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

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

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

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

CMC Considerations for Manufacturing of CAR T-Cell Product

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

Mitochondrial Manipulation Technologies: Preclinical Considerations

US FDA: CMC Issues for INDs

Regulatory Pathways for Rare Diseases

Copyright. Jeremiah J. Kelly (2015). All rights reserved. Further dissemination without express written consent strictly prohibited.

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

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

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

Clinical Development of Gene Therapy: Safety Evaluation and Monitoring

CBER Regulatory Updates: Initiatives for Product Review and Licensure

Quality development considerations - Regulatory perspective

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

Update from the Center for Biologics Evaluation and Research (CBER) Peter Marks, M.D., Ph.D. GMP By The Sea 2017

FDA Perspective on the Preclinical Evaluation of Biological Therapies for Cancer

Current Considerations on Chemistry, Manufacturing and Control of Cell Therapy Products (CTPs)

Regulation of Microbiota- Based Products

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

FDA Perspective on the Preclinical Development of Cancer Vaccines

Regulatory Implications for Global Manufacturing Development of Regenerative Medicines

Question Yes No. 1. Is the study interventional (a clinical trial)? Study Type data element is Interventional

Ancillary Materials for Cell & Tissue Therapies Definitions, US Regulatory Approach, and USP s Risk-Tiered Approach

Dr. Earl Dye CMC/GMP Considerations for Expedited Development Programs

FDA Inspections: FDA Inspections: An Overview Overview

FDA Oversight of Gene Therapy

Regulatory Issues in Human Subjects Research

Guidance for Industry

Integration of work flows for the generation of gene-modified cell products

Compassionate Use Navigator Information for Physicians

Defining Clinical Benefit in Clinical Trials: FDA Perspective

The Target Product Profile (a Regulatory Perspective)

Assessing and Controlling Potency of Vector and Drug Product for Chimeric Antigen Receptor T Cells

Beth Hutchins, PhD PhRMA ICH Gene Therapy Discussion Group

Global Regulatory Perspective Workshop

Development of Regenerative Medicine Products: FDA Perspectives

CQAs for C&GT Products to Enable Comparability Assessment. Ben Thompson Snr Director, Biopharmaceutical CMC RA GlaxoSmithKline

Scientific and Regulatory Considerations for Gene Modified T Cell Therapy. Graeme Price, PhD. Kristin Baird, MD

Guidance for Industry

Challenges associated with supply to larger patients populations: Elements of the CTL019 experience

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

Cellular and Gene Therapy Products - CBER Update

Drug Development - Points to Consider

Outcomes in Mesenchymal Stem Cell Manufacturing. Athena Russell, MT(AAB) Human Cellular Therapy Laboratory Mayo Clinic Jacksonville, FL

Inspections, Compliance, Enforcement, and Criminal Investigations

Comparative Study of Regulatory Requirements for Biologics Filing in United States and European Union

March 4, Dockets Management Branch (HFA-305) Food and Drug Administration 5630 Fishers Lane, Rm Rockville, MD 20852

Challenges in Commercialization of Autologous Cell Therapy Products. Bryan Silvey & Kanti Thirumoorthy Kite Quality

Engage with us on Twitter: #Molecule2Miracle

Structure and Mandate of FDA

ICH Considerations. Oncolytic Viruses September 17, 2009

Hot Topics in Drug Product Process Validation: A Reviewer s Perspective

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

Regulatory Perspective on Analytical Method Validation During Product Development

US FDA Expedited Programs and Expanded Access

Inspections, Compliance, Enforcement, and Criminal Investigations

Adoptive cellular therapies are based on the administration of live cells into a patient in order for them to serve a therapeutic purpose.

FDA Approach to the Regulation of Hematopoietic Stem/Progenitor Cells (HPC)

Sharon Tindle, MS, CQA (ASQ) QA Manager, BMT Tissue Services Mount Sinai Hospital, New York, NY. June 7, 2016

FDA Regulatory Updates: Related to Cancer Immunotherapy

Perspectives on Rare Diseases

Control strategy and validation. Emanuela Lacana PhD Office of Biotechnology Products CDER/FDA

Opportunities and Challenges for Manufacturing Scale Up of CAR T Cells. Mark Dudley Institute of Medicine March 1, 2016

CGMP Requirements for Investigational Products

Justification of Specifications (JOS): What Product and Process Development was all About. Christopher A Bravery

Nonclinical Data to Support FIH Clinical Trials for Cancer Immunotherapies. Whitney S. Helms, PhD IOM, February 29,2016

Oncology for Scientists Christopher Choi, PhD Director, TCPF Assistant Professor of Oncology

My Potency Assay is Quantitative But is it Quantitative of Potency?

Phase Appropriate GMPs for IMPs. Presented by: Karen S. Ginsbury For: IFF, October 31, Nov 02, 2017

ICH Considerations Oncolytic Viruses ONCOLYTIC VIRUSES (EMEA/CHMP/ICH/607698/2008) TRANSMISSION TO CHMP November 2008

Baek, Kyung-min. Recombinant Protein Products Division. Ministry of Food and Drug Safety

INTRODUCTION. How we regulate Cell and Gene Therapy Product? Presented by Azizah Ab Ghani National Pharmaceutical Control Bureau

ICH CONSIDERATIONS Oncolytic Viruses

The Early Chimeric Antigen Receptor (CAR) T-cell Experience From An Academic Perspective. CARs: LEARNING TO DRIVE

Office for Human Subject Protection. University of Rochester

Replacing Analytical Methods for Release and Stability Testing CBER Perspective

Biosimilars: Questions and Answers Regarding Implementation of the Biologics Price Competition and Innovation Act of 2009

Regulatory Issues and Drug Product Approval for Biopharmaceuticals

Advancing Manufacturing for Advanced Therapies

Toxicology - Problem Drill 24: Toxicology Studies in Pharmaceutical Development

CMC Consideration for the Development of Regenerative Medical Products

Notes from Round Table 5. January 26 and 27, 2016

Guidance for Industry Reference Product Exclusivity for Biological Products Filed Under Section 351(a) of the PHS Act

PROCESS VALIDATION ROCHAPON WACHAROTAYANKUN, PH.D.

Subpart H [Reserved] Subpart I Expanded Access to Investigational Drugs for Treatment. 21 CFR Ch. I ( Edition)

Quality of raw materials and manufacturing of advanced therapies. Fouad Atouf, Ph.D. Head, Global Biologics July 12, 2018

Considerations in Product Development with Advanced Therapies and Cancer Vaccines

Guidance for Industry

Product Testing & Release. PACT Workshop: Design & Operation of GMP Cell Therapy Facilities April 10 th /11 th, 2007

Manufacturing Challenges with Cell and Gene Therapy Products: A Health Canada Perspective

Scientific Considerations in Demonstrating Biosimilarity to a Reference Product. Guidance for Industry

Regulatory perspective on setting clinically relevant specifications. Joslyn Brunelle, PhD Team Leader Office of Biotechnology Products

Guidelines: c. Providing the investigational drug for the requested use will not interfere with the initiation, conduct, or completion of clinical

Regenerative Medicine and the Changing Regulatory Landscape

Long-Term Follow-Up in Gene Transfer Clinical Research

Supplies and Reagents

GMP for ATMP should be a document annexed to standard GMP (a new Annex) and not a stand-alone document.

The Role of Mass Spectrometry for Developing Biotherapeutics: Regulatory Perspectives

Transcription:

Regulatory Approval of Modern Gene-Based Cancer Immunotherapies CAR T Cells A product perspective ASQ509 Biomed/Biotech SIG 2/1/18 Xiaobin Victor Lu Division of Cellular and Gene Therapies Office of Tissues and Advanced Therapies Center for Biologics Evaluation and Research U.S. Food and Drug Administration

FDA Approves First CAR T Cell Therapies -BBC -Science 2

Overview Introduction of CAR T cells Genetically modified immunotherapy General requirements for a biologics license application (BLA) Manufacturing process control strategy Specific CMC considerations for a CAR T cell BLA Summary 3

CAR T Cells: Chimeric Antigen Receptor T Cells Genetically modified T cell immunotherapy Targets antigen on the cell surface Independent of MHC Living Drug Dynamic cell population during manufacturing process Expands and differentiates after administration 4

Structure of CAR Extracellular recognition domains Antibody-derived scfv Specific for tumor antigen On-target, off-tumor effects Intracellular signaling domains T cell-derived domains T cell activation: CD3ζ Co-stimulation signal: generally CD28 or 4-1BB Extracellular recognition domains Intracellular signaling domains V H V L TM domain Co-stimulation signaling domain CD3ζ activation domain 5

How Does a CD19-Directed CAR T Cell Work? CAR scfv binds to CD19 on B cell tumors Not restricted by HLA Binding of CAR to CD19 leads to T cell activation Promotes cell expansion and differentiation Triggers effector functions: Lysis of CD19 + cells Cytokine signaling Stimulation of bystander immune cells 6

Manufacturing Process Cancer Gene Therapy (2015) 22, 79 84 Vector 7

Personalized Medicine: A different manufacturing paradigm Conventional Drug/Biologic 1 product lot Raw materials CAR T cell 1 product lot cgmp Manufacturing In Process and Lot Release Testing Distribution Many patients One patient 8

Biologics License Application (BLA) Approval Clinical safety and efficacy Post marketing requirement (PMR) Risk evaluation and mitigation strategy (REMS) Cytokine Release Syndrome Neural toxicity Non-interventional registry Delayed adverse events Post marketing commitment (PMC) Validated manufacturing process & capacity under CGMPs Pre-license inspections Labeling 9

Regulatory Basis for BLA Request for permission to introduce a biologic product into interstate commerce (21 CFR 601.2) Demonstration of safety, purity and potency Section 505 of the Food, Drug and Cosmetic (FDC) Act Section 351 of the Public Health Service Act (PHS Act) (42 U.S.C. 262) Title 21 Code of Federal Regulations chapter 600 680 (21 CFR 600) 21 CFR 1271 Manufacturing facilities meet standards designed to assure that the biological product continues to be safe, pure, and potent (21 CFR 210 and 211 (CGMP)) Labeling (21 CFR 610.60, 610.61, 610.62) 10

Multidiscipline Review Team Chemistry, Manufacturing and Controls (CMC) - Product/Manufacturing information - Capable of consistently producing a safe, pure and potent product with defined stability Pharmacology and Toxicology - Proof of concept - Safety (prior to clinical studies) - Dose determination Clinical - Safety (clinical studies) - Efficacy 11

Manufacturing Controls Product Development Process Design Safety and quality built into the process Process development for improvement Comparability and change controls Control of raw materials and components Qualification programs Tracking of product Chain-of-identity Stability for storage, shipping and post-thaw time 12

Manufacturing Controls Later Phase Product Development Pivotal trials and commercial production - Defined critical process parameters (CPPs) - Critical quality attributes (CQAs) - Unit operations time limits - In-process controls - Lot release specifications Process validation Analytical test method validation Stability for expiry dating, storage & shipping time 13

Raw Materials and Components Risk assessment and qualification programs Identity test (21 CFR 211.84) and review of vendor s CoA Animal derived components (including human): Adventitious agents testing Human derived components: donor eligibility screen and testing 14

Raw Materials and Components Leukapheresis materials Suitability for further manufacturing (T cell # and composition) Aseptic process step is used for cryopreservation Gene transfer vector is a critical component required for product activity Assure identity, safety (including RCR test), purity, and potency CGMP conditions and subject to inspections Stability Validation of manufacturing process, test method and shipping 15

In-process and Lot Release Tests Selection of CQAs for in-process and lot release tests Validation of analytical test methods Justification of test acceptance criteria based on manufacturing data Late stage manufacturing data may be more reliable and a better reflection of commercial process CAR T cells may have lot release acceptance criteria with wide ranges Should be statistically justified Should reflect clinical lots shown to be safe and effective 16

Potency Considerations At the final cell product level Biological potency assay mode of action (e.g., cell killing) Cytokine production Transduction efficiency Vector copy number At the vector product level Biological potency assay mode of action Infectious titer (critical for MOI determination at the transduction steps) In Target cell and / or In a surrogate cell line 17

Process Validation Confirm that the process is capable of consistently producing a quality product for its intended purpose Validation plan Stage 1: Process design Process control strategy CPPs, CQAs, statistically established acceptance criteria Stage 2: process qualification Qualification of facility and equipment Process performance qualification (PPQ) Prospective PPQ protocols Execution and reports Stage 3: Continued process verification Protocol to continually monitor and ensure the state of control 18

Chain-of-Identity Ensure the right product goes back to the same patient from which the cells are derived Establish unbroken chain-of-identity through physical container closure labels and computer based electronic tracking systems Validate the systems to ensure no mix-up can occur throughout the entire manufacturing process from enrollment to final infusion Use at least two patient identifiers to define unique patient/product identity Have a contingency plan in place if the electronic system is down 19

Summary Key to manufacturing control is to minimize variations from all possible sources Demonstrate process control through process development, improvement, optimization, in-process and lot release testing, formal validation and continuing monitoring Vector is manufactured under CGMP conditions, tested for potency and subject to inspection Track cell product identity through validated chain-of-identity system Address issues early with FDA through various meetings during product development Pre-BLA meeting: All issues and questions should be discussed 20

FDA Guidance Documents Guidance for FDA Reviewers and Sponsors: Content and Review of Chemistry, Manufacturing, and Control (CMC) Information for Human Gene Therapy Investigational New Drug Applications (INDs) https:///downloads/biologicsbloodvaccines/guidancecomplianceregulatoryinformation/guidan ces/xenotransplantation/ucm092705.pdf Guidance for Industry: Eligibility Determination for Donors of Human Cells, Tissues, and Cellular and Tissue-Based Products (HCT/Ps) https:///downloads/biologicsbloodvaccines/guidancecomplianceregulatoryinformation/guidances/tissu e/ucm091345.pdf Guidance for Industry: Supplemental Guidance on Testing for Replication Competent Retrovirus in Retroviral Vector Based Gene Therapy Products and During Follow-up of Patients in Clinical Trials Using Retroviral Vectors https:///ohrms/dockets/98fr/994114gd.pdf Guidance for Industry: Gene Therapy Clinical Trials - Observing Subjects for Delayed Adverse Events https:///downloads/biologicsbloodvaccines/guidancecomplianceregulatoryinformation/guidances/cel lularandgenetherapy/ucm078719.pdf Guidance for Industry: Potency Tests for Cellular and Gene Therapy Products https:///downloads/biologicsbloodvaccines/guidancecomplianceregulatoryinformation/guidances/cel lularandgenetherapy/ucm243392.pdf 21

Contact Information Xiaobin Victor Lu xiaobin.lu@fda.hhs.gov Regulatory Questions: OTAT Main Line 240 402 8190 Email: OTATRPMS@fda.hhs.gov and Lori.Tull@fda.hhs.gov OTAT Learn Webinar Series: http:///biologicsbloodvaccines/newsevents/ucm232821.htm CBER website: /BiologicsBloodVaccines/default.htm Phone: 1-800-835-4709 or 240-402-8010 Consumer Affairs Branch: ocod@fda.hhs.gov Manufacturers Assistance and Technical Training Branch: industry.biologics@fda.gov Follow us on Twitter: https://www.twitter.com/fdacber FDA Headquarters 22

Thank You!