Title: Responses to FDA Gene Therapy Letter : Adenovirus Vector Titer Measurements and RCA Levels
1Responses to FDA Gene Therapy Letter Adenovirus
Vector Titer Measurements and RCA Levels
- BRMAC July 13, 2001
- Steven R. Bauer, Ph.D
- Division of Cellular and Gene Therapies
- CBER/FDA
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4Purpose
- Updates
- Development of an adenovirus reference material
- Change in recommendation on particle to
infectious unit (IU) ratio - Change in recommendation on RCA limit
- Discussion
- Application of RCA recommendation
5Adenovirus Vector Final Product
non-infectious particles
IU replication defective, infectious particle
RCA replication competent, infectious particle
VP all vector particles
6Characterization of Particles in Adenovirus
Vector Products
- VP physical/chemical measurement
- example A260 after lysis of VP
- IU biological assay
- examples
- measure plaques on a lawn of permissive cells
- immunological detection of infected cells with
fluorescent antibodies - RCA biological assay
- measure infection on cells that do not complement
defective vector
7Impact of VP, IU, RCA Safety, Efficacy,
Production
- Safety
- replication competent virus
- exposure to viral proteins
- Efficacy
- non-transducing particles
- Production process
8Development of Adenovirus Reference Material
- 1993 Adenoviral vectors used in CF Protocols
- CF Foundation recommended vector reference
standard - 1999 RAC Safety Symposium
- RAC AdSAT calls for standards
9What Will Be Accomplished by Reference Material
Development?
- Produce more consistent, safer, adenoviral
vectors - particle counts (10 inter-assay variability)
- infectious units (over 30 inter-assay
variability) - Allow comparability between preclinical and
clinical studies - Develop regulatory policy
- make recommendations based on standardized
measurements
10Reference Material Development
- Adenovirus Reference Material Working Group
(ARMWG) - Partnership
- Government/Industry/Academia
- Williamsburg Bioprocessing Foundation
- www.wilbio.com
- www.fda.gov/cber/minutes/workshop-min.htm
11Adenovirus Reference Material Production Scheme
Master Cell Bank
ARMWG Meetings March 22, 2001 May 31, 2001
Ad5 wt virus
Master Viral Seed Stock
Production of purified formulated bulk virus
Characterization, safety testing, provisional
titer
Vialing
Particle and Infectivity Titer Determinations,
Stability
Repository and Distribution
12Purpose
- Updates
- Development of an adenovirus reference material
- Change in recommendation on particle to
infectious unit (IU) ratio - Change in recommendation on RCA limit
- Discussion
- Application of RCA recommendation
13Changes in Recommendations
- ALARA
- As Low As Reasonably Achievable
- New recommendations based on review of
information submitted in March 6 letter responses - Applied to all Adenovirus GT products
14Change in Recommendation on Particle to IU ratio
- Previous Recommendation
- Based on review of production lot data
- lt 100 vp/iu
- Current Recommendation
- Based on review of production lot data from March
6 letter responses - lt 30 vp/iu
- (gt3.3 iu)
15Change in Recommendation on RCA Limit
- Previous recommendation
- imprecise since based on infectious titer
lt 1RCA / 109 iu - Current recommendation
- based on particle number
- better precision
- lt 1RCA / 3 x 1010 vp
16Purpose
- Updates
- Development of an adenovirus reference material
- Change in particle to infectious unit (IU) ratio
- Change in recommendation on RCA limit
- Discussion
- Application of RCA recommendation
17Application of RCA Recommendation
- lt 1RCA / 3 x 1010 vp
- recommended for all adenovirus vector lots
regardless of clinical use - Exposure risk at highest current doses
- dose of 3 x 1013 vp
- potential exposure up to 1000 RCA
-
18ALARA vs Risk Based
- Shift from ALARA to Risk-Based recommendation?
- What information do we have?
- Literature, clinical experience with wild-type ad
infection/reactivation - Clinical experience with gene transfer studies
- Some notable adverse events of unknown cause but
indications of innate immuniity - What information do we need?
19Wild-type Adenovirus in Bone Marrow
Transplantation
- Adenovirus, including types 2 and 5, is a
significant cause of morbidity and mortality in
BMT - Important to consider recipient immune status
- Infection/Reactivation
20Lessons Learned from Patients with Primary or
other Secondary Immunodeficiencies
- Neonatal adenoviral pneumonia Sporadic, severe,
localized outbreaks - SCID population at high risk Severe morbidity
and mortality - DiGeoge syndrome case reports of fatal hepatic
necrosis - Solid organ transplant
- Infection (rejection?) of transplanted organ
- Source reactivation and donor
- AIDS patients
- Co-infection with other pathogens
- Diversity of serotypes isolated
21Topics for Discussion
- Should recommendations regarding acceptable
levels of RCA in adenovirus gene transfer
products be the same for all clinical uses? - ALARA vs risk-based recommendation for RCA
exposure - severely immunosuppressed or immunocompromised
patients - mildly immunosuppressed or immunocompromised
patients - patients with genetic defects such as hemophilia,
cystic fibrosis, or other. - What data should be used to set acceptable limits
for RCA exposure? - Should RCA measurements be performed on ex-vivo
transduced cells?