All of this information is correct. You may also consider submitting a single Development Safety Update Report (DSUR) in lieu of each 1.13.X summary document (see
https://www.fda.gov/files/drugs/published/E2F-Development-Safety-Update-Report.pdf for more information on the DSUR). It's less work from a publishing standpoint and, since you have no information to share, may be easier to manage. There's a comparison of the DSUR Guidelines to Annual Report CFR Requirements listed here:
https://www.tech-res.com/TRIbune/Fall_2012/Comparison-of-DSUR-Guidelines-to-AR-CFR-Requirements.pdfHowever, if you choose to submit the DSUR format, note that you will not revert back to using the annual report sections 1.13.X - you'll move forward using the DSUR format entirely. Also consider if your product will have multiple formulations, etc., in the future, which would affect how easy the DSUR may be to develop in future reporting periods.
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Ashley Butler
Sr. Manager, Regulatory Operations
Cambridge MA
United States
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Original Message:
Sent: 28-Nov-2022 09:38
From: Anonymous Member
Subject: IND annual report
This message was posted by a user wishing to remain anonymous
FYI-For CMC changes for INDs, you need to submit as they occur and submit them as Amendments (i.e. before using in trial with the new change) and don't wait until annual report! Updated stability data or any minor updates to the sections already submitted in the original IND are ok to be submitted in the Annual Report!
Any significant CMC change need to be submitted as they occur NOT in the Annual Report!
If trial has not started, then you submit the AR with a statement under each section that nothing new happened during the reporting period since the Original IND was okayed!
Original Message:
Sent: 27-Nov-2022 16:52
From: Anonymous Member
Subject: IND annual report
This message was posted by a user wishing to remain anonymous
Hello RAPS Community,
I have a couple of questions about submitting an annual report for IND. Here is some basic information.
1) review division: CDER 2) clinical trial has not started (no patient has enrolled) 3) No new non-clinical studies
Questions:
1) We have not enrolled any patients and did not conduct any new non-clinical studies, and have no manufacturing or microbiological or labeling changes; I assume we do not need to submit the following documents.
- 1.13.1 Summary of Nonclinical Studies
- 1.13.2 Summary of Clinical Pharmacology Information
- 1.13.3 Summary of Safety Information
- 1.13.4 Summary of Labeling Changes
- 1.13.5 Summary of Manufacturing Changes
- 1.13.6 Summary of Microbiological Changes
Am I right?
2) We have updated stability data. We plan to (should we?) submit updated M 3.2.P.8.1, M 3.2.P.8.2, M 3.2.P.8.3, M 3.2.S.7.1, M 3.2.S.7.2, and M 3.2.S.7.3. Can we mention in the cover letter that we are submitting these updated documents? Or do we need to write something in the M 1.13.7 (Summary of Other Significant New information)?
Thank you!