Back to Explorer

Studying Multiple Versions of a Cellular or Gene Therapy Product in an Early-Phase Clinical Trial: Guidance for Industry

FinalCenter for Biologics Evaluation and Research11/04/2022
CMCPharmacology/Toxicology

Description

The purpose of this guidance is to provide recommendations to sponsors interested in studying multiple versions of a cellular or gene therapy product in an early-phase clinical trial for a single disease.  Sponsors have expressed interest in gathering preliminary evidence of safety and activity using multiple versions of a cellular or gene therapy product in a single clinical trial.  Although multiple versions of a product can be studied together in a single clinical trial, each version of the product is distinct and is generally submitted to FDA in a separate investigational new drug application (IND).  The objective of these early-phase clinical studies is to guide which version(s) of the product to pursue for further development in later-phase studies.  Thus, these studies are not intended to provide primary evidence of effectiveness to support a marketing application and generally are not adequately powered to demonstrate a statistically significant difference in efficacy between the study arms.  In this guidance, we, FDA, provide recommendations for studies that evaluate multiple versions of a cellular or gene therapy product, including how to organize and structure the INDs, submit new information, and report adverse events.  This guidance finalizes the draft guidance of the same title dated September 2021.

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

3
Cellular Therapy

Additional considerations may exist for cellular therapies.

Gene Therapy

A type of ATMP involving recombinant nucleic acids or viral vectors.

Cellular or Gene Therapy Product

The scope of the guidance regarding versions of products.

Stakeholders

3
Sponsor

Entity responsible for submitting applications under section 524B

Contract Manufacturer

External entity responsible for manufacturing activities

IRB

Institutional Review Board providing study approvals

Regulatory Context

Regulatory Activities

3
IND

Investigational New Drug submissions

Pre-IND meeting

discuss these considerations with OTP prior to the IND submission as part of a pre-IND meeting

INTERACT

Initial Targeted Engagement for Regulatory Advice on CBER Products meeting type.; INitial Targeted Engagement for Regulatory Advice on CBER/CDER ProducTs

Document Types

3
Master Protocol

Single trial infrastructure used in umbrella trials

Investigator Brochure

Must include summary of pharmacogenomic associations.

Annual Report

Reporting category for minor changes like removing a color additive

Attributes

2
Allogeneic

Cell source attribute for mesenchymal stromal cell products.

Autologous

Cell source attribute for mesenchymal stromal cell products.

Technical Details

Substances

5
Chimeric Antigen Receptor T cell

Example of a product version (CAR T cell)

Tumor-infiltrating lymphocytes

Example of a cellular product version change from bulk to purified CD8+.

Dendritic cells

Example of a cellular product version change involving pulsing with peptides.

Mesenchymal stromal cell

Example of a cellular product version change involving cell source.

Induced pluripotent stem cell

Example of a cell bank change to produce the same cell type.

Processes

2
Cell expansion

Manufacturing process change from serum-containing to serum-free media.

Suspension cell culture

Manufacturing process change from adherent to suspension.

Clinical Concepts

3
Early-Phase Clinical Trial

Scope of the guidance is limited to early-phase studies

Umbrella Trial

derivation in a simple case that power can be increased with disproportionately greater randomization

Adverse Events

Reporting adverse events when engaging with patients.; changes may be related to benefits, tolerability, and/or unintended effects

Standards & References

Specifications

1
eCTD Specifications

electronic common technical document format for IND submissions

Related CFR Sections (5)

Enforcement Impact

Deficiencies cited in Warning Letters referencing the same regulations

Failure to maintain an effective IND for the expanded access use
1
Failure to ensure prospective IRB review and approval
1
Failure to submit annual reports to FDA
1

Related Warning Letters (1)

Related MFDS Guidelines

Korean regulatory guidelines covering similar topics

See Also (8)

Studying Multiple Versions of a Cellular or Gene Therapy Product in an Early-Phase Clinical Trial: Guidance for Industry | Guideline Explorer | BioRegHub