CMC Human Gene Therapy Guidance ‘Inadequate’: PhRMA
Pharmaceutical Research and Manufacturers of America (PhRMA) says an FDA draft guidance on chemistry, manufacturing, and control (CMC) information for human gene therapy INDs is a positive step toward providing sponsors with more guidance and clarity, but “does not adequately adopt and identify risk-based and phase-appropriate recommendations that are tailored to IND submissions for these therapies.” The PhRMA letter gives comments and recommendations on guidance scope and structure, risk-based CMC approaches, and agency processes and policies. It also includes line-by-line editing recommendations.
The American Society of Gene and Cell Therapy says the draft’s recommendations “are generally welcomed and will provide clarity on CMC information for IND applications for human gene therapy.” The letter also contains line-by-line recommendations.
Pfizer comments that it is “generally supportive of the guidance” and suggests that recommendations on devices should be discussed in one specific section rather than dispersed across the guidance. The company also says it would be helpful to have more detail on a phase-driven approach to submitting information.
The Innovative Genomics Institute asks FDA to provide more specific and tailored guidance and recommendations for drug substances and products created by gene editing technologies, particularly those therapeutics that are created ex vivo using editing reagents that are not intended to persist.
Finally, the Parenteral Drug Association says the draft guidance “varies between the material presented for INDs and GMP requirements.” It recommends that either it be reorganized or the IND-relevant information be removed from IND quality practices and placed in a separate guidance.