Regulatory Open Forum

 View Only
  • 1.  FDA Form 1571

    Posted 26-Jan-2021 05:05
    Dear community,

    I need to fill out form 1571 for an upcoming IND submission and this is the first time. The IND will be a sponsor IND (pharma company).
    I have a few (surely naive) questions:
    - For a phase 1, should we indicate an indication in field 7 (Phase 1 with healthy volunteers) ?
    - Field 16, we have to provide the "Name and Title of the person responsible for monitoring the conduct and progress of the clinical investigations". Does this person have to be a MD ?
    - Field 17, we have to provide the "Name and Title of the person responsible for review and evaluation of information relevant to the safety of the drug". Does this person have to be a MD ?
    - Field 18, we have to provide the "Name of Sponsor or Sponsor's Authorized Representative". We want to name someone but do you have any recommendations for choosing the most appropriate person to be appointed ? A scientist ? A regulatory ? other ?

    Thank you very much for your precious help.

    Nathalie, PhD

    ------------------------------
    Nathalie DELESQUE TOUCHARD

    ------------------------------


  • 2.  RE: FDA Form 1571

    Posted 27-Jan-2021 08:16

    Dear Nathalie,

    Congratulations on your first IND! Your questions are not naive as everyone has to figure out the answer to these questions and can be different for every IND. Hear is my take, based on my experiences (the fun thing about regulatory affairs is that different people have different experiences and opinion about what is right):

    - I would include an indication in field 7 if it is known at the time. Certainly you can enter Phase 1 without a specific indication, but if you have had a preIND meeting, it probably included discussion of an indication.
    - Identification of the safety person named Fields 16 and 17 are not required to be MDs, but they should be qualified to perform the tasks of monitoring the investigations and safety. Usually they will have a doctorate with relevant training and experience (MD, DO, PhD, PharmD).
    - Field 18 will usually be the person accountable at the Sponsor to authorize the submission of the IND and conduct correspondence with the Agency. This is totally dependent on the structure of the company. A foreign company may have a US Representative who is authorized by the company to perform this function, and the original IND should include a letter of authorization. Some Divisions may require that both the US Representative and a Sponsor representative sign the original IND 1571. In a former life as CRO providing regulatory services, I would sign 1571s on behalf of the Sponsor regardless of whether they were US or foreign Sponsors. In a small company, the authorized person may be regulatory, chief medical officer, chief executive officer, etc., or anyone who is taking responsibility for the IND.

    I hope this helps.



    ------------------------------
    Glen Park PharmD
    Executive Director, Regulatory Affairs and Quality Assurance
    New York NY
    United States
    ------------------------------



  • 3.  RE: FDA Form 1571

    Posted 27-Jan-2021 12:31

    Dear Glen,

     

    Thank you very much for your message and all the valuable information.

    For sure, this helps me a lot !! I really appreciate ...

     

    And thank you for your humor! Me who thought the RA were very strict :-)

     

    Bien cordialement / Best regards,

    Nathalie

     






  • 4.  RE: FDA Form 1571

    Posted 27-Jan-2021 12:28
    Bonjour, Nathalie - welcome to working on your first IND!

    Here are my thoughts on this. If you are still employed by the Sponsor (Sanofi?), it makes sense you are completing the 1571 form. It is the Sponsor's responsibility to do this. If my assumption is true, people there have done this before and I've been at their Paris headquarters in meetings with other regulatory leaders there who are experienced at this, perhaps from other divisions. Ask around. For almost all products heading towards initial clinical trials, it behooves you to prepare for and hold a pre-IND meeting with FDA to discuss the regulatory pathway(s) and requirements you may face to proceed with clinical studies. If not already done, this could take months to prepare. But here you are, ready to file your IND.

    First, FDA has an instruction page at INSTRUCTIONS FOR FILLING OUT FORM FDA 1571www.fda.gov › media › download. Also be sure you are using the newest 1571 form that you can upload directly from FDA at FORM FDA 1571www.fda.gov › media › download. The instructions will address every Field. But your questions are great and here is a quick reply:

    1) For the indication in Field 7, this is not "study phase" specific. Insert the medical indication that is the target (i.e., disease) of the therapeutic/vaccine product. This allows FDA to forward the application to the correct reviewing division. (You can have more than one indication for the same product/IND, but one is enough to start. If you expect your product will have diverse disease indications, it is likely multiple INDs will be needed eventually, as they might be handled separately by different reviewing divisions. These things you discuss with FDA once your first indication is established.) Saying "healthy volunteers" alone is not useful for this, even for a vaccine that will eventually be used in healthy individuals. There is a Field 7B on the current form to put your indication into a standardized SNOMED category.

    2) For Field 16, the name of person here need not be an MD. It could, for example, be the director or manager of the CRO doing the monitoring, or a person in a similar leadership role within the Sponsoring company who may or may not be an MD.

    3) For Field 17, this is expected to be someone with adequate medical training to evaluate safety issues and therefore an MD (or equivalent, like MBBS) is expected. It would be very hard to defend not naming a medically-qualified person (i.e., a licensed practitioner as we say in the U.S.) in this role. It should be someone very familiar with the disease indication (a medical specialist) as well as the class of product being evaluated.

    4) Who is taking on the responsibilities of the IND as the Sponsoring organization is to be listed at Field 18. For a commercial (Pharma) company Sponsor, the named person is usually dictated by the organization's legal or internal structure, typically someone at the Director or VP level related to Regulatory Affairs, or as FDA says, "the sponsor's authorizing representative." They are committing the company to legal obligations, so it must not taken on by anyone without proper authorization. It is fairly common for a Pharma Sponsor to hire a CRO or other entity and authorize them to take on some-or even all-of the obligations of an IND (see 21 CFR 312.52). This can include signing IND submission documents like the 1571 (see Field 15 instructions). But if that transfer of regulatory obligations (TORO) is to take place, it must first be designated in writing and signed by that Pharma corporate officer or "authorizing representative." A copy of that TORO authorization document, with the specifics of what elements of responsibility are being transferred, would be included in the IND submission, so the chain of responsibilities is clear to FDA. Some Sponsors (and CROs) have TORO checklists to clearly designate which specific responsibilities are being transferred in their agreements, though in the long run, the Pharma Sponsor still has ultimate legal responsibilities. If signing FDA forms and submissions is part of the TORO agreement for the CRO, that "authorized representative" can be named at Field 17 and sign the 1571 at Field 27. It is perhaps more common for Pharma Sponsors to transfer virtually all other IND responsibilities except the signing of the 1571 forms. Perhaps this is a way of making the Sponsor review the materials prepared for them by the CRO, thus at least appearing to exercise some of the oversight they should have over their contractors.

    Hope that helps! Bonne chance!

    Jan

    ------------------------------
    Jan S. Peterson, MS, CCRA, RAC, ASQ CBA, ACRP-CP
    Consultant
    United States
    ------------------------------