6 Avoidable IND Killers in Nonclinical Development ๐ โ Transcript
Full transcript
- 0:00Good morning everyone. Today we are
- 0:01talking about IND killers. And so we're
- 0:03going to go through a couple of the
- 0:04things that can potentially put an IND
- 0:07on clinical hold, not get you a
- 0:09clearance or an IND approval to go FIH
- 0:11or into clinical trials. And the biggest
- 0:13takeaway from this is that every one of
- 0:17these is avoidable. Um and so we'll go
- 0:21through them here on the right. The
- 0:22first one that we're going to talk about
- 0:23is missing TK data. If if you know me,
- 0:25if you follow my LinkedIn content, if
- 0:27you've taken my course, um the complete
- 0:29guide to nonclinical development, uh you
- 0:31know that TK data, I talk about it all
- 0:33the time. It's a critical thing. Being
- 0:35able to correlate toxicity to exposure
- 0:37is the foundation of having a defensible
- 0:41regulatory narrative and regulatory
- 0:42submission that will pass um review at
- 0:45any regulatory agency, not just the FDA.
- 0:48tox having to talk data, having TK data
- 0:50on all of your tox studies, on your
- 0:52pharmarmacology studies, on your PK
- 0:54studies is critical to being able to
- 0:56correlate any toxicity to exposure and
- 0:58then to correlate any toxicity to
- 1:00efficacious exposure and then
- 1:02translating that to the clinic. Another
- 1:05one is unexplained deaths. So having
- 1:07deaths that happen without being able to
- 1:09justify that those deaths didn't weren't
- 1:11caused by your drug. That is where we
- 1:13want to be able to understand um these
- 1:15things. So a lot of times when you have
- 1:16a death it can be exposure driven high
- 1:19exposure it can be misdosing uh for
- 1:21example or vage you can misdose and the
- 1:23animal can die it could be due to just
- 1:25the animal species um why an animal died
- 1:28then there's doubt for the reviewer that
- 1:31um it could be due to your drug and
- 1:33that's going to be a big no no. You're
- 1:35going to have to be able to to
- 1:37understand that. you're gonna have to
- 1:39they're going to want you to dig down
- 1:40deep into that and understand why these
- 1:43deaths did or were not were or were not
- 1:45caused by your drug. Another one is
- 1:48irreversible organ toxicity. This is
- 1:50especially uh important in chronic
- 1:52dosing. If we want to chronic dose in
- 1:54patients, we need to understand if
- 1:56there's any organ toxicity that can't be
- 1:58reversed upon dose and sessation. If
- 2:00organ tox can't be reversed, then that
- 2:02is usually a big sign that that dose or
- 2:05that exposure is is too toxic to be able
- 2:08to go up to humans and and if you don't
- 2:09have an adequate uh safety factor or
- 2:12exposure margin to be able to compare
- 2:14that back to animals, you're going to
- 2:16have a tough time justifying that your
- 2:17drug is able to go first in human
- 2:21species specific findings not relatable
- 2:23to humans. So, a lot of you might know
- 2:25that for like the GLP1s that came out,
- 2:27there was a black box about uh thyroid
- 2:29cancer, a lot of the findings in the
- 2:32rodent um studies, carcinogenic studies
- 2:35and the tox studies showed tumors being
- 2:38formed. History of thyroid cancer or
- 2:40issues with their thyroid shouldn't be
- 2:42taken. The GLP-1s. So, rodent thyroids,
- 2:45they dysfunction in the human with their
- 2:47thyroid that might mimic the function
- 2:49that happens in the rat. Um, and so
- 2:51there is a potential for thyroid cancer.
- 2:53But species specific findings like that,
- 2:56um, that aren't relatable to humans,
- 2:59they are usually very toxic. They are
- 3:02usually, uh, something that you
- 3:05definitely have to clinically monitor.
- 3:07They're something that the FDA
- 3:08definitely red flags. This is a very
- 3:12important one. Your noal drives
- 3:14everything after it, meaning that it
- 3:16drives your exposure margins. It drives
- 3:18your clinical starting. If you have
- 3:20missing TK data and you can't establish
- 3:22a no, uh, you're dead in the water right
- 3:24there. So, a flat dose response. What we
- 3:27want to see in our tox studies,
- 3:28especially when we get to GOP, is that
- 3:30we can see a dose response in toxicity
- 3:32from the the low dose to the mid dose to
- 3:34the high dose. And that we can see that
- 3:36as exposure or CAX increases, the
- 3:39toxicity increases. And so, we can
- 3:42narrow down and understand where the
- 3:44changes are happening and be able to
- 3:46translate that into the clinic. If you
- 3:48have a flat, you haven't run your non
- 3:49GLOP studies adequately enough to uh
- 3:52have a dose range that is narrowed
- 3:54enough to provide an accurate noal. And
- 3:58sometimes the FDA, they really want to
- 3:59see a no or a dose level that doesn't
- 4:02have any effects so that they can
- 4:04understand where that threshold is where
- 4:06toxicity starts and then where adverse
- 4:08toxic based on your your uh indication
- 4:11in your patient population can
- 4:12definitely be an IMD killer. um oncology
- 4:15compounds, oncology indications, and
- 4:18particularly small molecule, your
- 4:19exposure margins are going to be at
- 4:21least 10x or higher uh depending on your
- 4:23patient population. And so if it's too
- 4:25narrow, then that's going to impact your
- 4:28clinical dose escalation. That's going
- 4:30to impact your clinical monitoring plan,
- 4:31your translation of toxicity to the
- 4:33clinic, and everything that basically
- 4:35that comes after it. Sometimes narrower
- 4:38exposure margins can be justified. Um,
- 4:41but more often than not, you're going to
- 4:42want to make sure that you've run your
- 4:43nonclinical intoxicity, whether it's
- 4:46your MTD or your dose range finding
- 4:48study, your DRF, and then making sure
- 4:50you have the right doses to be able to
- 4:52have adequate exposure margins within
- 4:53your GLP to justify uh a sufficient NOAL
- 4:58and a sufficient exposure that goes with
- 4:59that NOAL to support clinical
- 5:01development. And so, like I said, the
- 5:04takeaway from all of this is that these
- 5:06are avoidable upfront, right? Missing TK
- 5:08data. Add TK to every dose and every
- 5:10study that you that you run. Unexplained
- 5:13death. Make sure that you do your on
- 5:15offtarget safety assessments. You do
- 5:17your safety panels. You understand your
- 5:19CRO. Vetting your CRO and the technical
- 5:22capabilities is critical. Irreversible
- 5:25organ toxicity. Um this is something
- 5:27that can be mitigated within your study
- 5:30design. Species specific findings not
- 5:32related to humans. This takes a lot of
- 5:33weight of evidence and literature
- 5:35research. Flat dose response. This all
- 5:37has to do with dose selection and being
- 5:38able to make sure that you have
- 5:39well-designed studies of study or you
- 5:41designing an IND because all of this
- 5:43these things fall together and create
- 5:45this well-rounded puzzle to be able to
- 5:48support a sufficient uh nonclinical
- 5:51development package that has sufficient
- 5:53noses sufficient exposure margin
- 5:55sufficient TK data uh sufficient
- 5:57justification for any deaths sufficient
- 5:59justification for any irreversible organ
- 6:02toxicity and how you plan to mitigate
- 6:04that in the clinic. So that's it for
- 6:05today. Hope uh you guys had a great time
- 6:08learning about these IND killers. If you
- 6:10want to go a little bit further into
- 6:11this, we talk more about it in my
- 6:13course, the complete guide to
- 6:14nonclinical development. I tagged it in
- 6:16the description below. Take a look.
- 6:18There's a free preview on there so you
- 6:19can see what's in it. It's 60 plus hours
- 6:22of content over 14 modules covering the
- 6:24the whole spectrum of nonclinical
- 6:25development. Um and we talk a lot about
- 6:27IND and IND killers.
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