Regulatory Open Forum

 View Only
  • 1.  Multiple indications under one IND

    This message was posted by a user wishing to remain anonymous
    Posted 04-Dec-2018 09:26
    This message was posted by a user wishing to remain anonymous

    Hello, 

    Is there a policy from the FDA / DNP on multiple indications under one IND? 
    The situation: we have an existing IND for indication X and also an approval for indication X. The company now plans to explore a new indication Y and wants to submit the study protocol to the FDA for indication Y to the same existing IND for X. 

    Is that possible?
    The Agency is requesting that each indication be placed in its own IND- are there guidance documents for this or a policy in place?

    Your input is much appreciated. 
    Thank you!



  • 2.  RE: Multiple indications under one IND

    Posted 04-Dec-2018 09:35
    The indication X with an IND is already approved for that indication and so it has a NDA/BLA also? From the administrative point of view the FDA is giving you an appropriate advice. At this time I am unable to point out the regulations or guidance but when I find it I'll share it with you. Actually, this is very simple, all you have to do is submit an IND with the new protocol for indication Y and cross reference everything to the other IND or approved NDA.

    ------------------------------
    GRSAOnline
    ------------------------------



  • 3.  RE: Multiple indications under one IND

    This message was posted by a user wishing to remain anonymous
    Posted 04-Dec-2018 10:17
    This message was posted by a user wishing to remain anonymous

    New protocol can be submitted under existing IND if the new investigation is within the scope of the IND, we have occasionally added additional protocol with subtype of condition being studied for example, if your IND covers broader area of lung disease you could add individual protocol for diseases/conditions falling under one umbrella (COPD, BOS etc  or other specific subtypes) if the scope is similar. However, If the indication Y is completely different from X and changes the target population and risk/benefit ratio, as indicated by agency you will have to submit new IND [as suggested with cross reference to previous IND or package insert (if this is an approved product).




  • 4.  RE: Multiple indications under one IND

    This message was posted by a user wishing to remain anonymous
    Posted 04-Dec-2018 11:52
    This message was posted by a user wishing to remain anonymous

    It is very clear from the initial question that the new protocol is for a new indication!


  • 5.  RE: Multiple indications under one IND

    Posted 05-Dec-2018 14:15
    I agree with below response.  Just because indication is different it doesn't mean a new IND is required.  If the new indication is "related" then it could be filed under same existing IND.  So it depends on what indication Y is and how it relates to X.

    ------------------------------
    Tom
    Chicago
    ------------------------------



  • 6.  RE: Multiple indications under one IND

    Posted 05-Dec-2018 09:33
    My guiding principle is that a new IND probably should be opened if the indication puts the review into a new Division or there is a new formulation than what has been approved.  My second point, if I am not sure, is always to ask the PM.  It is more an administrative procedure than one governed by regulation.

    ------------------------------
    Glen Park
    Jersey City NJ
    United States
    ------------------------------