Expediting Drugs and Biologics Development

From the initial planning to the NDA/BLA review process, Expediting Drug and Biologics Development shows you how to use reverse-engineering techniques to drive and improve each aspect of a drug and biologic product development program’s design and implementation. Written by dozens of leading experts, this book is a real-world “doer’s” guide. It provides templates, forms, and tools to assist those “in the trenches” of new drug and biologic development today. With this book, you will learn how to:

Make planning the central part of all aspects of drug and biologics development.

Establish a Target Product Profile (TPP) to critically evaluate the needs of the evolving package insert and eventual marketing application before getting deeply into clinical trials.

Understand that the clinical development program dictates much of the nonclinical development program, and that both dictate the chemistry, manufacturing and controls development program.

Involve thoughtful ethics in the planning and execution of clinical research.

Leverage standardization to drive and expedite the entire development process, from the development of clinical trial protocols to the development of clinical data presentations.

Critically assess the needs of a final study report before developing the clinical protocol.


Chapter 1: Beginning at the Destination: A Corporate Culture
Begin at the Destination
View from the Corner Office
Target Product Profile
Regulatory Strategy
Product Development Plan
The Big Picture
Too Big to Fail
Planning, Planning, and More Planning
Planning Versus Execution
About the Author
Chapter 2: The Target Product Profile
Need for Planning
Need for Communication
What the TPP Is
What the TPP Is Not
TPP in the Press and Regulatory Agency Guidance
Implementation, and the Pharmaceutical Company Perspective
What Can a TPP Look Like?
Wrap-Up
About the Authors
Chapter 3: The Common Technical Document
What Is a CTD/eCTD?
Key Terms at a Glance
Organization
Reference Tools
Roadmaps for the NDA/BLA in CTD Format – Module 1
Begin with the End in Mind
Marketing Application Form – Form FDA 356h
Product Description
Established and Proprietary Names
Dosage Form and Route of Administration
Indication
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Marketing Application Types
505(b)(1) NDA
505(b)(2) NDA
ANDA
351(a) BLA
351(k) BLA
Combination Products
Cross References
Rx, OTC
Regulatory Information
Target Product Profile — Annotated Labeling
Comprehensive Table of Contents
Format and Content of the CTD – Modules 2 to 5
Chemistry (Quality)
Modules 2 and 3
Tips for Efficiency
CTD Table of Contents (TOC)
Labeling
Regulatory Interactions and Guidelines
Novel Excipients
Abbreviations
Hypertext Linking Consistency
Tabular Summaries
Nonclinical (Safety)
Modules 2 and 4
Tips for Efficiency
CTD Table of Contents (TOC)
Labeling
Regulatory Interactions and Guidelines
Abbreviations
Hypertext Linking Consistency
Tabular Summaries
Report Summaries/Synopses
Literature Reports
Clinical (Efficacy)
Modules 2 and 5
Tips for Efficiency
CTD Table of Contents (TOC)
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Labeling
Regulatory Interactions and Guidelines
Abbreviations
Hypertext Linking Consistency
Tabular Summaries
Report Summaries/Synopses
Literature Reports
FDA Review
Summary
References
About the Authors
Acknowledgments
Chapter 4: Expedited Development of New Drugs and Biologics
Introduction
Tracing the Roots of the FDA
The Origin of Expedited Programs
Concepts for Expedited Programs
Serious Condition
Available Therapy
Unmet Medical Need
The Specifics of the Expedited Programs
Fast Track Designation
Breakthrough Therapy Designation
Accelerated Approval Pathway
Priority Review Designation
Summary and Conclusions
About the Author
Chapter 5: Clinical Trials Enrolling Children
Rationale for Pediatric Studies
Protecting Children Participating in Clinical Research
Definitions
IRB Approval Process for Pediatric Research
Evaluation of Efficacy in Pediatric Research
Extrapolation of Adult Efficacy Data to the Pediatric Population
Evaluation of Safety in Pediatric Research
Considerations of Trial Design
Timing of Initiation of Pediatric Studies in Product Development
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Development of Pediatric Formulations
Federal Initiatives to Promote Pediatric Development
Best Pharmaceuticals for Children Act
The Pediatric Research Equity Act
Summary and Conclusions
About the Author
Acknowledgments
Chapter 6: Phase 1 Clinical Studies
Phase 1 Studies
Phase 1 Sites
Phase 1 Staff
Site Training and Experience
Safety in Phase 1 Studies
Sponsor Opportunities
Protocol Execution: A Day in the Life
Lessons Learned
About the Authors
Acknowledgments
Chapter 7: Nonclinical Development
Introduction
Nonclinical Testing: Introduction and Brief History
Nonclinical Development: A Multidisciplinary Integration
Formulating a Development Plan
Guiding Principles for Nonclinical Planning
Drugs: Nonclinical Safety Testing
General Nonclinical Testing Requirements
Studies Expected Prior to Phase 1 Testing
Pharmacology Studies
Safety Pharmacology Studies
Pharmacokinetics and ADME
Genetic Toxicity
General Toxicity Studies
Studies Expected During Clinical Development
Pharmacology Studies
Safety Pharmacology Studies
Pharmacokinetics and ADME
Genetic Toxicity
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General Toxicity Studies
Developmental and Reproductive Toxicity
Special Toxicity
Additional Studies Expected to Support a Marketing Application
General Toxicity Studies
Carcinogenicity
Developmental and Reproductive Toxicity
Juvenile Toxicity
Combination Toxicology Studies
Biologics: Nonclinical Safety Testing
Overview of Nonclinical Testing for Biologic Products
Key Principles for the Nonclinical Development of Biologics
Relevant Animal Model
Immunogenicity
Dose Selection and Safety Margin Calculation
Product Characterization
Product-Specific Nonclinical Issues for Biologics
Monoclonal Antibody (mAb) Products
Recombinant Proteins and Peptides
Somatic Cell Therapy
Gene Therapy
Preventive and Therapeutic Vaccines
Oligonucleotides
Nonclinical Safety Testing: General Technical and Scientific
Considerations
General Study Design Concepts
Species Selection
Number of Animals
Use of Recovery Groups
Dose Selection
Route of Administration
Dose Volumes and Good Practices
Dosing Regimen
Extrapolating Doses Between Species
Establishing Timelines
Typical Cost Estimates
Outsourcing Safety Studies
Summary
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References
About the Authors
Acknowledgments
Chapter 8: Integration of CMC into Drug Development:
Strategies for Success and Tactics for Avoiding Common Pitfalls
Introduction
The CMC Development Plan
Never Allow API or CTM to Be Rate Limiting
(or Always Make More)
Learn Where the Minefields Are
Know Your Compound
Know Your Dosage Form
Learn to Efficiently Manage Risk for CMC Activities
Biologics
Small Molecules
Phase-Appropriate Emphasis (Too Little or Too Much?)
The IND CMC Section Is Just the Tip of the Iceberg
Plan for Success
Adopting Smart Development Practices
Conclusion
About the Author
Acknowledgments
Chapter 9: The Sponsor/Contract Research Organization Partnership
Introduction
How to Pick a CRO
The Proposal Process
Option A
Pros
Cons
Option B
How to Pick a CRO Under Option B
The Bid Defense
Formal Transfers of Obligations
Project Management
The Sponsor Advocate
Sponsor/CRO Meetings
Clarity of Invoices
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Closing Remarks
About the Authors
Chapter 10: eCTD Submissions to the FDA
Background
Terminology
Tools
Planning
Team Members
Planning Process
Planning Content
Authoring
Compilation and Publishing
Archiving
Conclusion
About the Author
Chapter 11: Meeting with the FDA: Why Meet and How to
Communicate
Introduction
FDA Guidance
Types of Meetings
Type A Meetings
Type B Meetings
Type C Meetings
Meeting Request
Meeting Package
Industry and Regulator Observations on Meetings
Industry Perspective
Pre-Meeting Planning
During the Meeting
Regulator Perspective
Closing Thoughts
About the Authors
Chapter 12: Investigational New Drug Application
IND Content, Format, and Timeline
IND Content
IND Format
IND Review Clock
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Clinical Hold
ClinicalTrials.gov: Registration, Updates, and Informed Consent
Requirements
IND Amendments
Protocol Amendments
Information Amendments
IND Safety Reporting
Annual Reports
Administrative Considerations
Resources
About the Author
Chapter 13: Title 21 CFR Part 11
Introduction
Background and History
Applicability
Part 11 Requirements
Requirements for Electronic Records
Validation
Authorized Access
Audit Trails
Sequence Checks
Device Checks
Record Copies
Record Protection and Retention
Training
Controls Over System Documentation
Open Systems
Requirements for Electronic Signatures
Identity Verification
Signature Execution
Signatures on the Record
Digital Signatures
Additional Considerations
Application Inventory
System Description
User Training
Risk Determination
Programming Tools
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Scanned Records
EDC Systems
Other Record Systems
Email
Global Records and Regulations
Other US Regulations
Regulatory Guidances
Company Size
Outsourcing and Third Parties
The Future
About the Author
Acknowledgments
Chapter 14: The Investigator’s Brochure
Introduction
The Initial IB and the IND
Updating the IB
Safety Updates
Timing of Regular Updates
Evolution of the IB During Development
Administrative Issues
Summary
About the Author
Chapter 15: Clinical Study Reports
Introduction
Establishing the Format and Content
ICH E3: Structure and Content of Clinical Study Reports
Overall Development of a CSR
Using a CSR Template
Statistical Analysis Plan
Format and Content of a CSR
Outline
CSR Shell
Results
Summary Source Tables and Serious Adverse Event Narratives
Source Documents
Synopsis
Clinical Study Report Writing
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Overall CSR Development Timelines
Project Planning
Establishing Roles and Responsibilities
Developing Timelines
Clinical Study Report Development Process
Prior to Study Completion
At Study Completion
Database Lock to Final Analyses
Technical Issues Related to the Content of a CSR
Summary
About the Author
Chapter 16: Analysis Plans
Analysis Plans Defined
Standalone SAP
Statistical Guidelines
SAP Elements That Demand Special Attention
Definition of the Research Question and Estimands
An Example of an Estimand
The Process for Defining the Research Question and Estimand
Sensitivity and Supportive Analyses
Sample Size Calculations, Power, and Type I and Type II Errors
Clinical Outcome Assessments
Conclusion
About the Author
Chapter 17: An Integrated Approach to Data Management
Background and Industry Landscape
The New World of Technology and Its Impact
Putting the Data Puzzle Back Together
The New Data Tracking and Reporting Tools
Defining an Integrated Data Management Solution
Initial Protocol Strategy Meeting
Data Collection Requirements
Types of Data Collection Systems and Processes
eCRF Data
eCOA Data
Wearable Device Data
Data Tracking Requirements
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Data Cleaning Requirements
Data Analysis/Reporting Requirements
Implementation and Validation
The Role of Data Management in the Clinical Trials Process
Collaboration Is the New Integration
Data Stewardship
Summary & Conclusion
About the Authors
Chapter 18: The Protocol: A Clinical/Statistical Collaboration
The Protocol Strategy Meeting
The Participants
The Agenda
Objectives
Endpoints/Variables
Design
Entry Criteria
Schedule of Assessments
Data Presentations
End Products
Standard Protocol Content
Minimum Criteria
Adequate and Well Controlled
Protocol Content Considerations
Standard Protocol Format
Title Page
Investigator Protocol Signature Page
Table of Contents
Body of the Text
Protocol Synopsis (Summary)
Standard Protocol Template
Drafting an Individual Study Protocol
Conclusion
About the Authors
Chapter 19: Data Content and Design
Introduction
What Data Should Be Captured?
Data Design
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Tools of the Trade
Standard Formatting
Help the User Avoid Discrepancies
Adverse Event Capture
Date and Time
Templates
Standard Formatting for CRFs
Consider the Source
Implement the Standards
Basic CRF Design Principles
Standard Case Report Forms
Demographic Data
Medical History
Inclusion/Exclusion
Medication Log
Clinical Laboratory Data
Adverse Event CRF
Termination CRF
Comment Fields
Study-Specific Case Report Forms
Implementation
Data Team
Conclusion
About the Author
Chapter 20: Informed Consent, IRB Review, and Ethics
History and Regulatory Background
Preparing the Informed Consent Draft
Authors of the Informed Consent Document
Informed Consent Document Process
Enhancing Comprehension of the Informed Consent Form: Decreasing the
Reading Level
Elements of Informed Consent
Basic Elements of Informed Consent
Certificates of Confidentiality
Additional Elements of Consent
Documentation of Consent
Terminology
Process After Drafting the Informed Consent Form
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Study Site Investigator’s Review of the Draft Informed Consent Document
and Preparation for IRB Approval
Review of the Research Project by the IRB
Criteria for IRB Approval
IRB Approval Letter
Inclusion of Vulnerable Populations
Pediatric Studies
Women of Child-Bearing Potential and Minorities
Other Considerations
IRB Review of Multi-Site Studies
Sponsor’s File Copy
Direct Communication Between Sponsors and IRBs
Sponsors’ Access to IRB Written Procedures, Minutes, and Membership
Rosters
The International Council for Harmonisation
Conclusions
About the Author
Acknowledgments
Chapter 21: Clinical Trial Operations & Project Management
Introduction
Protocol Development
Study Planning
End-to-End Timeline
Feasibility
Enrollment Forecasting
Service Provider Selection
Study Kick-Off and Team Engagement
Study Execution: Start-Up Phase
Study Plan Development & Team Training
Investigator Site Evaluation/Selection, Initiation, and Activation
Investigator Meeting
Study Execution: Maintenance Phase
Site & Subject Tracking: Utilizing Metrics
Investigational Product Supply Management
Data Monitoring
Executing Clinical Database Lock
Study Reporting & Close-Out
Results Reporting
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Clinical Study Report Development
Investigator Site Close-Out
Lessons Learned
Conclusion
About the Authors
Acknowledgments
Chapter 22: Clinical Site Budgets and Contracts
Introduction
Clinical Trial Agreements
Clinical Trial Agreement Template
Clinical Trial Agreement Considerations
Third Party Agreements
Governing Laws
Indemnification
Clinical Trial Participant Rights
Clinical Trial Agreement Negotiations
Clinical Site Budgets
Clinical Site Budget Template
Per Patient Cost Benchmarking
Indirect Costs & Fees
Investigator Payment Administration
Clinical Site Budget Negotiations
Conclusion
About the Author
Acknowledgments
Chapter 23: Clinical Trial Monitoring
The Clinical Research Associate (CRA)
Background and Terminology
Roles and Responsibilities of the CRA
Site Selection Visits
Background Information for Site Selection Visits
Site Selection Visit: Preparation
Site Selection Visit: Conduct
Site Selection Visit: Follow-Up
Site Initiation Visit
Background Information for Site Initiation Visits
Site Initiation Visit: Preparation
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Site Initiation Visit: Conduct
Site Initiation Visit: Follow-Up
Periodic Site Visits
Background Information for Periodic Site Visits
Source Data Review and Source Data Verification
Risk-Based Monitoring
Periodic Site Visit: Preparation
Periodic Site Visit: Conduct
Periodic Site Visit: Follow-Up
Termination Site Visits
Background Information for Termination Site Visits (TSV)
Termination Site Visit: Preparation
Termination Site Visit: Conduct
Termination Site Visit: Follow-Up
Decentralizing Clinical Trials
Career Opportunities as a CRA
The Site’s Perspective on the Role of a CRA
About the Author
Chapter 24: Evaluation of Safety During Pharmaceutical Product
Development and Lifecycle
Introduction
Background
Strategy for the Evaluation of Clinical Safety
Compound Source/Structure
Formulation
Late Discoveries in Chemistry, Manufacturing, and Controls for the
Formulation
Route of Administration
Duration of Administration
Pharmacology
Late Discoveries from Pharmacology
Toxicology
Late Discoveries from Toxicology
Regulatory Expectations/Requirements/Standards
Alert Reporting
Serious
Unexpected
Associated
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Reporting Requirements
Breaking Blinds
Clinical Effects
Phase 1
Starting Dose in Phase 1
Multiple Doses in Phase 1
Use of Phase 1 Data
Phase 2
Phase 2a
Use of Phase 2a Data
Phase 2b
Use of Phase 2b Data
Phase 3
Phase 3a
Use of Phase 3a Data
Phase 3b
Use of Phase 3b Data
Phase 4
Postmarket (Phase 4) Studies Required upon Product Approval
Postmarket (Phase 4) Studies Required after Product Approval
Use of Phase 4 Data
Risk Evaluation and Mitigation Strategy
Role of the Medical Monitor
Summary
References
About the Author
Acknowledgments
Chapter 25: The FDA Marketing Application Review Process
Legislation, Policies and Procedures
Organization of the Review Process
Application Receipt and Processing
Filing Determination and Review Planning
The Administrative Filing Review of the Application
Internal Review Schedule Planning
Review
FDA Application Review Philosophy
120-Day Safety Update
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Mid-Cycle Meeting
Inter-Review Occurrences and Communications with the Company
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Obtaining Advice/Input for the Review Division
Labeling Meeting, Negotiations, and Philosophy
Late-Cycle Meeting
End of Review Activities
Wrap-Up Meeting
Final Action
Possible FDA Actions on a Pending Marketing Application
Working Towards a Good Review Cycle
About the Authors
Chapter 26: Preparing for FDA Inspection
Introduction
Prepare Early and Often
Internal Audit
External “Third-Party” Audit
The FDA Inspector’s Frame of Reference
The FDA Inspector’s Frame of Mind
Mulder’s Law
Genesis Factor
Stephens’ Legacy
Hoover Hypothesis
Murphy’s Law Correlate
Preparing the Clinical Study Site
Preparing the Sponsor or CRO
The FDA Inspection
Long Before the Visit
Procedure
Personnel
Inspection Coordinator
Responsible Parties
Reception
Study Staff or Project Team
Facilities
Just Before the Visit
During the Visit
After the Visit
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Conclusion
About the Author
Acknowledgments
Chapter 27: Preparing for an FDA Advisory Committee Meeting
Overview
About FDA Advisory Committees
Who Is on an Advisory Committee?
Subject Matter Experts
Industry Representative
The Chair
Committee Members
Designated Federal Officer
A “Typical” Advisory Committee Meeting
Meeting Space
Meeting Agenda
Materials and Timing Leading Up to an AC Meeting
Preparing for This High-Profile, High Stakes Event
Timeline
Define Strategy and Argument
Develop the Materials
Delivery
Mock Panels
Presenters
Q&A Moderator
Other Team Members
Communicating Effectively with the Committee
Know Thy Audience
Know Thy Message
Questions & Answers
Open Public Hearing
Best Practices for Advisory Committee Success
About the Author
Acknowledgments
Index
About Barnett International
About Cambridge Healthtech Institute

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