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In the United States, by contrast, Phase I trials typically require submission of an Investigational New Drug (IND) application to the U.S. Food and Drug Administration before initiation. This dual review — by both an IRB and the federal regulator — creates redundancy that lengthens the feedback loop. A CTN-like model for Phase I trials could preserve safety oversight while shifting scientific and toxicological reviews to accredited, transparently governed IRBs with expanded expertise. The FDA would retain the power to inspect, impose clinical holds, and intervene in high-risk cases, such as for novel gene therapies. But for the majority of small-molecule first-in-human studies, the default could be notification rather than permission.

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In May 2019, the 0 bar is rendered to be 55%, meaning on 55% days of that month I didn't drink any alcohol

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