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  • 1.  re-labeling IMP

    This message was posted by a user wishing to remain anonymous
    Posted 07-Apr-2017 08:52
    This message was posted by a user wishing to remain anonymous

    A study vaccine needs to be re-labeled with a new re-test date (manufacturer decided to use re-test date on original label instead of expiry date). The manufacturer will conduct stability and potency tests to support the new re-test dates. Should this information be submitted a priori as an information amendment or can it be included in the next annual report. There is some debate among the regulatory folks.thanks


  • 2.  RE: re-labeling IMP

    Posted 09-Apr-2017 16:33
    All CMC changes require an information amendment to an IND prior to implementation, except maybe submitting stability data, which can be done in an IND AR.

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  • 3.  RE: re-labeling IMP

    Posted 10-Apr-2017 11:58
    Hey,
    In my experience, extension of the shelf-life can be submitted in annual reports, provided that a protocol defining the criteria for extension of the shelf-life has been previously submitted and approved by the agency. A reduction in shelf-life would need to be submitted as an amendment.

    Refer to FDA's "Guidance For Industry: INDs for Phase 2 and Phase 3 Studies" May 2003.
    Or the EMA guidance: "Guideline on the requriements for quality documents concerning biological investigational medicinal products in clinical trials"

    cheers,
    Catherine



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    Catherine Campbell PhD RAC
    Biomarin Pharmaceuticals
    Novato CA
    United States
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  • 4.  RE: re-labeling IMP

    Posted 12-Apr-2017 10:19
    I think he is referring to the investigational vaccine/drug not a marketed drug in which case an extension of expiry date is submitted in an AR provided your original approved application contains a stability protocol with this proposal. My response is pecific to the INDs not NDA/BLAs.

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