Regulatory Flexibilities and Clarifications: Chemistry, Manufacturing and Control (CMC) Information for Original First in Human (FIH) Phase 1 INDs

CMC Information Generally Not Needed at the Time of FIH Phase 1 IND (For DS and DP): Risk assessments for elemental impurities and nitrosamine impurities are not expected.

cder-regulated_small_molecule_drug_products_cmc_ind_table (1).pdf (172.8 KB)

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I found the context of this document. It is linked from the page titled IND Applications for Clinical Investigations: Chemistry, Manufacturing, and Control (CMC) Information.”

FDA provides regulatory flexibility to support bringing innovative treatments to patients as quickly as possible. By focusing on minimum requirements to ensure phase-appropriate CMC information is provided, FDA estimates that sponsors of FIH Phase 1 INDs can reduce application development time by up to 12 months.

https://www.fda.gov/media/193163/download?attachment

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Interesting. I’ve been a part of multiple debates on this. I would say that best practice would be to at least identify your vulnerable amines so you’re not surprised later & can build scavengers into the plan early, if the need is likely.

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