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Guidance for Industry Information Program on Clinical Trials for Serious or Life-Threatening Diseases and Conditions U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) Center for Biologics Evaluation and Research (CBER) March 2002 Procedural Guidance for Industry Information Program on Clinical Trials for Serious or Life-Threatening Diseases and Conditions Additional copies are available from: Office of Training and Communication Division of Drug Information, HFD-240 Center for Drug Evaluation and Research Food and Drug Administration 5600 Fishers Lane Rockville, MD 20857 (Tel) 301-827-4573 http://www.fda.gov/cder/guidance/index.htm or Office of Communication, Training and Manufacturers Assistance, HFM-40 Center for Biologics Evaluation and Research Food and Drug Administration 1401 Rockville Pike, Rockville, MD 20852-1448 http://www.fda.gov/cber/guidelines.htm. Fax: 1-888-CBERFAX or 301-827-3844 (Tel) Voice Information System at 800-835-4709 or 301-827-1800 U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) Center for Biologics Evaluation and Research (CBER) March 2002 Procedural TABLE OF CONTENTS I. INTRODUCTION................................................................................................................. 1 II. BACKGROUND ................................................................................................................... 1 III. STATUTORY REQUIREMENTS FOR IND SPONSORS .............................................. 2 A. What information must I submit to the Clinical Trials Data Bank?......................................2 B. When should I begin submitting clinical trial information? ..................................................4 C. Can I submit my information at specified intervals rather than on a rolling basis? ..............4 D. What is a trial for a serious or life-threatening disease or condition?....................................4 E. What is a trial to test effectiveness?.......................................................................................5 F. Which trials must be included in the clinical trials data bank? .............................................5 G. Must I include information about foreign trial sites? ............................................................6 IV. IMPLEMENTATION ISSUES............................................................................................ 6 A. How do I submit information to the Clinical Trials Data Bank? ...........................................6 B. What information about trial sites must be included?...........................................................6 C. How long does it take for information to be made available on ClinicalTrials.gov? ...............7 D. How long do studies remain on ClinicalTrials.gov? ...............................................................7 E. Can information be transferred from a sponsor computer to the PRS? ................................7 F. Can intermediaries acting on behalf of a sponsor submit data? ............................................7 G. Can sponsors designate multiple individuals to be data providers?.......................................7 H. What happens to the information submitted to the Clinical Trials Data Bank? ....................7 I. Can I submit other information to the Clinical Trials Data Bank?........................................7 J. Should I continue submitting information to the ACTIS and PDQ databases? .....................8 K. Are there exemptions for submitting Clinical Trials Information? .......................................8 L. Is Institutional Review Board preapproval of the protocol listing required?.........................8 M. Will FDA monitor compliance?.............................................................................................9 1 Guidance for Industry1 Information Program on Clinical Trials for Serious or Life- Threatening Diseases and Conditions This guidance represents the Food and Drug Administration's (FDA's) current thinking on this topic. It does not create or confer any rights for or on any person and does not operate to bind FDA or the public. An alternative approach may be used if such approach satisfies the requirements of the applicable statutes and regulations. I. INTRODUCTION This guidance is intended to assist sponsors who will be submitting information to the Clinical Trials Data Bank. The data bank was established as required under section 113 of the Food and Drug Administration Modernization Act of 1997 (Modernization Act). This guidance combines the statutory and procedural issues discussed in two previously published draft guidances on this topic. It was finalized after considering comments received on the two draft guidances. II. BACKGROUND Section 113 of the Modernization Act creates a public resource for information on studies of drugs, including biological drug products, to treat serious or life-threatening diseases and conditions conducted under FDA's investigational new drug (IND) regulations (21 CFR part 312). Section 113 of the Modernization Act, enacted November 21, 1997, amends section 402 of the Public Health Service Act (42 U.S.C. 282). It directs the Secretary of Health and Human Services, acting through the Director of NIH, to establish, maintain, and operate a data bank of information on clinical trials for drugs to treat serious or life-threatening diseases and conditions. The Clinical Trials Data Bank is intended to be a central resource, providing current information on clinical trials to individuals with serious or life-threatening diseases or conditions, to other members of the public, and to health care providers and researchers. Specifically, section 113 of the Modernization Act requires that the Clinical Trials Data Bank contain (1) information about Federally and privately funded clinical trials for experimental treatments (drug and biological 1 This guidance has been prepared by the Implementation Team for section 113 of the Food and Drug Administration Modernization Act of 1997, including individuals from the Office of the Commissioner, the Center for Drug Evaluation and Research (CDER), the Center for Biologics Evaluation and Research (CBER), and the Center for Devices and Radiological Health (CDRH), at the Food and Drug Administration. 2 products) for patients with serious or life-threatening diseases or conditions, (2) a description of the purpose of each experimental drug, (3) patient eligibility criteria, (4) a description of the location of clinical trial sites, and (5) a point of contact for patients wanting to enroll in the trial. Section 113 of the Modernization Act requires that information provided through the Clinical Trials Data Bank be in a form that can be readily understood by the public. 42 U.S.C. 282(j)(3)(A). The National Institutes of Health (NIH), through its National Library of Medicine (NLM) and with input from the FDA and others, developed the Clinical Trials Data Bank. The first version of the Clinical Trials Data Bank was made available to the public on February 29, 2000, on the Internet.2 At that time, the data bank included primarily NIH-sponsored trials. On March 29, 2000, FDA made available in the Federal Register a draft guidance entitled Information Program on Clinical Trials for Serious or Life-Threatening Diseases: Establishment of a Data Bank.3 The draft guidance provided recommendations for industry on the submission of protocol information to the Clinical Trials Data Bank. It included information about the types of clinical trials for which submissions are required under section 113 of the Modernization Act, as well as the content of those submissions. FDA made available a second draft guidance entitled Information Program on Clinical Trials for Serious or Life-Threatening Diseases: Implementation Plan, in the Federal Register on July 9, 2001.4 The second draft guidance addressed procedural issues, including how to submit required and voluntary protocol information to the Clinical Trials Data Bank, as well as issues related to submitting certification to the Secretary that disclosure of information for a particular protocol would substantially interfere with the timely enrollment of subjects in the clinical investigation. The second draft guidance also proposed a time frame for submitting the information. This final guidance combines the two draft guidances into a single guidance. III. REQUIREMENTS UNDER SECTION 113 OF THE MODERNIZATION ACT FOR IND SPONSORS A. What information must I submit to the Clinical Trials Data Bank? Section 113 of the Modernization Act requires you to submit information to the data bank about a clinical trial conducted under an investigational new drug (IND) application if it is for a drug to treat a serious or life-threatening disease or condition and it is a trial to test effectiveness (42 U.S.C. 282(j)(3)(A)). If you wish, you can also provide information on non-effectiveness trials or for drugs to treat conditions not considered serious or life-threatening. Section 113 of the Modernization Act requires that you submit a description of the purpose of each experimental drug, patient eligibility criteria for participation in the trial, a description of the location of clinical trial sites, and a point of contact for those wanting to enroll in the trial. 2 See http://clinicaltrials.gov 3 See 65 FR 16620 and http://www.fda.gov/cder/guidance/3585dft.htm 4 See 66 FR 35798 and http://www.fda.gov/cder/guidance/4602dft.htm 3 Section 113 requires that the data bank provide this information in a form that can be readily understood by members of the public (42 U.S.C. 282(j)(3)(A)). To ensure that information available through the Clinical Trial Data Bank is in a form that is readily understood, we have established four data elements, which are listed below. The data elements are made up of the following data fields: (1) descriptive information, (2) recruitment information, (3) location and contact information, and (4) administrative data. We have established the Protocol Registration System (PRS), a Web-based data processing program, to facilitate collection of this information for the data bank. The four data elements, which are listed below, as well as definitions applicable to the PRS, can be viewed at http://prsinfo.clinicaltrials.gov/. 1. Descriptive Information Brief Title (in lay language) Brief Summary (in lay language) Study Design/Study Phase/Study Type Condition or Disease Intervention 2. Recruitment Information Study Status Information including · Overall Study Status (e.g., recruiting, no longer recruiting) · Individual Site Status Eligibility Criteria/Gender/Age 3. Location and Contact Information Location of Trial Contact information (includes an option to list a central contact person for all trial sites) 4. Administrative Data Unique Protocol ID Number Study Sponsor Verification date To verify the existence of an IND and to assist in administrative tracking, we ask that you also include in your submission the IND number and serial number and designate whether the IND is located in the Center for Drug Evaluation and Research (CDER) or the Center for Biologics Evaluation and Research (CBER). This administrative information is in a separate data field and will not be made public. 4 B. When should I begin submitting clinical trial information? Section 113 of the Modernization Act requires that sponsors submit information no later than 21 days after the trial is opened for enrollment5 (42 U.S.C. 282(j)(3)). Section 113 does not specify when sponsors must submit information about clinical trials that are existing and ongoing. To provide a transitional period for sponsors of clinical trials that are currently ongoing and expected to continue enrolling patients for more than 45 days, we ask that you submit information within 45 days after this guidance is made available through the Federal Register. We encourage you to submit information through the PRS for inclusion in the data bank as soon as possible.6 C. Can I submit my information at specified intervals rather than on a rolling basis? As discussed above, you must submit information about new protocols open for enrollment within 21 days after the trial is open for enrollment (42 U.S.C. 282(j)(3)), and we request that you submit information about existing ongoing trials within 45 days after this guidance is published. Supplemental information can be submitted at 30-day intervals. Such information includes amendments to the protocol with respect to one of the data elements, or interruptions, continuations, or completion of enrollment for a study. Protocol changes related to eligibility or status information, such as routine opening and closing of trial sites, can be made at 30-day intervals. FDA strongly encourages you to update information about trials that are unexpectedly closed (e.g., clinical hold) within 10 days after the closing or sooner if possible. To ensure that the information available through the data bank is timely and accurate, FDA also encourages you to review, verify, and update all active protocol records on a semi-annual basis, at a minimum. D. What is a trial for a serious or life-threatening disease or condition? FDA has defined serious and life-threatening diseases and conditions in previous documents. Most recently, FDA discussed issues related to products intended to treat serious or life- threatening diseases and conditions in the guidance for industry on Fast Track Drug Development Programs — Designation, Development, and Application Review (November 1998).7 In that guidance, we stated that all conditions meeting the definition of life-threatening, as set forth at 21 CFR 312.81(a), would also be serious conditions. The term life-threatening is defined as (1) diseases or conditions where the likelihood of death is high unless the course of the disease is interrupted and (2) diseases or conditions with potentially fatal outcomes, where the endpoint of clinical trial analysis is survival (21 CFR 312.81(a)). All references in this document to serious diseases or conditions include life-threatening diseases and conditions. 5 Section 113 says "not later than 21 days after the approval of the protocol." Because the Agency does not approve protocols, we have interpreted this to mean within 21 days after the trial is open for enrollment. 6 See http://prsinfo.clinicaltrials.gov 7 CDER guidances are available at http://www.fda.gov/cder/guidance/index.htm 5 As FDA reiterated in the Fast Track Guidance, the seriousness of a disease is a matter of judgment, but generally is based on such factors as survival, day-to-day functioning, and the likelihood that the disease, if left untreated, will progress from a less severe condition to a more serious one. For example, acquired immunodeficiency syndrome (AIDS), all other stages of human immunodeficiency virus (HIV) infection, Alzheimer's disease, angina pectoris, heart failure, cancer, and many other diseases are clearly serious in their full manifestations. Furthermore, many chronic illnesses that are generally well managed by available therapy can have serious outcomes. For example, inflammatory bowel disease, asthma, rheumatoid arthritis, diabetes mellitus, systemic lupus erythematosus, depression, psychoses, and many other diseases can be serious in some or all of their phases or for certain populations. Any investigational drug that has received fast track designation would be considered a drug to treat a serious disease or condition.8 Information on effectiveness trials for drugs that have received fast track designation would qualify for submission to the Clinical Trials Data Bank. E. What is a trial to test effectiveness? Not all trials carried out under 21 CFR part 312 are trials to test effectiveness. FDA considers all phase 2, phase 3, and phase 4 trials with efficacy endpoints as trials to test effectiveness.9 F. Which trials are provided to the public through the Clinical Trials Data Bank? Section 113 of the Modernization Act requires sponsors to submit information about clinical trials of experimental treatments for serious diseases and conditions when conducted under the IND regulations. 42 U.S.C. 282(j)(3)(A). Such information can be submitted at any time with the consent of the protocol sponsor, and must be submitted within 21 days after a trial to test effectiveness begins. In addition, section 113 of the Modernization Act states that information on all treatment IND protocols and all Group C protocols10 must be included in the Clinical Trials Data Bank. Although it is not specifically discussed in section 113 of the Modernization Act, there are situations in which there may be a significant number of patients with the disease or condition for which the drug is being developed who are not adequately treated by existing therapy, who 8 That a drug is intended to treat a serious or life-threatening disease or condition, however, does not mean that it fills an unmet medical need and qualifies for fast track designation under section 506 of the Food Drug and CosmeticAct (21 U.S.C. 356). 9 Listing a trial in the Clinical Trials Data Bank is not a guarantee that the trial design is considered adequate to support approval of a drug, nor does it reflect any judgment on the conduct, analysis, or outcome of the study. 10 "Group C protocols" refers to investigational drugs designated by FDA for the treatment of specific cancers. These drugs have reproducible efficacy in one or more specific tumor types. Such a drug has altered or is likely to alter the pattern of treatment of disease and can be safely administered by properly trained physicians without specialized supportive care facilities. See National Cancer Institute Handbook for Investigators, Appendix XV, "Policy for Group C Drug Distribution," http://ctep.info.nih.gov/HandbookText/Appendix_XV.htm#Proc_Mgmt_GrpC_Prot. 6 do not meet the eligibility criteria for enrollment, or who are otherwise unable to participate in a controlled clinical study. In these situations, sponsors may have initiated one or more expanded access protocols that include such patients. In such cases, FDA strongly recommends that sponsors also consider submitting information to the Clinical Trials Data Bank about the availability of any expanded access protocol for treatment use in addition to required submissions. For protocols not specifically mentioned above, sponsors should review each protocol submitted to an IND to determine if the protocol is for a serious disease or condition and if it is a trial to test effectiveness. If the protocol meets these criteria, the sponsor must submit information about the trial to the Clinical Trials Data Bank, unless the sponsor provides detailed certification to FDA that such a disclosure would substantially interfere with the timely enrollment of subjects in the investigation (42 U.S.C. 282(j)(3) and (j)(4)). Sponsors with questions on whether protocols meet the criteria for submission to the Clinical Trials Data Bank are encouraged to contact the appropriate review division for additional guidance. G. Must I include information about foreign trial sites? Yes, you must include information about foreign trials when those trials are conducted under an IND submitted to FDA and the trial meets the criteria for submission to the Clinical Trials Data Bank. Section 113 of the Modernization Act requires sponsors to submit informat