Applying to conduct a clinical trial: Applications requiring expert advice

Introduction
For certain trials, we will seek advice from an Expert Advisory Group (EAG)/ the Commission on Human Medicines (CHM) before approval for the trial can be given. Sponsors are requested to make contact with the MHRA before making the clinical trial authorisation (CTA) application for such trials and to make available a data package which will allow that advice to be obtained. The normal CTA application timeline will follow receipt of a valid application.

Sponsors of all first-in-human (FIH) trials should take account of the CHM Guideline on Strategies to Identify and Mitigate Risks for First-in-Human Clinical Trials with Investigational Medicinal Products (external link). For those planning a FIH clinical trial, sponsors and investigators should identify the factors of risk and apply risk mitigation strategies accordingly as laid down in that guideline.

Scope
The decision to refer applications for expert advice will be based on the assessment of risk factors and the proposed mitigation strategy. Areas for consideration when determining risk factors include mode of action, nature of the target and the relevance of animal species and models.

Here are some examples of trials where expert advice may be sought to include first-in-human trials with novel compounds:

• where the mode of action involves a target that is connected to multiple signalling pathways (target with pleiotropic effects), eg leading to various physiological effects or targets that are ubiquitously expressed
• acting (directly or indirectly) via a cascade system where there may be an amplification effect which might not be sufficiently controlled by a physiological feedback mechanism
• acting (directly or indirectly) via the immune system with a target or mechanism of action which is novel or currently not well characterised
• where there is novelty in the structure of the active substance eg a new type of engineered structural format such as those with enhanced receptor interaction as compared with the parent compound
• where the level of expression and biological function of the target receptor may differ between healthy individuals and patients with the relevant disease
• where there is insufficient available knowledge of the structure, tissue distribution, cell specificity, disease specificity, regulation, level of expression and biological function of the human target, including down-stream effects
• acting via a possible or likely species specific mechanism or where animal data are unlikely to be predictive of activity in humans.

In addition, the MHRA may refer other applications if particular issues are identified during the assessment process.

Process

• Sponsors should decide, based on the scope criteria above, whether their application comes within this category. Sponsors who wish to, may seek pre-submission advice on whether or not the compound in question comes within the category of ‘higher risk’
• when advice is sought, a summary of the nature of the compound, its target/mechanism of action and the relevance of the animal model(s) should be submitted on disk directly to:

Clinical Trials Unit
3.T
MHRA
151 Buckingham Palace Road
Victoria
SW1W 9SZ

• an email should be sent to the clinical trials helpline (clintrialhelpline@mhra.gsi.gov.uk) no later than the date of dispatch advising of the request. The title of this email should be ‘URGENT – FIH QUERY’. Responses to such queries will usually be sent within seven to 14 days
• sponsors should select the date of the EAG/CHM at which they wish their proposed trial to be discussed
• a data package should be prepared containing all relevant documents (see below) other than the application form/xml file - the data package should be submitted directly to

Clinical Trials Unit
3.T
MHRA
151 Buckingham Palace Road
Victoria
SW1W 9SZ

This should arrive in the unit no later than the latest submission date for the selected EAG/CHM

• an email should be sent to the clinical trials helpline (clintrialhelpline@mhra.gsi.gov.uk) no later than the date of dispatch, providing the sponsor name, the product name, the EudraCT number and the anticipated arrival date of the package - the title of this email should be ‘URGENT – FIH SUBMISSION’
• following initial assessment, feedback on the content and completeness of the data package may be provided to the sponsor
• the application form/xml file and fee should be sent directly to the Clinical Trials Unit to arrive during the week of the relevant EAG/CHM meeting
• the sponsor should note that data packages submitted prior to the latest submission date will follow the timeline as listed
• a formal response to the sponsor will be sent within seven to 14 days of the CHM meeting date.

 

Dates of Expert Advisory Groups and corresponding timelines

Expert Advisory Group meeting times for 2012

Latest submission date: 21 days before the meeting
Latest Response: 22 days after meeting

Relevant documents
 

• IMP dossier
• investigator’s brochure
• protocol
• responses to required
• CHM areas for discussion
• labelling Manufacturer’s authorisation
• Qualified Person (QP) declaration on Good Manufacturing Practice (GMP) (if necessary)
• EudraCT receipt
• covering letter.

CHM required areas for discussion

1. A discussion of the function of the target in man
2. A discussion of the ability of the subject to maintain a normal physiological response to challenge in the presence of the investigational product
3. A discussion for the transition from preclinical to human testing, particularly with regard to highly species specific molecules
4. A discussion of the potential for on-target and off-target effects and how this will be handled in the clinic
5. A discussion of the doses used in the relevant animal species (particularly with regard to the use in the animal model of the starting dose to be administered to man).
6. A rationale for the starting dose in man (including, for example receptor occupancy)
7. A rationale for the study population (particularly for the use of healthy volunteers)
8. A rationale for the administration schedule for the initial and subsequent cohorts. This should include the time interval between doses administered to individual subjects
9. A rationale for the dose escalation particularly with regard to potential adverse effect
10. A rationale for the proposed trial site, including the facilities available

Further guidance on first-in-human clinical trials is available below:
EMEA/CHMP/SWP/28367/07 Guideline on strategies to identify and mitigate risks for first-in-human clinical trials with investigational medicinal products (external link).