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What is one key difference in content between an IND for marketed products and one for new drugs?

A copy of the approved labeling can be provided instead of the Investigator's Brochure

The rationale behind the correct answer is that when submitting an Investigational New Drug (IND) application for marketed products, it is permissible to include a copy of the approved labeling in place of the Investigator's Brochure. This is significant because the Investigator's Brochure is meant to provide comprehensive information about the drug being investigated, including safety and efficacy data, to ensure that investigators have the necessary details to understand the risks and benefits. In the case of marketed products, much of this information is already captured in the approved labeling, making it adequate for the IND submission.

The other options are not accurate in reflecting the distinction between INDs for marketed products and new drugs. For instance, although prior clinical trial summaries are important, both new drugs and marketed products typically include summaries, making this not a distinguishing factor. Marketed products often still require cover letters for their submissions, as well as any other documentation specified by regulatory authorities, ensuring that communication regarding the submission process is maintained. Lastly, while the provision of pharmacological data is critical for IND submissions of new drugs, the requirement for full pharmacological data is not a specific difference with marketed products, as the degree of detail may vary based on existing data and regulatory requirements. Thus, the key differentiation highlighted by the

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The IND must contain a summary of prior clinical trials

Marketed products do not require a cover letter

New drugs must provide full pharmacological data

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