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  • 1.  IND safety report submissions for IMPs with multiple open INDs & sponsors

    This message was posted by a user wishing to remain anonymous
    Posted 10-Sep-2020 12:04
    This message was posted by a user wishing to remain anonymous

    How do you handle IND safety report submissions for IMPs with multiple open INDs?  Do you:
      1. Submit to the parent IND with a cross-reference to other open INDs in the safety report cover letter?
      2. Send the full safety report packet (Medwatch, form and cover letter) to the parent IND and only cover letter and form to other INDs? 
      3. Send the full safety report packet (Medwatch, form and cover letter) to all open INDs?
      4. Other?

     How do you handle IND submissions when there are multiple sponsor IMPs in the protocol? Do you:

      1. Submit to all of the open INDs for the IMP driving the reporting?
      2. Submit only to the IND of the IMP driving the reporting? Do you submit
      3. Submit only to the IND that the multiple IMP protocol was filed under?
      4. Other?

     Do you notify all investigators for all sponsor IMPs in the protocol? Do you notify only the investigators of the IMP driving the reporting?



  • 2.  RE: IND safety report submissions for IMPs with multiple open INDs & sponsors

    Posted 11-Sep-2020 08:13
    As I interpret your questions - 

    With one IMP and multiple INDs, regardless of whether is because of multiple dosage forms or indications, you would submit the Medwatch, form and cover letter to all open INDs under which the active ingredient is being investigated.

    With multiple IMPs and multiple sponsors, you would submit to the INDs of any IMP that was associated with the SUSAR under the protocol.

    Similarly, you would notify all investigators conducting a protocol with an IMP that was associated with the SUSAR.

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    Glen Park PharmD
    Executive Director, Regulatory Affairs and Quality Assurance
    Jersey City NJ
    United States
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  • 3.  RE: IND safety report submissions for IMPs with multiple open INDs & sponsors

    Posted 13-Sep-2020 17:26
    Same as Glen, in my experience, for question 1, we have submit the full safety report packet (Medwatch, form and cover letter) to all the INDs.


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    Aparna Donti Geddam
    AD, Regulatory Affairs
    Green Brook NJ
    United States
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  • 4.  RE: IND safety report submissions for IMPs with multiple open INDs & sponsors

    This message was posted by a user wishing to remain anonymous
    Posted 14-Sep-2020 08:46
    This message was posted by a user wishing to remain anonymous

    "How do you handle IND safety report submissions for IMPs with multiple open INDs?  Do you:
      1. Submit to the parent IND with a cross-reference to other open INDs in the safety report cover letter?
      2. Send the full safety report packet (Medwatch, form and cover letter) to the parent IND and only cover letter and form to other INDs? 
      3. Send the full safety report packet (Medwatch, form and cover letter) to all open INDs?
      4. Other?"
    As an example, If the safety incident happens with the parent IND STUDY (key point) with associated IMP, then the full submission goes to the parent IND and a cross reference to all other INDS are Okay. FDA has no problem with this.
    In other words the full package is submitted to the IND that is associated with that particular study in which the incident OCCURRED, and a cross reference should suffice to other INDs that are not associated with that safety incident. I can explain the scientific logic but its too long for this forum.


  • 5.  RE: IND safety report submissions for IMPs with multiple open INDs & sponsors

    Posted 14-Sep-2020 08:57
    Dear Anonymous,

    I would LOVE to read a long, explanatory SCIENTIFIC logic for a regulatory opinion about this question. It would, frankly, make my day. Please expound!!

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    Glen Park PharmD
    Executive Director, Regulatory Affairs and Quality Assurance
    New York NY
    United States
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  • 6.  RE: IND safety report submissions for IMPs with multiple open INDs & sponsors

    This message was posted by a user wishing to remain anonymous
    Posted 15-Sep-2020 17:06
    This message was posted by a user wishing to remain anonymous

    Here is a simple clue: The molecule/api and the dosage form used in that particular study plays an important role!!! Sorry, no free advice!!


  • 7.  RE: IND safety report submissions for IMPs with multiple open INDs & sponsors

    Posted 16-Sep-2020 07:50
    But, I thought that was we have this forum - FREE ADVICE!!  :-)

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    Glen Park PharmD
    Executive Director, Regulatory Affairs and Quality Assurance
    New York NY
    United States
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  • 8.  RE: IND safety report submissions for IMPs with multiple open INDs & sponsors

    Posted 16-Sep-2020 13:36
    I agree 100% with the anonymous! The other point that the anonymous is pointing out to is that the fact that there are multiple INDs for the same API, implies different dosage forms/indications exist and therefore the safety incident happens with one specific dosage form used in the associated clinical study should be primarily be relevant to that specific IND so the FDA is okay with submitting full package for that IND and just sending cc to other INDs using the same API. In my experience also, there is no problem with this approach with the FDA.

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    GRSAOnline
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