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Clinical Development-Strategic, Pre-Clinical, and Regulatory Issues PDF

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CLINICAL DEVELOPMENT Strategic, Pre-Clinical, Clinical, and Regulatory Issues Janice Steiner Boca Raton London New York CRC Press is an imprint of the Taylor & Francis Group, an informa business CRCPress Taylor & Francis Group 6000 Broken Sound Parkway NW, Suite 300 Boca Raton, FL 33487-2742 © 1997 by Taylor & Francis Group, LLC CRC Press is an imprint of Taylor & Francis Group, an Informa business No claim to original U.S. Govermnentw orks ISBN 13: 978-1-57491-028-5( hbk) This book contains informationo btained from authentic and highly regarded sources. Reasonable efforts have been made to publish reliable data and information, but the author and publisher cannot assume responsibility for the validity of all materials or the consequences of their use. The authors and publishers have attempted to trace the copyright holders of all material reproduced in this publication and apologize to copyright holders if permission to publish in this form has not been obtained. If any copyright material has not been acknowledgedp lease write and let us know so we may rectify in any future reprint. Except as permitted under U.S. Copyright Law, no part of this book may be reprinted, reproduced, transmitted, or utilized in any form by any electronic, mechanical, or other means, now known or hereafter invented, including photocopying, microfilming, and recording, or in any information storage or retrieval system, without written permission from the publishers. For permission to photocopy or use material electronically from this work, please access www. copyright.com (http://www.copyright.com/o) r contact the Copyright Clearance Center, Inc. (CCC), 222 Rosewood Drive, Danvers, MA 01923, 978-75 0-8400. CCC is a not-for-profito rganizationt hat provides licenses and registration for a variety of users. For organizationst hat have been granted a photocopy license by the CCC, a separate system of payment has been arranged. TrademarkN otice: Product or corporate names may be trademarks or registered trademarks, and are used only for identificationa nd explanationw ithout intent to infringe. Visit the Taylor& FrancisW eb site at http://w ww.taylorandfrancis.com andt he CRCP ress Web site at http://w ww.crcpress.com Library of Congress Card Number 96-41276 Library of Congress Cataloging-in-Publication Data Steiner, Janice, 1946- Clinical development: strategic, pre-clinical, clinical, and regulatory issues / Janice Steiner. p. cm. Includes bibliographical references and index. ISBN 1-57491-028-0 I. Drugs-Research-United States. 2. Pharmaceutical industry-United States. 3. Drugs-Law and legislation-United States. I. Title. [DNLM: I. Drug Approval-methods. QV 771 S822c 1997] RM301.25.S74 1997 615'. l 9'0973-dc20 DNLM/DLC 96-41276 Contents PREFACE ix CHAPTER 1. STRATEGY 1 What is a Development Plan? 1 Drivers and Goals 3 Purpose 5 The Elements of Strategy 6 Evaluating the Market 6 Strengths, Weaknesses, Opportunities, and Threats (SWOT) Analysis 9 Setting Direction 11 Assessing Risk 11 Identifying and Obtaining Resources 14 Setting Strategy 15 Defining Goals 15 Decision Points 16 Critical Path Analysis 17 Setting Priorities 18 iii iv Clinical Development What are the Criteria of Success 18 Musts, Nice to Have, and Unimportant 18 Timelines 20 Budgets 20 Where Are the Decision Points 21 Go/No Go Decision Points 21 Decisions Between Competing Projects 22 Summary 23 References 23 CHAPTER 2. THE MARKET 25 Market Definition and Competition 25 Economic Indicators 25 Pricing Considerations 26 Increasing the Value of a Product: Product Differentiation 28 Mass and Niche Markets 28 Indication and Demography 30 The Cost of Competition 32 Market Segmentation 33 Who Pays 34 Pharmacoeconomic Analyses 35 Price Competition 37 What Is the Intention of the Development? 38 Bringing a Product to Market 38 Differentiating Between Products in the Marketplace 39 Adding Value 40 Contents v Summary 41 References 41 CHAPTER 3. THE CLINICAL PLAN 43 How to Support the Market Without Going Overboard 45 The Outline of the Plan 46 Choice of Infrastructure—Make or Buy 48 Database Choices 50 What Are Valid Endpoints? 51 Clinical Endpoin ts 51 Surrogate Endpoints 54 Quality of Life 55 Economic Outcome Measures 56 Phase III 57 Phase II 58 Phase I 59 Summary 61 CHAPTER 4. THE PRECLINICAL PLAN 63 Pharmacology 63 Mechanisms ofA ction 65 Efficacy, Specificity, and Potency 66 Dose Finding 66 Understanding and Interpreting Pharmacological Data 67 Chemistry and Pharmacy 72 Drug Metabolism, Distribution, and Pharmacokinetics 74 vi Clinical Development Toxicology 85 Summary 87 CHAPTER 5. REGULATORY ISSUES 89 The Registration Approval Process 89 Which Authorities? 89 Choice of Routes to Clinical Trails in Europe 94 Insurance 97 Conformity with Good Practices 98 Differences Between the U.S. and Europe 98 Digital Submissions 100 Sources of Information: Guidelines, ICH, and Approval Documents 100 Significance of the Summary of Product Characteristics 103 Issues Associated with the Global Dossier 103 Setting a Regulatory Strategy 104 Taking Advantage of Intercountry Differences 106 How Not to Get Caught in Local Traps 107 Interacting Between the U.S. and Europe 114 Summary 116 References 116 CHAPTER 6. GOOD CLINICAL PRACTICE- INCORPORATING IT AND ITS MANAGEMENT INTO THE CLINICAL PLAN 117 Institutional Review Board/Ethics Committee 119 Investigator Requirements 122 Contents vii Sponsor Responsibilities 127 Clinical Trial Design 127 Quality Assurance and Quality Con trol 130 Investigational Site Management 132 Communications with the Regulatory Authorities 133 Allowing for the Practical Impact 134 How to Implement GCP 136 What to Do When Things Go Wrong 138 Harmonising Between the U.S. and Europe 140 Summary 141 CHAPTER 7. PROJECT MANAGING THE PLAN 143 What Is the Organisation 143 Centralised Versus Decentralised Structures 147 Start-Up and Virtual Organisations 150 Contracting In and Out 152 Planning and Management as a Function of Structure and Project 154 Matrix Versus Functional Management 156 Multidisciplinary Teams 158 What Are the Constraints? 159 Time 159 Money 161 Personnel 164 Material Supplies 166 Infrastructure 167 Management of Risk and Uncertainty 167 Setting a Project Management Strategy 171 viii Clinical Development CASE STUDY: MIRACULO CORPORATION 177 Preclinical Pharmacology 181 The Project Team 184 The Project Starts 186 The First Real Project Team Meeting 188 Development Begins in Earnest 190 Dose Response Curves 194 Testing for Safety 196 The Clinical Development Plan 198 Revising the Plan 200 Presenting the Plan to Management 206 Evaluating the Safety Data 208 The Entiy to Clinic 212 Getting into Phase II 216 Phase II 220 Phase III 222 Choosing Trial Locations 224 The Final Outcome 226 Index 227 Preface This book is intended for all those who are approaching clinical development, not from a position of total ignorance, but from a desire to understand how the whole is derived from the parts. More importantly, it is for those who would want to consider how to plan and implement drug development programmes that produce coherent commercial products without making fundamental mistakes. I have spent years working in clinical development groups in both large and small companies, teaching junior members of the pharmaceutical industry about the objectives and implementation of clinical development and ex- amining physicians for their qualifying examinations in pharmaceutical medicine. My experience repeatedly has taught me that many individuals, even at quite senior level, fail to understand the overall purpose and interrelationships of what they are doing. This frequently happens because they are cut off from the larger corporation or because they have been inadequately trained. Clearly, they would be in a position to do a better job and to gain more job satisfaction if they were able to understand properly the requirements, problems, and achievements of disciplines other than their own. As the pharmaceutical industry approaches the millennium, as demands for ever greater research and development productivity become the norm, and as the timelines to the marketplace become progressively shortened, this overall understanding of the process will become more vital to all involved. This will apply as much to large corporations as to small concerns. Indeed, one of the phenomena of the last 20 years has been the rise of a new start up pharmaceutical industry, populated often by those who are unfamiliar with the procedures and pitfalls inherent in their activities. ix

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