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2010. 12.
이 참고자료집은 미국, 유럽, 일본의 세포치료제 관련 최신 지견을 정보제공
하기 위하여 마련되었습니다. 세포치료제 연구개발 시, 미국 FDA, 유럽
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세포치료제 역가시험 자료집
목 차
1. 역가시험 관련 가이드라인
2. 세포치료제 역가시험 관련 연구
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1. 세포/유전자치료제 역가시험법 [FDA 가이드라인(안)]
[FDA 가이드라인(안)]
목 차
I. 서론
II. 배경
A. 허가된 생물학적제제의 역가에 대한 규제 요구사항
B. 임상시험용 세포유전자치료제의 역가 요구사항
B. 역가측정에 사용되는 방법
C. 세포유전자치료제에서 역가와 임상적 유효성사이의 관계
D. 역가시험법 개발 시기
E. 진행성역가시험법 수행
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Ⅰ 서론
II 배경
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기에는 역가, 무균, 순도 그리고 확인시험이 포함된다. 이러한 요구사항은 하나의
로트가 단일 투여 용량으로 정의되는 자가 그리고 단일 환자 동종 제제를 포함한
모든 생물학적제제에 적용된다.
- 역가(potency)는 적절한 실험실 시험이나 의도된 방법으로 제제의 투여를 통해
적절하게 관리된 임상시험에 의해 의도한 효과를 나타내는 제제의 특성이나 능력
8)
으로 정의된다(21 CFR 600.3(s)). 강도(strength) 는 역가, 즉 적절한 실험실 시
험이나 적절하게 개발되고 조절된 임상자료에 의해 나타내어지는 의약품의 치료
적 활성으로 정의된다(21 CFR 210.3(b)(16)(ii)).
규정에서 “역가 시험법은 각 제제에 대해 특이적으로 고안되어 600.3(S)의 규정
에 의한 역가의 설명을 충족시키기에 적절한 역가를 나타낼 수 있는 생체 외 또
는 생체 내 또는 두 방법 모두로 구성될 수 있다(21 cfr 610.10)”고 명기하고 있
다.
- FDA 규정은 각 제제에 대한 역가의 적절한 측정을 결정함에 있어 상당한 유연성
을 허용하고 있다. 역가는 각 제제의 특성에 기초해서 결정되므로 역가 시험법의
적절성은 각 제제별로 평가되어야 한다. 허가된 생물학적 제제의 출하시험을 위
한 모든 역가 시험법은 다음을 포함한 관련 생물학적제제와 cGMP규정에 부합하
여야 한다.
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상연구의 모든 단계에서 사용하는 제제의 안정성(21 CFR 312.23(a)(7)(ii)) 뿐만
아니라 확인, 순도, 역가(21 CFR 312.23(a)(7)(i))를 보증하기 위한 자료를 제출
하여야 한다. 필요한 자료의 양은 임상시험 단계, 연구 기간, 다른 이용 가능한
정보의 양에 따라 다양하다.
- 역가 측정은 모든 임상시험단계에서 투여되는 제제가 일관성 있게 생산됨을 확립
9)
하기 위하여 사용되는 제제 특성 시험 , 비교 동등성시험, 안정성 시험계획서(프
로토콜)에 필요하다. 그러나 세포/유전자치료제의 복합성 때문에 역가 시험법을
확립하기 위한 많은 시도가 필요하다(표 1). 세포/유전자치료제의 개발을 촉진하
기 위하여 역가 시험법 개발을 포함한 제제 특성 시험을 위해 점증적 접근법
(incremental approach)을 권장한다. 진행식(progressive) 역가 측정 시험 수행
을 위한 일반적인 권장사항은 Section III.E에 나와 있다. 이 가이드라인의 III.A,
III.E 그리고 IV.C.4에서 기술한 바와 같이 역가 측정은 제제가 개발됨에 따라 개
선되고 현저하게 바뀔 것이다.
◦ 투여부위에서부터 이동
◦ 원하는 세포로 분화
제제의 생체 내 운명 ◦ 바이러스 또는 세포성 복제
◦ 바이러스 벡터 감염, 탈피(uncoating), 그리고
이식유전자의 발현
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상시험에 의해 입증된다. 임상적 유효성은 제제의 역가와 상관관계에 있지만 임
상시험 자료가 로트 출하를 위한 역가의 실질적인 정량방법은 아니다. 오히려 임
상시험결과는 제제의 임상적 유효성과 역가 시험법 사이의 상관관계10)를 확립할
때 사용되어 질 수 있으며, 이는 로트 출하, 안정성 그리고/또는 비교동등성 시
험에 사용될 수 있다(상관성연구와 관련해서 더 자세한 것은 III.C. 참조).
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여러 개의 벡터, 여러 개의 항원 결정기(epitope)를 가진 백신)에 의존할 수 있
다. 어떤 복합제품(예, 세포 종양 백신)의 경우, 어떤 성분이 역가를 나타내는지
모호할 수 있다. 알려진 하나 이상의 유효 성분을 포함하는 제제의 경우, 모든
유효 성분의 생물학적 활성(강도)을 결정할 수 있는 역가 시험법을 디자인해야
한다(21 CFR 211.165(a)) 참조). 따라서 제제가 하나 이상의 주성분을 포함하고
있다면, 하나의 시험법이 각 유효성분의 활성을 측정하는데 불충분할 수 있으므
로 제제의 역가를 측정하기 위해 하나 이상의 시험법이 필요하다(III.B.3 참조).
부가적으로, 시험법을 디자인 할 때, 주성분 간의 방해나 상승작용의 가능성을
고려하여야 한다.
1. 생물학적 시험법
- 생물학적 제제의 역가를 평가하는 전통적인 방법은 효과를 나타내는 특이적인 활
성과 관련된 제제의 활성을 측정하는 그리고 Section II.A.에 나타나 있는 기준을
충족하는 정량적인 생물학적 시험법(bioassay, 생물검정)을 개발하는 것이다. 생
물검정은 살아있는 생물학적 시스템 내에서 제제의 유효성분을 평가함으로써 역
가를 측정한다. 생물검정은 생체 내 동물실험, 생체 외 기관, 조직, 세포 배양 시
스템 또는 이들의 조합을 포함할 수 있다. 생체 외 또는 생체 내 시험법을 사용
할 수 있으나, 가능하다면 동물사용의 제한을 권장한다(참고문헌 12).
2. 비생물학적 분석시험법12)
- 어떤 세포/유전자치료제에 대한 정량적인 생물검정법의 개발은 제제의 특성 그리
고/또는 기술적인 한계 때문에 복잡할 수 있다(표 1). 생물검정법 개발이 가능하
지 않다면, 생물학적 활성의 대리지표를 확인하는 것이 필요하다. 예를 들어, 로
트 출하를 위해 실제적이며 신뢰할 수 있는 분석 시험법(analytical assays)을 사
용하는 것이 필요하다. 분석 시험법은 제제의 면역학적, 생화학적 그리고/또는
분자적인 특성을 평가함으로써 광범위한 제제의 특성 자료를 제공할 수 있다. 만
약 대리 지표측정법이 적절한 제제 특이적인 생물학적 활성과 상관성이 있음이
입증될 수 있다면 이러한 특성은 역가를 나타내는데 사용될 수 있다(Section
III.C, 참고문헌 13과 14 참조). 상관성을 확립하기 위해서는 이 가이드라인에서
권장하는 것과 같이 엄격한 제제의 특성 시험을 행해야 한다.
3. 복합시험법(assay matrix)
- 많은 경우, 하나의 생물학적 또는 분석 시험법으로는 역가를 측정하는데 적절하
지 않을 수 있다. 다음에 제시하는 가능성 때문이다.
• 제제가 복잡한 작용기작을 가지고 있음
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• 제제가 여러 가지 유효 성분을 가지거나 그리고/또는 여러 가지 생물학적 활
성을 가지고 있음
• 제한된 제제 안정성
• 생물학적 분석법이 정량적이지 않고, 충분히 강건(robustness)하지 않으며 또
는 정확성이 없음
- 만약 하나의 분석법이 역가를 나타내는 제제의 특성을 측정하기에 충분하지 않다
면, 품질, 일관성, 안정성과 관련된 다른 제제의 특성을 측정하는 여러 가지 보
조 시험법을 개발할 수 있다. 같이 사용했을 때 그리고 결과가 적절한 생물학적
활성과 상관관계가 있다면 이러한 보조적인 시험법도 역가를 측정하는데 적절할
수 있다. 그러한 assay matrix(시험법의 모음)은 생물학적 시험법, 생물학적 및
분석 시험법 그리고 분석 시험법만으로 구성될 수 있다(참고문헌 13과 14).
Assay matrix는 정량적인 정보(예, 활성 단위) 또는 정성적인 정보(예, 적합/부적
합)를 주는 시험법을 포함할 수 있다.
만약 정성적인 시험법이 로트 출하, 안정성 또는 비교동등성 시험을 위한 역가를
결정하기 위한 assay matrix의 일부로 사용된다면, 하나 또는 그 이상의 정량적
인 시험법도 첨가되어야 한다(Section II.A 참조).
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D. 언제 역가측정법 개발을 시작해야 하는가
- 이 문서 전반에서 기술한 것처럼, 제품의 특성분석을 통해서 품질, 일관성 그리
고 안정성에 영향을 미치는 제품의 지표(들)에 대한 이해가 필요하다. 더욱이, 이
러한 지표들의 이해와 관리가 생산 로트 간의 일관성 증명, 다른 제조과정 그리
고/또는 다양한 측정법의 비교평가에 필요하며, 또한 어떤 제품이 유효한 제품인
지 결정하는 것이 필요할 수 있다. 따라서, 역가 측정 능력은 제품의 특성분석에
기초하기 때문에 가능한 많은 제품의 정보를 얻기 위하여 전임상과 임상시험 초
기단계 동안 역가시험법 개발을 시작하여야 한다.
- 제품 개발 초기 동안의 역가측정은 다음과 같은 많은 장점을 가진다.
• 제품개발 전기간 동안의 제품 활성, 품질 및 일관성을 증명할 수 있음
• 로트 출하를 위한 규격을 뒷받침하는 자료수집이 이루어짐
• 제조방법 변경을 평가하기 위한 기초자료를 제공
• •제품의 안정성 평가를 가능하게 함
• 별개의 시험법에서의 기술적 문제 또는 그 이유를 알 수있음
• 다중시험법(multiple assay)의 평가가 가능함
• 필요하다면, 상관성 연구를 뒷받침하는 충분한 양의 자료를 모을 수 있음
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가시험법이 기술되어야 하며, 생물학적 제제허가신청 (21 CFR 601.2(a),
211.165(e) 및 Section II.A 참조)에서 정의되어 있어야 한다. 수용가능한 기준은
제조 경험을 통해 얻어진 지식정보, 임상조사 및 제품생산의 모든 기간 동안 이
루어진 시험으로부터 모아진 자료가 기초되어야 한다(참고문헌 5). 주요한 임상
시험에 사용하기 위해 제조된 로트 또는 적합한 로트의 제제를 평가할 때 수용
기준은 이러한 자료를 반영하여 개선되어야 한다.
- 역가시험법의 수용기준은 이후의 로트 출하시험을 위해 생물학적제제허가신청에
서 설명되어야 하며, 임상적 유효성을 증명하기 위한 주요 임상시험에서 사용되
는 제품 롯트에 대한 역가한계 설정이 상세히 기술되어야 한다(FDC Act,
Section 505(d), 21 U.S.C. 351 참조).
IV. 시험법 설계 및 검정
A. 시험법 설계 동안 무엇이 고려되어야 하는가?
- cGMP 규정을 따르면, 시험법 설계는 반드시 시험법 평가를 위한 자료수집이 이
루어져야 한다. 여기에는 통계분석을 고려한 충분한 반복시험, 편향성(bias)(예:
96-well plate의 위치에 따른 편향성)을 줄이기 위한 무작위 샘플의 사용 및 적
절한 관리 등이 포함된다. 또한 시험법 설계는 시험법 가변성에 영향을 주는 인
자에 대한 지식을 반영해야 한다. 따라서, 시험법의 가변성에 대한 원인들을 고
려하고, 시험법 설계에서 이 원인들을 제한시키기 위한 조치를 취해야 한다. 가
변성을 감소시키기 위한 일반적인 원칙은 잘 정제된 시약, 잘 조정된 실험기기의
이용 그리고 충분히 훈련된 실험자 등이다. 또한 시험법의 가변성은 자세하게 기
술된 표준작업수순서(SOP)와 적절한 장소 및 적절한 관리를 통해 충분히 감소시
킬 수 있다. 시험법 특이적 관리(assay-specific controls)는 이용하는 시험법 뿐
만 아니라 분석되는 제제에 따라 달라질 수 있다. 또한 기준물질(reference
materials)과 대조물질(controls)을 포함하는 중요한 시약의 장기간의 유효성도
고려하여야 한다. 제조자는 시험법 설계 전략의 상세한 검토를 위해 각기 다른
공급원을 구할 수 있다(예. 참고문헌 13-20).
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표준품 및 대조물질이 이용가능하거나, 생물학 특성평가를 위해 계속 개발되고
있다. 예를 들면, 시험기기를 보정하거나 정량적 FACS 분석(참고문헌. 18)을 위
해 수용가능한 parameter를 정의하는데 도움을 주는 형광성의 비드(bead)/항체
14)
및 입자크기의 표준품 그리고가이드라인서15)가 있다. 기준물질은 또한 현재
adenovirus type 5(Ref. 19)16) 그리고 retrovirus17) vector에 이용할 수 있다.
adeno-associated virus type 2 vectors18)에 대한 기준물질은 개발중에 있다.
lentivirus vectors를 위한 표준물질과 대조물질 역시 기술되어 있다(참고자료.
20).
- 만일 일반적인 표준 또는 기준물질이 유효하지 않다면, 당신은 독자적인 회사내
(“in house") 표준물질을 개발하여야 한다(참고문서. 9 - 11). 이를 위해서는 당
신 또는 다른 곳으로 부터의 잘 특성분화된 임상적 로트들 또는 다른 잘 특성 분
석된 물질들(예를 들어 당신의 제품과 유사한 특성을 가진, 특성분석이 잘 되어
있는 세포주)이 준비되어야 한다. 이때에는 표준물질(자체개발 표준물질/대조물질
을 포함)을 어떻게 그리고 왜 선정했는지에 대한 분명한 이론적 근거가 있어야
한다. 우리는 표준물질을 개발 또는 획득할 때 생물의약품 평가 연구센터의 심사
부서(review team)에게 상의할 것을 권장한다.
- 표준물질은 제품 개발 및 특성분석의 다양한 단계에서 사용되므로, 이 물질에 대
한 안정성 연구를 제품의 안정성 연구와 동시에 수행하여야 한다(참고자료. 7).
또한 표준물질의 각 새로운 배치에 대하여 적절하게 특성분석을 실시하고 원형
과의 비교를 통해 적절한 절차를 수립하여, 새로운 표준물질의 유효성을 증명해
야 한다. 가능하다면 새로 제조된 표준물질과의 비교를 위해 각 로트의 표준물질
시료를 보존(참고자료. 6-8)하고 표준물질의 소진 또는 유효기간 만기에 대비하
여 미리 준비해야 한다.
- 13 -
• 직선성과 한계범위
• 조직적합성
• 강건성/강직성
2. 통계학적 설계 및 분석
- 역가측정에서 실험의 분석 및 설계에 대한 적절한 통계학적 방법은 아주 중요하
다. 그렇지 않다면, 그러한 실험 자료로부터의 추론은 유효하지 않을 수 있다.
반복실험에서 측정법의 변경성 및 변경의 잠재적인 근원은 결과를 보고할 때 고
려되어야 한다. 당신은 정당성과 이론적 근거를 포함한 분석방법을 완전히 기술
하여야 한다. 이러한 설명은 연구보고서상에서 독립적인 통계학적 분석과 평가가
이루어졌음을 명확히 해야 한다. 역가시험법 밸리데이션 연구에서 수집된 자료가
전자파일로 되어 있다면 CBER 검토위원회에서 이루어지는 통계학적 평가를 용
이하게 할 수 있다. 밸리데이션 연구 결과는 표적된 검정 parameter를 기술하여
야 하며, 이는 수용기준과 일치하여야 한다. 우리는 역가시험의 분석과 설계에서
피드백을 받을 수 있도록 심사부서와 초기부터 논의하기를 권장한다(반드시 보관
해야 하는 실험실 기록의 필요요건: 21 CFR211.194 참고)
3. 품질시험의 밸리데이션
- Section III.B.3에서 기술한 바와 같이, 품질시험법은 역가를 평가하기 위해서 시
험법 매트릭스(assay matrix)의 한 부분으로 사용될 수 있으며, 적절한 상관성
연구를 수행할 수 있도록 한다. 반드시 품질시험을 반영할 수 있는 모든
parameter에 대하여 밸리데이션하여야 하며, 품질과 연관성이 없다고 결정한
parameter 들에 대한 이론적 근거를 제시하여야 한다. 예를 들어 어떤 시험법의
검정 parameter가 품질평가시험에 잘못된 정보 판독으로 적용가능하지 않더라도
(예를 들어 직선성), 적절한 대조시료가 특이성, 민감도 시험 뿐 아니라 다른 수
용 가능한 연구특징(강건성 , 시험법 체계의 적절성 등)을 규명하기 위해 사용되
어야 한다
- 정량적 자료가 없어도, 정확성과 정밀성의 결과로 고려할 수 있다: 어쨌든 적당
한 시험법 설계(예: 충분한 반복시험)를 가지고, 재현성을 기술할 수 있다. 부분
적 정량시험(semi-quantitative assays)(아주 변하기 쉬운 정량적 판독정보, 예:
동물모델에서의 반응)에서는 강직성과 재현성 시험에서 더 넓은 수용범위가 고려
될 수 있다. 또한 검출한계 그리고/또는 정량이 적절한 기준 시험설계에서 세워
질 수 있다. 예를 들어 만일 합리적인 양의 대조 또는 기준물질이 충분한 통계적
정의에서 기대했던 활성을 나타내지 않는다면, 시험법은 일반적으로 받아들이기
어려울 수 있다. CGT제품의 복합성 때문에 특정 시험법의 적절성을 결정하는 상
황은 시험법 마다 다를 수 있다.
- 14 -
4. 시험법의 평가 및 변경
- 제품개발 동안 또는 인허가 후, 또는 둘 모두에서 제조 및 시험과정은 역가시험
법 재평가에 필수적이며/또는 유익할 수 있다. 만일 승인된 시험법을 변경하거나
새로운 시험법을 제안할 계획이라면, 반드시 적절한 역가측정을 통해 변경된 또
는 새로운 시험법을 증명하는 검정연구를 수행하여야 한다(21 CFR 211.165(e)).
승인된 적용에 대한 이러한 변경들은 반드시 보충자료를 제출하여야 한다(21
CFR 601.12(b)(3)(vi)).
- 역가측정법 변경을 뒷받침하는데 필요한 자료의 양은 인자(factor)의 수에 따라
결정된다.
• 제품개발 단계
• 현행 시험법 내의 변화 유형
• 다른 제품의 특성 측정에 이용되는 어떤 시험법이 이용되는지
• 제안된 시험법이 상단에 기술된 시험법 기준을 충족하는지(상단 또는 Section
ILA 참조)
- 만일 조사연구기간 동안 역가측정법을 변경한다면 시험법 자체가 수정되어야 하
며 제안된 변경(들)이 정당하다는 증명이 제시되어야 한다(예를 들어 더 적절하
고 더 유용하고 더 정량적인 방법임을 입증)
- 권고사항으로 어떠한 경우라도 시료(예: 제품, 표준물질들, 주요시약들)의 보존유
지가 중요함을 더욱 강조하게 된다. 만일 새로운 시험법이 적절한 시료보관 분석
이 없이 적절히 수행된다면 시험법들의 비교 또는 결정은 어려울 것이다.
- 이 가이드라인서에서 지적하듯이, 제품의 적절한 역가측정법 개발에 상당량의 자
료가 필요할 수도 있으며(참고자료. 14 참조), 당신의 시험법(들)은 당신의 제품
개발 시기에 따라 또는 새로운 정보와 방법 습득여부에 따라 변할 수도 있다. 우
리는 당신이 역가측정법의 설계, 평가 및 밸리데이션에 따라 적시에 심사부서와
논의하기를 권장한다.
- 15 -
2. 세포,유전자치료제 역가시험법 (Draft, 2008, FDA) _ 영문
Potency Tests for Cellular and Gene Therapy Products (Draft Guidance)
Table of Contents
I. INTRODUCTION ................................................................................................................. 1
II. BACKGROUND .................................................................................................................. 2
A. What Are the Regulatory Requirements for Potency of Licensed Biological Products? .2
B. What are the Potency Requirements for Investigational CGT Products? ................. 3
C. What Is the Relationship Between Potency and Clinical Effectiveness for CGT Products? ... 4
V. REFERENCES ................................................................................................................... 14
- 16 -
Guidance for Industry
Potency Tests for Cellular and Gene Therapy Products
This draft guidance, when finalized, will represent the Food and Drug Administration’s
(FDA’s) current thinking on this topic. It does not create or confer any rights for or
on any person and does not operate to bind FDA or the public. You can use an
alternative approach if the approach satisfies the requirements of the applicable statutes
and regulations. If you want to discuss an alternative approach, contact the appropriate
FDA staff. If you cannot identify the appropriate FDA staff, call the appropriate
number listed on the title page of this guidance.
I. INTRODUCTION
We, FDA, are issuing this guidance to provide you, manufacturers of cellular and gene
therapy (CGT) products, with recommendations for developing tests1 to measure
potency.2 These recommendations are intended to clarify the potency information that
could support an Investigational New Drug Application3 (IND) or a Biologics License
Application4 (BLA). Because potency measurements are designed specifically for a
particular product, this guidance does not make recommendations regarding specific types
of potency assays, nor does it propose criteria for product release. This guidance is
intended to supplement related documents (Refs. 1 through 11, and 15) and does not
replace or supersede any existing documents.
This guidance applies only to CGT products5 reviewed by FDA’s Office of Cellular,
Tissue and Gene Therapies (OCTGT), CBER under Section 351 of the Public Health
Service Act (PHS Act) (42 U.S.C. 262) (Refs. 1 and 2). This guidance does not apply
to human cells, tissues, and cellular and tissue products (HCT/Ps), which are regulated
solely under section 361 of the PHS Act (42 U.S.C. 264) as described under 21 CFR
1271.10 or to products regulated as medical devices under 21 CFR Part 820. This
guidance also does not apply to biological products reviewed by CDER or by CBER’s
Office of Vaccine Research and Review (OVRR) or Office of Blood Research and
Review (OBRR).
FDA’s guidance documents, including this guidance, do not establish legally enforceable
responsibilities. Instead, guidances describe the FDA’s current thinking on a topic and
- 17 -
should be viewed only as recommendations, unless specific regulatory or statutory
requirements are cited. The use of the word should in FDA’s guidances means that
something is suggested or recommended, but not required.
BACKGROUND
What Are the Regulatory Requirements for Potency of Licensed Biological Products?
All biological products must meet prescribed requirements of safety, purity and potency
for BLA approval (42 U.S.C. 262, Federal Food, Drug and Cosmetic Act, (FDC Act)
(21 U.S.C. 321 et seq.); 21 CFR 601.2). For CGTs, product conformance testing (21
CFR 601.20(a)) and control of the manufacturing process (21 CFR 601.20(c)) are
required to comply with FDA’s Current Good Manufacturing Practice (CGMP) For
Finished Pharmaceuticals regulations (21 CFR Parts 210 and 2116) as well as the
biologics regulations (21 CFR Part 600 et seq.). No lot of any licensed product may be
released by the manufacturer prior to the completion of tests for conformity with
standards applicable to such product, (21 CFR 610.1), which include tests for potency,
sterility, purity, and identity (21 CFR Part 610, Subpart B). These requirements apply to
all biological products, including autologous and single patient allogeneic products,
where a lot may be defined as a single dose.
Potency is defined as “the specific ability or capacity of the product, as indicated by
appropriate laboratory tests or by adequately controlled clinical data obtained through the
administration of the product in the manner intended, to effect a given result.” (21 CFR
600.3(s)). Strength7 is defined as “potency, that is, the therapeutic activity of the drug
product as indicated by appropriate laboratory tests or by adequately developed and
controlled clinical data. . . .” (21 CFR 210.3(b)(16)(ii)). Regulations stipulate that
“[t]ests for potency shall consist of either in vitro or in vivo tests, or both, which have
been specifically designed for each product so as to indicate its potency in a manner
adequate to satisfy the interpretation of potency given by definition in § 600.3(s) of this
chapter.” (21 CFR 610.10).
FDA regulations allow for considerable flexibility in determining the appropriate
measurement(s) of potency for each product. Potency is determined based on individual
product characteristics; therefore, the adequacy of potency assays is evaluated on a
- 18 -
case-by-case basis. All potency assays used for release testing of licensed biological
drug products must comply with applicable biologics and CGMP regulations including:
• Indicate potency (biological activity/activities) specific to the product (21 CFR 600.3(s)
and 610.10; and 21 CFR 210.3(b)(16)(ii));
• Provide test results for release of the product (21 CFR 610.1; 21 CFR 211.165(a))
• Provide quantitative data (21 CFR 211.194; see also 21 CFR 600.3(kk); 21 CFR
211.165(d); 211.165(e););
• Meet pre-defined acceptance and/or rejection criteria (21 CFR 211.165(d); see also 21
CFR 600.3(kk); and 21 CFR 210.3(b)(20));
• Include appropriate reference materials, standards, and/or controls (see; 21 CFR
210.3(b)(16)(ii) and 211.160);
• Establish and document the accuracy, sensitivity, specificity and reproducibility of the
test methods employed through validation (21 CFR 211.165(e) and 211.194(a)(2));
• Measure identity and strength (activity) of all active ingredients (21 CFR 211.165(a);
see also 21 CFR 210.3(b)(7));
• Provide data to establish dating periods (see 21 CFR 600.3(l) and 610.53(a))
• Meet labeling requirements (21 CFR 610.61(g)(3) and 610.61(r))
In early clinical phase investigations, it may not be possible to meet all of the
requirements described above for licensed biological products (Refs. 3, 4, 8).
Nonetheless, you must submit data to assure the identity, quality, purity and strength
(21 CFR 312.23(a)(7)(i)) as well as stability (21 CFR 312.23(a)(7)(ii)) of products used
during all phases of clinical study. “[T]he amount of information needed to make that
assurance will vary with the phase of the investigation, the proposed duration of the
investigation, the dosage form, and the amount of information otherwise available.” (21
CFR 312.23(a)(7)(i)).
Potency measurements are necessary for product characterization testing,8 comparability
studies (Ref. 6), and stability protocols (Ref. 7), which are used to establish that a
consistently manufactured product is administered during all phases of clinical
investigation. However, the complexity of CGT products can present significant
challenge(s) to establishing potency assays (see Table 1). To facilitate the development
- 19 -
of CGT products, we recommend an incremental approach to product characterization
testing, including the development of potency assays. General recommendations for
progressive potency assay implementation are outlined in Section III.E. As described in
Sections III.A, III.E, and IV.C.4 of this document, your potency measurement will
evolve and may change significantly as you develop your product.
Table 1:
C. What Is the Relationship Between Potency and Clinical Effectiveness for CGT
Products?
There is no single test that can measure adequately those product attributes that predict
clinical efficacy. Clinical effectiveness is demonstrated by adequate and well-controlled
clinical investigations conducted with a consistently manufactured quality product.
Clinical effectiveness may be correlated to product potency, but clinical study data is
not a practicable quantitative measure of potency to release a lot. Rather, clinical study
results may be used to establish a correlation(s) 9 between the product’s clinical efficacy
and a potency measurement(s), which can be used for lot release, stability, and/or
comparability studies (see Section III.C for more details related to correlation studies).
- 20 -
A. How to Determine What to Measure for Potency?
Because of the complexity of CGT products, you need to acquire an appropriate
understanding of the biological properties of your product in order to develop relevant
and meaningful potency measurements. You should collect sufficient data throughout
preclinical and clinical development to inform and refine your approach to measuring
potency.
When initially determining the biological activity or activities that will guide your
potency assay design, you should consider relevant pre-clinical investigations, proof of
concept studies, early clinical studies, available historical experience, and available
reference materials and controls (see Section III.C). This information may provide you
with a basic understanding about product characteristics and biological activities that
contribute to function. Characterization data obtained during product development may
provide support for the potency assay that you choose initially, or it may lead to an
improved potency measurement as you prepare to market your product (see Sections
III.E and IV.C.4). As you develop your product(s), you should measure a wide range of
product properties in addition to those performed for routine lot release. This may help
you to assess which product attribute(s) best correlate(s) with potency. Although some
of the assays you evaluate may not be practical for lot release (e.g., difficult to
consistently obtain quantitative results, time-consuming), most properly designed assays
(see Section IV.A) have the potential to provide valuable information about product
attributes related to biological activity or clinical effectiveness, or both.
CGT products may present challenges for developing assays to measure specific
biological attributes that quantitatively demonstrate potency (see Table 1). CGT products
often have complex and/or poorly defined mechanism(s) of action (i.e., relevant
therapeutic or clinical functional activity), making it difficult to determine which product
attribute is most relevant to measuring potency. Nonetheless, potency measurements
should reflect the relevant biological attributes. For example, a gene therapy vector
should rely on at least two biological activities for its potency: the ability to transfer a
genetic sequence to a cell and the biological effect of the expressed genetic sequence.
Therefore, the potency assay should incorporate both a measure of the gene transfer
frequency and the biological effect of the transferred gene.
In addition, the proposed mechanism(s) of action for CGT products may be dependent
on more than one active ingredient10 (e.g., multiple cell types, multiple vectors,
multi-epitope vaccines). For some complex products (e.g., cellular tumor vaccine) there
- 21 -
could be ambiguity about which ingredients contribute to potency. For products that
contain more than one known active ingredient, you should design potency
measurement(s) to determine the biological activity (strength) of all active ingredients
(see 21 CFR 211.165(a)). Thus, if your product contains more than one active
ingredient you might need more than one assay to measure potency of the product
because one assay might be insufficient to measure the activity of each of the active
ingredients (Section III.B.3). Additionally, when designing your assay(s), you should also
consider the potential for interference or synergy between active ingredients.
- 22 -
• Product has complex mechanism of action
• Product has multiple active ingredients and/or multiple biological activities
• Limited product stability
• Biological assay is not quantitative, not sufficiently robust, or lacks precision
If one assay is not sufficient to measure the product attribute(s) that indicates potency,
then an alternative approach could be used to develop multiple complementary assays
that measure different product characteristics associated with quality, consistency and
stability. When used together and when results are correlated with a relevant biological
activity, these complementary assays should provide an adequate measure of potency.
Such a collection of assays (referred to as an assay matrix) might consist of a
combination of biological assays, biological and analytical assays, or analytical assays
alone (Refs. 13 and 14). The assay matrix may include assays that give a quantitative
readout (e.g., units of activity) or qualitative readout (e.g., pass/fail). If qualitative assays
are used as part of an assay matrix to determine potency for lot release, stability or
comparability studies, they should be accompanied by one or more quantitative assays
(see SectionC. What is Necessary to Correlate an Analytical Assay with Biological
Activity?
To demonstrate potency using an analytical assay as a surrogate measurement of
biological activity, you should provide sufficient data to establish a correlation between
the surrogate measurement(s) and the biological activity(ies) that is related to potency.
The relationship between the surrogate measurement and biological activity may be
established using various approaches, including comparison to preclinical/proof of concept
data, in vivo animal or clinical data, or in vitro cellular or biochemical data. If you
choose to use an analytical assay as a surrogate measurement of biological activity to
meet the potency requirements for licensed biological products, you should meet criteria
listed above in Section II.A. This could necessitate that you stress the product (i.e.,
show that the assay can detect an inactive or degraded product) and perform sufficiently
controlled studies (see Section IV.).
The suitability of data used to support surrogate assays for biological activity is
evaluated on a case-by-case basis and depends on or is influenced by the following:
- 23 -
• The amount of product information you have accumulated;
• How well the biological activity of the product is understood; and
• How well the surrogate measurement(s) reflects biological activity.
- 24 -
than assays used in later phase investigations. Nevertheless, as clinical studies progress
and product knowledge increases, you should develop and implement improved potency
measurement(s) that quantitatively assesses relevant biological product attribute(s) (see 21
CFR 312.23(a)(7)).
2. Later phase product development:
The primary objective of later phase investigational studies (i.e., Phase 3, pivotal12) is to
gather meaningful data about product efficacy. Efficacy is determined by adequate and
well-controlled clinical study(ies). Therefore, your potency assay design and acceptance
criteria should be sufficient to assure that a well-characterized, consistently manufactured
product was administered during your pivotal study(ies). Conformance to established
limits for potency should thus provide reasonable confidence that future product lots will
perform as expected at a given dose in patients.
In addition, you should use a well-characterized potency assay with established limits
during stability testing of conformance lots used to establish expiry dating for licensure
(see 21 CFR 610.53; Ref. 7).
3. Biological License
To market a biological product, a validated potency assay with defined acceptance
criteria must be described and justified in the BLA (21 CFR 601.2(a) and 211.165(e),
see also Section II.A). The acceptance criteria should be based on knowledge gained
through manufacturing experience and data collected from assays performed during all
phases of product development and clinical investigation (Ref. 5). As you evaluate
product conformance lots or lots manufactured explicitly for use in your pivotal clinical
studies, acceptance criteria should be refined to reflect these data.
The potency assay acceptance criteria defined in your BLA, which are intended for
subsequent lot release testing, should depict the potency limits established for product
lots used in the pivotal clinical studies demonstrating clinical effectiveness (see FDC
Act, Section 505(d), 21 U.S.C. 351).
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including appropriate controls. Assay design should also reflect knowledge of the factors
that influence assay variability. Therefore, you should consider sources of variability in
the assay method and take steps to limit them in your assay design. General principles
for reducing variability include using well-defined reagents, well-calibrated equipment,
and adequately trained operators. Assay variability can also be substantially reduced by
following detailed standard operating procedures (SOPs) and having appropriate controls
in place. Assay-specific controls will depend on the product being analyzed as well as
the assay used. You should also consider the long-term availability of critical reagents,
including reference materials and controls. Manufacturers may refer to several resources
for a more detailed discussion of assay design strategies (e.g., Refs. 13 through 20).
B. How Should Reference Materials and Controls be Utilized?
As with all well designed experiments, developing a potency assay should include
appropriate controls and a comparison to an appropriate reference material, when
available. Running a reference material and/or control samples in parallel with the
product helps ensure that the assay is performing as expected. In addition, controls help
establish that the equipment and reagents are working within established limits. A well
designed set of control samples can substantially increase confidence that results are
meaningful and reproducible.
Reference materials and standards can help with assay development and can be used to
develop and qualify more relevant “in house” reference materials and/or controls. A
number of reference materials, standards, and controls are available or are being
developed for characterizing biologics. For instance, there are fluorescent bead/antibodies
and particle size standards13 and guidelines14 available to help calibrate equipment and
help define acceptable parameters for quantitative flow cytometry analysis (Ref. 18).
Reference materials are also currently available for adenovirus type 5 (Ref. 19)15 and
retrovirus16 vectors. A reference material for adeno-associated virus type 2 vectors17 is
under development. Standard materials and controls for lentivirus vectors have also been
described (Ref. 20).
In the event that a universal standard or reference material is not available, you should
develop your own “in house” reference material(s) (Refs. 9 through 11). These may
include well characterized clinical lots or other well characterized materials prepared by
you or another resource (e.g., a well characterized cell line with a profile similar to
your product). There should be a clear rationale for how and why the reference material
(including “in house” reference material/control) was developed. We encourage you to
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consult with your CBER review team when developing or obtaining reference materials.
Because you will use reference materials at various stages of product development and
characterization, you should subject them to stability studies in parallel with your
product stability studies (Ref. 7). Moreover, you should appropriately characterize each
new batch of reference material, compare it with the original, and establish appropriate
procedures to qualify and eventually validate new reference materials. When possible,
you should retain samples (Refs. 6 through 8) of each lot of reference material for
comparison with newly manufactured reference material and prepare in advance for
depletion or expiration of reference materials.
C. What Should be Considered for an Assay Validation Plan?
1. Regulations
To obtain a biologics license, you must submit data in your BLA demonstrating, among
other things, that your product meets prescribed requirements of potency (21 CFR
601.2), which requires that you validate your potency assay with predefined acceptance
criteria (see 21 CFR 211.165(e)). The validation process identifies potential sources of
errors and quantifies them within the assay method. Numerous resources are available
for analytical methods validation (Refs. 9 through 11). You should perform analysis and
validation of all relevant assay parameters (Refs. 9 through 11), including:
• Accuracy
• Precision (Repeatability, Reproducibility)
• Sensitivity (Limit Of Detection/Quantitation)
• Specificity
• Linearity and Range
• System Suitability
• Robustness/Ruggedness
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statistical analysis and evaluation of the results presented in the study reports. Data
collected from potency assay validation studies, when provided in electronic format, can
facilitate statistical evaluations by the CBER review committee. The results of
validation studies should address the targeted validation parameters and their
conformance to acceptance criteria. We encourage you to initiate early discussions with
the review team to receive feedback on the design and analysis of potency experiments.
(See 21 CFR 211.194 for requirements pertaining to the laboratory records you must
keep.)
3. Validation of qualitative assays
As discussed in Section III.B.3, qualitative assays may be used as part of an assay
matrix to assess potency, provided that you conduct suitable correlation studies. You
should validate all parameters relevant to your qualitative assay and provide a rationale
for those parameters that you determine are not relevant. For example, although certain
assay validation parameters (e.g., linearity) may not be applicable to a qualitative assay
with a pass or fail readout, appropriate control samples should be used to characterize
the assay for specificity and sensitivity as well as for other features of acceptable
performance (e.g., robustness, system suitability).
Without quantitative data, demonstrating accuracy and precision could be challenging;
however, with proper assay design (e.g., sufficient replicates), you might be able to
demonstrate reproducibility. For semi-quantitative assays (assays with highly variable
quantitative readout, e.g., response in an animal model), broader acceptance ranges may
be considered for determining assay robustness and reproducibility. Also, limits of
detection and/or quantitation may be built into the assay design suitability criteria. For
example, if a reasonable amount of the control or reference material does not exhibit
the desired activity with sufficient statistical justification, the assay would not generally
be considered acceptable. Importantly, because of the complex nature of CGT products,
specific circumstances for determining assay suitability will vary from assay to assay.
Therefore, we encourage you to discuss planned experiments with your CBER review
team before you initiate specific assay designs and/or detailed experimental analyses of
potency measurements.
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plan to modify an assay that is used in an approved application or propose a new
assay, you must perform validation studies to demonstrate that the modified/new assay
continues to be an appropriate measure of potency (21 CFR 211.165(e)). These changes
must be submitted as a supplement to an approved application (21 CFR
601.12(b)(3)(vi)).
The quantity of data needed to support changes to potency measurements(s) will depend
upon a number of factors, including:
If you modify the potency measurement used during an investigational study, you
should qualify the assay and provide justification for the proposed change(s) (e.g., more
relevant, more practical, more quantitative).
These recommendations further emphasize the importance of maintaining retention
samples (e.g., product, reference materials, critical reagents) whenever possible. It will
be difficult to compare assays or determine if new assays are performing appropriately
without analyzing appropriate retention samples.
As this guidance indicates, a considerable amount of data might be necessary to develop
a suitable measurement of potency for your product (see also Ref. 14), and your
assay(s) might change over time as you develop your product and learn new
information and methods. We recommend that you have timely discussions with your
review team as you design, evaluate and validate your potency measurement.
V. REFERENCES
2. Guidance for Industry: Source Animal, Preclinical, and Clinical Issues Concerning the
- 29 -
Use of Xenotransplantation Products in Humans. (April 2003). Available at
http://www.fda.gov/cber/gdlns/clinxeno.htm.
3. Guidance for FDA Review Staff and Sponsors: Content and Review of Chemistry,
Manufacturing, and Control (CMC) Information for Human Gene Therapy Investigational
New Drug Applications (INDs). (April 2008). Available at
http://www.fda.gov/cber/gdlns/gtindcmc.htm.
4. Guidance for Reviewers: Instructions and Template for Chemistry, Manufacturing, and
Control (CMC) Reviewers of Human Somatic Cell Therapy Investigational New Drug
Applications (INDs). (April 2008). Available at
http://www.fda.gov/cber/gdlns/cmcsomcell.htm.
8. Guidance for Industry: CGMP for Phase 1 Investigational Drugs. (July 2008).
Available at http://www.fda.gov/cber/gdlns/indcgmp.htm.
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11. Chapter <1225> Validation of Compendial Methods. US Pharmacopeia 28, United
States Pharmacopeia Convention, Inc., Rockville, MD: 2005.
13. Kawakami K, Puri, RK. Regulatory Expectations During Product Development for
Tumor Vaccines. Brown F, Petricciani J editors. Development of therapeutic cancer
vaccines. Dev. Biol, Basel, Karger, 2004, vol 116, pp. 53-9.
14. Potency Measurements for Cellular and Gene Therapy Products, Cellular, Tissue and
Gene Therapies Advisory Committee (CTGTAC) Meeting. Gaithersburg Hilton, February
9, 2006. Available at
http://www.fda.gov/ohrms/dockets/ac/cber06.html#CellularTissueGeneTherapies.
15. Chapter <111> Design and Analysis of Biological Assays. US Pharmacopeia 28,
United States Pharmacopeia Convention, Inc., Rockville, MD: 2005.
16. Brown, F., Mire-Sluis A. (Eds.), The Design and Analysis of Potency Assays for
Biotechnology Products. Brown, F. (ed.), Developments in Biologicals, Vol. 107, Basel:
Karger (2002).
17. Montgomery, D. C. Design and Analysis of Experiments. John Wiley & Sons; 6th
edition (2005).
19. Hutchins, B., et al., Working Toward an Adenovirus Vector Testing Standard.
Molecular Therapy Vol. 2, No. 6, (December 2000).
- 31 -
20. Kiermer, V., et al., Report from the Lentivirus Vector Working Group: Issues for
Developing Assays and Reference Materials for Detecting Replication-Competent
Lentivirus in Production Lots of Lentivirus Vectors. BioProcessing Journal, March/April
2005: 39-42.
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GUIDELINE ON POTENCY TESTING OF CELL BASED IMMUNOTHERAPY
MEDICINAL PRODUCTS FOR THE TREATMENT OF CANCER
(EMEA/CHMP/BWP/271475/2006)
TABLE OF CONTENTS
3. SCOPE .................................................................................................................................... 3
PRODUCTS ................................................................................................................................ 4
DEFINITIONS ........................................................................................................................... 7
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1. EXECUTIVE SUMMARY
Licensed biological medicinal products must meet specifications for appearance, identity,
purity, biological activity and/or quantity of the drug substance. Determining the
biological activity of cell based immunotherapy products is not easy since the active
ingredient is usually composed of whole cells and the activity of these products can
generally not be attributed to one specific cell characteristic. The potency (i.e., the
quantitative measure of biological activity) of cell based immunotherapy products can be
measured using in vivo or in vitro tests. An appropriately validated potency assay
should be based on a defined biological effect as close as possible to the mechanism(s)
of action/clinical response. Surrogates for potency may be developed to demonstrate
biological activity of the test sample. Development and validation of such assays for
cell based immunotherapy products need special considerations. This document represents
CHMP’ current thinking on these issues.
2. INTRODUCTION (background)
Cell based immunotherapy aims at treating patients by stimulating their immune system
using autologous or allogeneic cells. Immunotherapy of cancer is based on an immune
response targeted against tumour-specific/tumour associated antigen(s), leading to
destruction of malignant cells. The targeting of interactions between the immune system
and the tumour constitute a complex approach of which the precise mechanisms of
action are often not fully understood.
In the scientific literature, cell based immunotherapy products for the treatment of
cancer are sometimes called cell based tumour vaccines or cancer vaccines.
According to the ICH guideline1 the biological activity describes the specific ability or
capacity of a product to achieve a defined biological effect. Potency is the quantitative
- 34 -
measure of biological activity based on the attribute of the product, which is linked to
the relevant biological properties.
Current guidance on cell therapy based medicinal products is found in the Guideline for
Human Cell based Medicinal Products (CHMP/410869/2006) replacing the CPMP Points
to consider (PtC) on the manufacture and quality control of human somatic cell therapy
medicinal products (CPMP/BWP/41450/98). According to these guidelines the final cell
therapy product should be subjected to quality control and lot release testing as well as
to tests to evaluate the shelf-life of the product. This should include a potency assay,
which should be properly validated. However, specific guidance related to the
development and validation of such assays is not available.
3. SCOPE
This guidance document covers viable cell products for cancer-immunotherapy from
autologous or allogeneic origin, consisting of e.g. whole tumour cells or autologous
dendritic cells loaded with tumour antigens, all intended to induce tumour-specific
cytotoxity although the immunological pathway may differ between products.
Tumour-specific cells intended for adoptive transfer (i.e. passive immunisation strategies)
are also included, for example ex-vivo primed T-cells. Some principles outlined in this
document may also be applicable to tumour cell lysates.
4. LEGAL BASIS
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This guideline has to be read in conjunction with the introduction and general principles
(4) and Part I: Standardised marketing authorisation dossier requirements as well as Part
IV: Advanced therapy medicinal products of the Annex I to Directive 2001/83/CE as
amended.
Determining the biological activity of cell based immunotherapy products is not easy
since the active ingredient is usually composed of whole cells and the activity of these
products can generally not be attributed to one specific cell characteristic. Potency
assays for immunotherapy products will be based on complex immune mechanisms
which are often poorly or incompletely understood and which may be complicated by
multi-antigen formulations and inherent variability of the starting material.
- 36 -
complex involving both a cellular and humoral immune response. Assays based on
antibody formation against selected antigens or assay based on quantitative antigen
expression could thus be considered as well. However, the results of the pivotal studies
should ultimately support the chosen assay. Induction of a non-relevant immune
response (e.g. an antibody response that is not relevant as regards to the defined
biological effect) in animals following administration of the medicinal product is
generally not accepted as a measurement of potency.
Ideally, one single properly developed and validated assay is sufficient to cover both
characterisation issues and batch release testing. However, different kinds of assays may
be needed depending on the purpose of the assay, e.g. to characterise the active
substance, to validate the production process, to show batch-to-batch consistency, and to
determine the stability during shelf life. A potency assay is an extremely valuable tool
to provide assurance of unaltered biological characteristics of the product throughout the
development of the product. This is especially important when changes to the
manufacturing process are introduced after production of material for non-clinical studies
or pivotal clinical studies.
It may be prudent to develop in parallel different potency assay most suitable for their
intended use. These may comprise for example functional bioassays or, where justified,
assays based on quantitative antigen expression.
Preferably, a suitable potency assay should be in place already when material for the
first clinical trial is produced and it should be validated prior to phase III clinical trials
unless otherwise justified. Lot release and shelf life specifications for potency should be
determined and amended during product development, as appropriate. It is strongly
recommended that the development of a suitable potency assay be started as soon as
possible.
- 37 -
An in vivo potency assay is a useful tool to verify the biological activity of the active
ingredient. However, the development of a relevant biological in vivo potency assays for
cell based immunotherapy products may be hampered by the lack of a relevant animal
model due to the inherent immunological differences between man and animals. In
addition to the lack of suitable animal models, it is acknowledged that such assays very
often suffer from wide inherent biological viability.
In vivo potency testing may also be particularly lengthy to perform and as such may
not be practical for lot release. However, the use of relevant animal models should be
fully explored for their applicability for routinely performed assays. Moreover, they
might be useful as a product characterization tool, e.g., after the introduction of a
process change or any other change that may impact the quality of the medicinal
product. For example, animals which are transgenic for human major histocompatibility
antigens can be used to present human antigens to the immune system of these animals.
Also, immuno-compromised animals (e.g., athymic mice) might be used to determine
the functional response of adoptively transferred human T-cells as the measurement of
potency.
As for any animal based potency assay, suitable conditions for conducting in vivo
animal testing should be set after appropriate validation. Some principles outlined in
current available guidance for biological assays of prophylactic vaccines and their
statistical analysis may be useful (e.g. Ph.Eur. 2.7 & 5.3.6).
Where a direct measure of potency is not possible, surrogates for potency may be
developed to verify biological activity of the test sample provided that a correlation
between the surrogate and the defined biological activity has been demonstrated.
Surrogate analysis may comprise different kind of tests including determination of cell
- 38 -
surface markers, activation markers, secretion of factors, expression of a single gene
product or protein expression pattern. Surrogate for potency may be developed for both
in vitro and in vivo potency tests.
If the mechanism of action of the medicinal product can be clearly related to specific
antigens (i.e., tumour-specific antigens, tumour-associated antigens), the potency assay
could be based on quantification of these antigens by suitable methods (e.g. flow
cytometry analysis). However, special consideration should be given to the validation of
non-standard methods if used for batch release testing. The possibilities of using
combinations of certain parameters (e.g. viability, cell marker expression, antigen
expression) could be envisaged.
One of the requirements included in Directive 2003/63/EC (Annex I, part IV) is that
human somatic cell therapy medicinal products are made of a defined number (pool) of
viable cells. Cell viability is an important parameter of product integrity and may be
used as an in-process control after manipulation of certain cell characteristics e.g.
up-regulation of cell surface expression of specific antigens after cytokine treatment. Cell
viability may also be an important element of the potency of cell based products.
However, it should be linked with other measures of potency that demonstrate the
potential for biological activity of the product, such as quantitative antigen expression or
biological activity as measured in the bioassay.
For cell based immunotherapy products comprised of autologous cells, sample and time
constraints may hamper complete batch control testing at release. In addition, there may
be an inherent variability within the sourced autologous cell population, which cannot be
fully rectified by the manufacturing process. In this case the use of variable cell
populations may be clinically justified. This variability in cell characteristics could pose
difficulties in validation of the potency assay and in assigning acceptance limits for
potency.
- 39 -
Nevertheless, whenever a manipulation generates a more homogeneous subpopulation, the
development of an appropriate potency assay should be fully explored, which could
effectively be applied either as a characterisation tool or batch release test, or both. In
this situation, the absence of a suitable potency assay is not accepted without proper
justification, as this will pose difficulties in demonstrating production consistency of
autologous cell preparations after changes in manufacture or product composition have
been implemented.
In general, potency assays on biological medicinal products rely heavily on the use of
reference preparations with an established potency. Most likely, no international reference
preparation will be available for highly specific cell based immunotherapy products and
it may be difficult to generate such preparations for autologous products.
‘n-house’reference materials should be characterised in terms of their composition, purity
and biological activity as thoroughly as possible by physicalchemical- biological
methods. The in-house reference material should preferably be clinically qualified
or shown to be comparable to materials shown to be efficacious in clinical trials.
There may be cases, where immunotherapy products will require an adjuvant to raise
their low immunogenicity. However, it should be kept in mind that these adjuvants may
exert activities that may interfere with the intended potency assay. For example,
Mycobacterium bovis (bacillus Calmette- Guerin - BCG)5 has been used as an adjuvant
but one of the BCG activities is associated with activation of monocytes/macrophages6.
Where the adjuvant is combined with the active cellular moiety prior to performing the
potency assay and the adjuvant may interfere with the specific biological activity,
special considerations should be given to this issue during assay development.
Compounds that are given separately and/or at a different time point in order to
pre-condition the immune system and that may be needed for biological activity, are not
considered to be adjuvants. As such, those compounds are outside the scope of this
specific section.
- 40 -
DEFINITIONS
Biological activity:
The specific ability or capacity of the product to achieve a defined biological effect.
Potency:
The measure of the biological activity using a suitably quantitative biological assay (also
called potency assay or bioassay), based on the attribute of the product, which is linked
to the relevant biological properties.
Medicinal Products
6 Suttmann H., Jacobsen M., Reiss K., Jocham D., Bohle A,. Brandau S.
- 41 -
GUIDELINE ON HUMAN CELL-BASED MEDICINAL PRODUCTS
TABLE OF CONTENTS
- 42 -
EXECUTIVE SUMMARY
This guideline replaces the Points to Consider on the Manufacture and Quality Control
of Human Somatic Cell Therapy Medicinal Products (CPMP/BWP/41450/98). It takes
into account the current legislation and the heterogeneity of human cell-based products,
including combination products. A risk analysis approach can be used by the applicants
to justify the development and evaluation plans and can be a basis for the preparation
of a risk management plan.
In the quality and manufacturing section, guidance is provided on the criteria and
testing of all starting materials, on the design and validation of the manufacturing
process, on characterisation of the human cell-based medicinal products, on quality
control aspects, on the development programme, traceability and vigilance* and on
comparability issues. Guidance specific to the matrix/device/scaffold component in
combination products is
The guideline acknowledges that conventional non-clinical pharmacology and toxicology
studies may not be appropriate for cell-based medicinal products. Therefore the guideline
addresses which non-clinical studies are necessary to demonstrate proof-of-principle and
to define the pharmacological and toxicological effects predictive of the human response.
Special problems might be associated with the clinical development of human cell-based
medicinal products. Guidance is therefore provided on the conduct of
pharmacodynamic/pharmacokinetic studies, dose finding and clinical efficacy and safety
studies. The guideline describes the special consideration that should be given to
pharmacovigilance aspects and the risk management plan for these products.
1. INTRODUCTION (background)
Rapid development in the fields of biology, biotechnology and medicine has led to the
development of new treatments and highly innovative medicinal products, including
medicinal products containing viable cells. These new cell-based medicinal products have
a high potential in the treatment of various diseases where there is a previously unmet
medical need.
Human cell-based medicinal products are heterogeneous with regard to the origin and
type of the cells and to the complexity of the product. Cells may be self-renewing stem
cells, more committed progenitor cells or terminally differentiated cells exerting a
specific defined physiological function. Cells may be of autologous or allogeneic origin.
- 43 -
In addition, the cells may also be genetically modified. The cells may be used alone,
associated with biomolecules or other chemical substances or combined with structural
materials that alone might be classified as medical devices (combined advanced therapy
medicinal products).
2. SCOPE
Although this document does not cover non-viable cells and cellular fragments
originating from human cells, the underlying scientific principles may be applicable.
3. LEGAL BASIS
This guideline should be read in conjunction with the introduction and general principles
(4) and part 4 of the Annex I to Directive 2001/83/EC1 as amended and the Regulation
on Advanced Therapy Medicinal Products 1394/2007/EC2.
Also, donation, procurement and testing of cells from human origin must comply with
- 44 -
overarching Directive 2004/23/EC4 and technical directives drawn from it, Directives
2006/17/EC5 and 2006/86/EC6.
At the beginning of the product development, an initial risk analysis may be performed
based on existing knowledge of the type of product and its intended use. This should
be updated by the applicant throughout the product life cycle as data are collected to
further characterise the risk.
The comprehensive risk analysis should be used to justify the product development. It
should also serve as a basis for the preparation of a risk management plan in
accordance with the guideline on risk management systems for medicinal products for
human use (EMEA/CHMP/96268/2005)7. In particular, the results of the comprehensive
risk analysis should be used:
• to identify risk factors associated with the quality and safety of the product;
• to determine the extent and focus of the data required during non-clinical and
clinical development;
• when establishing the need for risk minimisation activities;
• when determining the post market risk management activities specified
The following general risk criteria (non-exhaustive) can be used in the estimation of the
- 45 -
overall risk of the product:
• origin (autologous-allogeneic);
• ability to proliferate and/or differentiate;
• ability to initiate an immune response (as target or effector);
• level of cell manipulation (in vitro/ex vivo expansion/activation/ differentiation
/genetic manipulation/ cryo-conservation);
• mode of administration (e.g. ex vivo perfusion, local or systemic surgery);
• duration of exposure or culture (short to permanent) or life span of cell;
• combination product (cells and bioactive molecules or structural materials);
• availability of clinical data on or experience with similar products.
CBMP often contain, or consist of cell samples of limited size and many are intended
to be used in a patient-specific manner. This can raise specific issues pertaining to
quality control testing designs for each product under examination. Since this document
covers a variety of CBMPs, processes involved can vary from very simple to highly
complex. For certain CBMPs, the starting material, the active substance and the finished
product can be closely related or nearly identical. For such products, some requirements
listed below could be inadequate and in those cases only relevant sections and items
should be addressed.
- 46 -
The manufacturing process of CBMP usually does not include terminal sterilisation,
purification steps, viral removal and/or inactivation steps. Therefore, stringent sourcing
requirements and acceptance criteria for all materials derived from human or animal
origin should be adequately defined according to their intended use.
4.2.1.1. Cells
Donated cellular material from single or pooled donors, once processed (see 4.2.2.1)
may be:
• A single primary cell isolate used directly for the CBMP;
• Primary cells cultured for a few passages before being used for the CBMP;
• Cells based on a well-defined cell bank system consisting of a master cell
bank and a working cell bank.
The specific requirements for donation, procurement and testing laid down in Directive
2006/17/EC5 shall be met.
Procedures and standards employed for the selection of appropriate donors and the
exclusion of high-risk or otherwise unsuitable candidate donors should be clearly
delineated and justified. If it is necessary to pool cells from different donors, the risk
analysis should address the possibility that pooling of allogeneic cell populations may
increase the risk of undesired immunological responses in the recipient and compromise
its therapeutic activity. In addition, pooling of cells may increase the risk of disease
transmission. Depending on the nature of the source of the cells and tissues, other risk
- 47 -
factors, e.g. previous radiation exposure, should be also considered and addressed.
Quality parameters aimed at the definition of acceptance criteria for a given organ or
tissues should be specified, taking into consideration general aspects such as shipment
and storage conditions.
In the case of autologous donation, the testing regimen of the starting material should
be justified, taking into account the autologous use.
Where allogeneic primary cells are collected and expanded for use in multiple patients,
the cell lot should be appropriately characterised. The same characterisation programme
shall be applied to each new cell lot.
Where cell lines are used, an appropriately characterised Master Cell Bank (MCB) and
Working Cell Bank (WCB) should be established, whenever possible. Cell banking and
characterisation and testing of the established cell banks should comply with the ICH
guideline Q5D10.
Various materials are needed for collection, selection, culture or even genetic or
phenotypic modification of cells, such as other cells, enzymes, antibodies, cytokines, sera
and antibiotics. Exposure to such materials can also impact on the quality, safety and
efficacy of the final therapeutic product. As a consequence, each substance used in the
procedure should be clearly specified and evaluated as to its suitability for the intended
- 48 -
use. The microbial purity and low endotoxin level of these materials should be ensured.
Materials, including cells that function as support for growth and adhesion e.g. feeder
cells should be evaluated and/or validated as to their suitability for the intended use.
The quality of biologically active additives in culture media such as growth factors,
cytokines and antibodies, should be documented with respect to identity, purity, sterility
and biological activity and absence of adventitious agents. It is recommended to keep
the use of such materials to a minimal and to avoid the use of reagents with
sensitisation potential e.g. β-lactam antibiotics.
Where appropriate, the Note for Guidance on the “Production and quality control of
medicinal products derived by recombinant DNA technology”16 and the Note for
Guidance on the “Production and quality control of Monoclonal Antibodies”17 should be
taken into account.
When the raw materials, reagents and/or excipients have a marketing authorisation or
mentioned in a Pharmacopoeia, appropriate references may be given.
The following information must be added for materials of human or animal origin:
- 49 -
culture media, the use of serum isolated from the same individual who donated the cells
is preferred, where possible, to alternate allogeneic serum.
Where cells or tissues of animal origin are used e.g. as supportive cells, the guidance
given in “Points to consider on Xenogeneic Cell Therapy Medicinal Products”19 should
be followed.
Animal derived reagents may harbour infectious agents and may increase undesirable
immunological responses in the recipient. When applicable, the use of animal reagents
should be avoided and replaced by non animal derived reagents of defined composition.
When bovine serum is used, the recommendations of the Note for Guidance on the
“Use of Bovine Serum in the Manufacture of Human Biological Medicinal Product”20
should be followed. The use of irradiated sera and/or alternative synthetic media is
encouraged and should be considered.
For viral safety testing of materials of other animal species, the table of extraneous
agents to be tested for in relation to the general and species-specific guidelines on
production and control of mammalian veterinary vaccines21 and Note for Guidance on
Production and Quality Control of Animal Immunoglobulins and Immunosera for Human
use22 should be consulted.
C. Special considerations
Special recommendations for the starting materials of cell-based Gene Therapy Medicinal
Products
When the cells in the active substance are genetically modified, the “Note for Guidance
on the quality, preclinical and clinical aspects of gene transfer medicinal products”23
should be followed, which gives details on the quality control, characterisation and
preclinical testing of gene transfer vectors. Cell populations which are transformed
should be assayed for appropriate and reproducible expression of the newly acquired
- 50 -
characteristics. Special attention should be paid to the level and length of expression
and quality of the gene product(s) produced by the cells. As far as applicable and
practicable, the new characteristics of the cells should be quantified and controlled.
Any matrices, fibers, beads, or other materials that are used in addition to or in
combination with the cells should be described and their function underpinned by means
of chemical, biological, physical (e.g. structure and degradation) and mechanical
properties. Inclusion of additional bioactive molecules should also be described and their
impact should be evaluated.
A detailed description of the manufacture of the active substance and of the finished
product should be provided. The type of manipulation(s) required for cell processing and
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the physiological function of the cells shall be described. A flow diagram of the entire
process starting from biological fluid/tissue/organ or from cell banks should be prepared
indicating critical steps and intermediate products (e.g. intermediate cell batches), as well
as operating parameters, in-process controls and acceptance criteria. Manufacture of
combined medicinal products consisting of cells and matrices/devices/scaffolds, require
additional consideration regarding the cell-matrix/scaffold interactions and quality issues
raised there from. Attention should be paid to biodegradable materials, which may
possess the potential for environmental changes (e.g. raising pH) for the cells during the
manufacture or after administration.
The manufacturing area should be physically separated from the procurement area If
different tissues and cellular products are processed and stored in the same
manufacturing area there is an increased risk of cross contamination during each step of
the procedure, e.g. via processing equipment or in storage containers such a liquid
nitrogen tanks, and therefore, adequate control measures to prevent cross-contamination
should be put into place.
Equipment and premises used for manufacturing of CBMP should be suitable and
qualified for aseptic production. It is recommended that dedicated, product-specific or
single-use equipment are used in the production, whenever possible.
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and growth characteristics of the cells.
After appropriate controls have been performed / implemented, the biological fluid /
tissue /organ can undergo one or more of the following steps:
Organ/tissue dissociation
The procedure to obtain the cells from the organ/tissue has to be described (with
respect to the type of enzyme, media, etc.) and validated. Consideration should be given
to the degree of disruption applied to the tissue in order to preserve the intended
functional integrity of the cellular preparation and to minimize cell-derived impurities in
the product (cell debris, cross contamination with other cell types).
Any procedure used to isolate and / or purify the cell population of interest should be
described. Its effectiveness should be addressed in relation to the intended use and the
method(s) should be validated.
Cell culture
During in vitro cell culture, consideration should be given to ensure acceptable growth
and manipulation of the isolated cells. The processing steps should be properly designed
to preserve the integrity and control the function of the cells. The procedures for any
manipulation should be documented in detail and closely monitored according to specific
process controls. The duration of cell culture and maximum number of cell passages
should be clearly specified and validated. The relevant genotypic and phenotypic
characteristics of the primary cell cultures, of the established cell lines 10 and the
derived cell clones should be defined and their stability with respect to culture longevity
determined. Consistency/repeatability of the cell culture process should be demonstrated
and the culture conditions including the media and the duration should be optimised
with respect to the intended clinical function of the cells.
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growth factors since cell subpopulations may gain a growth advantage under defined in
vitro culturing conditions.
Cell modification
Various treatments (physical, chemical or genetic) can be applied to cells. The method
used to modify the cells should be fully described. In the case of genetic modification
of cells, requirements set up in the Note for guidance on Quality, preclinical and
clinical aspects of gene transfer medicinal products23 should be followed.
If the cells are grown directly inside or on a matrix/device/scaffold, the quality of the
combined advanced therapy medicinal product relies predominantly on the properly
controlled manufacturing process. For such products, the cell culture process has to be
thoroughly validated and the effect of the device on the cell growth, function and
integrity has to be taken into account. The effect that the cells may exert on the device
(e.g. on rate of degradation) should also be considered (see also 4.2.6. Development
Pharmaceutics).
2. In-process controls
3. Batch definition
The purpose of the batch definition is to ensure consistency and traceability. A clear
definition of a production batch from cell sourcing to labelling of final container should
be provided (i.e. size, number of cell passages/cell duplications, pooling strategies, batch
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numbering system). In the autologous setting, the manufactured product should be
viewed as a batch.
A description of the container closure system should be provided. Compatibility with the
product should be demonstrated. It should be indicated if the container closure per se
has a CE marking under the Medical Devices Directive 93/42/EEC24. Information on the
sterilisation procedures of the container and the closure should be provided.
4.2.3 Characterisation
The characterisation of a CBMP should encompass all the components present in the
finished product. Characterisation may prove particularly challenging for products
containing cells together with matrices, scaffolds and innovative devices. Characterisation
data are likely to be necessary for single components as well as for the combined final
product. Characterisation data could encompass data obtained throughout the development
and/or manufacturing process. It should be noted that in a combined product the
characteristics of both the cellular and the non-cellular components may be altered by
the process of integration.
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components acting in a “tissue-like” fashion as a whole. Therefore, when considering
the extent of characterisation, the following issues should be taken into account: i)
autologous cells vs. allogeneic cells, ii) extensively or minimally manipulated in vitro,
iii) immunologically active or neutral, iv) proliferative capacity of the cells, v) cell-like
or tissue-like organisation and dynamic interactions amongst cells and with the structural
component, vi) intended use.
The characterisation should be designed to allow setting up the routine controls that will
be applied for release of the active substance and finished product as well as those to
be performed at several steps of the process to guarantee batch consistency.
If biologically active molecules (e.g. growth factors, cytokines etc.) are present as
components of the cell-based products, these have to be described adequately and their
interaction with the other components of the product and the surrounding tissues after
administration should be characterised. This should involve an appropriate range of in
vitro and where necessary in vivo methods.
1. Identity
Cellular Component
The identity of the cellular components, depending on the cell population and origin,
should be characterised in terms of phenotypic and/or genotypic profiles.
When addressing the phenotype of the cells, relevant markers could be used, where
justified. These markers may be based on gene expression, antigen presentation,
biochemical activity, response to exogenous stimuli, capability to produce biologically
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active or otherwise measurable molecules, etc. For adherent cells, morphological analysis
may be a useful tool in conjunction with other tests. Where applicable, a description of
the procedures which could lead to a modification of the characteristic of the product,
including adhesion, absorption, degradation, presentation of components of the culture
media, should be provided.
Combination Products
2. Cell purity
The cellular population of interest could contain other cells that are of different lineages
and/or differentiation stage or that may be unrelated to the intended population.
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Where a specific cell type is required for the indication, the unwanted cells should be
defined and their amount in the final product should be controlled by appropriate
specifications, i.e. acceptance criteria for the amounts of contaminating cells should be
set.
In cases, where the desired biological activity and efficacy of the product requires a
complex mixture of cells, the cell mixture needs to be characterised and its composition
controlled by appropriate in-process controls and release testing.
Irrespective of the cell type, the cell population can be contaminated with non-viable
cells. Since cell viability is an important parameter for product integrity and directly
correlated to the biologic activity, the ratio between non-viable and viable cells should
be determined and specifications should be set.
3. Impurities
Product or process-related
Any material capable to introduce degradation products into the product during the
production, e.g. biodegradable materials, should be thoroughly characterised in this
respect and the impact of the degradation products to the cell component(s) should be
addressed.
If genetically modified cells are used in the product, any additional proteins expressed
from the vector, e.g. antibiotic resistance factors, selection markers, should be analysed
and their presence in the product should be justified.
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Adventitious agents
A critical aspect is to establish that CBMP are free from adventitious microbial agents
(viruses, mycoplasma, bacteria, fungi). The contamination could originate from the
starting or raw materials (see above), or adventitiously introduced during the
manufacturing process. A risk assessment should be performed to evaluate the possibility
of reactivation of cryptic (integrated, quiescent) forms of adventitious agents. A thorough
testing for the absence of bacteria, fungi and mycoplasma shall be performed at the
level of finished product. These tests should be performed with the current
methodologies described in the European pharmacopoeia for cell based products28. In
cases where the short shelf life of the CBMP is prohibitive for the testing of absence
of bacteria under the Eur Ph. requirements, alternative validated testing methods may be
acceptable, if justified.
4. Potency
According to the ICH guideline 6QB29, potency is the quantitative measure of biological
activity based on the attribute of the product, which is linked to the relevant biological
properties. The assay demonstrating the biological activity should be based on the
intended biological effect which should ideally be related to the clinical response.
Basically, two types of potency assays can be envisioned: 1) in vitro assays using cell
systems and 2) in vivo assays using animal models. Major cellular functions as viability,
self renewal, death and differentiation are pivotal to the quality, function and
sustainability of the CBMP and may need to be monitored during production and at
release using surrogate markers and appropriate technology (e.g. gene expression profiles
by microarrays, flow cytometric immunofluorescent analysis, cell cloning, PCR and many
others). In vivo assays for potency may also be useful especially when experimental
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animal models are available.
Markers for purity and markers for potency should not be mixed in the same assay. .
An in vivo test can either be performed in an animal model mimicking the intended
clinical tissue repair/ regeneration or can otherwise be based on the mode of action
(e.g. an ectopic model). An in vitro assay can be based on the expression of markers
that have been demonstrated to be directly or indirectly (surrogate markers) correlated to
the intended biological activity, such as cell surface markers, activation markers,
expression pattern of specific genes. Also a physiological response under defined
conditions such as differentiation in specific cell types and/or secretion of tissue specific
proteins (e.g. extracellular matrix components) can be used as a basic principle for a
potency test. The manufacturers should, however, ensure that the method of
characterisation is relevant for the intended biological effect in vivo.
The potency assay should be performed by using a specified number of cells and, when
possible, quantified against a qualified reference preparation. The potency should be
defined as the required time to obtain a predefined effect (e.g. restoration of function or
repair of anatomical structure) or the potency is calculated from the measured effect in
a defined time period.
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express certain desirable proteins like growth factors, cell surface antigens or other
molecules in order to sustain the biological response as long as needed in the new
microenvironment. Therefore, the potency assays to be developed should be able to
assess the activity-related aspects of the active substance that may be composed not
entirely of intact viable cells but also of other components.
If the intended biological function of the CBMP is mainly based on the capacity of
cells to secrete specific molecule(s) e.g. to repair a metabolic disorder, to promote
growth, to release a metabolite, then its potency assay will be based on the detection of
the active molecule(s) produced and the biological activity expected. This can be carried
out by conventional reliable qualitative and quantitative analytical methods (protein
analysis, nucleic acid identification, HPLC chromatography etc.). The same molecule can
be also assessed for function in animal model systems assuming that the active
substance is released from the cell-based medicinal product into biological fluids
(plasma, CSF, urine or interstitial fluid).
Immunotherapy
Potency assays of cell-based medicinal products intended for immunotherapeutic use will
be based on complex immune mechanisms which may be complicated by multi-antigen
formulations and inherent variability of the starting material. Special guidance for
cell-based immunotherapy medicinal products is provided in Guideline on “Potency
testing of cell-based immunotherapy medicinal products for the treatment of cancer”30.
5. Tumourigenicity
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vaccines for human use31.
For proper quality control, the active substance and/or the final product should be
subjected to release testing, whenever possible. If justified, it would be acceptable to
have reduced testing at one level provided an exhaustive control is performed at the
other. All release testing should be performed using methods validated at the latest at
the time of submission of an application.
1. Release criteria
The release specifications of the active substance and finished product should be
selected on the basis of parameters defined during the characterisation studies. Selection
of tests is product-specific and has to be defined by the manufacturer.
Specifications for release testing should include identity, purity, potency, impurities,
sterility, potency, cell viability and total cell number, unless otherwise justified. If the
structure is an essential characteristic of the product, the structural characteristics of the
active substance or finished product shall be defined and justified. In case the primary
function of the CBMP is the excretion of specific proteins, specifications regarding these
excreted proteins should be set.
If certain release tests cannot be performed on the active substance or finished product,
but only on key intermediates and/or as in-process tests, this needs to be justified. In
these cases an adequate quality control has to rise from the manufacturing process,
supported by the results of the clinical studies. These exceptions may include the
following:
§ Some release tests might not be feasible on the combined components of the
active substance/ finished product for technical reasons.
§ A complete release testing cannot be finalised before the product is
administered to the recipient due to time restrictions (e.g. in case of
autologous products, which are administered immediately after completion of
the production and initial testing). However, a critical set of essential tests
that can be performed in the limited time prior to clinical use must be
defined and justified. Whenever feasible, retention samples should be stored
for future analysis.
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§ The amount of available product is limited to the clinically necessary dose
(e.g. due to very limited cell numbers at collection or low proliferation rates).
The release of the product should be justified by the validation of the cell
manipulation process and the in-process controls.
2. Stability testing
A shelf life for the cells under specified storage conditions shall be determined for the
following materials: i) all intermediates subject to storage if applicable, ii) components
of the combined CBMP, iii) the active substance, iv) the finished product. Furthermore,
a valid in-use shelf life (after opening from the transport container) should be assigned
to the CBMP. Also, all storage conditions including temperature range should be
defined. Transportation and storage conditions should be supported by experimental data
with regard to the maintenance of cell integrity and product stability during the defined
period of validity. If relevant, appropriate methods for freezing and thawing should be
documented.
Due to the complex nature of the active substance of a CBMP, requirements for
stability should be defined on a case-by-case basis. Whenever possible, stability should
be assessed for both the cellular as well as the non-cellular component prior to
combination and together as a finished product in the final packaging.
If cells have been genetically modified, quality control must be performed in compliance
with guidance available on gene transfer medicinal products23. This information is in
addition to control of the cells according to the guidance presented elsewhere.
Specifications for structural components of the product shall be defined. Impurities and
degradation product that originate from the structural component (matrix, scaffold,
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device) shall be described and specifications for the relevant impurities should be set.
Testing of the structural/mechanical properties and biological activity with reference to
the anticipated conditions for use and potential for degradation may be difficult to
conduct as part of release testing. Thus, it is anticipated that these parameters could be
explored through proper testing of raw materials and characterisation studies of the final
product. In extremely limiting conditions (e.g. for autologous products with small cell
numbers), the analysis of structural/functional characteristics of a combination product
may necessitate the development of a model product composed of same non-cellular
components combined with cell component(s) of equal characteristics but with proven
availability.
The entire manufacturing process, including cell harvesting, cell manipulation processes,
maximum number of cell passages, combination with other components of the product,
filling, packaging, transport, storage etc., should be validated. Validation of the
production process of a combined product should encompass all steps from separate
components up to the final combination to ensure consistent production.
It should be demonstrated that each step of the manufacturing process of the active
substance, supportive components and final product is well controlled. The selection and
acceptance criteria of the operational parameters and the in-process controls should be
justified. Putative variability, related to starting materials and biological processes, should
be taken into account in the validation. Furthermore, the critical points of the
manufacturing process should be defined and validated, especially the aseptic processing.
Any preservation steps, holding periods and/or transportations of the active substance,
final product, supportive structures or intermediate products during the manufacturing
process should be validated.
In case of limited sample sizes (e.g. autologous preparations for one single
administration), it is recommended that a more extensive validation is performed with
cell preparations of comparable characteristics but available in sufficient amounts for
validation purposes. It is recommended that validation of such a manufacturing process
is performed depending on the product characteristics, for adventitious agents, identity,
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potency, viability, purity/impurities and other product specific parameters.
The general principles set out in Note for Guidance on Development Pharmaceutics for
Biotechnological/Biological Products32 can be applied to human CBMP. The potential
complexity of composition and the dynamic nature of a product containing living cells
will result in very specialised pharmaceutical and biopharmaceutical requirements for
each development programme from the individual cell components into the final product.
1. Cellular Components
The development programme should address the choices of materials and processes to
be used in production. This should be addressed from the point of view of the
biological/therapeutic function, the maintenance and the protection of the cell population.
Integrity of the cellular component is most critical for the CBMP and must be assessed
by the ability of cells to survive, and maintain the genotype or phenotype needed for
the intended functions. However, detection of possible changes in cellular nature that
may influence the intended function, can be feasible by analysis of cellular surface
antigens, proteomics and functional genomics analysis (e.g. microassay for gene
expression profile, flow cytometry etc.). Cell viability can be easily assessed in culture
by employing widely applied assays. For combined products, where structural
components are an integral part of the active substance, such assays may be more
difficult to apply. Alternative approaches could be sought such as combination of other
suitable assays (e.g. detection of pH and O2 / CO2), where needed.
2. Non-Cellular Components
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molecules, proteins or chemical entities. These may supply structural support, suitable
environment for growth, biological signalling or other functions. They may also be used
during the ex vivo manipulation process.
Matrices, scaffolds, devices, biomaterials or biomolecules which are not an integral part
of the active substance, are considered as excipients of the finished product. For
excipient(s) used for the first time in combination with cells and/or tissues, the
requirements for novel excipients, as laid down in part I, Annex I of Directive
2001/83/EC1, do apply. Conventional excipients should also be characterised with respect
to their combination with cells.
Information on the choice of excipients, their properties, their characteristics and the
design and testing of a final scaffold/matrix should be provided in the dossier as part
of the development pharmaceutics.
Should the finished product contain components that act to modify the delivery or
ensure the local retention of cells after administration, the scientific rationale should be
provided and supported by adequate development data. The evaluation of individual
non-cellular components is required although aspects of this evaluation may be
incorporated into studies designed to assess the product as a whole. Where the safety of
a non-cellular component has previously been established for other applications, for
example in support of the approval of a particular material for a medical device or
medicinal product application, elements of that evaluation may be applicable to an
evaluation of its safety and suitability when used in a cell-based medicinal product, if
justified.
The relevance of the structural and functional characteristics of the non-cellular
components in a combination product should be discussed. Interaction of the cellular
component and any additional non-cellular components with the device should be
evaluated and the development and characteristics of the combined product as a whole
should be presented.
Tissue differentiation and functionality are highly dependent on the local environment
and thus on the choice of biomaterials and cell signalling biomolecules (e.g. growth
factors). Therefore, studies should be carried out to verify critical aspects of the
character and performance of biomaterials and other non-cellular components used in the
CBMP, for example biocompatibility and mechanical strength.
In particular, to confirm that the properties of a biomaterial permit the growth and
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proper function of the tissue/cells with which it is in contact and support the overall
performance of the product, assurance should be provided in relation to the following:
The stability of the non-cellular components should be assessed in the presence and
absence of cellular components in order to determine whether the non-cellular
component undergoes degradation, or physico-chemical alterations (e.g. aggregation,
oxidation) that may impact on the quality of the product by affecting cellular behaviour
and survival. The effect of the cellular component or of the surrounding tissues on the
degradation (rate and, if appropriate, products) or stability of the structural component
should be assessed, considering also the effect of the non-cellular components throughout
the expected lifetime of the product. The general principles that are applied to the
biological evaluation of medical devices can also be applied to the evaluation of
biomaterials intended for use in CBMP. Such an evaluation involves a programme of
characterisation, testing and review of existing data to assess the potential for an
adverse biological reaction to occur as a result of exposure to the biomaterial. These
principles are set out in international standard ISO 10993 Part 133. Other parts of the
ISO 10993 series of standards specify methods that may be relevant to the assessment
of material characteristics, biological safety and degradation of biomaterials used in
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cell-based medicinal products. Additional studies (e.g. cell adhesion studies, growth
studies) may be necessary to demonstrate aspects of biocompatibility specific to
cell-based applications.
3. Final Product
Once the “formulation”, i.e. the delivery system of a combined product has been
established, the parameters for determining the role of constituents and appropriateness
of composition should be presented within a justification of the composition of the
product.
The key parameters for performance testing of the completed product should be justified
in relation to the development data and the final quality requirements. It may be
appropriate that in vitro and in vivo testing of the formulation/delivery system/combined
product during development are included.
4.2.7 Traceability
A system allowing complete traceability of the patient as well as the product and its
starting materials is essential to monitor the safety and efficacy of cell-based medicinal
products. The establishment and maintenance of that system should be done in a way to
ensure coherence and compatibility with traceability and vigilance requirements laid
down in Directive 2004/23/EC4 and in Directives 2006/17/EC5 and 2006/86/EC6 and Art.
15 of the Regulation (EC) No 1394/20072.
Article 15 of the Regulation (EC) No 1394/20072 defines a two tiered system connecting
the required traceability from cell donation and procurement (Dir 2004/23/EC) to the
manufacturer and user (hospital or practice). This means that anonymity can be
guaranteed. At the tissue establishment there has to be a link between the donor and
the donation. At the manufacturing side, there has to be a link between donation and
product and at the hospital/practice side there has to be a link between the product and
the recipient. The systems should allow full traceability from the donor to the recipient
through anonymous coding systems. Manufacturers should establish their coding systems
in a rational way, building from the coding system of the tissue establishment, and
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designing it to facilitate the tracing of the donation to the product and to the patient.
Bar coding and peeling labelling systems could be suitable tools for the purpose of
patient management.
4.2.8 Comparability
The scrutiny applied during non-clinical testing should take into account the nature of
the Cell-based medicinal product (CBMP) and be proportional to the risk expected to be
associated with clinical use.
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The variability of cell-based medicinal products should be reflected in the non-clinical
studies. Conventional requirements as detailed in Module 4 for pharmacological and
toxicological testing of medicinal products may not always be appropriate. Any deviation
from these requirements shall be justified. If cells in a CBMP have been genetically
modified, non-clinical development must be performed in compliance with guidance
available on gene transfer medicinal products23.
The safety and suitability of all structural components for their intended function must
be demonstrated, taking into account their physical, mechanical, chemical and biological
properties. (See section 4.2.6 Development pharmaceutics).
4.3.1. Pharmacology
Primary pharmacodynamics
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Non-clinical studies should be adequate to demonstrate the proof of principle of the
CBMP. The principal effects should be identified in non-clinical studies in a suitable
model in vitro or in vivo.
If the intended use of the CBMP is, for example, to restore the function of deficient
cells/tissue (tissue regeneration), functional tests should be implemented to demonstrate
that function is restored. If the intended use is, for example, adoptive immunotherapy in
cancer patients, the biological effect should be supported by data describing the
immunologic action of the CBMP.
Secondary pharmacology
Safety pharmacology
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Safety pharmacology should be considered on a case-by-case basis depending on the
characteristics of the CBMP. Cells may secrete pharmacologically active substances
resulting in CNS, cardiac, respiratory, renal or gastrointestinal dysfunctions. Alternatively,
cells by themselves could be envisaged to induce such consequences for example stem
cells or muscle cells transplanted to infarcted regions of the heart.
For further guidance see ICH S7A Guideline36 when applicable.
Conventional ADME studies are usually not relevant for human CBMP. However,
studies should be carried out to demonstrate tissue distribution, viability, trafficking,
growth, phenotype and any alteration of phenotype due to factors in the new
environment.
Cells may migrate within the host, thus presenting clinical concerns regarding adverse
reactions deriving from displaced, possibly differentiating cells. This should be evaluated
in animals using appropriate methods for specific identification of the cells.
Regarding biodistribution, the use of small animals allows meticulous cell detection,
which will be practically more difficult in larger animals.
For human CBMP producing systemically active biomolecules, the distribution, duration
and amount of expression of these molecules and the survival and the functional
stability of the cells at target sites should be studied.
Interactions
The interaction of the applied cells or surrounding tissue with the non-cellular structural
components and other bioactive molecules as well as the integration of the CBMP with
the surrounding tissue should be monitored.
4.3.2. Toxicology
The need for toxicological studies depends on the product. However, as conventional
study designs may not be appropriate, the scientific justification for the models used, or
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the omission of studies, shall be provided.
Toxicity may evolve, for example, due to unknown cellular alterations developing during
the manufacturing process such as altered excretion patterns and in vivo behaviour due
to differentiation of the cells. Other potential factors that may induce toxicity include
the allogeneic use of the product, the presence of components that are used in the
manufacturing process or are part of a structural component, or proliferation of the
applied cells in an unwanted quantity or in an unwanted location.
Conventional toxicology studies might nevertheless be required, for example for complex
regimens where CBMP are combined with other medicinal products or treatments such
as adjuvants/cytokines or irradiation, respectively. The need for drug interaction studies
is dependent on the intended use and the type of the cell-based product and should be
discussed.
The induction of an immune response against the cells themselves and/or towards
cell-derived pharmacologically active substances might modulate the efficacy of the
CBMP. Therefore, the possible immunogenicity of a CBMP should be considered. For
guidance on immunogenicity of excreted substances see ICH S6 Guideline35.
Auto-immunity should be considered when cells are used for immunotherapy purposes,
e.g. cancer immunotherapeutic products.
Toxicity studies should be performed in relevant animal models. If the human cells are
not immediately rejected, the studies may be combined with safety pharmacology, local
tolerance, or proof of concept and efficacy studies. Sufficiently characterized analogous
animal-derived cells may be used for some allogeneic CBMP when not immediately
rejected.
The duration of observations in such studies might be much longer than in standard
single dose studies, since the cells are supposed to function for long times, or induce
long term effects, which should be reflected in the design of these studies. The route
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and dosing regimen should reflect the intended clinical use. Repeated dose toxicity
studies are only relevant if the clinical use includes multiple dosings.
Local tolerance studies may be required in an appropriate species. Most often, local
tolerance, tissue compatibility and tolerance to excreted substances can be evaluated in
single or repeated dose toxicity studies.
The risk of inducing tumourigenesis due to neoplastic transformation of host cells and
cells from the CBMP should be considered, as appropriate, on a case-by-case basis.
Conventional carcinogenicity studies may not be feasible. Tumourigenesis studies should
preferably be performed with cells that are at the limit of routine cell culturing or even
beyond that limit. Tissues found to contain applied cells or expressed products during
the biodistribution studies should also be analysed with special emphasis during
tumourigenicity studies.
Genotoxicity studies are not considered necessary for human CBMP, unless the nature
of any expressed product indicates an interaction directly with DNA or other
chromosomal material.
The need for reproductive studies is dependent on the CBMP and should be considered
on a case-by-case basis.
In general, when a Cell-based medicinal product (CBMP) enters the clinical development
phase, the same requirements as for other medicinal products apply. The clinical
development plan should include pharmacodynamic studies, pharmacokinetic studies,
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mechanism of action studies, dose finding studies and randomised clinical trials in
accordance to the Directive 2001/20/EC37 and to the existing general guidances and
specific guidances for the condition evaluated.
Due to specific biologic characteristics of CBMP, alternative approaches to Phase I to
Phase III clinical trials might be required and acceptable for clinical development, if
justified. The relevant non-clinical studies, previous clinical experience of the treated
pathology, and initial clinical studies could be applied for demonstration of the “proof
of principle” and the choice of clinically meaningful endpoints for safety and efficacy
evaluation. European scientific advice is strongly recommended in case of uncertainties
in rationale of CBMP development at the earliest phase.
CBMP might require administration through specific surgical procedures, method of
administration or the presence of concomitant treatments to obtain the intended
therapeutic effect. The biological effects of CBMP are highly dependent on the in vivo
environment, and may be influenced by the replacement process or the immune reaction
either from the patient or from the cell-based product. These requirements coming from
the clinical development should be taken into account for the final use of these
products. Their standardisation and optimisation should be an integral part of the clinical
development studies. The therapeutic procedure as a whole, including the method of
administration and required concomitant medication, such as immunosuppressive regimens
need to be investigated and described in the product information, notably in the
Summary of Product Characteristics (SPC).
4.4.2 Pharmacodynamics
Even if the mechanism of action is not understood in detail, the main effects of the
CBMP should be known. When the purpose of the CBMP is to correct the function of
deficient or destroyed cell/tissue, then functional tests should be implemented. If the
intended use of the CBMP is to restore/replace cell/tissues, with an expected lifelong
functionality, structural/histological assays may be potential pharmacodynamic markers.
Suitable pharmacodynamic markers, such as defined by microscopic, histological, imaging
techniques or enzymatic activities, could be used.
When CBMP includes a non cellular component, the combination should be assessed
clinically for compatibility, degradation rate and functionality.
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4.4.3 Pharmacokinetics
Conventional ADME studies are usually not relevant for human CBMP. Study
requirements, possible methodologies and their feasibility shall be discussed, attention
being paid to monitoring of viability, proliferation/differentiation, body distribution /
migration and functionality during the intended viability of the products.
If multiple (repeated) administrations of the CBMP are considered, the schedule should
be discussed in view of the expected in vivo life span of the CBMP.
The selection of the dose should be based on the findings obtained in the quality and
the non-clinical development of the product and it should be linked with the potency of
product. Even though the dosage for cell-based product might be determined by
individual characteristics of the intended patients (i.e. cell mass density per body weight/
volume of missing tissue/ missing surface), the dose to be tested in the confirmatory
trial should be supported by the evidence provided by the phase I/II studies.
Phase I/II studies should be designed to identify a Minimal Effective Dose, defined as
the lowest dose to obtain the intended effect or an Optimal Effective Dose Range,
defined as the largest dose range required to obtain the intended effect based on the
clinical results for efficacy and tolerability. If possible, also the Safe Maximal Dose,
defined as the maximal dose which could be administered on the basis of clinical safety
studies without acceptable adverse effects, should be investigated.
Clinical efficacy studies should be adequate to demonstrate efficacy in the target patient
population using clinically meaningful endpoints, to demonstrate an appropriate
dose-schedule that results in the optimal therapeutic effect, to evaluate the duration of
therapeutic effect of the administered product and to allow a benefit – risk assessment
taking into account the existing therapeutic alternatives for the target population.
Confirmatory studies should be, as stated before, in accordance to the existing general
guidelines and specific guidelines for the condition evaluated.
Deviations from these will need a justification. For example, the fact that the nature and
- 76 -
the mechanism of action of the CBMP may be entirely novel does not mean necessarily
that the therapeutic benefit should be measured by different endpoints from those
recommended in the current disease-specific guidelines (e.g. medicines vs. cell implants
for Parkinson’s disease).
For new therapeutic applications of CBMP where limited guidance exists, consultation of
regulatory authorities on the clinical development plan, including the confirmatory
studies, is highly recommended.
The safety database should be able to detect common adverse events. The size of the
database might be decided also in the light of previous clinical experience with similar
products.
The risk of the therapeutic procedure as a whole, e.g. the required surgical procedures
to administer the CBMP or the use of immunosuppressive therapy, shall be evaluated
and used to justify the clinical studies and the choice of the target patient population
All safety issues arising from the preclinical development should be addressed, especially
in the absence of an animal model of the treated disease or in the presence of
physiologic differences limiting the predictive value of homologous animal model.
- 77 -
For products with expected long term viability, patient follow-up is required in order to
confirm long term efficacy and safety issue related to the product.
The routine pharmacovigilance and traceability of the product should be described in the
EU Risk Management Plan (RMP) as described in Guideline on risk management
systems for medicinal products for human use7. CBMP may need special long-term
studies to monitor specific safety issues, including loss of efficacy.
- 78 -
2004/23/EC of the European Parliament and of the Council as regards certain technical
requirements for the donation, procurement and testing of human tissues and cells.
6. Commission Directive 2006/86/EC of 24 October 2006 implementing Directive
2004/23/EC of the European Parliament and of the Council as regards traceability
requirements, notification of serious adverse reactions and events and certain technical
requirements for the coding, processing preservation, storage and distribution of human
tissues and cells.
7. EMEA/CHMP Guideline on risk management systems for medicinal products for
human use (EMEA/CHMP/96268/2005)
8. Directive 2003/94/EC laying down the principles and guidelines of good
manufacturing practice in respect of medicinal products for human use and
investigational medicinal products for human use.
9. Annex 2 of Directive 2003/94/EC: Manufacture of Biological Medicinal Products for
Human Use.
10. ICH Q5D, Derivation and Characterisation of Cell Substrates Used for Production of
Biotechnological/Biological Products (CPMP/ICH/294/95)
11. ICH Q5A Guideline on Quality of Biotechnological Products: Viral Safety
Evaluation of Biotechnology Product Derived From Cell Lines in of human or animal
origin (CPMP/ICH/295/95)
12. EMEA/CPMP Note for Guidance on Virus Validation Studies: The Design,
Contribution and Interpretation of Studies validating the Inactivation and Removal of
Viruses (CPMP/BWP/268/95)
13. Eudralex Vol. 2 B, Notice To Applicant, part II-V : virological documentation
14. Ph. Eur. General Text 5.1.7: Viral safety (01/2008:50107)
15. EMEA/CPMP/CVMP Note for guidance on minimizing the risk of transmitting
animal spongiform encephalopathy agents via human and veterinary medicinal products
(EMEA/410/01 rev.2)
16. Guideline on Production and Quality Control of Medicinal Products Derived by
Recombinant DNA Technology. (3AB1A)
17. EMEA/CHMP Note for Guidance on Production and quality control of Monoclonal
Antibodies (CHMP/BWP/157653/07)
18. EMEA/CPMP Note for guidance on plasma-derived medicinal products
(CPWP/BWP/269/95, rev.3)
19. EMEA/CHMP Points to consider on Xenogeneic Cell Therapy Medicinal Products
- 79 -
(CPMP/1199/02)
20. EMEA/CHMP Note for Guidance on Use of Bovine Serum in the Manufacture of
Human Biological Medicinal Product (CPMP/BWP/1793/02)
21. Eudralex Vol. 7Blm10a Table of extraneous agents to be tested for in relation to
the general and species specific guidelines on production and control of mammalian
veterinary vaccines
22. EMEA/CPMP Note for Guidance on Production and Quality Control of Animal
Immunoglobulins and Immunosera for Human use (CPMP/BWP/3354/99)
23. EMEA/CHMP Note for Guidance on the quality, preclinical and clinical aspects of
gene transfer medicinal products (CPMP/BWP/3088/99)
24. Council Directive 93/42/EEC of 14 June 1993 concerning Medical Devices
25. Council Directive 90/385/EEC of 20 June 1990 on the approximation of the laws of
Member States relating to Active Implantable Medical Devices
26. EN/ISO 10993-18:2005 Biological evaluation of medical devices- Part 18: Chemical
characterization of materials
27. EN/ISO 10993-19:2006 Biological evaluation of medical devices- Part 19:
Physico-chemical, morphological and topographical characterization of materials
28. Ph.Eur. Text 5.1.6: Alternative methods for control of microbiological quality
(01/2008:50106) and General Method 2.6.27: Microbiological control of cellular products.
29. ICH Q6B Note For Guidance on Specifications: Test Procedures and Acceptance
Criteria for Biotechnological/Biological Products. (CPMP/ICH/365/96)
30. EMEA/CHMP guideline on potency testing of cell-based immunotherapy medicinal
products for the treatment of cancer (CHMP/BWP/271475/06).
31. Ph. Eur. General Text 5.2.3: Cell substrates for the production of vaccines for
human use (01/2008:50203)
32. EMEA/CPWP Note for Guidance on Development Pharmaceutics for
Biotechnological and Biological Products (CPMP/BWP/328/99)
33. EN/ISO 10993-1, Biological evaluation of medical devices - Part 1: Evaluation and
testing
34. ICH Q5E, Comparability of Biotechnological/Biological Products
(CPMP/ICH/5721/03)
35. ICH S6; Preclinical safety evaluation of biotechnology derived products
(CPMP/ICH/302/95)
36. ICH S7A, Safety pharmacology studies for human pharmaceuticals
- 80 -
(CPMP/ICH/529/00)
37. Directive 2001/20/EC of the European Parliament and Council of 4 April 2001 on
the approximation of the laws, regulations and administrative provisions of the Member
States relating to the implementation of good clinical practice in the conduct of clinical
trials on medicinal products for human use.
- 81 -
암치료를 위한 수지상 세포치료제 평가시 고려사항
목 차
1. 일반적 사항 ................................................................................ 1
2. 수지상 세포의 품질에 관한 사항 .................................................... 1
1) 제조과정에 관한 사항 ................................................................ 1
2) 확인: 표면항원 ......................................................................... 2
3) 순도 ........................................................................................ 2
4) 세포 생존율 ............................................................................. 3
5) 역가 ........................................................................................ 3
2) 독성 평가 ................................................................................ 4
3) 용법·용량 설정시 고려사항 ......................................................... 4
4. 임상 평가 ................................................................................... 5
1) 용법?용량 설정시 고려사항 ........................................................ 5
2) 안전성 평가 ............................................................................. 6
3) 유효성 평가 ............................................................................. 6
5. 적응증을 변경할 경우 고려사항 ..................................................... 7
6. 참고문헌 ..................................................................................... 7
- 82 -
암치료를 위한 수지상 세포치료제 평가시 고려사항
1. 일반적 사항
1) 제조과정에 관한 사항
2) 확인 : 표면항원
- 83 -
발현의 측정이 유용할 것으로 생각되며, 공통적으로 확인 가능할 것으로
생각되는 표면항원은 다음과 같다.
- 발현이 최소로 감소되는 표면항원 : CD14 (유래에 따라 고려), CD3, CD19
- 발현이 증가되는 표면항원 : HLA ClassⅠ/Ⅱ, CD80/CD86
- 성숙지표로 활용가능 할 것으로 생각되는 표면항원 : CD83
3) 순도
4) 세포 생존율
5) 역가
- 84 -
○ 수지상 세포의 분화 유도를 위하여 항원을 사용한 경우에는 사용 방법에 따라
사용항원의 자가 품질 기준을 명확히 설정한다. 예를 들어 Peptide 항원을
사용한 경우, 순도, 물질적 특성에 따른 용해도, dimer 형성 여부, 분해 정도
등을 평가하여야 한다. Tumor lysate를 사용한 경우에는 생산방법, 오염도,
단백질 함량 등을 평가하여야 한다.
3. 비임상 평가
1) 효력 평가
2) 독성 평가
- 85 -
○ 투여 일정의 경우에는 살아있는 세포가 생체 내에서 세포면역을 유도할 수
있도록 적절한 시간간격을 두고 투여일정 확립을 위한 시험을 실시하여야 하며,
면역반응과 관련한 세포의 형성 유도를 위해 반복투여에 대한 사항이 충분히
고려되어야 한다.
4. 임상 평가
- 86 -
2) 안전성 평가
3) 유효성 평가
- 87 -
고려되어야 한다. (예 ; 전신노출 정도가 커진 경우 피하주사 → 정맥주사 등)
6. 참고문헌
○ Carl G Figdor et al. Dendritic cell immunotherapy: mapping the way, Nat.
Med. 10, 475-480(2004)
○ Jacques Banchereau & Ralph M. Steinman, Dendritic cells and the control
of immunity, Nature 392, 245-252(1998)
○ Theresa L. Whiteside & Christine Odoux, Dendritic cell biology and cancer
therapy, Cancer Immunol Immunother. 53, 240-248(2004)
- 88 -
용역연구개발과제 최종보고서
과제번호 응용연 09172 652
과 제 명 역가시험법 검증연구
disease)
주관 성 명 소속 및 부서 전 공
연구책임자 유경하 소아과학교실 혈액종양
총연구기간 년 월 일 ~ 년 월 일 개월
2009 3 1 2009 11 30 ( 9 )
총 연구개발비 천원 70,000
2차년도 년 월 일 ~ 년 월 일 천원
관계규정과 모든 지시사항을 준수하면서 이 용역연구개발연구사업을
성실히 수행하고자 다음과 같이 용역연구개발과제최종보고서를
제출합니다 .
2009 년 월 11 일
주관연구책임자 : 유경하 (서명 또는 인)
주관연구기관장 : 조지형 (직 인)
식품의약품안전평가원장 귀하
- 89 -
Ⅰ. 총괄연구개발과제 요약문 (국문 요약문)
과 제 명 줄기세포치료제의 역가시험법 검증연구
GVHD(graft-versus-host disease)
중심단어 이식편대숙주병 줄기세포치료기술 지방조직유래줄기세포 역가 평가
, , , ,
주관연구기관 이화여자대학교 산학협력단 주관연구책임자 유 경 하
연구기간 2009-03-01 ~ 2009-11-30
연구목표
1. 본 연구는 중간엽줄기세포 면역조절능력을 이용한 이식편대숙주병(GVHD)의 치료 시 발생
하는 세포 수의 부족을 줄기세포 공급원과 이식기술을 다양화하여 해결하고자 한다.
2. 이를 위해 선행 연구에서 제시된 GVHD in vitro 역가 시험법을 이용하여 지방조직 유래 중간
엽줄기세포의 치료 역가를 측정하고, 마우스 동물모델에 이식하여 반복투여 및 면역억제제
와의 병용투여 시 in vivo 효능과의 상관성 입증함으로써 줄기세포치료제의 GVHD역가 시험
법을 검증하고 이를 확립하고자 한다.
연구내용 및 성과
1. 지방조직 유래 중간엽줄기세포(AD-MSCs) 이용 GVHD 치료 기술 개발
(1) AD-MSCs의 면역표현형 및 다분화능 확인
- AD-MSCs를 분리하여 배양하였고, 면역학적으로 CD34, CD45에는 음성이고, 줄기세포
표지자인 CD73, CD90, CD105에 양성으로 표현되는 MSC임을 확인하였으며 BM-MSC
과 유사하였다.
- 이 세포들은 지방세포 (oil red o), 뼈세포 (Alizarin red S), 신경세포 (NSE, TUJ1,
MAP-2, Nestin, GFAP), 근육세포 (Myosin) 및 연골세포 (toluidine blue O)등으로 다
양한 분화능력이 있음을 확인하였다.
(2) AD-MSC의 면역조절 능력
- AD-MSC의 T-세포 억제 효과는 AD-MSC 주입용량에 비례하였다.
- BM-MSC과 비교하였을 때 AD-MSC의 면역조절능력은 MSC:T 비율이 1:1 이하에서
는 T-세포 증식억제효과가 낮았으며, 1:1 비율 이상에서는 같은 효과를 보였다.
- AD-MSC에 의해 T-reg cell의 발현이 증가하였고 이는 BM-MSC와 일치하는 소견이
었다.
(3) AD-MSC 이용 GVHD 치료기술 개발
- 8Gy 용량의 방사선 조사후 T세포 이식 방법으로 GVHD 마우스 모델을 제작하였고 이
식받은 마우스의 골수, 흉선, 비장에서 donor 세포가 착생됨을 바이오이미징으로 확인
하였다.
- GVHD 마우스 군은 지속적으로 육안적 평가점수가 심각한데 비해 대조군과 MSC 주
입군에서는 시간이 지날 수록 호전됨을 확인하였다.
- AD-MSC 이식 후 조직학적점수가 소장, 피부, 대장에서 호전됨을 확인하였다.
2. MSC 이용 GVHD 치료효과 극대화 기술 개발
(1) 단회 및 반복 이식 효과 분석
- AD-MSC 이식은 전체적으로는 생존율 향상에 도움이 되지만 BM-MSC에 비해 효과
는 미미하였R고 특히 생존율 분석에서는 단회이식에 비해 반복이식의 효과가 미미하였
다.
(2) 기존 면역억제제와 병합사용 효과 분석
- 스테로이드의 용량은 5 mg/kg 군보다는 1 mg/kg가 더 적절한 용량임을 확인하였고
단회이식이 반복 이식 군에 비해 효과가 우수하였다.
- 그러나 MP만 사용한 경우보다는 중간엽줄기세포를 같이 이식한 군은 마우스 모두 생
존하는 높은 생존율을 보였다.
기대효과
-지방흡인술 후 버려지는 지방조직으로부터 MSC을 얻어 GVHD를 치료 할 수 있다면 어렵
게 골수채취를 해야 하는 번거로움과 경제적인 문제를 한꺼번에 해결할 수 있는 무한한 가
치를 가질 수 있다.
- 90 -
세포치료제 역가시험 참고 자료집
══════════════════════════════════════════
발 행 일 : 2010년 12월
편 집 위 원 장 : 바이오생약국장 이정석
편 집 위 원 : 식품의약품안전청 바이오생약심사부
장승엽, 손여원, 박윤주, 김종원, 안광수, 서수경,
백경민, 김영은, 이선미, 김민정, 서수진, 진미령,
권오석
식품의약품안전평가원 의료제품연구부
박순희, 정승태, 오일웅, 류시형, 박기대, 최민정
발 행 부 서 : 바이오생약국 첨단제제과
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