FDA Requirements for ensuring Premarketing Clinical Trial Safety

FDA Requirements for ensuring Premarketing Clinical Trial Safety 2

The FDA has set out requirements for sponsors and organizations that carry out clinical trial to ensure premarketing clinical trial safety. This is a very vital requirement because this is the stage at which the database that goes into clinical trials is formed. Its integrity and safety is an important ingredient for assessing the risks and benefits that go into the clinical trial, and errors need to be identified and corrected at this stage. Wrong data could lead to disastrous consequences for the study, the subjects that are part of it, the organization and eventually, patients.

Basic nature of FDA requirements for premarketing clinical trial safety

FDA Requirements for ensuring Premarketing Clinical Trial Safety 1

The FDA has a set of requirements for premarketing clinical trial safety, but these are mostly informal and loose. They are more of an advisory nature than being stringent regulatory requirements that are legally enforceable. Most FDA guidance is on a case-by-case nature.

FDA Requirements for ensuring Premarketing Clinical Trial Safety 4

Basically, the FDA’s guidance is based on its working with large to very large clinical trials. It has thus far not seriously considered working with small groups for assessing premarketing clinical trial safety. At its barest, the FDA seeks to:

  • Advise sponsors or organizations undertaking the clinical trial about ways by which their data collection can be simplified so as to ensure that it is neither too huge nor too small, and should lead to giving insights about the drug’s safety. Essentially, the FDA guideline on premarketing clinical trial safety seeks to prevent sponsors from collecting data that is not relevant.
  • Get sponsors to consult the FDA’s review division for its premarketing clinical trial safety.
The FDA has different requirements for different kinds of studies that relate to clinical trials. For example:

premarketingClinicalTrialSafety

The FDA’s requirements for non-IND Foreign Clinical Studies

The FDA grants marketing approval for certain types of medical products whose application is the result of foreign clinical studies, provided the products and the clinical studies meet certain conditions. The types of medical products

The FDA's requirements for non-IND Foreign Clinical Studies 2

that are permitted under this system of foreign clinical studies include:

  • A human drug
  • A biological drug
  • A medical device

The guidelines for foreign clinical studies requirements

The guidelines under which the FDA accepts medical products for approval when they are the result of foreign clinical studies are spelt out in various sections of 21 CFR.

Any foreign clinical study has to be meet requirements of 21 CFR Part 312or 21 CFR Part 812, which relate to studies conducted under an Investigational New Drug Application (NDA) or Investigational Device Exemption (IDE) respectively, just the same way in which American companies too have to

In case a foreign clinical study is not conducted under an IND; the FDA will still accept it, so long as it fulfills the ethical principles set out in the Declaration of Helsinki, or is in accordance with the laws of the respective country from which the study originates, based on whichever of these two offers stronger protection of the subjects of the study.

Highlights of the Helsinki Declaration

The FDA's requirements for non-IND Foreign Clinical Studies 1

The World Medical Association adapted the Helsinki Declaration from the time it was passed in 1964. In 1975, given the popularity of the Declaration in guaranteeing humane protection of human subjects in a clinical study; the FDA adapted the principles of the Helsinki Declaration as the basis for accepting non-IND compliant drugs. This Declaration has been revised a few times, although the FDA is yet to include the latest of these, that of October 2000, into its regulations.

Points of significance

The Investigational New Drug Applications mechanism in the USA

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The IND is a process which gives the sponsor the opportunity to start marketing across the States of the US without having to complete the formal process. it also gives the patient the assurance that the drug that is being administered may not have gone through the full regulatory process as yet, but is as effective as one that is already in the market. The FDA has three mechanisms in place for submission of an IND.

Present Federal law requires a manufacturer who wants to market a drug in the US to subject the drug to an approved marketing application before it gets transported and/or distributed for interstate commerce, i.e., within the different States in the US.

Since it is very likely that the sponsor of a clinical trial may want to ship the investigational drug to clinical investigators across several states, it is but natural that the sponsor would look for exemption from this legal requirement. The Investigational New Drug (IND) Applications in the USA is the mechanism through which this exemption issues from the FDA to the sponsor.

investigationalNewDrugApplicationsInTheUsaWe can understand the Investigational New Drug Application this way: it is a request made by the sponsor of a clinical study with the FDA asking for its authorization to administer a biological product or an investigational drug to humans before the product goes through interstate shipment. The IND application should also be made before administering a drug that is not the same as an approved New Drug Application or Biologics/Product License Application.

The rationale behind filing Investigational New Drug Application

 

Ensuring a drug’s safety for use in humans is the basis for the entire idea of filing an Investigational New Drug Application. This is the prelude to the steps for its commercialization. By paving the way for further actions such as data collection; the Investigational New Drug Application is often the predecessor step for reinforcing the drug’s safety. An Investigational New Drug Application can be understood or taken as some kind of assurance or guarantee that when the drug that is at this stage of studies is administered on humans; it is not harmful and does not carry risks.

Ensuring a drug’s safety for use in humans is the basis for the entire idea of filing an Investigational New Drug Application. This is the prelude to the steps for its commercialization. By paving the way for further actions such as data collection; the Investigational New Drug Application is often the predecessor step for reinforcing the drug’s safety. An Investigational New Drug Application can be understood or taken as some kind of assurance or guarantee that when the drug that is at this stage of studies is administered on humans; it is not harmful and does not carry risks.

The FDA’s roleinvestigationalNewDrugApplicationsInTheUsaThe FDA’s comes into the picture when the sponsor who files an Investigational New Drug Application wants to test the effect on humans of molecules that it has screened and identified. At this stage, the status of the molecule changes into a new drug that is subject to the requirements set out by the regulatory system.

Kinds of INDsThere are three types of Investigational New Drug Applications:

investigationalNewDrugApplicationsInTheUsa
Elements of an Investigational New Drug Application
investigationalNewDrugApplicationsInTheUsaThe FDA requires an Investigational New Drug Application to contain the following:

  • Studies carried out for testing animal pharmacology and toxicology
  • Information about the manufacturing aspects of the drug
  • Information about the clinical protocols and investigator of the Investigational New Drug Application

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What is logistics and supply chain management?

What is logistics and supply chain management

Logistics and supply chain management (SCM) constitute a very important element of businesses. Getting the logistics and supply chain management aspects right is necessary for the smooth flow of products from their source to destination, during the course of which many activities need to be performed.

Logistics and supply chain management is emerging as a major area of business because of the evolution and growth of globalization. Many products and goods are produced in one country and consumed in another situated thousands of miles away. The right logistics and supply chain management helps to deliver the goods and products to the right person, at the right time, at the right place and in the right condition. Lack of proper logistics and supply chain management is a recipe for disaster.

logistic-and-supply-chain-management
What is logistics and supply chain management?Among the lay people, there is a tendency to use the two words synonymously and interchangeably. In trade, however, there are major differences between the two. Logistics is just a part of the supply chain. In simple, general and broad terms, one can understand the difference between logistics and supply chain in the following ways:

Logistics is a part of supply chain, meaning that it is a set of activities that are carried out within an organization. Supply chain, on the other hand, is the full set of activities that are carried out from start to finish, i.e., from the time it departs the organization that it is leaving till the time it reaches its logical destination. In this process, supply chain management involves the coordination and collaboration of many entities. In this sense, supply chain is a whole set of activities, of which logistics is only a part.

Another way of understanding logistics and supply chain management 

logistic-and-supply-chain-managementAnother way of understanding logistics and supply chain management is this:

Logistics can be understood as being a discipline in which the following activities are involved:

logistic-and-supply-chain-management

On the other hand, supply chain management can be said to include more extended activities, which include:

logistic-and-supply-chain-management

Logistics and its extended activitiesLogistics often is described in terms of inbound and outbound logistics. Simply put, inbound logistics is the movement of raw materials and goods that are bought by and transported into a company. When these are processed and finished and shipped to customers; they become part of outbound logistics.

Logistics and supply chain management in a broader contextWhen one tries to get an understanding of logistics and supply chain management at a higher or broader level in the way logistics has been described above; supply chain management can be understood as consisting of these elements:

logistic-and-supply-chain-managementA sound supply chain system seeks to create value for the organization by building and utilizing logistics infrastructure. Logistics and supply chain management become meaningful when the organization synergizes demand with supply, stock and supply and inventory management

 

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The FDA’s Adverse Event Reporting Requirements

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The adverse event reporting system is an important highlight of the FDA’s adverse event reporting requirements. This is the mechanism through which adverse event reporting requirements are listed out for the FDA to take further action.

The adverse event reporting system may be understood as being a database that aids and supplements the FDA’s postmarketing surveillance program for all its approved products that fall in the category of therapeutic biologics and drugs. So, this database has a record of the adverse event reporting done by all individual and sponsors of their clinical trials. It is a catalog of all the error reports that get generated at various times and stages of the clinical research program.

Voluntary in nature

The FDA's Adverse Event Reporting Requirements4

The outstanding aspect of the FDA’s adverse event reporting requirements is that these reporting requirements are not mandatory. Yet, those involved in clinical research, such as sponsors, healthcare and pharmaceutical organizations, institutions and individuals strictly adhere to adverse event reporting requirements in order to steer clear of legal entanglements that could come their way in the future, and to help other players keep track of all adverse events.

Some of the core adverse event reporting requirements

The FDA's Adverse Event Reporting Requirements1

Applicants should electronically submit all Individual Case Safety Reports (ICSRs) for human drug and nonvaccine biologic products in xml format. Among the adverse event reporting requirements, this has been in place from 2000.

The FDA has been amending rules relating to adverse event reporting requirements from time to time. According to the amendment passed in June 2015; the following adverse event reporting requirements apply:

All applicants should submit all ICSRs, ICSR attachments, and periodic safety reports electronically. They can do this using either of these options:

The E2B method specifies that the files should be in xml format, and the attachments in pdf.

The FDA's Adverse Event Reporting Requirements3

The Safety Reporting Portal (SRP) is meant for those applicants that do not have the database-to-database capability. To fulfill this among the FDA’s adverse event reporting requirements, the applicant needs to have an account with which to access the portal site. FDA’s adverse event reporting requirements state modes and criteria that applicants have to meet to request an SRP account, to activate the account, to add attachments, and for submitting Periodic Safety Reports (PSR).

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Philadelphia woman tries passing fake scripts at Palmer pharmacy

Philadelphia woman tries passing fake scripts at Palmer pharmacy

PALMER TWP., Pa. – A Philadelphia woman is facing fraud charges after she allegedly arrived at a Northampton County pharmacy Wednesday night with fake prescriptions for more than 200 pills.

Police arrested Samantha M. Brown at a Palmer Township Rite Aid with fraudulent prescriptions for Oxycodone, Alprazolam and Flexiril. The 25-year-old now faces three felony counts of trying to acquire a controlled substance. District Judge James Narlesky arraigned Brown late Wednesday night, setting bail at $7,500.

Palmer Township police were dispatched to the Rite Aid at 601 S. 25th St. about 8:30 p.m. The pharmacist told officers that a woman later identified as Brown was sitting in the waiting area, according to court records.

The pharmacist said she tried filling prescriptions for 120 30 mg tablets of Oxycodone, 60 1 mg tablets of Alprazolam and 30 10 mg tablets of Flexiril. Alprazolam is an anxiety medication, and Flexiril is a muscle relaxant.

The prescription was in another person’s name, and the pharmacist told police that she confirmed with the doctor listed on the script that it was a fake. A search of the doctor’s name listed in the criminal complaint shows a physician in Williamsport, Lycoming County.

The doctor notified the pharmacist that the prescription was not filled out in the manner he usually writes scripts and that the person listed on the prescription was not a patient.

 

Read More: http://snip.ly/q0s14#http://www.wfmz.com/news/lehigh-valley/philadelphia-woman-tries-passing-fake-scripts-at-palmer-pharmacy/654023244

Lonza news Tolvaptan identified as a treatment for autosomal dominant polycystic kidney disease

A phase 3 trial studying the effects of tolvaptan has found that the drug slowed the rate of decline in kidney function in patients with polycystic kidney disease…

Tolvaptan identified

A phase 3 trial studying the effects of tolvaptan has found that the drug slowed the rate of decline in kidney function in patients with the most common form of polycystic kidney disease, a condition with no cure.

This is the first treatment that targets a mechanism that directly contributes to the development and growth of the kidney cysts in autosomal dominant polycystic kidney disease

The results of the trial demonstrated tolvaptan’s ability to intervene in a way that slows kidney function decline in this population.

“This is the first treatment that targets a mechanism that directly contributes to the development and growth of the kidney cysts in autosomal dominant polycystic kidney disease,” says Dr Vicente Torres, director of Mayo Clinic’s Translational Polycystic Kidney Disease Center. “This in effect means it may delay the need for a kidney transplant or dialysis in patients with this disease.”

Autosomal dominant polycystic kidney disease is an inherited condition that affects 1 in every 500 to 1,000 individuals in the U.S. This disease is found in all races and sexes. Autosomal dominant polycystic kidney disease, which is the fourth most common cause of end-stage kidney disease, requires dialysis or a kidney transplant.

The disease causes a slow but relentless growth of cysts that damage the kidneys. In addition to negatively affecting the quality of life, the condition also causes hypertension and painful complications. The cysts, which can damage kidneys with their size, can develop in other organs, especially the liver.

Approximately half of individuals with autosomal dominant polycystic kidney disease eventually will require dialysis or kidney transplant by age 60.

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