB issues and, finally, what we may look forward to in the future.     

Radiation countermeasure agents: an update (2011 – 2014)

Introduction: Despite significant scientific advances over the past 60 years towards the development of a safe, nontoxic and effective radiation countermeasure for the acute radiation syndrome (ARS), no drug has been approved by the US FDA. A radiation countermeasure to protect the population at large from the effects of lethal radiation exposure remains a significant unmet medical need of the US citizenry and, thus, has been recognized as a high priority area by the government.

Area covered: This article reviews relevant publications and patents for recent developments and progress for potential ARS treatments in the area of radiation countermeasures. Emphasis is placed on the advanced development of existing agents since 2011 and new agents identified as radiation countermeasure for ARS during this period.

Expert opinion: A number of promising radiation countermeasures are currently under development, seven of which have received US FDA investigational new drug status for clinical investigation. Four of these agents, CBLB502, Ex-RAD, HemaMax and OrbeShield, are progressing with large animal studies and clinical trials. G-CSF has high potential and well-documented therapeutic effects in countering myelosuppression and may receive full licensing approval by the US FDA in the future.     

QUALITY ASSURANCE IN CLINICAL TRIALS*

Abstract

A comprehensive review of Sections 314.l(f) [21 CFR 1982] and 314.2(f) [21 CFR 1983] and the impact of the proposed regulations, dated October 19, 1982, on Sections 6, 7, and 8 of the Application for FDA approval to market a new drug.     

New patented histone deacetylase inhibitors

Importance of the field: Following FDA approval of vorinostat in 2006, several novel HDAC inhibitors (HDACis) have entered clinical trials, and there are numerous published patent applications claiming novel HDACis which were optimized as potential drug candidates, designed for regional or systemic release, and created as dual or multifunctional inhibitors. Given the breadth and depth of recent reporting of novel HDACis, there has emerged a need to review the field from a chemist's perspective in one compact article.

Areas covered in this review: This review provides a summary of published patent applications claiming novel HDACis from 2007 until mid-2009, covering mainly classes I, II and IV anticancer HDACis including those that have recently advanced to the clinic.

What the reader will gain: Readers will rapidly gain an overview of the majority of HDACi scaffolds with representative structure–activity relationships; they will learn how these new compounds were created, how their drug like properties were improved and which companies are the main players in the field.

Take home message: Although competition in this field is intense, the future application of HDACis to treat human disease either as single agents or in combination with existing drugs holds real promise.     

Update and trends on pharmacokinetic studies in patients with impaired renal function: practical insight into application of the FDA and EMA guidelines

Introduction: The incidence of kidney dysfunction increases with age and is highly prevalent among patients with hypertension. Since many therapeutic compounds are primarily eliminated through the kidneys, impaired renal function can have negative consequences on drug disposition, efficacy and safety. Therefore, regulatory agencies such as the Food and Drug Administration (FDA) and European Medicines Agency (EMA) have issued detailed guidelines for new drug applications to determine posology requirements for patients with renal impairment.

Areas covered: The current review highlights and contrasts agency requirements for pharmacokinetic renal impairment clinical studies. While many of the guidelines are similar among the two agencies, glomerular filtration rate (GFR) determination and reporting differ. Design considerations for a reduced, full or dialysis renal impairment study, as well as modifications to the FDA’s draft guidance are discussed. Furthermore, scenarios where pharmacokinetic modelling analysis can benefit a drug development program are also reviewed. Moreover, practical solutions for patient recruitment challenges are addressed.

Expert commentary: We summarize how ‘one size does not fit all’ for GFR assessment, and recommend when to use certain modalities. Finally, we highlight the need for the pharmaceutical industry to engage therapeutic experts to assist in protocol development for renal impairment studies, as these experts understand the nuances of this special population and recommended guidelines.     

Targeting the dopamine receptor in schizophrenia: investigational drugs in Phase III trials

Introduction: Antipsychotic drugs date back to the 1950s and chlorpromazine. Soon after, it was established that blockade of dopamine and, in particular, the D₂ receptor was central to this effect. Dopamine continues to represent a critical line of investigation, although much of the work now focuses on its potential in other symptom domains.

Areas covered: A search was carried out for investigational drugs using the key words ‘dopamine’, ‘schizophrenia’ and ‘Phase III’ in an American clinical trial registry (clinicaltrials.gov), published articles using the National Library of Medicine's PubMed database, and supplemented results with a manual search of cross-references and conference abstracts. Drugs were excluded that were already FDA approved.

Expert opinion: There remains interest, albeit diminished, in developing better antipsychotic compounds. The greatest enthusiasm currently centres on dopamine's role in negative and cognitive symptom domains. With theories conceptualising hypodopaminergic activity as underlying these deficits, considerable effort is focused on drug strategies that will enhance dopamine activity. Finally, a small body of research is investigating dopaminergic compounds vis-à-vis side-effect treatments. In domains beyond psychosis, however, dopamine arguably is not seen as so central, reflected in considerable research following other lines of investigation.     

Expert opinion on existing and developing drugs to treat female sexual dysfunction

ABSTRACT

Introduction: Female sexual dysfunction (FSD) is a highly prevalent, yet commonly underdiagnosed and undertreated condition. This paper reviews the diagnostic terminology for FSD, and basic sexual physiology in women. The Food and Drug Administration (FDA) approved drugs for FSD are discussed, followed by investigational drugs for FSD currently in phase 2 or 3 clinical trials, reasons for failure of drug development, and potential future drug targets.

Areas covered: A literature review was conducted for available treatments for FSD: flibanserin, estrogen, ospemifene and prasterone. Potential treatments are assessed, as was the Pharmaprojects database which includes clinical trial information. Testosterone, bremelanotide, bupropion-trazodone, PDE-5 inhibitors, prostaglandins, tibolone and combination therapies, and the theoretical basis of potential drug targets are discussed.

Expert opinion: The lack of established endpoints for phase 3 studies of FSD has impeded approval of new treatments, and required additional studies for validation, resulting in proposed changes to the FDA draft guidance for FSD clinical trials in October 2016. Current DSM-5 diagnostic nosology also fails to capture the full range of symptomology. Several promising compounds have shown no movement for several years limiting women’s options. Overcoming socio-cultural bias against women’s sexual and reproductive health will be critical in the approval of new treatments for FSD.     

药包材变更管理的分析与探讨

目的：通过汇总分析美国对药包材变更的管理法规和管理方式,为我国实施关联审评审批后对药包材变更管理提供借鉴,从而保证药品在整个生命周期内的安全、有效和质量可控。方法：从法规和技术层面分析美国FDA对制药企业以及药包材企业的变更监管,探讨其优势和存在的问题,对比中国与美国行业的特点。结果：中国与美国在监管理念和法规上日渐趋同,但是国内药包材企业与美国在规模和管理上还存在较大差异。结论：药包材变更是药品生命周期维护的组成部分,行业监管机构需要出具相应的变更技术指导原则以及相应的法规路径作为研发人员对变更评估的重要参考依据。     

Pharmaceutical industry perspective on risk evaluation and mitigation strategies: manufacturer take heed

Introduction: Enactment of the Food and Drug Administration Amendments Act of 2007 (FDAAA) authorized the FDA to require manufacturers to submit Risk Evaluation and Mitigation Strategy (REMS) when it was deemed necessary to ensure that a drug's benefit outweigh its risk. REMS apply to new drug applications (NDAs), abbreviated new drug applications (ANDAs) and biologics license applications (BLAs). The objective of this review is to describe the impact of REMS requirements on the pharmaceutical industry.

Areas covered: Articles were identified in MEDLINE searches through October 11, 2011, using the MeSH terms and keywords pharmaceutical industry, risk management, United States Food and Drug Administration, REMS, ETASU, and Medication Guide in various combinations.

Expert opinion: The new powers ascribed to the FDA are notable, as they add enforceability to safety strategies that were not part of FDA's prior risk management tools, risk minimization action plans (RiskMAPs). Failure to comply with REMS can lead to financial penalties up to $10 million, and a drug could be deemed misbranded if the REMS is not followed. The new approach to risk management via FDAAA has elevated the rigor with which manufacturers must fulfill postmarketing safety commitments.     

Current advances in BCG-unresponsive non-muscle invasive bladder cancer

Introduction: The current first line therapy for high grade (HG) non-muscle invasive bladder cancer (NMIBC) is intravesical Bacillus Calmette–Guerin (BCG). Patients who recur or progress despite BCG are recommended to undergo radical cystectomy or participate in clinical trials. There is an urgent need for alternative therapies in the BCG-unresponsive NMIBC realm.

Areas covered: We queried clinicaltrials.gov and pubmed.gov for current and recently completed early clinical trials pertaining to investigational agents used for the treatment of BCG-unresponsive NMIBC. These included intravesical chemotherapy, immunotherapy, vaccines, gene therapy, viruses, and agents used with novel drug delivery methods. In this article, we discuss the treatment guidelines for non-muscle invasive bladder cancer and therapeutic approaches under investigation in clinical trials.

Expert opinion: The FDA is currently allowing single-arm studies as a pathway for approval in BCG-refractory patients with CIS. Although many agents are currently undergoing testing, none have been approved since Valrubicin. Hopefully, we will identify therapies sufficiently effective and durable to achieve FDA approval. Other considerations in this realm include the use of biomarkers in NMIBC to identify patients who will most likely respond to specific interventions. In addition, as systemic agents such as checkpoint inhibitors, are studied further, a multidisciplinary approach may be needed to treat this subset of patients     

Responsibilities of Clinical Trial Investigators

Abstract

Never has compliance with Title 18 of the Code of Federal Regulations (CFR) Part 312, and with good clinical practices (GCPs) been of greater importance and under more public scrutiny than today. The current regulatory environment at the Food and Drug Administration (FDA) has fueled a keener awareness not only of how clinical investigators are conducting their research under Investigational New Drug (IND) regulations, but also how they are documenting the research activity. Further, the present climate at the Agency is geared to enforcement of the regulations and to application of sanctions when indicated.

This article describes the responsibilities that a clinical investigator legally assumes upon signing the Statement of Investigator, Form FDA 482, an interpretation of some of the regulations pertinent to IND research, and how to abide by the applicable regulations: what to do, how to do it, and what not to do.     

美国药品标识类型和要求研究

目的：通过回顾美国药品标签和说明书监管历程,阐述美国药品标识类型和要求,以期为完善我国药品说明书和标签管理提供借鉴,进一步提高卫生专业人员和公众合理用药水平。方法：查询FDA及美国联邦政府的官方网站、中国知网数据库,采用对比分析和统计分析等研究方法,对美国药品标识分类和要求进行分析。结果与结论：美国药品标识围绕目标人群的专业水平、药品使用风险差异两大监管原则,逐步形成了类型丰富、层次鲜明、内容详实的药品标识群。我国药品说明书和标签监管制度,可以从进一步明确我国药品说明书和标签的功能定位、加强对处方药和非处方药说明书和标签的管理等方面,借鉴美国处方药和非处方药标识的管理经验。