Paula M. Jacobs, Ph.D. SAIC Frederick Cancer Imaging Program/DCTD/NCI/NIH September 5, 2006 Phase 0 Trials in Oncologic Drug Development DCTD Phase 0 Workshop.

Paula M. Jacobs, Ph.D.SAIC Frederick

Cancer Imaging Program/DCTD/NCI/NIH September 5, 2006

Phase 0 Trials in Oncologic Drug Development

DCTD Phase 0 WorkshopDCTD Phase 0 Workshop

Nuts and Bolts:You Too Can Prepare an

IND

Overview of Early Development

Synthesize a number of new imaging drugs

Evaluate them in pre-clinical settings Pick the best ones to test in humans Learn to prepare them consistently Perform in vivo pharmacology and

toxicology in appropriate animal models Chose initial dose for human studies:

least risk Assemble the data and submit to FDA or

to your RDRC Obtain IRB approval Test in human subjects

Approach to Regulatory Requirements

Regulations are the same for Labeled therapeutic agents Functional imaging agents General imaging agents

Development strategy may differ with goal Basic information about a therapeutic Basic information about a tumor Imaging for evaluating response to

therapy

Investigational Clinical Trials

The sponsor must apply for permission to study drugs in humans From FDA for IND – traditional or

exploratory From the Radioactive Drugs Research

Committee (RDRC) at your institution From an IRB for either

“Sponsor” Individual physician Institution Industry

RDRC vs. IND

RDRC: for basic research only E.g., kinetics, distribution, dosimetry NOT safety or efficacy Pediatric studies restricted Only small doses and few patients Drug must have been in humans before

IND: not restricted to basic research Can study safety and efficacy (i.e., clinical trials) Can do basic research Pediatric studies less restricted

Types of IND

Three types of traditional INDs: An investigator initiated IND Emergency use IND (E-IND) Treatment IND

And a new type: Exploratory (“phase 0”, x-IND)

What’s the difference?

Traditional Single agent Plans for Phase 1, 2, 3 trials and NDA Extensive pre-clinical data needed to begin Dose escalation, therapeutic evaluation

Exploratory Multiple agents under one IND, go/no go Microdose, first in man studies No therapeutic intent Biodistribution, pharmacokinetics, safety Less pre-clinical data required Resubmit as Traditional IND if successful

FDA Guidance on the IND process with multiple links to other documentation: http://www.fda.gov/cder/regulatory/applicatio

ns/ind_page_1.htm

Comprehensive FDA Guidance Page http://www.fda.gov/cder/guidance/

guidance.htm

An “how-to” guide from the Biological Development Program at NCI-Frederick with multiple links http://wwwbdp.ncifcrf.gov/pdf/GuidetoRegSub

s.pdf

Schedule a pre-IND meeting

Where to get information

Talk to th

e FDA!

Nuts and Bolts of an IND

What data are needed What supporting information

is needed How is the application put

together What happens when it is

submitted

Information Required in INDs

Pharmacology/toxicology in animals

Dosimetry for radiopharmaceuticals

CMC: Chemistry, Manufacturing and Controls

Some of these data may be referenced from existing INDs or the literature

Clinical Information

Clinical Protocols and Investigator Information

Detailed protocol for clinical study

Qualifications of clinical investigators

Commitments To obtain informed consent To obtain review of the study by an

institutional review board (IRB) To adhere to the investigational new

drug regulations

IND Application

1. Form 1571 (Application)

2. Table of Contents of Application

3. Introductory Statement

4. General Investigational Plan

5. Investigators’ Brochure (multi-site)

6. Protocol Study Protocol Investigator Data – Form 1572, CV

IND Application

7. Chemistry, Manufacturing, and Control Data

8. Pharmacology and Toxicology Data

9. Previous Human Experience

10. Additional Information. Dosimetry Letter from IND or DMF-holder allowing

cross- reference to their files Site/NCI Data and Safety Monitoring Plan Cited literature

Practical Issues

Make it easy for multiple reviewers to find and understand the information – repeat information in different sections

Include all sections, even if empty Comprehensive Table of Contents and

TOC for any section more than a few pages

Consecutive page numbers for entire IND (can be numbered by section )

Include copies of all cited literature Don’t assume the reviewers will be

expert in your subject area

What happens next?

Submit 5-15 copies (ask FDA Division)

Wait 30 calendar days before beginning the first study on IND

The document goes to several reviewers

FDA reviews the IND first and foremost for risk to subjects – NOT for scientific interest

FDA may request changes Safety related in protocol Purity/safety related in CMC

FDA will call/fax with questions

Begin your investigational study in human subjects

jacobsp@mail.nih.gov

The Next Speaker is:

Dr. Anthony Shields