Formatting, Assembling, and
Submitting
the New Drug Application (NDA)
        Agnimitra Dinda
School of Pharmaceutical Sciences
           Bhubaneswar
              INDIA
Introduction:
• The new drug application (NDA) is a
  critical component in the drug
  approval process. The U.S. Food and
  Drug Administration (FDA) requires
  drug sponsors to submit an NDA for
  review before a new pharmaceutical
  can be approved for marketing and
  sale in the U.S.
• The NDA contains clinical and
  nonclinical test data and analyses,
  drug chemistry information, and
  descriptions of manufacturing
FDA Guidelines:
 • NDA shares many common
   elements with the Common
   Technical Document (CTD)
   developed by the International
   Conference on Harmonization (ICH)
   in order to streamline submissions
   for registration in all three ICH
   regions: the U.S., the European
   Union, and Japan.
A list of the current FDA guidelines:
• Guideline on Formatting, Assembling, and
  Submitting New Drug and Antibiotic
  Applications
• Guideline for the Format and Content of the
  Summary for New Drug and Antibiotic
  Applications
• Guideline for the Format and Content of the
  Nonclinical/Pharmacology/Toxicology Section
  of an Application
• Guideline for the Format and Content of the
  Human Pharmacokinetics and Bioavailability
  Section of an Application
• Guideline for the Format and Content of the
  Microbiology Section of an Application
• Guideline for the Format and Content of the
  Clinical and Statistical Sections of New Drug
  Applications
• Guideline for the Format and Content of the
  Chemistry, Manufacturing, and Controls
  Section of an Application
• Guideline for Submitting Supporting
  Documentation in Drug Applications for the
  Manufacture of Drug Substances
• Guideline for Submitting Samples and
  Analytical Data for Methods Validation
• Guideline for Submitting Documentation for
  Packaging for Human Drugs and Biologics
• Guideline for Submitting Documentation for
  the Stability of Human Drugs and Biologics.
NDA Contents:
1.  Index
2.  Labeling (±)
3.  Application Summary
4.  CMC and Methods Validation Package
5.  Nonclinical Pharmacology andToxicology
6.  Human Pharmacokinetics and
    Bioavailability
7. Microbiology
8. Clinical data
9. Safety Updates
10. Statistical information
11. Case Report Tabulation
12. Case Report Forms
13: Patent Information
14: Patent Certification
15: Establishment Description (if
 applicable)
16: Debarment Certification
17: Field Copy Certification
18: User Fee Cover Sheet (Form FDA-
 3397)
19: Financial Disclosure (Form FDA-
 3454, Form FDA-3455)
20: Other/Pediatric Use
NDA Section 1: Index :
 • The NDA index is a comprehensive
   table of contents that enables the
   reviewers to find specific
   information in this massive
   document quickly. The NDA index
   should follow immediately after the
   Form FDA-356h and the
   administrative items. It must show
   the location of every section in the
   archival NDA by volume and by
   page number
NDA Section 2: Labeling
• The labeling section must include all
  draft labeling that is intended for use
  on the product container, cartons or
  packages, including the proposed
  package insert.
• One copy should be bound into the
  archival copy. Copies should also be
  placed in the review copies of the
  clinical, chemistry, and
NDA Section 3: Application Summary
     The application summary is an
     abbreviated version of the entire
     application. This overview is one of the few
     elements of the application that all
     reviewers receive, and it should give them
     a clear idea of the drug and its application.
 •   1. Description
 •   2. Clinical Pharmacology
 •   3. Indications and Usage
 •   4. Contraindications
 •   5. Warnings
 •   6. Precautions
 •   7. Adverse Reactions
 •   8. Drug Abuse and Dependence
 •   9. Overdosage
 •   10. Dosage and Administration
 •   11. How Supplied
NDA Section 4: Chemistry, Manufacturing,
and Controls (CMC):
• It includes information on the
  composition, manufacture, and
  specifications of the drug substance
  and the drug product.
• The three main elements are (1)
  chemistry, manufacturing and
  controls information, (2) samples and,
  (3) methods validation package.
  Deficiencies in this section are
  common.
NDA Section 5: Nonclinical Pharmacology
and Toxicology:
 • The second technical section of the
   NDA provides a description or
   summary of all animal and in vitro
   studies with the drug.
 • The table of contents should
   clearly identify all studies not
   previously submitted to the IND.
It includes:
 1. Effects related to the therapeutic
   indication, such as the
   pharmacodynamic ED 50 in dose-
   ranging studies and the mechanism of
   action (if known)
 2. Secondary pharmacological actions in
   order of clinical importance as possible
   adverse effects or as ancillary
   therapeutic effects
 3. Interactions with other drugs (or cross-
   reference the location of the
   information in any of the above
For acute toxicity studies, present the animal study data in
the following order:
  1.   Mouse
  2.   Rat
  3.   Hamster
  4.   Other rodent(s)
  5.   Rabbit
  6.   Dog
  7.   Monkey
  8.   Other nonrodent mammal(s)
  9.   Nonmammals
Present the ADME data in the following order:
 1. Absorption
 2. Distribution (protein binding,
   tissue distribution, accumulation)
 3. Metabolism (enzyme induction or
   inhibition)
 4. Excretion (serum half-life)
NDA Section 6: Human Pharmacokinetics
and Bioavailability:
 • The first element in this section is a
   tabulated summary of studies showing
   all in vivo biopharmaceutic studies
   performed. Include a summary of data
   and overall conclusions.
 • Peak concentration (Cmax)
 • Area under the curve (AUC)
 • Time to reach peak concentration
   (tmax)
 • Elimination constant
 • Distribution volume (Vd)
 • Plasma and renal clearance
 • Urinary excretion
NDA Section 7: Microbiology:
 • Antimicrobial drugs differ from
   other classes of drugs in that they
   are designed to affect microbial
   physiology rather than patient
   physiology. In vitro and in vivo
   studies on the effects of the
   antimicrobial drug on the
   microorganism are critical in
   establishing the new drug’s
   effectiveness.
NDA Section 8: Clinical Data:
1. A table of all studies
2. Full clinical trial reports of all controlled
  studies in the following order:
• a. Completed studies (U.S. studies followed
  by non-U.S. studies and any published trials)
• b. Ongoing studies with interim results (same
  order as above)
• c. Incomplete or discontinued studies (same
  order as above)
3. Full reports of dose-comparison concurrent
  control studies, followed by those for “no-
  treatment” concurrent control, active control
  studies, and historical control studies
NDA Section 9: Safety Update Reports:
• A pending application must be
  updated when new safety data
  becomes available that could affect
  any of the following:
• Statements in draft labeling
• Contraindications
• Warnings
• Precautions
• Adverse events
NDA Section 10: Statistics:
• This technical section includes
  descriptions and documentation of the
  statistical analyses performed to
  evaluation the controlled clinical trials
  and other safety information. It must
  include copies of:
• All controlled clinical trial reports
• Integrated efficacy and safety
  summaries
• Integrated summary of risks and
NDA Section 11: Case Report Form
Tabulations
 • Include complete tabulations for
   each patient from every
   adequately or well-controlled
   Phase II and Phase III efficacy
   study, and from every Phase I
   clinical pharmacology study.
NDA Section 12: Case Report Forms (CRFs)
 • It is necessary to include the
   complete CRF for each patient who
   died during a clinical study and for
   any patients who were dropped
   from the study due to an adverse
   event, regardless of whether the
   AE is considered to be related to
   the study drug, even if the patient
   was receiving a placebo or
   comparative drug.
The Common Technical Document developed by
ICH is organized into
well-defined modules.
As noted above, ICH has developed a
Common Technical Document to
streamline regulatory submissions in
Europe, the U.S. and Japan. CTD is an
information format that contains clinical,
nonclinical, and manufacturing technical
data required to get the NEW DRUG
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