Regulatory Open Forum

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  • 1.  IND consulting needed for novel cell therapy

    Posted 27-Jan-2016 10:49

    Hi everyone,

    My group is developing a novel cell therapy at NIH in preparation for clinical trials, and we will need some help with the IND.  Can any of you recommend a CRO or consultant in the Washington, DC area with expertise and good outcome in these matters?  

    The therapeutic is an autologous, iPS cell-based retinal pigmented epithelial patch for treating severe age-related (dry) macular degeneration.  

    Right now, we need some help in IND strategy.  For example, is there an advantage in preparing for eCTD vs. paper-based submission?  What programs at FDA/CBER, and which of their pet issues, should be considered during product development and IND preparation?  Because this therapeutic is biologic but contains matrix and surgical device components, how can we structure the submission?  Etc.

    Thank you, -Matt

    ------------------------------
    Matthew D. Phillips, Ph.D., RAC
    Clinical Research Associate [C]
    NIH/CC/DTM, Cell Processing Section
    Bethesda, MD
    ------------------------------


  • 2.  RE: IND consulting needed for novel cell therapy

    Posted 27-Jan-2016 18:01
    Matthew,

    You are in a good area!  

    BTW: have you initiated a dialogue/communicated with the FDA already? 

    Thank you.  

    s/ David
    ______________________________________________
    Dr. David Lim, Ph.D., RAC, ASQ-CQA 
    Phone (Toll-Free): 1-(800) 321-8567



    "Knowledge is power only when it is practiced and put into action." - Regulatory Doctor

    NOTICE: This communication (including any attachments) may contain privileged or confidential information intended for a specific individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this communication and/or shred the materials and any attachments and are hereby notified that any disclosure, copying or distribution of this communication, or the taking of any action based on it, is strictly prohibited.





  • 3.  RE: IND consulting needed for novel cell therapy

    Posted 28-Jan-2016 12:30

    Dear David,

     
    Yes, a pre-IND package has already been submitted and we have scheduled a pre-IND meeting in the next couple of months.  Your recommendation would be appreciated...
     
    Thanks,
    -Matt
    ------------------------------
    Matthew Phillips PHD, RAC
    Rockville MD
    United States



  • 4.  RE: IND consulting needed for novel cell therapy

    Posted 29-Jan-2016 12:44
    Dear Matthew,

    I supposed you may have done so.

    I have two submissions before the same division at OCTGT/CBER/FDA using tissue derived regenerative cells with a medical device (I also helped the firm clear it) as a combination product. 

    It seems you have a cell therapy product containing a medical device (surgical). 

    Our client has chosen to take an IDE and PMA pathway in lieu of an IND and BLA through the OCTGT/CBER. 

    May I ask your rationale to choose an IND/BLA pathway? Are you aware of the FDA guidance on feedback requests on medical device submission?

    I am scheduled to lead a discussion with the FDA in early March.

    Thank you.  

    s/ David
    ______________________________________________
    Dr. David Lim, Ph.D., RAC, ASQ-CQA 
    Phone (Toll-Free): 1-(800) 321-8567



    "Knowledge is power only when it is practiced and put into action." - Regulatory Doctor

    NOTICE: This communication (including any attachments) may contain privileged or confidential information intended for a specific individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this communication and/or shred the materials and any attachments and are hereby notified that any disclosure, copying or distribution of this communication, or the taking of any action based on it, is strictly prohibited.





  • 5.  RE: IND consulting needed for novel cell therapy

    Posted 28-Jan-2016 09:06

    Good morning,

    Nowadays, eCTD is so much better than paper submission and so even it is not mandatory I always do my submission electronically. For the fact that your drug product has a device associated with, this is pretty standard with cell therapy and so some company used already marked device (i.e. catheter) or they built their own in which case both the new drug investigation and the new device move together on the product development path. The FAD are used to this approach.

    Good luck.

    Catherine

    ------------------------------
    [Catherine] [Bernard]
    [Principal]
    [International Ref Affairs]
    [cbernard@iras-regs.com]



  • 6.  RE: IND consulting needed for novel cell therapy

    Posted 28-Jan-2016 09:13

    eCTD without any doubt at all.

    ------------------------------
    Sorin Alb
    Project Manager, Regulatory Affairs
    NUCRO TECHNICS
    Scarborough ON
    Canada



  • 7.  RE: IND consulting needed for novel cell therapy

    Posted 28-Jan-2016 12:34

    We want to discuss the IND strategy in some depth with an expert consultant or CRO as mentioned above, if you have any recommendation of someone in the DC area.  But thank you Sorin and Catherine for your answers on the eCTD issue!

    -Matt

    ------------------------------
    Matthew Phillips PHD, RAC
    Rockville MD
    United States



  • 8.  RE: IND consulting needed for novel cell therapy

    Posted 29-Jan-2016 08:22

    Hi Matthew,

    I recently prepared and submitted an IND for an autologous stem cell project and it cleared on the 28th day of the review cycle with just one request.

    I spoke with a Project Manager at CBER before submitting the IND and was told my client could submit an eCTD or paper or hybrid. The company did not have additional funds to submit an eCTD and we choose to submit a hybrid.

    All comments concerning the use of the eCTD are correct as to the easy of use for follow-on submissions and the ultimate BLA but not all submitters are comfortable with the process. My client knows they will have to migrate to the CTD for their BLA but are happy now with their decision for their Phase II.

    Let me know if I can answer any questions for you.


    Best regards,

    Bob Bard

    ------------------------------
    Robert Bard JD RAC
    Managing Director
    Healthcare Technologies Consultants
    South Lyon MI
    United States



  • 9.  RE: IND consulting needed for novel cell therapy

    Posted 29-Jan-2016 10:39

    Dear Matt,

    You should definitely consider Biologics Consulting (www.biologicsconsulting.com) for your project needs.  We have consultants in both cell therapy and devices, many with CBER and CDRH experience, and have over 18 years of experience helping companies and research groups like yourself successfully present your products to the FDA.  The company is headquartered in Alexandria, VA and many of the consultants are located in the DC/Maryland/Virginia area.  We also have an in-house publishing group with lots of experience in preparing and sending both paper and electronic submissions.

    I encourage you to look over our website and see if our experience matches your needs.  You can use the "Contact Us" page to leave us your information and we will get back to you quickly.

    Best of luck with your very interesting product.

    ------------------------------
    Debra Barngrover RAC
    Senior Consultant
    Biologics Consulting
    Southborough MA
    United States



  • 10.  RE: IND consulting needed for novel cell therapy

    Posted 29-Jan-2016 09:31

    Hi Matthew

    I am a regulatory and clinical strategy scientist with Cato Research.  We are headquartered in RTP, NC but have an office in Rockville MD.  We have extensive expertise in novel therapies including combination products and preIND/IND strategy and interactions.  We are a mid-sized CRO and a great fit for smaller sponsors and NIH-sponsored projects.  I am happy to have someone from our office there contact you if you'd like, to see if we can help you with your IND planning.

    Best regards,

    Lisa Sanders

    ------------------------------
    Lisa R. Sanders, Ph.D., R.A.C.
    Principal Scientist
    Cato Research
    Phone: +1-919-361-2286
    lsanders@cato.com
    www.cato.com