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ANOTHER WAY TO GET A LIFE SAVING DRUG
Drug Access and Emergency IND's
(C) April 1994. All Rights Reserved.
Eugene P. Schonfeld, Ph.D.
President and Chief Executive Officer
National Kidney Cancer Association
1234 Sherman Avenue
Evanston, Illinois 60202
708-332-1051
The Food and Drug Administration (FDA) is charged with regulating food,
therapeutics (pharmaceuticals and biologics), vaccines, diagnostic kits, blood
supplies, and medical devices. Access to new drugs and therapies is controlled
by the FDA through clinical trials leading to formal marketing approval.
For several years, patients with life threatening diseases have pushed the U.S.
Food and Drug Administration to provide greater access to new treatments. The
National Kidney Cancer Association has been a strong advocate of expedited FDA
procedures for new cancer treatments and easier patient access to new
therapies.
During the last half of 1993, the FDA started to respond to the needs of cancer
patients. It created two new full time staff positions in the Office of AIDS
and Special Health Issues. These positions were filled by Patty Delaney and
Ellen Cutler, well qualified FDA employees with prior experience in oncology
and public communications. Their assignment is to provide better liaison
between the FDA and cancer organizations as well as patients, and to coordinate
cancer related activities with the FDA and Public Health Service agencies.
Approved Drugs and Clinical Trials
Typically, cancer patients are treated with approved therapies or with an
Investigational New Drug through a clinical trial. In kidney cancer,
interleukin-2 is the only FDA approved treatment for advanced metastatic
disease. It is marketed by Chiron Corporation under the tradename Proleukin.
Some kidney cancer patients are also treated with drugs which are FDA approved
for diseases other than kidney cancer. The most common drug of this type is
interferon-alpha which is made by several companies, most notably Schering
under the tradename Intron-A.
Many patients are also treated with Investigational New Drugs and therapies
through clinical trials. It is not uncommon to see kidney cancer patients in
trials treated with IL-4, IL-6, gamma interferon, GM-CSF, and other agents.
Before these products enter human clinical trials, they have been researched
with laboratory tests and in animals. They have not yet been approved by the
FDA for general marketing, however, they have demonstrated enough efficacy and
safety to justify warrant use in clinical trials.
Emergency IND's
Patients who are not eligible for clinical trials may be eligible to receive
drugs and therapies which are not yet FDA approved by having their doctor apply
to the FDA for an Emergency IND (Investigational New Drug). Many patients and
physicians may not be familiar with the process of applying for an Emergency
IND. But it really is quite simple and may be extremely useful in the care of
patients.
Who?
An Emergency IND starts with a single patient and a single doctor. The doctor
makes a request to the FDA for an Emergency IND and proposes a course of
treatment. If the Emergency IND is granted, it authorizes the doctor to treat
the patient with a drug or therapy which is not yet FDA approved. In the case
of a cancer drug or therapy, the physician can contact Ellen Cutler at the FDA
by calling 301-443-0104. The physician will be directed to the appropriate
division within the FDA where the request for an Emergency IND will be
reviewed.
When?
Seeking an Emergency IND is especially appropriate under the following
circumstances: (1) when the patient is no longer responding to approved
therapies and no other adequate treatment is available; (2) when a patient is
not eligible for a clinical trial but would be an appropriate candidate for
treatment with a drug that is being tested in a clinical trial; (3) when the
most appropriate drug or therapy for the patient is not currently available
through a clinical trial (i.e. a drug that was tested in a clinical trial but
is no longer available); and (4) when a promising drug has been through pre-
clinical testing but has not yet entered into human clinical trials.
One or more of these conditions may indicate that it is appropriate to seek an
Emergency IND for a patient. In making a request, it is always important (1)
to state those conditions which support the request and (2) to submit
information which supports the proposed course of treatment. For example, a
doctor can submit a medical journal article on the drug and protocol. For a
drug or therapy not yet tested clinically, a doctor must submit pre-clinical
animal research data, toxicity data and manufacturing information assuring the
identity, quality, purity, and strength of the drug (e.g. a certificate of
analysis).
What is Submitted?
The physician needs to submit information to the FDA review division so the
agency can make an informed decision and assess the appropriateness of the
request. This information includes:
(1) The name of the drug and the indication for which it is being sought. A
statement regarding the supplier of the drug (source of the drug, such as the
drug company which makes it or the NCI which distributes it.)
(2) The medical history of the patient for which the drug or therapy is
intended. This history should include information on any prior therapy and
response, and the rationale for the proposed treatment. The rationale may be
strengthened by including any research information on the patient's tumor, such
as results of an in vitro drug test with the proposed agent on the patient's
tumor.
(3) The protocol detailing the proposed treatment plan (dose, route of
administration, and duration). The doctor should also include procedures for
monitoring the patient and planned modifications in the event of intolerable
toxicity or unforeseen side effects.
(4) A statement that informed consent will be obtained prior to initiating
treatment. The application should include a copy of the consent form which has
been drafted for the patient's signature, or signed by the patient.
(5) A statement of the physician's qualifications as an investigator should be
included. A copy of his or her curriculum vita is sufficient.
(6) If the physician has obtained approval of the IRB (Institutional Review
Board) at his institution, a statement to that effect should be included with
the application. At the very least, a statement should be included that the
IRB will be advised of the treatment within five days.
The completed application for an Emergency IND can be FAXed to the appropriate
FDA division.
FDA Response
The FDA recognizes that a request for an Emergency IND is urgent and the agency
will try to respond as quickly as possible. Typical response time is 24 to 48
hours, and same day approvals are not uncommon, particularly when the request
is well documented and complete.
If the FDA approves the application, response is made by letter acknowledging
the issuance of the IND number with instructions on how to complete the
process. Someone from the FDA will call the physician directly and will
verbally provide the IND number.
Physician Response
The physician then calls the supplier of the drug or therapy, provides the IND
number, and the drug is shipped, usually by express shipping service. The
physician then treats the patient according to his plan.
As part of the process, upon receipt of the FDA letter, the physician is
required to fill out FDA Form 1571 and provide a complete copy of the original
correspondence. When treatment is completed, the physician should submit the
results of treatment to the FDA and request withdrawal of the IND.
In some cases, when treatment is extended, the physician is required to submit
an annual report on the patient's progress. Some suppliers also request a
follow up report in return for providing the drug.
Regulatory Restraints
Clinical investigators' responsibilities when using investigational drugs are
well defined by FDA regulations (21 CFR Part 312), including: (1) use of the
drug or therapy only in accordance with the treatment plan submitted; (2) use
of the drug or therapy only in the named patient under the doctor's personal
supervision or under the supervision of other investigators who are responsible
to him or her; (3) assurance that an IRB reviews or approves the study; and (4)
obtaining proper informed consent from the patient or from his or her legal
representative.
Under the regulations, the physician is precluded from: (1) giving the drug to
another physician not responsible to him or her, (2) giving the drug to
patients other than the one named in the application, and (3) giving the drug
to a physician in another institution for use on his or her patients.
Limitations
The Emergency IND is a very special application because its relates to an
individual patient who is confronting an immediate medical crisis. Hopefully,
treatment under the Emergency IND will be successful.
However, even if the IND is granted and treatment proves successful, the
company producing the drug or therapy may not find the results useful. When a
physician provides a new drug or therapy in an emergency situation, the
protocol may be tailored to the specific patient. It may not be applicable to
the overall population of patients with the same disease.
Other Benefits
When used appropriately, the Emergency IND can benefit patients and advance the
development of new drugs and therapies, particularly if information from the
Emergency IND makes its way into the scientific community as well as back to
companies and the FDA.
Patients, physicians, researchers, companies, and the FDA itself should give
careful consideration to using Emergency IND's. These applications are useful
tools which can help individual patients and provide insights which help all
patients.
Get In Touch
For more information, contact: Ellen Cutler, Food and Drug Administration HF-
12, Parklawn Building Room 12A40, 5600 Fishers Lane, Rockville, MD 20857, 301-
443-0104, FAX 301-594-6807.