1 about omics group omics group international is an amalgamation of open access publications and...

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1 About OMICS Group About OMICS Group OMICS Group International is an amalgamation of Open Access publications and worldwide international science conferences and events. Established in the year 2007 with the sole aim of making the information on Sciences and technology ‘Open Access’, OMICS Group publishes 400 online open access scholarly journals in all aspects of Science, Engineering, Management and Technology journals. OMICS Group has been instrumental in taking the knowledge on Science & technology to the doorsteps of ordinary men and women. Research Scholars, Students, Libraries, Educational Institutions, Research centers and the industry are main stakeholders that benefitted greatly from this knowledge dissemination. OMICS Group also organizes 300 International conferences annually across the globe, where knowledge transfer takes place through debates, round table discussions, poster presentations, workshops, symposia and exhibitions.

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1

About OMICS GroupAbout OMICS Group

OMICS Group International is an amalgamation of Open Access publications and worldwide international science conferences and events. Established in the year 2007 with the sole aim of making the information on Sciences and technology ‘Open Access’, OMICS Group publishes 400 online open access scholarly journals in all aspects of Science, Engineering, Management and Technology journals. OMICS Group has been instrumental in taking the knowledge on Science & technology to the doorsteps of ordinary men and women. Research Scholars, Students, Libraries, Educational Institutions, Research centers and the industry are main stakeholders that benefitted greatly from this knowledge dissemination. OMICS Group also organizes 300 International conferences annually across the globe, where knowledge transfer takes place through debates, round table discussions, poster presentations, workshops, symposia and exhibitions.

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About OMICS Group About OMICS Group ConferencesConferences

OMICS Group International is a pioneer and leading science event organizer, which publishes around 400 open access journals and conducts over 300 Medical, Clinical, Engineering, Life Sciences, Phrama scientific conferences all over the globe annually with the support of more than 1000 scientific associations and 30,000 editorial board members and 3.5 millionfollowers to its credit.

OMICS Group has organized 500 conferences, workshops and national symposiums across the major cities including San Francisco, Las Vegas, San Antonio, Omaha, Orlando, Raleigh, Santa Clara, Chicago, Philadelphia, Baltimore, United Kingdom, Valencia, Dubai, Beijing, Hyderabad, Bengaluru and Mumbai.

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Regulatory Considerations in the United States Associated with Cell

TherapyWilliam Lee, Ph.D., RAC

4th International Conference onPharmaceutical Regulatory Affairs

September 10, 2014

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Overview

• Summary of FDA Cell Therapy Regulations

• Case Study #1: Epicel

• Case Study #2: Autologous Cell Therapy – PROVENGE

• Case Study #3: Autologous Gene/Cell Therapy – CAR T-cell

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US FDA Regulations for Cell Therapies

▼Medical Device

▼Biologic– Cell Therapy drug

▼Gene Therapy – Gene/Cell therapy drug

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FDA Regulations

▼Mode of Action– Inert – Regulated as a Medical Device– Chemical – Regulated as a Drug or a Biologic

▼Gene Therapy Component– No Added Genetic Element – Regulated as a

Biologic– Added Genetic Element – Regulated as a Gene

Therapy

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Case Study # 1▼Epicel® - Cultured Epidermal Autografts

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Medical Device - Epicel® - Cultured Epidermal Autografts

• Skin replacement therapy for the treatment of life-threatening burns

• Made from patient’s own skin cells

• Regulated as a device– Primary mode of action is not through chemical action – not dependent upon being metabolized

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Medical Device Definition

• "an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article, including a component part, or accessory which is:– intended for use in the diagnosis of disease or other conditions, or in the cure,

mitigation, treatment, or prevention of disease, in man or other animals, or

– intended to affect the structure or any function of the body of man or other animals,

– and which does not achieve any of its primary intended purposes through chemical action within or on the body of man or other animals and which is not dependent upon being metabolized for the achievement of any of its primary intended purposes."

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Marketing Submission to FDACDRH

▼PMA

▼HDE (Humanitarian Device Exemption)

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Case Study # 2

▼PROVENGE

– Autologous cellular immunotherapy for the treatment of prostate cancer

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Cell Therapy - PROVENGE

▼PROVENGE

– Primary mode of action• Induces immune response targeted against an antigen

(PAP) expressed in most prostate cancers

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FDA Definition of Biological Product

▼Biologics are isolated from a variety of natural sources — human, animal, or microorganism — and may be produced by biotechnology methods and other cutting-edge technologies

– Primary mode of action is via “chemical action”

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FDA Definition of Cell Therapy

▼Cellular therapy products include cellular immunotherapies, and other types of both autologous and allogeneic cells for certain therapeutic indications, including adult and embryonic stem cells.

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Additional Nonclinical Requirements of Cell Therapies

Regulated as Biologics

▼ Tumorigenicity through the same route of administration in patients▼Stem cell therapy – evaluated more rigorously for

tumorigenicity▼ Cell fate studies (trafficking, survival, differentiation)▼ No Genotoxcity studies

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Additional Clinical Requirement of Cell Therapies Regulated as

Biologics▼FDA often requests a Data Safety Monitoring

Committee in the First-in-human clinical trial

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PROVENGE Regulated as a Biologic

▼Under purview of the FDA Office of Cell and Gene Therapy within CBER– Similar requirements as an investigational biologic

(recombinant protein or monoclonal antibody)• Two Phase 3 studies• File BLA as Marketing Application

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Case Study # 3

▼CAR T-Cell▼Chimeric Antigen Receptor T cell Therapy▼Patients’ own immune cells engineered to

recognize and attack their tumors▼In one clinical trial, 18 of 21 patients with

advanced acute lymphoblastic leukemia had complete responses

▼Gene Therapy Component

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FDA Definition of Gene Therapy

▼Human gene therapy refers to products that introduce genetic material into a person’s DNA to replace faulty or missing genetic material, thus treating a disease or abnormal medical condition.

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Regulatory Oversight

▼Clinical studies involving gene transfer are regulated by the FDA and in nearly all instances by the NIH.

▼FDA– Office of Cellular, Tissue, and Gene Therapies,

CBER

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Submission to the US Regulatory Authorities for Clinical Trials

• NIH/RAC

• IBC

• FDA

• IRB

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Regulatory Oversight

National Authority FDA – Office of Cellular, Tissue and Gene Therapies

NIH/RAC

Responsible party Sponsor Principal Investigator

Local Authority IRB IBC

AE reporting MedWatch form MedWatch form or NIH Reporting Template

Nature of Review ConfidentialSafety/Non-clinical review by FDA reviewers

PublicCritical scientific review by leading gene therapy researchers

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NIH Oversight• NIH oversight is required under the following

conditions:

– Clinical Investigators participating in clinical trials who receive NIH funding or

– Clinical Investigators who are affiliated with institutions that receive NIH funding or

– Clinical trials conducted at institutions that receive NIH funding

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NIH Oversight• Recombinant DNA Advisory Committee (RAC) in the office

of Biotechnology Activities (OBA) within the NIH oversees gene therapy

– RAC does not have oversight over vaccines

– RAC meets quarterly for public discussion of gene transfer clinical studies that are deemed novel

– Accelerated review process for clinical studies that are deemed not to be novel and not to represent significant risk

• Clinical protocols and Informed Consent documents are subject only to written reviews by several members of the RAC committee

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Evolving Gene/Cell Therapy Regulations

▼As of 2014▼No requirement to submit to RAC Committee for

routine investigational gene therapy treatments▼First CAR T cell clinical trial is non-routine and had

been reviewed by the RAC Committee▼Subsequent CAR T cell clinical trials may be

deemed “routine”

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Institutional Biosafety Committee (IBC)

▼Review body appointed by the institution of the proposed clinical trial site

▼Review and approves all experiments involving gene transfer in human research participants

▼Must consider issues raised and recommendations made during RAC review

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Unique FDA Clinical Requirement for Certain Gene Therapy Drugs

▼15-year follow-up Monitoring Plan for subjects in clinical trials with integrating vectors – CAR T cells

– Retrovirus

– This monitoring plan must be in the initial IND or the FDA will put the IND on hold

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Unique Manufacturing AspectPre-competitive cooperation

FDA, industry and academia

▼ Request by FDA for CAR T-cell therapies at the 2014 American Society for Cell and Gene Therapy

▼ Assess the potential for replication competent lentivirus in their cellular product

29

FDA Review Division

• Office of Cellular, Tissue and Gene therapies (OCTGT)– Division of Cellular and Gene Therapies (DCGT)– Division of Clinical Evaluation and

Pharmacology/Toxicology (DCEPT)

• CMC Review – DCGT

• Pharmacology/Toxicology and Clinical Review - DCEPT

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Starting a Cell Therapy Clinical Trial in the United States

▼Is it a Medical Device?▼CDRH

▼Is it a Biologic?▼CBER

▼Is it Gene Therapy?▼CBER▼RAC Committee

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Let Us Meet Again

We welcome you all to our future We welcome you all to our future conferences of OMICS Group conferences of OMICS Group

International International

Please Visit:Please Visit:

[email protected] [email protected] [email protected]@conferenceseries.net

http://http://regulatoryaffairs.pharmaceuticalconferences.comregulatoryaffairs.pharmaceuticalconferences.com

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