The Role of Standards in U.S. FDA Regulation of Cellular Therapy Products

Similar documents
Mitochondrial Manipulation Technologies: Preclinical Considerations

Cell Therapy Product Manufacturing Considerations. July 17, 2017 CMC Strategy Forum Mo Heidaran, Ph.D.

FDA Update. Scott A. Brubaker, CTBS Director, Division of Human Tissues Office of Tissues and Advanced Therapies CBER/FDA

FDA Regulatory Updates: Related to Cancer Immunotherapy

Regulatory considerations for manufacturing and testing of investigational chimeric antigen receptor (CAR) T-cell products

FDA Oversight of Gene Therapy

US FDA and International Regulatory Efforts in Cellular and Gene Therapies

Regulatory Approval of Modern Gene-Based Cancer Immunotherapies CAR T Cells A product perspective

The Target Product Profile (a Regulatory Perspective)

A Life Cycle Approach to Raw Material Qualification for Cell and Gene Therapy Products

Pre Pre-IND and Pre-IND Interactions for Cell and Gene Therapy Products

Tissue Engineered Medical Products

CMC Considerations for Stem Cell-based. Donald W. Fink, Jr., Ph.D.

Topic 05 Standards in Biomedical Informatics Part 1

Regulatory Pathways for Rare Diseases

Regulatory science insights into cellular products and practical microscale technologies for their assessment

Regulatory Implications for Global Manufacturing Development of Regenerative Medicines

Regulatory Perspectives on Gene Therapies for Rare Diseases Rare Diseases Forum Washington, D.C. October 17, 2018

Cellular and Gene Therapy Products - CBER Update

Established Conditions: Reportable CMC Changes for Approved Drug and Biologic Products Guidance for Industry

Development of Regenerative Medicine Products: FDA Perspectives

CBER Regulatory Updates: Initiatives for Product Review and Licensure

The FDA/CDRH Perspective in the Regulation of Surgical Mesh

Regulation of Biologics in The United States: From a Rich Tradition To A Challenging Future

Synopsis: FDA Process Validation Guidance

Product Testing & Release. PACT Workshop: Design & Operation of GMP Cell Therapy Facilities April 4 th /5 th, 2006

SALDA In Vitro Diagnostics in South Africa. Welcome. December 2015

Supplies and Reagents

Supplies and Reagents

US FDA: CMC Issues for INDs

Educational Web Seminar Ask the Experts

Overview of FDA Regulations and Guidance Documents related to PET Drug Chemistry. Steve Zigler, Ph.D. Siemens PETNET Solutions

Medidée Services SA. Nano-Tera.ch. 05 February 2015 part 8. PMA, 510k, IDE. Pierre-Alain Sommer

The Role of a Notified Body in Defining Risk Assessment for a Recombinant Protein Used in a Medical Device Case Study

CDRH Scorecard Metric Determination. Presentation to the Balanced Scorecard Interest Group March 17, 2005

Clinical Development of Gene Therapy: Safety Evaluation and Monitoring

CMC Writing for IND Applications. David H. McKenna, Jr., M.D. University of Minnesota PACT Web Seminar II July 14, 2005

OMB A What Are The Goals Of The Government In Using Voluntary Consensus Standards?

CBER Regulation of Devices for Cell Therapy

Replacing Analytical Methods for Release and Stability Testing CBER Perspective

Document issued on: March 19, The draft of this document was issued on May 20, 2010.

The Role of Chemists in the FDA Drug Approval Process

Presentation Outline

Strategies for IND Filing Success: Chemistry, Manufacturing and Controls

Medical Devices; Immunology and Microbiology Devices; Classification of the Automated

Guidance for Industry

PACIFIC RIM CONSULTING COMMENTS ON FDA PROPOSAL TO REVISE GLPS

Scott Colburn, CAPT USPHS Director, FDA/CDRH Standards Program

Services for Medical Devices. Expert solutions for product development from concept to commercialization

Structure and Mandate of FDA

Chin Koerner Executive Director US Regulatory and Development Policy

LDT Review: The New York Experience

Safa Karandish Office of Tissues and Advanced Therapies Division of Human Tissues. Pharma Conference February

American Academy of Forensic Sciences Standards Board, LLC

Regulatory requirements for cell based medicinal products

Global Regulatory Perspectives

Drug-Device Combination Product Development: INDs for Device Companies

Osteobiologic B O N E G R A F T I N G S O L U T I O N S

Medical Devices; Exemption From Premarket Notification; Class II Devices; Autosomal

Overview of Biologics Testing and Evaluation: Regulatory Requirements and Expectations. Audrey Chang, PhD, Senior Director Development Services

ISBT 128 and the Single European Code

Enhancing Laboratory Data Infrastructure to Access Real-World Evidence (RWE) for in vitro Diagnostics (IVDs): Three Models for RWE Use

Beth Hutchins, PhD PhRMA ICH Gene Therapy Discussion Group

Raw Materials: Sourcing and Qualification Testing

IDE Submissions for Devices Used to Manufacture Cell Therapy Products

Point-of-Care Cell Processing Devices A Manufacturer s Perspective Clinical trials, regulatory compliance, and commercialization.

How to Avoid Common Deficiencies in INDs and NDAs. Ramesh Raghavachari, Ph.D. Branch Chief, Branch IX ONDQA/OPS/CDER

Tina Morrison, Ph.D. Chair, Committee on Modeling and Simulation Office of the Chief Scientist U.S. Food and Drug Administration

Introduction to the FDA. Historical Context. Changes over Time FDA - BE-200 9/23/2004. Copyright C. S. Tritt, Ph.D. 1

Preparing for a United States Food and Drug Administration (FDA) Inspection: VOICE

Medical Devices; Immunology and Microbiology Devices; Classification of the Automated

Method Validation Studies How GLP Interacts With Guidance Documents

Effective Management and Operations of GXP Laboratories

Bioresearch Monitoring Inspections in Vitro Diagnostics Devices

Alliance for Regenerative Medicine

Greg LeBlanc Dir. Regulatory Affairs and Quality Systems Cook (Canada) Inc.

Global Clinical Trials in Korea

OUR MISSION OUR EXPERTISE OUR SERVICES

Agenzia Italiana del Farmaco

March 19, Division of Dockets Management (HFA-305) Food and Drug Administration 5630 Fishers Lane Room 1061 Rockville, MD 20852

Bipartisan Policy Center, Top Medical Innovation Priorities

Production Assistance for Cellular Therapies PACT

IND - Cell Therapy. Robert W. Lindblad, MD, FACEP. Where Did you Hear

ADB Consulting & CRO Inc.

AAMI s Medical Device Standards Program

Standards for biomaterials in tissue engineering

Molecular Diagnostics: The Shift to Complexity. Molecular Diagnostics Regulation: Where do we go from here? David W Feigal, Jr.

Regulatory considerations for Global Haplobank

Perspectives on Rare Diseases

Cell Therapy Services Your Product. Our Passion.

Introduction to CMC Regulatory Affairs

The Role of Mass Spectrometry for Developing Biotherapeutics: Regulatory Perspectives

FDA Perspective on the Preclinical Evaluation of Biological Therapies for Cancer

RE: Docket No. FDA 2017 N 0041: Agency Information Collection Activities; Proposed Collection; Comment Request; Safety Assurance Case

Question-based Review (QbR)

What is biomedical science?

Regulation of Cell and Gene Therapy Products in Canada

CTLM Cell Therapy Liaison Meetings

Division of Dockets Management (HFA-305) Food and Drug Administration 5630 Fishers Lane, rm Rockville, MD 20852

Medical Devices; Immunology and Microbiology Devices; Classification of the Next Generation

Transcription:

The Role of Standards in U.S. FDA Regulation of Cellular Therapy Products Judith Arcidiacono M.S. International Regulatory Expert Standards Development Activities Liaison U.S. Food and Drug Administration Center for Biologics Evaluation and Research Office of Cellular, Tissue and Gene Therapies

Scope of Presentation FDA Policy for Standards Activities Terminology Used for Standards Examples of Standards for Cell Therapy Products 2

FDA Policy on Standards Activities FDA s Staff Manual Guide (SMG 9100.1) establishes Agency-wide policies and procedures related to standards management to assure a unified approach to standards within the FDA Regulations governing participation in standard setting activities, 21 CFR 10.95 (a), FDA encourages employee participation in outside standard-setting activities that are in the public interest 3

Agency Expectations for Employees Individuals who interact with Standards Development Organizations (SDOs) must do so clearly on behalf of the Center, the Agency, and the Department, and in a manner that assures all information or input provided reflects the positions of the Center, the Agency, and the Department. Provide routine updates on SDO engagement to the leadership in Center/Office 4

Benefits of Standards Development Address issues not covered by FDA Guidance Facilitate the development and maintenance of FDA Guidance Facilitate product design Improve time to market Leverage industry efforts May lead to international harmonization 5

Developing performance characteristics Testing methodology Manufacturing practices Product standards Possible Areas for Standardsetting Activities Scientific protocols Compliance criteria Ingredient specifications Labeling, and other technical or policy criteria 6

Terminology Used for Standards 7

Definition: Standard Common and repeated use of rules, conditions, guidelines, or characteristics for products or related processes and production methods, and related management systems practices. OMB Circular A-119 8

Regulations vs. Standards Regulations Government implementation of statues that have the force of law Define specific requirements for safety Provide accurate information to health professionals and consumers Standards Voluntary Frequently developed outside of the government Written standards describe how manufacturers might meet regulatory requirements Physical standards provide benchmark materials 9

Types of Standards Voluntary Consensus Non-consensus Physical Standards/Reference Materials Accreditation Standards Harmonization Standards ICH WHO 10

Definition: Voluntary Consensus Standard Standards developed or adopted by voluntary consensus standards bodies, both domestic and international. Voluntary consensus standards include provisions requiring that the owners of relevant intellectual property agree to make that intellectual property available on a nondiscriminatory, royalty-free or reasonable royalty basis to all interested parties 11

Definition: Standards Development Organization An SDO is an entity that develops or sponsors the development of voluntary standards for the use of information by any person involved in the manufacture, distribution, sale, or use of products or services or legal regulation of such products and services. SMG 9100.1 12

SDO Accreditation American National Standards Institute (ANSI) Provides interested US parties with a neutral venue to work towards common agreements Process guided by consensus, due process, and openness Ensures access to the standards including an appeals mechanism for interested parties. 13

Non-Consensus Standards Standards developed in the private sector, not with consensus e.g. industry standards, company standards, professional practice standards Government unique standards Developed by the U.S. government for its own use Standards mandated by law e.g. Prescription Drug User Fee Act (PDUFA V) 14

Definition: Physical Standards/ Reference Materials Highly characterized reagents that are distributed to assure consistency, quality and safety. Reference materials are materials that are sufficiently homogeneous and stable with respect to one or more specified properties, and have been established to be fit for its intended use in a measurement process. 15

Accreditation Standards Accrediting organizations that are not accredited by ANSI (do not meet the definition of a voluntary consensus SDO) AATB (tissue banking) AABB (blood and tissue banking) FACT (cellular therapy) ICCBBA (blood, tissue identification & labeling) 16

Harmonization Standards World Health Organization (WHO) Written standards WHO Requirements, Recommendations and Guidelines Physical Standards for manufacture and control of biological products WHO standards are applicable to US FDA products and may be used at various stages of product development 17

Harmonization Standards (continued) International Conference on Harmonisation (ICH) Q4B Pharmacopoeial Harmonisation Interchangeable pharmocopeia methodsidentified in FDA Guidance http://www.fda.gov/scienceresearch/specialto pics/runningclinicaltrials/guidancesinformation sheetsandnotices/ucm219488.htm Joint Initiative on SDO Global Health Informatics- electronic standards 18

Standards Recognition/Use Recognition - a term proscribed by the medical device legislation (FD&C ACT 514(c)) describing the process used by FDA Center for Devices and Radiological Health (CDRH) for the identification of standards that manufacturers of medical devices may cite to meet relevant regulatory requirements Use - citation of standards in a regulatory application, regulation, guidance, or incorporation into policy statements 19

Standards Use in CBER Manufacturers of medical devices regulated in CBER may use standards recognized by CDRH to support regulatory submissions to CBER. Non-recognized standards may also be used. Consultation with the Review Office is recommended. CBER does not have a formal standards recognition (as does CDRH). 20

Standards Use for Cellular Therapy Products Sponsor can cite a standard in their regulatory application Sponsor can use a reference material in the development and testing of their product. 21

Examples of SDOs and Standards for Cell Therapy Products

American Society for Testing Materials International ASTMi Committee F04: Medical and Surgical Devices Subcommittees for TEMPS F04.41 Classification and Terminology F04.42 Biomaterials and Biomolecules F04.43 Cells and Tissue Engineered Constructs F04.44 Assessment preclinical evaluation of TEMPs F04.45 Adventitious Agent Testing F04.46 Cell Signaling 23

Examples of ASTMi Standards for Cell Therapy Products F2315-11 Standard Guide for Immobilization or Encapsulation of Living Cells or Tissues in Alginate Gels F2944-12 Standard Test Method for Automated Colony Forming Unit (CFU) Assays Image Acquisition and Analysis Method for Enumerating and Characterizing Cells and Colonies in Culture F2383-11 Standard Guide for Assessment of Adventitious Agents in Tissue Engineered Medical Products (TEMPs) 24

ISO Tissue Engineering Technical Committees TC150 SC7 Implants for Surgery, Tissue Engineered Medical Products WG 1 Management of Risk WG 2 General Guideline of Safety Test WG 3 Tissue-Engineered Medicinal Products for Skeletal Tissues TC194 SC1 Biological Evaluation of Medical Devices, Tissue Products Safety WG 1 Risk assessment, terminology and global aspects WG 2 Sourcing controls, collection and handling WG 3 Elimination and/or inactivation of viruses and TSE agents WG 4 TSE Elimination 25

Examples of ISO Standards for Cell Therapy Products ISO 10993.xx (Biocompatibility) AAMI/ISO 13022:2012 Application of Risk Management to Viable Materials of Human Origin Used for the Production of Medical Products AAMI/ANSI/ISO 13408(R2011) Aseptic Processing of Health Care Products 26

American Type Culture Collection (ATCC) ATCC Biological Resource Center Mission: To acquire, authenticate, preserve, develop, standardize, and distribute biological materials and information for the advancement and application of scientific knowledge ATCC ANSI accredited SDO Mission: To develop best practices (standards) in life science laboratory testing and to promote their use globally, using a consensus-driven process that balances the viewpoints of industry, government, academic and clinical professions. Goal: To develop written standards for life science products and methods ATCC published standards are recognized by the American National Standards Institute (ANSI) and are compatible with requirements of the International Organization for Standardization (ISO). 27

ATCC Standards Written Standard: ASN-0002-2011 Authentication of Human Cell Lines: Standardization of STR Profiling Reference Materials/Physical Standards ATCC VR-1516 Adenovirus Type 5 ATCC VR-1616 Adenovirus Type 2 CRM-CCL-2 HeLa cells for lab competency testing Ca Ski positive control for HPV 28

Clinical Laboratory Standards Institute (CLSI) Accredited by ANSI CLISI Consensus Committees Automation and Informatics Clinical Chemistry and Toxicology Evaluation Protocols Hematology Immunology and Ligand Assay Microbiology Molecular Methods Point-of-Care Testing Quality Systems and Laboratory Practices 29

Examples of CLSI Standards for Cell Therapy Products H42-A2 Enumeration of Immunologically Defined Cell Populations by Flow Cytometry; Approved Guideline- Second Edition H43-A2 Clinical Flow Cytometric Analysis of Neoplastic Hematolymphoid Cells 30

Standards Use for Characterization

Examples Standards for Characterization Standard ASTM 2027 ASTM 2064 ASTM F2150 ISO 10339 ICH Q5E Title Standard Guide for Characterization and Testing on Raw or Starting Materials for TEMPs Standard Guide for Characterization and Testing of Alginates as Starting Materials Intended for Use in Biomedical or TEMPs Standard Guide for Characterization and Testing of Biomaterial Scaffolds Used in TEMPs Biological Evaluation of medical devices Comparability of Biotechnological/Biological Products Subject to Changes in Their Manufacturing Process 32

Summary Written standards complement regulations by describing how manufacturers might meet the regulatory requirements for a particular product. Standards can complement FDA guidances by providing an alternate approach or an acceptable technology. Standards address numerous topics such as design, manufacturing, professional practices, nomenclature, and testing. Standards can be useful tools throughout the life cycle of a product in many disciplines. 33

OCTGT Contact Information Judith Arcidiacono International Regulatory Expert Standards Activity Liaison Judith.Arcidiacono@fda.hhs.gov 301-827-9149 Regulatory Questions: Contact the Regulatory Management Staff in OCTGT at CBEROCTGTRMS@fda.hhs.gov or Lori.Tull@fda.hhs.gov or by calling (301) 827-6536 OCTGT Learn Webinar Series: http://www.fda.gov/biologicsbloodvaccines/newsevent s/ucm232821.htm 34

Public Access to CBER CBER website: http://www.fda.gov/biologicsbloodvaccines/default.htm Consumer Affairs Branch (CAB) Email: ocod@fda.hhs.gov Phone: 301-827-3821 Manufacturers Assistance and Technical Training Branch (MATTB) Email: industry.biologics@fda.gov Phone: 301-827-4081 Follow us on Twitter https://www.twitter.com/fdacber 35