Lessons Learned from Gene Therapies: CBER Official

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FDA’s limited experience in approving seven gene therapies to date has provided some valuable “lessons learned,” according to CBER Office of Tissues and Advanced Therapies director Wilson Bryan. Speaking at a 12/6 online update for the Alliance for a Stronger FDA, Bryan said all seven products were approved based on data from single-arm studies because they had large effect sizes. “If there's a large effect size, the clinical trials don't need to be big, and we can do clinical trials in small populations,” he told the Alliance.

 

Bryan said that two gene therapy approvals — Spark Therapeutics’ Luxturna (voretigene neparvovec-rzyl) and Novartis’ Zolgensma (onasemnogene abeparvovec-xioi) — were approved based on two trials each and totaling 36 patients in each approval. Zolgensma used natural history controls, he said, adding that “(w)hen you have good natural history data and you have a huge effect size then natural history controls and small studies are feasible. We need more natural history studies, and we need to design clinical trials for these rare diseases.”

 

The science has advanced to the point where huge effects can be seen, and this means that the first-in-human studies of gene therapy products need to be randomized because it could provide evidence of effectiveness to support a marketing application, according to Bryan. “We need to stop thinking about doing Phase 1 and Phase 2, then Phase 3 studies in rare diseases,” he observed. “There simply aren't enough patients for that paradigm because of the huge unmet need and people can't wait.”

 

And regarding the speed of product development, Bryan said that what’s holding up approvals in many cases is chemistry, manufacturing and controls (CMC) and other manufacturing issues. “We really need for sponsors to start working on CMC issues earlier and potency assays are a particular challenge,” he said. “You’ve got to understand your product and you’ve got to figure out its mechanism of action and develop a good potency assay as early as possible in development.”

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