Cell/Gene Therapy Guide on Common Questions

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FDA has posted a draft guidance entitled “Frequently Asked Questions — Developing Potential Cellular and Gene Therapy Products.” The document is intended to provide industry with answers to frequently asked questions (FAQs) and commonly faced issues that arise during cell/gene therapy development. The FAQs cover multiple disciplines, including regulatory review, chemistry, manufacturing, and controls, pharmacology/toxicology., clinical, and clinical pharmacology.

For example, under clinical endpoints for traditional approval, the agency recommends that these “directly reflect a meaningful clinical benefit (i.e., how study participants feel or function, or how long they survive) or validated surrogate endpoints (i.e., those that have been shown to predict a specific clinical benefit).” For accelerated approval, the agency says the endpoint should produce evidence of a demonstrated effect on a surrogate endpoint that is reasonably likely to predict a clinical benefit or on an intermediate clinical endpoint (an endpoint that can be measured earlier than irreversible morbidity or mortality).

Regarding safety, FDA says that because many cell/gene therapy products are administered once, close subject monitoring “immediately following product administration is critical to capture early safety signals. This means that during and immediately following product administration, there should be intensive safety monitoring with frequent monitoring of vital signs, physical examinations, laboratory studies, radiologic evaluations, and other relevant studies as warranted. During the subsequent weeks and months, subjects should be monitored frequently for assessment of emerging safety signals via clinical evaluation and ancillary testing.”

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