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Review of the Fialuridine (FIAU) Clinical Trials (1995)
Institute of Medicine (IOM)

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. "FDA-Proposed Changes to the Code of Federal Regulations." Review of the Fialuridine (FIAU) Clinical Trials. Washington, DC: The National Academies Press, 1995.

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Review of the Fialuridine (FIAU) Clinical Trials

REPORTS

Safety Reports
  • Periods for submission of written and telephone reports extended to 15 and 7 calendar days respectively; faxes acceptable in lieu of telephone reports.

  • Form 3500A (same as proposed form for postmarketing reports) allowed.

  • Disclaimer to apply to all safety information so as not to constitute a statement or admission of a causal link between drug and a subsequent adverse event.

Semiannual Reports
  • Current annual death and serious adverse experiences report to be supplemented by semiannual reports; semiannual report not to take place of annual report.

  • Report all deaths, serious adverse experiences, and study discontinuations due to adverse experiences, whether or not unexpected, and whether or not caused by the study drug.

  • Data required from IND studies, worldwide premarketing studies, and foreign postmarketing trials or reporting systems.

  • Data to be presented cumulatively as well as for a 6-month period.

  • Worst case analysis of data required—presumption against drug then attempt to refute presumption.

  • Submission of all available autopsy reports and medical reports of deaths required; sponsor to clarify inconsistencies between reports and cause of death reported to FDA by the sponsor.

  • FDA may modify reporting requirements, e.g., when it would interfere with a blinded (masked) study, in which neither patients nor study staff are aware of which patients are receiving control treatment until the end of the trial.

Special Safety Summary
  • Data on events not defined as serious adverse reactions.

  • Agency to determine when it is needed and the information required.

  • Should contain results of cumulative analyses in other reports as well as analyses of lesser events.

  • Generally, 30 days from request to comply.

Final Clinical Study Report
  • FDA may require a final report or study summary of a study at its discretion.

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Front Matter (R1-R10)
Executive Summary (1-15)
Introduction (16-19)
Clinical Trials (20-33)
Hepatitis B and Other Viral Diseases (34-41)
Clinical Trials of FIAC at Memorial Sloan-Kettering Cancer Center (42-50)
Oclassen Clinical Trial R89-001-01 (51-54)
Oclassen Clinical Trial R90-001-01 (NIH Protocol 91-AI-0031) (55-60)
Oclassen Clinical Trial R91-001-10 (NIH Protocol 91-DK-AI-213) (61-65)
Eli Lilly Trial H3X-MC-PPPA (66-69)
Eli Lilly Trial H3X-MC-PPPG (70-72)
Eli Lilly Trial H3X-MC-PPPC (NIH Protocol 93-DK-0031) (73-89)
Summary of Patient Interviews (90-92)
Overall Assessment of the Trials (93-97)
Recent Studies of FIAU Toxicity (98-103)
Review of the FDA Task Force Report 'Fialuridine: Hepatic and Pancreatic Toxicity' (104-120)
Review of 'Report to the Advisory Committee to the Director, National Institutes of Health' (121-132)
FDA-Proposed Changes to the Code of Federal Regulations (133-142)
Ancillary Issues Raised During the Period Following The H3X-MC-PPPC Trial (143-149)
Conclusions and Recommendations (150-154)
Appendix A: Chronology of FIAU/FIAC Clinical Trials (155-164)
Appendix B: Bibliography and References (165-177)
Appendix C: Agendas from the Three Committee Meetings (178-183)
Appendix D: Informed Consent Documents (184-243)
Appendix E: Example of Oclassen Fax Data Summaries (244-245)
Appendix F: FIAC and FIAU Preclinical Toxicity Studies (246-250)
Appendix G: Patient Summaries, Lilly Trial H3X-MC-PPPA (251-255)
Appendix H: Statistical Analysis of Mortality in the FIAU/FIAC Clinical Trials (256-265)
Glossary (266-269)