
Investigational Exemption Procedures for New Drugs-Reply
AMA Department of Drugs
Chicago
JAMA. 1970;213(11):1902-1904.
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To the Editor.—
This letter from Dr. Simmons evokes our profound disagreement. Dr. Simmons suggests that a physician employing a drug in his practice in some way differing from the recommendations of the drug's labeling should submit to the FDA a "Notice of Claimed Investigational Exemption for a New Drug" (IND). His arguments to encourage this procedure are not persuasive.
The IND procedure, provided by regulations authorized by the Food, Drug, and Cosmetic Act, is a mechanism by which the manufacturer or comparable distributor of a new drug in interstate commerce may have the necessary testing performed to market the drug. There is no other legitimate purpose for the procedure. It is true that a manufacturer may already have a drug on the market and may submit another IND to prepare for some change in the conditions under which he sells the drug. He may propose a new dosage form—say
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