Esther,
Although I am not certain, it sounds like you are looking to be granted an exemption from the IND regulations for a clinical protocol. This is possible when you are performing clinical studies with marketed products (usually in an indication not yet approved). If so, the process to be followed and the criteria used by FDA are described in 21 CFR 312.2. Furthermore, it appears that you work in the Cancer field. FDA issued a specific guideline on exemptions for lawfully marketed products for cancer:
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM071717.pdf.
I suspect that this will provide the information you need to determine whether the study you are proposing would be exempt from IND requirements.
If you need any further guidance, please contact me.
Regards,
Mark
-------------------------------------------
Mark Ammann PharmD
President
Catalyst Regulatory Services, LLC
Dexter MI
United States
-------------------------------------------
Original Message:
Sent: 08-21-2012 08:56
From: Esther Hendrickson
Subject: protocol exclusion
Dear colleague,
I need to excluse a protocol from an IND since we do not intend to use the data for approval. How do I go about doing this? What kind of information will the FDA ask or can I just exclude the protocol.
Thank you for your help in this matter.
Regards,
-------------------------------------------
Esther Hendrickson, MISM
Manager, Regulatory Affairs
LICR
New York NY
United States
-------------------------------------------