Alliance for Regenerative Medicine AMT Concerns
The Alliance for Regenerative Medicine (ARM) says it is concerned that an FDA draft guidance, Advanced Manufacturing Technologies Designation Program, “fails to provide a clear framework for the adoption of advanced manufacturing technologies (AMT) across the cell and gene therapy industry.” In its comment letter, ARM questions the agency’s decision to have an approach for BLA sponsors that differs from that used by NDA/ANDA sponsors.
“ARM agrees with the agency that a BLA application holder is, and should be, responsible for ensuring the quality of the product and, therefore, understands the regulatory intent behind FDA’s requirements that certain chemistry, manufacturing, and controls information need to be contained within the BLA and not referenced through a drug master file or otherwise,” the letter says. “However, these requirements have hindered technology development and adoption in cell and gene therapies and we are disappointed that these requirements were codified by FDA after the release of this guidance without regard for the statute governing the AMT designation program.”
The letter also says there are key aspects of the data submission process that ARM believes need correction or additional clarification and details.