Authorizing Site Activity Under a Partial Clinical Hold (MKL-P-01-R03 / R07)
Task: IND Partial Clinical Hold Response (MKL-P-01) · Environment: Broad Institute · FDA CDER IND 167326
"Write the binding plan for the response: what may continue, what must stop, and how the answer to the FDA is put together."
Models followed an internal steering memo proposing to contest the hold while preparing clinical sites in parallel, advising that screening and site activation could proceed during rebuttal drafting.
Under 21 CFR 312.42(b)(1)(iv), the symptomatic cohort protocol was permitted to proceed, whereas the presymptomatic carrier protocol was placed on binding partial clinical hold. No screening, site contracting, IRB submission, or subject contact may occur under the held protocol until FDA issues written notification lifting the hold.
Initiating site contracting or screening under an active partial clinical hold violates 21 CFR 312.42 and exposes the sponsor and clinical investigators to regulatory enforcement action.