Table 1.
Reason | Clinical Hold, n | Denial, n |
---|---|---|
Incomplete application | 7 | |
Unsafe dosing | 4 | |
Lack of any demonstrated efficacy | 4 | |
Availability of adequate alternative therapies | 3 | |
Commercial IND on hold | 2 | |
Product quality issues | 2 | |
Inadequate safety monitoring | 1 | |
Unreasonable risk | 1 | |
Not an emergency | 21 | |
Duplicate requests | 2 | |
Unknowna | 15 | |
Total | 24 | 38 |
All investigational new drugs (INDs) are subject to clinical hold, and only emergency IND requests for expanded access are subject to denial.
The absence of any documentation prohibited determination of reason for denial.