Publications

The CMC chasm. Why most biotech IND submissions fail at chemistry, not biology.

Author: Andrew Jonathan Hillman (ORCID 0009-0001-5396-321X)
Published: , Zenodo. Also published in The Hillman Letter.
DOI: 10.5281/zenodo.23352278 (all versions); this version 10.5281/zenodo.23352279
License: CC BY 4.0

Abstract

Explains why the Chemistry, Manufacturing, and Controls section is a frequent cause of IND clinical holds. Describes what CMC covers under 21 CFR 312.23(a)(7) and how sponsors should build it as a program rather than paperwork.

This essay describes FDA regulatory process for educational purposes. It is not legal or regulatory advice.

Indexed in OpenAlex under author A5139488776.

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