FDA Issues New PDF Specifications

 

In the chaos of the holidays, you might have missed the release of an important new guidance from FDA.  On 20 December 2011, FDA issued version 3 of “FDA Portable Document Format (PDF) Specifications,” fulfilling a promise made at the recent DIA Electronic Submission conference to release the document by year’s end.  This new version is a welcome update to a guidance that was last revised in June 2008.

Some highlights of the guidance include:

  • FDA will now accept documents in PDF Version 1.7 (PDF Version 1.4 remains the minimum version required).  As GlobalSubmit’s Rahul Mistry recently reported, the ICH specification will also soon be updated to allow PDF Version 1.7 as well.
  • All fonts should be embedded in PDF documents to ensure that documents are readable by FDA reviewers.  As an extra measure to ensure readability, the guidance also includes a list of standard fonts that FDA recommends you stick to when creating documents.
  • Documents should be set up to print on 8.5 by 11 inch paper; however, there is an exception for oversize documents such as CAD drawings or promotional materials.  These documents should be provided in their actual page size.
  • The guidance provides information on image compression and optimization settings to minimize PDF file sizes. Continue reading
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Fifth China Medicinal Biotech Forum – Conference Recap

I recently returned from the Fifth China Medicinal Biotech Forum held in Beijing, China from 07-09 November 2011.  The purpose of this conference was to update graduate students in China on the latest trends in biotechnology.  This forum also allowed scientists from Europe, Australia, Japan, US, and South America to collaborate with Chinese colleagues at the Chinese CDC and at universities and research institutions in Beijing, Shanghai and other areas in China.  Some of the visiting scientists were also looking for funding for their research programs and some Chinese universities were looking to fill research professorships.  Over lunches and dinners, scientific collaborations were being discussed and many scientists were staying after the conference to tour the laboratories of the universities, companies, and research institutes in Beijing.

At the Key Note event of this conference, senior Chinese government officials declared that China was focusing on biologics in a big way.  The Chinese government has noted that half of the top 10 blockbuster drugs sold in the US last year were biologics – either recombinant proteins or monoclonal antibodies.  For the next few years, these government officials declared that there will be a big push from the government in funding Chinese companies to bring biosimilars to market.  Whether it is to market these biosimilars in China or around thew world is unclear.

I gave a talk on the topic of “Initiating a Gene Therapy Clinical Trial in the US.”  This talk outlined the recent history of gene therapy and the extra regulatory requirements for gene therapy clinical trials as compared to small molecule or monoclonal antibody investigational drugs.  These extra requirements are the submissions to the Recombinant DNA Advisory Committee of the NIH and the Institutional Biosafety Committee at the clinical site.

In addition to this talk, there were other gene therapy talks.  In particular, there was one talk about a Phase IA clinical trial in the US sponsored by Marina Biotech for the treatment for Familial Adenomatous Polyposis (FAP).  This gene therapy is first-in-class; it is the bacterial delivery of shRNA that is intended to reduce the amount of intracellular Beta-catenin; the Beta-catenin gene is known to be dysregulated in classical FAP.   The bacteria in this gene therapy is live E. Coli and will be orally administered for 28 days.  The primary objective of this study is to establish general safety and to determine the Maximum Tolerated Dose.

Of note in this conference, Dr. Fernandes of Ludger Ltd in the UK described how Genzyme ran into manufacturing problems when scaling up its Pompe Disease drug, alglucosidase alfa (Lumizyme) .  FDA requested more information after its first review of the marketing application for Lumizyme because during the scale-up, the glycosylation pattern of the recombinant protein had changed.  This change was the alteration of a key sugar residue.  Therefore it pays to look closely at the glycosylation patterns of the recombinant protein or monoclonal antibody early in development and find the critical sugar residues and make sure it is maintained during scale-up.  Putting careful thought up front before generating the Master Cell Bank for the cell line producing the recombinant protein will eventually increase both safety and efficacy – safety in terms of reduced immunogenicity and efficacy by generating the required pharmacological effect at a lower dose.

This is a post by Will Lee, Ph.D. Will is the Director, Regulatory Affairs at Cato Research.

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Free Webinar – Optimal Clinical Study Designs and International Regulatory Strategies

Update: the slides are available here (pdf)

In today’s competitive climate, it is essential to optimize clinical trials during early development to best predict success in pivotal trials and position clinical outcomes for licensing and marketing.  Please join us at a joint webinar between the Netherlands Centre for Human Drug Development (CHDR) and Cato Research that addresses current challenges and provides clinical and regulatory strategies to the most expeditious and cost-effective path towards clinical proof of concept and approval.  The webinar will be held on Tuesday, 15 November 2011 from 1:00 to 2:00 PM ET.

Featured topics include:

  • Novel Phase 1 and 2 clinical study designs
  • Selection and optimal use of biomarkers, pharmacodynamic parameters, and PK analysis
  • Parallel FDA and EMA development pathways
  • Regulatory requirements and timelines in Europe
  • Conduct of foreign clinical studies under U.S. INDs

Our experts for the webinar are:

  • Professor Adam Cohen, CEO of CHDR
  • Dr. Kimberley Cummings, Senior Director, Regulatory Affairs at Cato Research.

Please visit the registration page to sign up for this webinar. Continue reading

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Project Management for Biotech Companies

In today’s fast paced, high pressure world of drug development there are multiple factors that can and do affect marketing success.  Large organizations understand the value that project management can contribute to a successful project.  The smaller companies tend to lag behind and often do not recognize that project management is not too complex or does not cost too much to fit into their smaller culture.  Project Management should not be considered as only a box of tools but a mindset on how to approach management of a project.  A small company can get huge payback just by incorporating basic project management into their processes.  Simple processes such as developing a project scope, identifying risks, and setting common goals for the project team performance can lead to benefits by shortening timelines, eliminating costly mistakes, and ensuring project success.  A cooperative alliance between a biotech company and a contract research organization (CRO), such as Cato Research, can help bridge any gap that may exist in the company’s experience level and ensure clear communication among all the team members through experienced project management.  Understanding the differences in the team’s work environments will lead to better communication and improve the overall performance. Continue reading

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Pre-IND Submissions in eCTD Format

Historically, we made our Pre-IND submissions in paper (e.g., Pre-IND meeting request, briefing package, and meeting minutes) and we began using eCTD format with the initial IND submission.  However, since FDA assigns a Pre-IND number, which ultimately becomes the IND number, and Module 1 includes at least two places that are appropriate for including Pre-IND documents (either Module 1.12.1 or Module 1.6 for meeting-related documents), we should be able to make these submissions in eCTD format as well.  Doing so would allow us to ease into the use of eCTD format, which would be especially useful when working with sponsors who are new to the eCTD format.

So, I recently asked the CDER Electronic Submissions team if it is possible to make Pre-IND submissions in eCTD format.  As usual, I received a quick and helpful reply to my query, this time from Regulatory Information Specialist Valerie Gooding.  Continue reading

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