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Category: First-in-Human

  • Adverse event and SUSAR reporting to ANVISA during a FIH trial in Brazil

    Device FIH safety reporting in Brazil is not drug pharmacovigilance with the logo swapped. The clocks are different, the form is different, and “SUSAR” is a useful overlapping idea — not the name of the ANVISA device channel.

    If your FIH data are meant to support a later FDA investigational or marketing file, you still report to ANVISA under device rules. You then keep a narrative and causality trail that an IDE medical officer can read without asking why Brazil used a drug module.

    The statute you actually report under

    Current device clinical-investigation procedure is RDC 837/2023, announced by ANVISA in its December 2023 update. It replaced RDC 548/2021, which had already revoked RDC 10/2015. Chapter VII is the safety-monitoring chapter. Do not write SOPs against RDC 10/2015 clocks, and do not paste RDC 945/2024 drug-trial SUSAR text into a device FIH plan.

    Law 14.874/2024 still applies to the ethics layer. Article 26 requires the sponsor to notify investigators, the institution, ethics bodies, and the sanitary authority of findings that may adversely affect participant safety. Article 55 makes serious adverse events reportable to the CEP that approved the research, and, for clinical trials intended to support sanitary registration, also to the sanitary authority. The law does not replace RDC 837/2023’s device form or day counts.

    NotivisaEC is the device channel; VigiMed is not

    ANVISA’s manual for adverse-event notification and safety monitoring in clinical trials involving investigational medical devices is the operational text. It tells sponsors to notify unexpected serious adverse events to ANVISA on the electronic NotivisaEC form:

    https://pesquisa.anvisa.gov.br/index.php/847543?lang=pt-BR

    The manual is explicit that those notifications go exclusively through that form, and that login is not required to notify. It also states that a SUSAR (suspected unexpected serious adverse reaction) sits inside the criteria for a notifiable serious event — but the RDC criteria are not limited to the drug-style SUSAR definition. If your safety database only flags “SUSAR = yes,” you will miss device cases that are unexpected, serious, and causally possible even when a medical monitor refuses the drug label.

    VigiMed-Pesquisa Clínica is ANVISA’s channel for SUSARs in drug and biologic trials, under the drug clinical-trial framework (currently discussed by the Agency against RDC 945/2024). ANVISA’s own clinical-trial notification page describes VigiMed in that medicine context and requires a study-specific VigiMed registration, including the DEEC expediente. That is not the device DICD file. Do not open a VigiMed-Pesquisa Clínica account as a substitute for NotivisaEC on an implant FIH.

    Post-market technovigilance (commercial devices after registro or notification) is a different duty and a different system generation. Keep investigational NotivisaEC cases out of the commercial technovigilance queue until the unit is actually on the market.

    What is notifiable, in device language

    RDC 837/2023 defines an adverse event as any unfavorable medical occurrence in a participant that is not necessarily causal. A serious adverse event includes death; a life-threatening event; persistent or significant disability; hospitalization or prolongation of hospitalization; congenital anomaly; suspected transmission of an infectious agent via a medical device; or a clinically significant event.

    An event is unexpected when it is not described as an adverse reaction in the investigator brochure or in the instructions for use / operator manual of the investigational device. That is why the brochure is a reporting instrument, not a marketing appendix.

    The sponsor must notify ANVISA of unexpected serious events that occurred in Brazil and whose causality versus the investigational product is possible, probable, or definite. Expected serious events, unrelated events, and non-serious events still belong in the sponsor’s file and in the annual tabulated report. They are not the 7- and 15-day electronic cases.

    Causality is not a hallway opinion. The device manual points sponsors to the WHO-UMC causality scale (possible / probable / certain, plus the lower categories) when classifying every event, including non-serious ones. Train Brazilian investigators on that scale before site initiation. A PI who only knows “related / not related” will force you to re-code under the clock.

    The clocks — investigator, sponsor, ANVISA

    RDC 837/2023 is blunt on time. Count from knowledge, not from “when safety closed the query.”

    • Investigator → sponsor: serious adverse events or death within 24 hours of the investigator becoming aware.
    • Sponsor → ANVISA, fatal or life-threatening, unexpected, causality possible/probable/definite, Brazil: document and notify on the electronic form within 7 calendar days of sponsor awareness. Complementary follow-up goes on the same form within 8 calendar days after that initial notification.
    • Sponsor → ANVISA, all other unexpected serious events meeting the same causality and territory tests: 15 calendar days from sponsor awareness.

    Immediate protective measures are not optional. On a notifiable serious event, the form expects the measures already taken, the plan if the same event recurs, the care location, and identifiers that can trace the event and the participant. Notification is due even if you are in the middle of a brochure update, a protocol amendment, an annual report, or an early termination.

    Temporary safety suspensions of the investigation must be notified to ANVISA within 7 calendar days of the suspension, with reasons, scope, treatment interruption, risk-minimization measures, and recruitment status. Restart waits for ANVISA approval published in the Official Gazette. That is a calendar item, not a medical-monitor footnote.

    DSUR / ICH E2F is not a substitute for the device annual report

    ANVISA publishes the ICH E2F Development Safety Update Report in its medicines clinical-trial library. E2F is a drug-development periodic-safety standard. It is a sensible internal template if the same legal entity also runs an IND. It is not the device annual report that RDC 837/2023 requires.

    For a DICD, the sponsor files an annual follow-up report as a secondary petition to the DICD, covering Brazilian centers only, in tabulated form: title, reference number, recruitment status, amendment history, enrollment by site, deviations and violations by site, and a description of all adverse events in the period, with the case-report-form participant codes. The anniversary is the date of the Brazil start-of-investigation notification. The petition is due within 60 calendar days of that anniversary. Missing the report can cancel the investigation.

    The final report is a different secondary petition, due within 12 months of the investigation’s end date, with demographics, statistical analysis, all events with causality, endpoint results, and any design changes. If you already produce a DSUR for a companion drug or combination product, map the Brazilian device tables into an annex. Do not file the DSUR and assume ANVISA has been served.

    Pivotal high-risk (Class III/IV) designs are expected to constitute a data-monitoring committee. Recommendations go to ANVISA as a DICD addendum within 30 calendar days of the sponsor receiving them. An FIH that is not labeled “pivotal” can still justify a DMC on risk. Write that justification in the plan before first patient, including why you did not constitute one.

    What must stay aligned if the FIH will later support FDA

    FDA device investigations do not use the IND SUSAR clock. They use unanticipated adverse device effect (UADE) rules under 21 CFR 812.150. An investigator reports a UADE to the sponsor and reviewing IRB as soon as possible, and no later than 10 working days after first learning of it. The sponsor evaluates immediately and reports the evaluation to FDA, all reviewing IRBs, and participating investigators within 10 working days of first notice. If the UADE presents an unreasonable risk, termination clocks in 21 CFR 812.46 are 5 working days from that determination and 15 working days from first notice. FDA’s IDE FAQs repeat the same 10-working-day sponsor evaluation report.

    Those clocks will not match Brazil’s 24-hour / 7-calendar / 15-calendar structure. Alignment is not “pick the longer one and hope.” Alignment is a single source narrative:

    • One event identifier from the Brazilian CRF code through NotivisaEC and, if an IDE exists or will exist, through the UADE file.
    • One expectedness baseline — the same brochure version cited in the DICD and in the IDE investigational plan. If Brazil updates the brochure after an unexpected event (RDC 837/2023 requires investigators to be informed and the brochure to be updated), send that version into the FDA file in the same week.
    • One causality sentence that a device reviewer recognizes (device, procedure, disease, concomitant product). Do not let the Brazilian form say “possible” and the IDE memo say “unrelated” without a dated reconciliation.
    • Device identifiers — lot, serial, software version, accessory — on every case. Import traceability under the DICD DOU number is the same data FDA will ask for when the unit later supports a 510(k), De Novo, or PMA.
    • Quality-system evidence that the investigational unit was built under a system you can defend as you move toward the QMSR. A NotivisaEC case that cannot find the device history record is already a future FDA inspection finding.

    If there is no U.S. IDE yet, still write Brazilian cases as if 812.150 will apply later. Reconstructing UADEs from a drug-safety database two years on is how FIH datasets lose credibility.

    Where programs actually break

    The bottleneck is rarely the web form. It is the weekend between the PI’s 24-hour email and a U.S. medical monitor who is still arguing expectedness against an old brochure. Build a Brazil on-call roster that can file NotivisaEC without waiting for California business hours. Give the Brazilian authorized representative and the ORPC (if one is the DICD face) read-only access to the safety tracker. Import holds, ethics queries, and ANVISA inspections all ask for the same case list.

    Second break: treating CEP notification and ANVISA notification as the same send. Law 14.874/2024 sends serious events to the CEP. RDC 837/2023 sends a narrower unexpected-and-related set to ANVISA on NotivisaEC. Your SOP should have two lines, two clocks, two receipts.

    Third break: annual-report amnesia. The 60-day secondary petition is how ANVISA sees aggregate harm. If your data-management lock cannot produce site-level AE tables from Brazilian CRF codes, you will miss a petition that can cancel the DICD — after first patients are already in.

    A practical next step

    Before site initiation, run one tabletop: a fatal unexpected device-related event at 18:00 Brasília on a Friday. Walk the 24-hour investigator notice, the 7-calendar-day NotivisaEC filing, the 8-day follow-up, the CEP notice under Law 14.874/2024, the brochure update, and — if an IDE is live or planned — the 10-working-day UADE evaluation to FDA. If any of those hands is “we’ll figure it out,” rewrite the safety SOP and name the NotivisaEC filer. First-patient week is the wrong time to discover that VigiMed was the only account anyone opened.

  • ANVISA medical device classification rules for FIH studies in Brazil

    Most first-in-human (FIH) delays I see in Brazil do not start on the ANVISA clock. They start earlier, when regulatory affairs treats class as a registration afterthought instead of the decision that decides whether you even file a clinical investigation dossier, what the import petition can carry, and what the investigator brochure must treat as expected.

    This is not another walkthrough of Brazil’s 90-day ANVISA review window, and it is not a recap of Law 14.874/2024. Those calendars matter, but they sit on top of a classification call. If that call is wrong, the clock you are watching is the wrong clock.

    RDC 751/2022 is the class rule, not a slogan

    Collegiate Board Resolution RDC No. 751 of 15 September 2022 is ANVISA’s current framework for medical-device risk classification, labeling and instructions for use, and the notification versus marketing-authorization (registro) regimes. Article 5 places devices in four intrinsic-risk classes:

    • Class I — low risk
    • Class II — medium risk
    • Class III — high risk
    • Class IV — maximum risk

    Articles 6 and 7 then split the premarket path: Classes I and II are subject to notification; Classes III and IV are subject to marketing authorization. ANVISA’s English overview of the same split is on the Agency’s medical devices page.

    Classification is not a marketing preference. It is a rules exercise against the manufacturer’s intended purpose. Annex I of RDC 751/2022 sets the classification rules (duration of use, invasiveness, active energy, implants, special rules). The most stringent applicable rule wins. Software as a medical device is classified on its own intended purpose when it is standalone. In vitro diagnostic devices sit on a separate IVD classification track; do not force an IVD into the same clinical-investigation box as an implant.

    For an FIH program, lock three statements in the same document: intended purpose in Portuguese that will appear on the DICD and later on the registro file; the Annex I rule (or rules) you applied; and the resulting Class I–IV. If clinical, quality, and the Brazilian authorized representative cannot repeat those three lines without hedging, you are not ready to talk about first-patient dates.

    RDC 10/2015 is not the current FIH filing rule

    Sponsors still arrive with “RDC 10/2015” in the regulatory plan. That resolution existed. It is not the current device-investigation statute.

    RDC No. 548 of 30 August 2021 revoked RDC No. 10 of 20 February 2015 (Article 84 of RDC 548/2021). RDC No. 837 of 13 December 2023 then replaced that 2021 text. ANVISA announced the update and the alignment with international practice in its 18 December 2023 notice (in force early January 2024). Article 80 of RDC 837/2023 revokes RDC 548/2021.

    Current device clinical-investigation procedure is RDC 837/2023. Use RDC 10/2015 only as history. Do not cite it as the filing basis for a 2026 FIH.

    How class drives whether you file a DICD

    RDC 837/2023 is explicit about scope. A Dossiê de Investigação Clínica de Dispositivo Médico (DICD) is required for clinical investigations involving Class III or Class IV devices that are not yet registered in Brazil. A registered device studied for an indication different from the indication in the sanitary registration also goes in as a DICD.

    The same resolution carves out investigations that do not go to ANVISA as a DICD, including:

    • clinical performance studies of IVDs;
    • usability/human-factors-only studies (unless the clinical investigation also includes those endpoints among others);
    • investigations of devices already registered in Brazil for the same approved indications;
    • clinical investigations of Class I or Class II devices.

    Class I and II investigations are still expected to follow good clinical practice. RDC 837/2023 points to the Document of the Americas and ISO 14155 as the GCP standard. They still need ethics approval. They do not get a free pass on import controls or on manufacturing quality of investigational units. What they do not get is a DICD as the ANVISA on-ramp.

    That is the classification bottleneck. A U.S. significant-risk implant that an RA lead quietly “simplifies” to Class II to avoid a dossier is not a timeline win. It is a first-patient hold when import, ethics, or a later registro reviewer asks why the intended purpose looks like Rule 8 (long-term surgically invasive / implant) and the file says Class II. The opposite error is also expensive: forcing a true Class II tool through a DICD because someone copied a Class III playbook wastes petition fees and a review cycle you did not owe.

    What the DICD actually has to carry

    When class puts you in DICD scope, RDC 837/2023 consolidates the old two-dossier habit into one submission. The petition typically includes the DICD form, the sanitary-surveillance fee (GRU) or exemption, the investigator brochure, a safety-experience summary (prior human use and any foreign post-market experience), the investigational-device dossier, the clinical investigation plan under GCP, and proof of registration in a WHO ICTRP or ICMJE-recognized trial registry (or that proof at start-date notification if it is not ready at first protocolization).

    ANVISA’s petition checklist for DICD subject 80104 is published in the Agency’s SAT instruction list. Use that list, not a recycled IND table of contents.

    Two operational rules from the same resolution save weeks if you lock them before translators start:

    • The party who files the DICD owns every later secondary petition. Do not let a consultant file “just this once.”
    • An organização representativa de pesquisa clínica (ORPC) may file only when the sponsor has no headquarters or branch in Brazil. If you already have a Brazilian legal presence, that presence is the face of the file.

    RDC 837/2023 gives ANVISA 90 calendar days (dias corridos) to issue a manifestation on the DICD, with a tacit-start path after ethics approval if the Agency is silent. Law 14.874/2024 Article 58 speaks of 90 business days (dias úteis) for primary sanitary analysis of clinical-trial petitions intended to support registration. Those are not the same unit of time. Treat the mismatch as a planning flag; do not invent a hierarchy in a slide. The clock posts already cover activation math. Classification decides whether that math applies to you at all.

    Import, IOR/AR, and QMSR sit on the same class decision

    Investigational units do not enter Brazil on a commercial registro. RDC 837/2023 Chapter IX puts exclusive clinical-use import under sanitary inspection and SISCOMEX release. The importer must cite the Diário Oficial da União resolution number for the DICD grant. Outer packaging must carry that DOU number, storage conditions, and a lot, identification, or serial code that can trace the unit. Quantities are limited to what the investigation needs. Commercialization of those units is prohibited.

    If someone other than the DICD holder imports, both parties sign a delegation-of-import-responsibility document. That is your import authorized representative problem, not a freight problem. The same legal person who will later hold notification or registro as authorized representative should see the investigational import list now. A first-patient kit that is not on the DICD product list will sit on the dock.

    On quality: RDC 837/2023 requires investigational devices, and any placebo or sham, to be manufactured to good manufacturing practice and labeled so they are identifiable as investigational. ANVISA may inspect the manufacturing site against the technical, production, and quality-control story in the DICD. If the same design will later support an FDA marketing file, build those units under the quality system you intend to defend — including the United States Quality Management System Regulation transition — not under a “prototype exception” that you cannot reconstruct.

    What the RA lead must lock before first patient

    Write these eight items as a one-page gate. Do not open the site until each line has an owner and a document ID.

    1. Intended purpose. The Portuguese indication that will classify the device under RDC 751/2022 Annex I and that will appear in the investigator brochure. Changing “long-term implant” to “intraoperative aid” after ethics approval is a new class, not a wording tweak.
    2. Class and rule. Class I–IV plus the governing Annex I rule. Record why neighboring rules were rejected.
    3. DICD yes/no. Apply RDC 837/2023 Articles 2 and 4. Class I/II, same-indication post-market, IVD performance, and usability-only studies are out of DICD scope. Class III/IV unregistered, and new indications on a registered device, are in.
    4. Filing face. Sponsor legal entity in Brazil versus ORPC. Name the person who will own secondary petitions: start/end dates, amendments, annual report.
    5. Import list. Every investigational SKU, spare, and accessory that will clear SISCOMEX, mapped to the DICD form. No “we’ll add the introducer later.”
    6. Expectedness language. The brochure and operator manual define “unexpected” for later safety notification. If the FIH protocol lists risks the brochure omits, you have built a 7- and 15-day reporting trap.
    7. Ethics path. CEP submission under Law 14.874/2024 in parallel with, not after, the sanitary file when a DICD is in scope. Single-CEP review for multicenter protocols is a legal design, not a courtesy.
    8. Start-date discipline. RDC 837/2023 requires start- and end-date forms as secondary petitions within 30 calendar days of each Brazil date. First patient is a regulatory event, not only a clinical one.

    Amendments after that gate are expensive. Substantial changes to the brochure or device dossier that can affect quality or safety wait for ANVISA manifestation (again, 90 calendar days in RDC 837/2023). Substantial protocol amendments that affect participant safety or scientific value wait the same way, except amendments that remove an immediate risk, which you implement and notify. Classification mistakes tend to surface as those amendments.

    A practical next step

    This week, run a 90-minute classification huddle with RA, clinical, quality, and the Brazilian representative. Put the intended-purpose sentence, the Annex I rule, the Class I–IV result, and a yes/no DICD decision on one page. Attach the RDC 751/2022 English text and the RDC 837/2023 scope articles. If those four people cannot sign the page, do not book first-patient week. The calendar you save is not ANVISA’s — it is the month you would have spent unscrewing a class you never locked.

  • After First Patients: How to Sequence FDA/IDE Data and LATAM Registration

    Most founders treat Latin America as a trial geography until first patients are in, then treat it as a launch geography only after FDA has spoken. The post-FIH question is not “FDA first, then LATAM.” It is: what do you do with the same evidence package while the clock is still cheap?

    You already have ethics approvals, an investigational import path, and a first cohort. Two clocks now compete for the same documents: FDA use of that data (IDE, 510(k), De Novo, or PMA) and sanitary registration at ANVISA, INVIMA, COFEPRIS, and ANMAT. Mixing those clocks is how teams lose a year.

    The split that matters after first patients

    Clinical-trial authorization and sanitary registration are not sequential stamps of the same permit. They are different legal objects, usually held by different local entities, with different import codes and different labeling.

    • Trial authorization lets you treat patients under a protocol. The device arrives as an investigational product. The local face is often an importer of record (IOR) plus a site or CRO, not your future commercial holder.
    • Sanitary registration lets you sell. The device arrives as a commercial product. The local face is an authorized representative / registration holder. The label, IFU, and QMS evidence must match the marketed configuration—not the “we’ll lock it after the last implant” version sitting in the design-history file.

    Converting a trial import into a commercial shipment without a new holder, a new dossier, and a locked configuration is a new problem, not a paperwork update.

    What FDA actually accepts from the FIH you just ran

    OUS FIH data can support an IDE or a device marketing submission. That is not folklore. In February 2018 FDA issued a final rule on acceptance of data from clinical investigations of medical devices. FDA’s own summary is here: Acceptance of Data from Clinical Investigations for Medical Devices.

    The operative text lives in 21 CFR 812.28 (Subpart B). In short:

    1. FDA will accept information from a well-designed, well-conducted investigation conducted outside the United States to support an IDE or a device marketing application or submission if the investigation was conducted in accordance with good clinical practice (GCP) as defined in § 812.28(a)(1).
    2. GCP, as defined there, includes independent ethics committee (IEC) review and approval (or a favorable opinion) before initiation, continuing IEC review, and documented informed consent—except in the narrow life-threatening situations the regulation itself describes.
    3. The sponsor or applicant must submit the supporting information in § 812.28(b) (or a cross-reference to where it lives in the file), including a description of the actions taken to ensure the research conformed to GCP.

    Do not “clean the data later for FDA” while you send a different CSR to Latin America. One evidence room. If the FIH lacked IEC review, consent, monitoring, and traceable source, you have a feasibility anecdote, not a bridge.

    QMSR is the other quiet bottleneck. FDA’s quality-system expectations sit on ISO 13485 architecture. A LATAM holder who cannot produce design controls, CAPA, supplier control, and a PMS plan will stall a registro even when the clinical tables look fine.

    What you are actually waiting on after FIH

    After first patients, the calendar is usually waiting on you—not “the regulator.”

    1. Configuration lock. Registration is for a defined product, models, accessories, software version, and intended use. If you are still iterating the delivery system after patient 6, you are not registration-ready.
    2. A CSR or a disciplined interim. High-risk dossiers want clinical evidence, not a slide. File on a pre-specified locked interim or wait for last-patient-last-visit. That choice drives the country clocks below.
    3. The commercial holder, not the trial IOR. Brazil, Mexico, Colombia, and Argentina all require a local legal person to hold or promote the sanitary authorization. Appointing that holder after you “finish the study” is how you add a quarter you will never get back.
    4. Language and labeling. Portuguese IFU for Brazil. Spanish labeling for Mexico (NOM-137 is the usual label conversation), Colombia, and Argentina. English source files that are still in draft are not a translation problem; they are a lock problem.
    5. Import identity. Investigational import permissions expire with the trial. Commercial import needs a registration number, a holder, and a tariff/sanitary identity that matches the registered product.

    Four country clocks—registration, not trial

    These are market-access clocks. They are not the trial-authorization clocks you already ran.

    ANVISA (Brazil) — notification vs registro

    ANVISA’s English medical-device page states that equipment is premarket-authorized under two regimes: notification for risk Classes I and II, and marketing authorization (registro) for Classes III and IV, under the classification rules in RDC No. 751/2022. See ANVISA: Medical devices and the service page Solicitar registro de dispositivo médico.

    What that means after FIH:

    • The applicant company must already be regularized with ANVISA (CNPJ, Solicita access). A foreign legal manufacturer does not file as itself.
    • For Classes III and IV, ANVISA’s page is explicit that the manufacturing unit must hold a valid GMP certificate issued by ANVISA; the agency may accept a GMP-certification protocol at application, but effective approval depends on publication of the GMP certification. That is often the real Brazil clock—not the clinical tables.
    • The service page cites RDC 751/2022 (devices) and RDC 830/2023 (IVDs) and states that a granted registro is valid for 10 years from publication in the Diário Oficial da União.

    Do not reuse the trial import file for commercial launch. The trial IOR and the Brazil Registration Holder are often different companies. Align them before you translate the CSR.

    INVIMA (Colombia) — I/IIA automatic vs IIB/III prior evaluation

    INVIMA’s device pages describe the sanitary registration as the public document issued under Decreto 4725 de 2005 that authorizes production, import, and commercialization. See INVIMA: Dispositivos médicos y equipos biomédicos.

    The operational split after FIH is class, not “did we already run a trial in Bogotá”:

    • Risk I and IIA: automatic-style sanitary registrations / renewals when the file is complete.
    • Risk IIB and III: prior technical-legal evaluation. INVIMA’s own normograma material on the procedure states that the Institute will process IIB and III sanitary-registration or marketing-permit requests in 90 business days once the technical and legal requirements are complete, and that a single deficiency cycle gives the applicant 90 days to respond or the request is treated as withdrawn.

    FIH data helps the IIB/III file. It does not skip the holder, the unique INVIMA form, or Spanish labeling. A site that wants to keep using the device after the protocol closes has a registration problem, not an amendment.

    COFEPRIS (Mexico) — trial authorization is not registro sanitario

    Mexico is where sponsors most often confuse the two permits. DIGIPRiS is used for both clinical-research filings and device registros. They are still different authorizations.

    COFEPRIS publishes device-authorization material at Autorización de Dispositivos Médicos and the agency home at gob.mx/cofepris. Commercial entry is a registro sanitario promoted by a Mexico Registration Holder, with Spanish labeling and a technical monograph. Equivalence / abbreviated (reliance) routes exist when you already have a reference-authority approval; those routes are not a substitute for having a holder and a Spanish dossier.

    If the next FDA step is still an IDE, Mexico’s equivalence conversation is usually later. Treat trial-to-registration as its own workstream. Do not wait for a 510(k) number unless Mexico is explicitly “abbreviated after FDA.”

    ANMAT (Argentina) — HELENA is the commercial desk

    ANMAT’s product-medical page points commercial filings to Sistema HELENA for electronic registration of productos médicos (including IVDs). See ANMAT: Productos Médicos and the HELENA login at helena.anmat.gob.ar.

    HELENA is not your ethics committee. After FIH you need a locally enabled manufacturer/importer, a class-correct expediente, and Spanish files. Argentina looks “slow” when company habilitation and digital signature start after the CSR.

    A post-FIH sequence that does not fight itself

    A sequence I use when first patients are in and the board wants both a U.S. story and a LATAM revenue story:

    1. Week 0–2 after first-patient-in: freeze the commercial identity. Intended use, models, accessories, software baseline, sterile barrier, and the claims you are willing to put on a label. If the next three patients will change the device, you are still in design, not in registration.
    2. Week 2–6: stand up holders in the countries you will actually sell, not the countries you studied. A Panama or El Salvador FIH does not create an ANVISA or COFEPRIS registration. Pick the commercial four (or a subset) and appoint holders while enrollment continues.
    3. In parallel: FDA use-case for the same data. If the next U.S. step is an IDE, write the IDE as the primary consumer of the FIH package (GCP statement, IEC packet, monitoring, device accountability). If the next U.S. step is 510(k)/De Novo, decide whether FIH is supporting clinical evidence or only human-factors/feasibility color. That choice changes how hard you should push LATAM registration on interim data.
    4. Stagger the four LATAM files by what they wait on, not by national pride.
      • INVIMA I/IIA and ANMAT lower-class HELENA filings can often start as soon as the holder and Spanish admin file exist—clinical depth is lighter.
      • ANVISA III/IV waits on BGMP as much as on the CSR. Start the GMP petition the week you lock the manufacturing site, not the week you lock the tables.
      • COFEPRIS standard registro can start on a complete Spanish monograph; save equivalence/abbreviated for when you actually have a reference-authority approval to lean on.
    5. Do not file four countries on four different device descriptions. One source IFU, four translations. One PMS / tecnovigilancia plan architecture, four local implementations. One complaint-handling owner.

    Three sequencing mistakes I still see after first implants

    1. Using the trial IOR as the future registration holder “to save a contract.” Cheap in month one. Expensive when you want to change distributors, add a second importer, or survive an inspection.
    2. Waiting for FDA clearance before opening any LATAM registro because “reliance will be faster.” Reliance is real in Mexico when you have something to rely on. It is not a reason to delay holder appointment, translations, or Brazil GMP.
    3. Sending LATAM a marketing brochure version of the FIH while sending FDA a GCP package. Reviewers talk. More importantly, your own QMS will not survive two truths about the same study.

    One tactical next step

    This week, build a one-page post-FIH evidence map: FDA plus the LATAM countries you will actually file, and three rows—(1) what is locked (protocol, IEC letters, device version), (2) what is open (CSR date, GMP, holder, translations), (3) the first document each agency is waiting on that is not “more patients.” Share it with regulatory, quality, and the person who signs import paperwork. If those three people cannot point to the same configuration and the same holder, you are hoping, not sequencing.

    Disclosure: I am CEO of bioaccess®, a FIH/EFS medical-device CRO and LATAM launch/in-country-holder group. The sequencing above is how I tell sponsors to think about the calendar; it is not a pitch for a particular vendor to hold your registration.

  • Brazil’s 90 Day Clinical Trial Clock: A Practical Activation Playbook For First-In-Human Studies

    Brazil’s 90-Day Clinical Trial Clock: A Practical Activation Playbook for First-in-Human Studies

    For MedTech founders and regulatory leaders, Brazil has quietly become one of the most “plannable” countries in Latin America for early-stage clinical activation. A core reason is Brazil’s recent legal and regulatory modernization, which introduced a defined review window and clearer guardrails for starting studies.

    This article translates the change into a sponsor-facing activation playbook: what the 90-business-day clock means, how it interacts with ethics approvals, and what you should build into your timeline to avoid rework. The goal is not to “rush” a trial—it’s to make your activation schedule predictable and audit-ready.

    1) What changed in Brazil (and why it matters for FIH planning)

    Brazil’s Law No. 14.874/2024 established a national system of ethics in research involving humans and introduced a defined 90-business-day review window for ANVISA’s assessment of clinical trial applications that support marketing authorization.

    In practical terms, this is a planning upgrade. Sponsors can build a realistic activation calendar, align manufacturing and logistics windows, and avoid “open-ended” waiting periods that often inflate costs in early-stage programs.

    Importantly, Brazil still requires both ethics approval and ANVISA approval before initiation. However, the rules allow parallel submission so you can run key workstreams concurrently rather than serially.

    2) The activation sequence: ethics, ANVISA, and parallelization

    For most sponsors, the fastest compliant path is a two-track plan:

    • Track A (Ethics): prepare site documents, informed consent, investigator materials, and submit to the local ethics committee process.
    • Track B (Regulatory): prepare the ANVISA dossier and submit in parallel, ensuring your package is consistent with what ethics committees will see.

    A common pitfall is treating ethics and regulatory packages as separate artifacts. Instead, use a single “source of truth” for protocol versioning, risk language, endpoints, and safety reporting workflows.

    3) Don’t miss the hidden gating item: the trial-specific dossier

    Brazil’s process includes a key practical requirement: ANVISA’s technical analysis of the primary petition may depend on the filing of a trial-specific dossier. That means your internal readiness must include not only the umbrella development dossier, but also at least one trial-specific submission with the minimum documentation set.

    Operational takeaway: build your activation plan around “dossier completeness” milestones, not just “submission sent.” Sponsors who plan only to the submission date often discover late-stage gaps in translations, investigational product documentation, or safety reporting alignment.

    4) What “decurso de prazo” means (and what it does NOT mean)

    Brazil’s reforms also created an important concept often summarized as decurso de prazo: if the health authority does not issue a decision within the legal timeline and the study has the required ethics approvals, clinical development can begin.

    For sponsors, this is best treated as a risk-managed backstop rather than a default strategy. Your activation plan should still assume you will operate with an explicit authorization outcome and complete documentation. Use the statutory timeline to reduce uncertainty—not to reduce diligence.

    5) A sponsor-ready 90-day activation checklist

    If you want to benefit from predictable timelines, your internal systems must be “startup-ready” before the clock runs out. Here is a checklist that consistently prevents avoidable delays:

    • Regulatory narrative consistency: protocol synopsis, device/drug description, intended use, and risk statements match across all documents.
    • Import and labeling readiness: confirm investigational supply chain steps, packaging needs, and local labeling conventions early.
    • Safety workflow: clear SAE reporting path, vendor responsibilities, and escalation coverage (including weekends/holidays).
    • Data integrity: eCRF, source templates, and monitoring plan support inspection readiness from Day 1.
    • Site enablement: training plan, delegation logs, and equipment calibration records are not afterthoughts.

    6) How to use Brazil strategically inside a Latin America multi-country plan

    Many early-stage sponsors run a multi-country Latin America strategy to balance speed, cost, and enrollment diversity. Brazil’s clearer timeline can play multiple roles:

    • Anchor country: you plan your “first patient in” forecast around a predictable activation window.
    • Evidence builder: you generate high-quality data to support later reimbursement or regulatory submissions elsewhere.
    • Operational benchmark: you standardize SOPs and monitoring routines that can be replicated across the region.

    The key is harmonization: standardize your core protocol and quality system while adapting country-level workflows (ethics requirements, import pathways, and contracting norms).

    FAQ

    Does Brazil still require ethics approval before starting a clinical trial?

    Yes. Sponsors should plan for both ethics and regulatory authorization and use parallel workstreams to compress time without compromising compliance.

    Is the 90-business-day period a guarantee that my trial will be approved?

    No. It is a defined review window that improves predictability; approval still depends on dossier completeness and meeting regulatory and ethical requirements.

    What is the biggest activation mistake sponsors make in Brazil?

    Underestimating the time to assemble a trial-specific dossier and align all documents (protocol, consent, IP description, safety reporting). “Submitted” does not equal “complete.”

    Bottom line: Brazil’s reform is a planning advantage. Sponsors who pair it with disciplined document control, parallel submission strategy, and site readiness can reduce activation uncertainty—one of the most expensive problems in early-stage trials.

  • A Practical Regulatory Timeline For First-In-Human Medical Device Studies In Latin America (2026)

    A Practical Regulatory Timeline for First-in-Human Medical Device Studies in Latin America (2026)

    For MedTech founders and regulatory directors, Latin America can be the fastest path to a first-in-human (FIH) medical device milestone—if you treat timeline as an operational deliverable, not a hope. The region is not a single market: documentation, ethics review cadence, import steps, and contract mechanics vary by country and by whether your study is observational, non-significant risk (NSR), or significant risk.

    This article provides a practical way to plan an FIH device study timeline across Latin America in 2026: what workstreams to run in parallel, where delays typically occur, and how to de-risk your critical path without compromising compliance or participant safety.

    1) Start with a “workstream map,” not a single Gantt chart

    FIH device studies commonly stall because sponsors build one linear plan when the reality is a set of interdependent workstreams. A useful planning framework separates your launch into seven workstreams, each with its own owners, documents, and review cycles:

    • Protocol package (protocol, IB/IFU, risk analysis, monitoring plan, DSMB plan if needed)
    • Country regulatory submission (device classification/route, authority forms, translations, legalization requirements if any)
    • Ethics approval (central/local IRB/ethics committee workflow, consent language, recruitment materials)
    • Site contracting & budgets (CTA, indemnification, insurance certificates, payment triggers)
    • Import & logistics (shipping lanes, customs broker readiness, temp-control, labeling)
    • Site activation (SIV readiness, staff training, device accountability tools)
    • First patient in (FPI) (screening plan, recruitment levers, backup sites)

    When these workstreams are run deliberately in parallel, many sponsors can compress timelines materially versus the “submit, wait, then do the next thing” approach.

    2) A realistic 2026 timeline template (what to do in each month)

    Every program differs, but for early-feasibility or FIH device studies, a practical timeline template often looks like this:

    • Weeks 0–2: Feasibility + site shortlist. Confirm patient pool, investigator interest, imaging/lab capabilities, and whether your endpoints are standard-of-care in that setting.
    • Weeks 1–4: Submission-ready document set. Build the “country-ready” version of the protocol package: consistent terminology, device description aligned with IFU, and localized consent templates.
    • Weeks 3–8: Parallel ethics + regulatory preparation. Prepare authority-specific forms while the ethics packet is being finalized; do not wait for final contracts to start regulatory readiness.
    • Weeks 6–12: Contracts, budgets, and insurance. In many countries, the slow step is not scientific review but the negotiation of indemnification clauses, invoice rules, and insurance wording.
    • Weeks 8–14: Import and first shipment readiness. Align labeling, airway bills, and broker processes early; confirm whether your device is shipped as commercial goods, samples, or study materials and plan accordingly.
    • Weeks 12–18: SIV + site activation. Execute training, device accountability procedures, and data capture dry runs.
    • Weeks 16–24: FPI window. A strong screening plan and backup sites protect you from “approval achieved, recruitment delayed.”

    Rather than treating “approval” as the finish line, treat it as the midpoint: you still need operational readiness to reach FPI.

    3) Where timelines slip (and how to protect the critical path)

    Across Latin America, recurring delays tend to cluster into a few categories:

    • Translation and document consistency issues. Inconsistencies between protocol, IFU, and consent language trigger rework during ethics review.
    • Contract sequencing mistakes. If you wait for final CTA language before starting budget alignment or insurance certificates, you create avoidable idle time.
    • Import readiness left too late. Even when the device is low-risk, shipments can be rejected if labeling, documentation, or declared values are unclear.
    • Over-reliance on a single site. A single high-performing hospital is not a recruitment strategy; build a backup shortlist early.

    Two simple practices prevent many timeline slips: (1) run a weekly “document control” check to keep all versions synchronized, and (2) hold a pre-import readiness call with your broker and study team before any shipment is booked.

    4) Country selection: choose based on constraints, not hype

    Latin America offers multiple attractive options, but the best country for your FIH study depends on constraints:

    • Need speed? Prioritize clear ethics pathways, experienced investigators, and predictable import lanes for study materials.
    • Need specific patient phenotypes? Choose where that patient population is concentrated and where endpoints align with standard clinical practice.
    • Need imaging or specialized procedures? Ensure site infrastructure and maintenance/QA standards can support your device and endpoints.

    A practical rule: pick the country where your operational bottleneck is easiest to solve. If your bottleneck is import complexity, choose the market where your logistics and broker experience is strongest. If your bottleneck is investigator capability, choose the market with the deepest specialty network.

    FAQ

    • How long does an FIH device study typically take to reach first patient in (FPI) in Latin America?
      Many sponsors plan a 4–6 month window from kick-off to FPI when workstreams run in parallel, but timelines depend on device risk, required reviews, contracting speed, and import readiness.
    • What is the most common avoidable delay?
      Contracting and insurance language misalignment, followed closely by late import readiness and inconsistent translated documents.
    • How can sponsors reduce timeline risk without cutting corners?
      Use a workstream map, keep document versions synchronized, and build redundancy (backup sites, backup shipping lanes, and a recruitment contingency plan).

    Bottom line: In 2026, sponsors that treat Latin America FIH timelines as an integrated regulatory-and-operations program—rather than a single “submission” event—can reach FPI faster and with fewer surprises.

  • Brazil’s 90 Day Clinical Trial Review Cap: What Medtech Sponsors Should Do Before Submitting

    Brazil’s 90-Day Clinical Trial Review Cap: What MedTech Sponsors Should Do Before Submitting

    Brazil has moved from being a “high-potential but unpredictable” country for early-stage MedTech studies to a jurisdiction with a defined statutory review clock. For sponsors, that shift is not just a speed story — it is a planning story. When review timelines become shorter and more predictable, the relative impact of preventable sponsor-side errors gets larger.

    This article is written for MedTech founders, clinical operations leaders, and regulatory directors who want to run first-in-human (FIH) or early feasibility work in Brazil without losing weeks to rework. We focus on what you can control before submission: dossier readiness, ethics strategy, local operational prerequisites, and vendor orchestration.

    Why a faster regulatory clock changes the sponsor playbook

    Short timelines compress decision-making. If you used to “fix it after ANVISA feedback,” you may no longer have that luxury — because site contracts, import permits, radiology workflows, and ethics committee coordination can become the rate-limiting steps. A faster clock also forces clearer internal governance: who owns the final protocol, the risk assessment, the device technical file, and the country-specific annexes?

    Practically, the sponsor question becomes: How do we arrive at Day 0 with no missing pieces? The goal is to avoid pauses caused by translation gaps, document format mismatches, incomplete investigator packages, or unaligned device documentation.

    Pre-submission checklist: what to lock down before Day 0

    • Protocol version control: Confirm the final protocol, synopsis, schedule of assessments, and statistical plan are aligned — and that the same versions appear in every submission component.
    • Risk classification and device description: Ensure the device description, intended use, instructions for use, and risk analysis are consistent across documents. Inconsistency is one of the most common sources of questions.
    • Investigator and site packages: Collect CVs, training evidence, GCP documentation, and site capabilities early. In Brazil, the operational readiness of sites can become as important as the regulatory dossier.
    • Translations and local formatting: Build time for Portuguese localization and formatting checks. A strong translation is not only linguistic — it must preserve clinical meaning and match annex references.
    • Informed consent strategy: Prepare consent language that is clear, compliant, and aligned to local norms. If your device includes software, connectivity, or data transfer, incorporate that into consent and data handling text.
    • Import and logistics planning: Map the path for device shipment, labeling, and storage. Even for non-radioactive devices, customs, temperature needs, and distribution responsibilities can derail timelines.

    Parallel ethics + regulatory review: how to operationalize it

    When a system allows parallel tracks, the bottleneck often shifts to coordination. Sponsors should treat ethics submission as a project with its own critical path, not as an administrative afterthought. Build a unified submission calendar and align on:

    • Sequence of internal approvals: Decide who signs off on ethics content and who owns final responses.
    • Site-by-site variance: Even with a national framework, each site can introduce operational nuance. Standardize as much as possible, but plan for local adjustments.
    • Response management: Pre-write response templates for common questions (risk/benefit, recruitment strategy, device safety, data management) so you can move quickly.

    For FIH and early-stage work, ethics committees will often focus on patient protection and feasibility: training, emergency procedures, follow-up, and the practical ability of the site to manage adverse events. Your dossier should show readiness, not just compliance.

    What MedTech sponsors often underestimate in Brazil

    Speed-friendly frameworks do not eliminate complexity; they amplify the cost of under-planning. The most common underestimates include:

    • Data and privacy workflows: If your study uses digital endpoints or remote monitoring, align data flows, storage, and access controls early.
    • Device accountability: Plan how devices will be tracked, stored, returned, and reconciled. Accountability gaps create audit risk and can slow activation.
    • Training: Documented training is not optional in early-stage device studies. Build training into your timeline and capture evidence systematically.
    • Vendor interdependencies: CRO, imaging core lab, shipping/logistics, and local regulatory support must operate from the same timeline assumptions and document set.

    FAQ

    1) Does a statutory review cap guarantee approval in 90 days?
    No. A cap can improve predictability, but the practical timeline still depends on dossier quality, completeness, and how quickly questions are resolved.

    2) Should we treat Brazil as a first-choice country for FIH studies?
    Brazil can be compelling when the patient population, investigator expertise, and activation path fit the product. Sponsors should evaluate Brazil alongside other Latin American jurisdictions based on feasibility, ethics speed, and operational readiness.

    3) What’s the biggest sponsor-side mistake?
    Submitting with misaligned documents (protocol vs. device description vs. risk file) and assuming issues can be fixed “during review.” In faster systems, that approach often costs more time, not less.

    Bottom line: If your goal is to capture the benefit of a faster review framework, your work starts well before Day 0. A sponsor-side checklist — executed early — is often the difference between a fast approval and a slow cycle of preventable questions.

  • Brazil’s 2025 Clinical Research Rulebook: What Early-Stage Sponsors Should Do Differently

    Brazil’s 2025 Clinical Research Rulebook: What Early-Stage Sponsors Should Do Differently

    Brazil continues to be one of the most important anchors for early-stage clinical development in Latin America, but the compliance baseline is moving. In 2026, Anvisa highlighted that Brazil’s clinical research environment has been updated through Law No. 14.874/2024 (ethical aspects of research with human beings) and the newer regulatory package RDC 945/2024 plus IN 338/2024 for clinical research supporting registration of medicines, which Anvisa notes took effect in early 2025 (Anvisa).

    For MedTech founders and regulatory directors planning first-in-human (FIH) or early pivotal work in the region, the strategic opportunity remains: access to experienced investigators, high-quality sites, and diverse patient populations. The operational requirement, however, is to design submissions, vendor oversight, and essential documentation so you can demonstrate control at any moment—especially as inspection programs mature.

    1) What changed in Brazil’s research governance—and why it matters for sponsors

    Anvisa’s 2025 activity reporting explicitly connects the new ethical law and the updated clinical research regulation to the agency’s current oversight approach (Anvisa). In parallel, Anvisa’s inspection metrics reporting emphasizes inspection readiness against GCP expectations (ICH E6 (R2) or updates) while referencing RDC 945/2024 and Law 14.874/2024 as part of the inspection framework (Anvisa).

    Practical takeaway: even when timelines are competitive, sponsors should assume that documentation quality, vendor governance, and data integrity controls will be evaluated more explicitly. This is good news for well-prepared early-stage teams: strong fundamentals can shorten back-and-forth with sites and reduce downstream remediation.

    2) A sponsor-ready timeline: how to think about “FIH speed” without compliance debt

    Internal execution experience across Latin American programs repeatedly shows that speed usually breaks down in predictable places: incomplete essential documents, misaligned responsibilities between sponsor and CRO, and late-stage changes to protocol and informed consent artifacts. Treat “speed” as a systems outcome rather than a hero effort.

    • Pre-submission (4–8 weeks): lock protocol operational feasibility, confirm investigational product/device logistics, and establish a document control plan.
    • Submission-ready package: create a single source of truth for protocol, IB/IFU (as applicable), safety reporting plan, and data handling plan.
    • Site activation: standardize training, delegation, and vendor onboarding so the first site is not a one-off build.

    Many startups underestimate that “time to first patient” is often constrained by operational readiness, not just authority review. Investing early in a repeatable activation model is one of the highest ROI moves you can make.

    3) Inspection readiness: build once, benefit for years

    Anvisa’s inspection metrics report notes its focus on inspections conducted in 2024 and 2025 and positions inspections as a tool to protect participants and data integrity (Anvisa). For early-stage sponsors, the implication is clear: build inspection readiness into your operating rhythm rather than treating it as a “phase 3 problem.”

    Start with five non-negotiables:

    • Essential document discipline: version control, signatures, and clear ownership.
    • Delegation and training: role-based training mapped to tasks; keep it auditable.
    • Deviation and CAPA workflow: define severity levels and timelines; trend issues.
    • Vendor oversight: documented qualification, KPIs, and periodic review for CROs, labs, and logistics partners.
    • Data integrity: audit trails, access controls, and reconciliation between source, eCRF, and safety database.

    4) How to operationalize this across Latin America (not just Brazil)

    Brazil is rarely the only country in a Latin America strategy. Use Brazil as the quality anchor and replicate the same operating system across additional countries. You can localize what must be localized (ethics committee formats, language, import processes), while keeping your core compliance artifacts stable.

    A useful mental model: create a regional master file (core documents, SOPs, training), plus country modules (local submissions, contracts, import permits), plus site modules (delegation, logs, training, monitoring).

    FAQ

    When did Brazil’s latest clinical research regulations take effect?
    Brazil’s updated framework referenced by Anvisa includes Law 14.874/2024 (in force since 29 Aug 2024) and RDC 945/2024 plus IN 338/2024 (effective 2 Jan 2025).

    Do these changes apply to medical devices too?
    The Anvisa updates cited relate to clinical research for registration of medicines and biologics; device sponsors should still align operational quality systems and inspection readiness to ICH GCP expectations and local ethics requirements.

    How should startups prepare for inspection readiness?
    Build inspection-ready documentation from day one: role-based training, version-controlled essential documents, delegation logs, deviation management, and vendor oversight that can be demonstrated quickly.

    Need help designing a Latin America FIH plan? bioaccess® supports sponsors with regional feasibility, activation, and execution strategies built for speed and inspection readiness.

  • First-In-Human In Brazil In 2026: A Practical Timeline For Sponsors

    First-in-Human in Brazil in 2026: A Practical Timeline for Sponsors

    Primary keyword: first-in-human trial Brazil timeline

    Brazil is increasingly on the shortlist for early-stage clinical development because sponsors can combine a large patient base with growing regulatory clarity. A recent policy analysis argued that Lei 14.874 de 2024 created the basis for a more predictable environment and, for the first time, establishes timelines and greater regulatory clarity for clinical studies.

    This article gives a practical, sponsor-side timeline for launching a first-in-human (FIH) study in Brazil in 2026—what to do first, what typically slows teams down, and how to sequence work so you do not lose weeks to preventable back-and-forth.

    1) Define the “Brazil-ready” FIH package (Weeks 0–2)

    Before any submission, align internal stakeholders on what “Brazil-ready” means. For most MedTech and biopharma sponsors, FIH readiness is not only a protocol question—it is also a documentation and site execution question.

    • Protocol and IB alignment: Ensure endpoints, safety monitoring, and dose-escalation logic are consistent with your global plan.
    • Country adaptations: Identify what must be localized or supplemented (consent language, site materials, labeling, and investigator documentation).
    • Feasibility assumptions: Confirm whether required imaging, lab, or procedural capabilities exist at target sites.

    Internal best practice: Create a single “FIH Brazil master checklist” with owners and due dates. Treat it as a deliverable, not an afterthought.

    2) Select sites for speed, not just prestige (Weeks 1–4)

    In FIH, startup speed is highly correlated with site readiness. Sponsors often choose sites based on reputation, then discover contracting and operational realities late.

    • Prioritize operational maturity: Look for sites with dedicated research staff, established ethics processes, and experience with sponsor audits.
    • Validate recruitment pathways: Treatment-naive populations can be an advantage, but referral networks still matter.
    • Assess import and handling constraints: If your study uses temperature-sensitive materials, confirm storage and chain-of-custody procedures early.

    3) Build a parallel workstream plan (Weeks 2–6)

    The most common timeline mistake is running tasks sequentially that can be executed in parallel. Even when formal review clocks improve, sequential execution can erase the benefit.

    To compress time, run these workstreams at the same time:

    • Regulatory dossier preparation (quality, safety documentation, and trial authorization package)
    • Ethics submission package (site-specific documents and consent)
    • Contracts and budgets (CTA, indemnities, payment schedules, and monitoring model)
    • Supply and logistics readiness (import planning, labeling, storage validation, and back-up scenarios)

    Even when legal reforms aim to improve predictability, sponsors still need coordinated execution across stakeholders to realize those gains.

    4) Anticipate “hidden” startup time: contracts, import, and training (Weeks 4–10)

    Even when review timelines are favorable, sponsors can lose time after approvals due to operational bottlenecks:

    • Contract negotiation cycles: Build buffer time for legal review, redlines, and institutional sign-off.
    • Import and release: If your investigational product or device must be imported, confirm lead times and documentation requirements early.
    • Site initiation and training: FIH trials require strict adherence to safety procedures; schedule training sessions while approvals are in progress.

    Practical tip: Maintain a “go-live readiness dashboard” that tracks contract status, shipment readiness, and training completion. This prevents surprises when the green light arrives.

    5) A sponsor-friendly 2026 FIH timeline (example)

    Every program is different, but a realistic planning template looks like this:

    • Weeks 0–2: Brazil-ready protocol package, checklist, and internal alignment
    • Weeks 1–4: Site selection, feasibility, and early budget/CTA drafts
    • Weeks 2–6: Parallel dossier + ethics package finalization
    • Weeks 4–10: Contracts, import planning, training, and vendor setup
    • Weeks 10–14: Final site activation steps and first-patient readiness

    If you are aiming for speed, measure time-to-ready as rigorously as you measure time-to-approval. In many FIH programs, the fastest sponsors are simply the ones that avoid rework.

    FAQ: First-in-human trial Brazil timeline

    • How long does it take to start a first-in-human trial in Brazil?
      Timelines vary by protocol complexity and site readiness, but sponsors should plan for parallel regulatory and ethics pathways, early document localization, and realistic contracting and import lead times.
    • What is the biggest cause of FIH delays in Brazil?
      In practice, delays often come from incomplete documentation, late site selection, and underestimated startup logistics (contracts, import permits, and investigational product readiness), not just the formal review clock.
    • Can Brazil FIH data support US or EU submissions?
      Yes, when the trial is designed to international GCP standards and endpoints align with your global regulatory strategy, Brazilian data can be part of a broader evidence package.

    Need help planning an FIH startup in Brazil or across Latin America? bioaccess® supports sponsors with country startup planning, site activation, and operational execution—without exposing confidential details publicly.