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 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: ¬ ¬ _page_1.htmhttp:// _page_1.htm   Comprehensive FDA Guidance Page ¬ ¬ guidance.htm   An “how-to” guide from the Biological Development Program at NCI-Frederick with multiple links ¬ ¬   Schedule a pre-IND meeting Where to get information Talk to the 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

The Next Speaker is: Dr. Anthony Shields