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Pharmaceuticals · IND CMC Support

CMC and GMP Support for an IND

The short answer

Sponsors filing an IND usually need two things at once: CMC content for the application and a quality system capable of overseeing clinical manufacturing. We build both, sized to the phase, without installing commercial-scale bureaucracy on a Phase 1 program.

01

Why this matters

  • A sponsor quality system built too heavy early is abandoned; built too light, it cannot release material.
  • CMO oversight is a sponsor responsibility that cannot be delegated by contract.
  • Early documentation decisions determine how much rework the NDA or BLA requires.
02

Applicable regulations and standards

21 CFR 312.23(a)(7)
CMC content required for the IND.
FDA Guidance — CGMP for Phase 1 Investigational Drugs
Phase-appropriate control expectations.
ICH Q7
GMP for active pharmaceutical ingredients.
03

What our consultants actually do

  • Build a right-sized sponsor quality system: release, deviations, change control, document control
  • Author or review CMC sections and supporting development documentation
  • Establish quality agreements and CMO oversight practices
  • Set phase-appropriate specifications and stability protocols
  • Plan the GMP maturity path toward commercial readiness
04

Across the product lifecycle

  1. 01 / DEVELOP

    Development data documented for later filings.

  2. 02 / SCALE

    Clinical supply scale and controls defined.

  3. 03 / TRANSFER

    Method and process transfer to the CMO.

  4. 04 / VALIDATE

    Qualification appropriate to phase.

  5. 05 / MANUFACTURE

    Clinical batch manufacture and sponsor release.

  6. 06 / MAINTAIN

    IND amendments and system maturation by phase.

05

Problems we are usually called about

  • Quality agreement that assigns responsibilities nobody at the sponsor performs
  • No sponsor review of executed batch records
  • Specifications carried forward from the CMO template without justification
06

Typical deliverables

  • Sponsor quality system procedures
  • CMC content and development documentation review
  • Quality agreement and CMO oversight plan
  • Phase-by-phase GMP roadmap
07

Frequently asked

We are a virtual company. Is that a problem?
No, but the oversight has to be real. Virtual sponsors need a small number of well-run processes — release, change control, deviation review and CMO oversight — rather than a full copy of a manufacturer's quality system.
08

References

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