Satisfying the FDA14 Sep 2023 12:05
What happens when the FDA imposes a clinical hold?
The Agency communicates the clinical hold to the sponsor, usually in a teleconference - TICK (June)
Within 30 days from the date of the teleconference placing an IND on clinical hold, the Agency
must send the sponsor a clinical hold letter, signed by the Division Director or Acting Division
Director, that describes in detail the reasons for the clinical hold - TICK (early July RNS clearly stating ONE issue)
If the sponsor addresses all of the clinical hold issues identified in the Agency’s clinical hold letter
(a complete response), (RNS Sept - Hemo responded in August 2023 with a detailed plan, supported by laboratory tests)
FDA must respond to the sponsor within 30 days of receipt of the complete response (Hemo confirm in Sept RNS that has now received confirmation from the FDA that the Company's plan satisfactorily addresses the agency's comment)
How does the FDA define a COMPLETE RESPONSE?
A response from the applicant in which all clinical hold issues identified in the clinical hold letter have been addressed.
What happens if I think my response is complete, but the FDA disagrees?
If FDA finds that your response is not complete, FDA will notify you as soon as possible by
phone or other means of rapid communication, but no later than 30 days after receipt of your
response. The Agency will tell you what information is needed to make it a complete response.
The 30-day clock will not start until the FDA receives what it believes to be a complete
response to the clinical hold letter. (THIS IS NOT THE CASE - NO MENTION IN RNS THAT FDA DID NOT BELIEVE HEMO HAVE ADDRESSED THE CH)
Should non hold issues be addressed in the response to the Agency’s clinical hold letter?
No, even if the Agency includes nonhold issues in the clinical hold letter, you should ensure that
the complete response to a clinical hold letter contains no material related to issues other than
the IND clinical hold. If you wish to address any nonhold issues raised by the Agency, please
do so in a separate amendment or letter.
This is taken directly from FDA guidance for sponsors who have a clinical hold placed on their IND. Based on the recent RNS from Hemo and the guidance from FDA - its looks very clear cut to me that Hemo submitted a COMPLETE RESPONSE and FDA have accepted it.
My personal opinion is that whilst i cannot find it written in the FDA Guidance - It is the responsibility of Hemo to refine IND with any changes or test data that was detailed in the Complete Response.
Ahead of trials, i expect Hemo are working on a few other tweaks following the feedback from FDA to improve safety and I'm sure more testing will be involved.
I have no doubt that Hemo are fully focused on starting Clincial Trials ASAP (as per RNS) and , like today, we'll have another great RNS in the coming weeks.
Brilliant News, gl to shareholders