Tag Archives: clinical

Drug Regulators, EMEA, Publish an Overview of Comments Received on Draft Guidance on Clinical Investigations of Medicinal Products Used in Osteoarthritis

Drug Regulators, EMEA, Publish an Overview of Comments Received on Draft Guidance on Clinical Investigations of Medicinal Products Used in Osteoarthritis.

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Interested party (Organisations or individuals) that commented on the draft Guideline as released for
consultation
Stakeholder
No.
Name of Organisation or individual
1 OARSI, Osteoarthritis Research Society International
2 USZ, Department of Rheumatology and Institute of Physical Medicine, University Hospital
of Zurich, Switzerland
3 AESGP, Association of the European Self-Medication Industry
4 EFPIA
5 GREES, Osteoarthritis section
6 EULAR

Drug Regulators, EMEA, Release Overview of Comments Received on Draft Guidance on Clinical Evaluation of Diagnostic Agents

Drug Regulators, EMEA, Release Overview of Comments Received on Draft Guidance on Clinical Evaluation of Diagnostic Agents.

Full Text here

Comments contributed by:

1 Industry Task Force and AIPES
2 EORTC
3 GE Healthcare LTD
4 International Society for Clinical Biostatistics (ISCB)
5 MSD
6 Novartis Pharma
7 Jorgen Hilden (Dept of Biostatistics, University of Copenhagen)
8 Anabel Cortes-Blanco

Drug Regulators, European Medicines Agency, Publish Concept Paper on Revision of the Notes for Guidance on Gene Transfer Medicinal Products

Drug Regulators, European Medicines Agency, Publish Concept Paper on Revision of the Notes for Guidance on Gene Transfer Medicinal Products

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This Concept Paper proposes a revision of the Note for Guidance on the Quality, Preclinical and Clinical Aspects of Gene Transfer Medicinal Products (CPMP/BWP/3088/99) that came into effect in 2001. The revision of the Note for Guidance, Guideline according to the new terminology, will address the issues identified from clinical experience and provision of Scientific Advice on gene therapy medicinal products and will lay down detailed and updated requirements for the quality, nonclinical and clinical aspects of gene therapy medicinal products. The revised Guideline will refer to a number of recently developed scientific guidelines and will comply with Regulation (EC) No 1394/2007 on Advanced Therapy Medicinal Products and the Commission Directive 2009/120/EC amending of the Annex I Part IV of Directive 2001/83/EC

Drug Regulators, EMEA, Publish Guidline on Xenogenic Cell-Based Medicinal Products

Drug Regulators, EMEA, Publish Guidline on Xenogenic Cell-Based Medicinal Products

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Xenogeneic cell-based therapy is the use of viable animal somatic cell preparations, suitably adapted for: (a) implantation/ infusion into a human recipient or (b) extracorporeal treatment through bringing (non-human) animal cells into contact with human body fluids, tissues or organs. The principal objective is reconstitution of cell/tissue/organ functions. The genotype and/or phenotype of the cells may have been modified, e.g. by isolation, culture, expansion, pharmacological treatment or
combination with various matrices. This guideline is an annex to the guideline on cell-based medicinal products (EMEA/CHMP/410869/2006) and deals specifically with requirements unique to xenogeneic specificities. This document is intended to provide general principles to be taken into consideration for the development and assessment of xenogeneic cell-based products without prejudice to medical practice or national legislation, which may be applicable. The main scientific and technical issues identified so far concern the sourcing and testing of animals, manufacture, quality control, as well as the non-clinical and clinical development of xenogeneic cellbased medicinal products are addressed. Relevant public health aspects are discussed and measures to ensure a proper surveillance for infections, including zoonoses are highlighted. These general
principles may apply to a range of products using animal tissues as the starting material, as the key objective is to ensure that the product to be administered is of acceptable quality and standard, and free from contamination.
The additional risks associated with xenogeneic cell-based Medicinal Products should be taken into account in the clinical development of these products. Attention is also given to principles of animal health and welfare in the processes of sourcing of xenogeneic materials for the medicinal products intended for human use.

Drug Regulators, EMEA, Re-Publish Guidance on Special Populations Geriatrics

Drug Regulators, EMEA, Re-Publish Guidance on Special Populations Geriatrics

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It is important to ensure that clinical testing programs are carried out according to harmonised guidelines based on agreed ethical and scientific principles so that the international development of valuable innovative drugs is achieved with maximum efficiency. Harmonisation in relation to medicines for geriatric populations is an important issue because the total population of the elderly will increase significantly in the coming years in Europe, Japan and the USA. The use of drugs in this population requires special consideration due to the frequent occurrence of underlying diseases, concomitant drug therapy and the consequent risk of drug interaction.

This guideline is directed principally toward new Molecular Entities that are likely to have significant use in the elderly, either because the disease intended to be treated is
characteristically a disease of aging ( e.g., Alzheimer’s disease) or because the population to be treated is known to include substantial numbers of geriatric patients (e.g., hypertension). The guideline applies also to new formulations and new combinations of established medicinal products when there is specific reason to expect that conditions common in the elderly (e.g., renal or hepatic impairment, impaired cardiac function, concomitant illnesses or concomitant medications) are likely to be encountered and are not already dealt with in current labelling. It likewise applies when the new formulation or new combination is likely to alter the geriatric patient’s response (with regard to either safety/ tolerability or efficacy) compared with that of the non-geriatric patient in a way different from previous formulations. The guideline also applies to new uses that have significant potential applicability to the elderly.

If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

Drug Regulatos Publish Draft Reflection Paper on In-vitro Cultured Chondrocyte Containing Products for Cartilage Repair

Drug Regulators, EMEA, Publish Draft Reflection Paper on In-vitro Cultured Chondrocyte Containing Products for Cartilage Repair

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This reflection paper addresses specific points related to products containing autologous chondrocytes intended for the repair of lesion of cartilage of the knee not discussed in the ‘Guideline on human cell based medicinal products’ (EMEA/CHMP/410869/2006) and therefore it should be read in conjunction with the guideline. – Deadline for comments is 31st December 2009.

If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

Drug Regulators Publish ICH consideration on Virus and Vector Shredding

EMEA Publishes ICH Considerations on the General Principles to Address Virus and Vector shedding

a copy is available here.

Introduction

Drug Regulators Publish ICH consideration on Virus and Vector Shredding Virus / vector shedding should not be confused with biodistribution, e.g., spread within the patient’s body from the site of administration.1 Virus / vector2 includes gene therapy vectors3 and oncolytic viruses.

Assessment of shedding can be utilized to understand the potential risk associated with transmission to third parties and the potential risk to the environment. The scope of this document excludes shedding as it relates to environmental concerns because it is regulated differently in various regions.

The focus of this document is to provide recommendations for designing non-clinical and clinical shedding studies when appropriate. In particular, emphasis will be on the analytical assays used for detection, and considerations for the sampling profiles and schedules in both non-clinical and clinical studies. The interpretation of non-clinical data and its use in designing clinical studies is also within the scope of this paper, as well as the interpretation of clinical data in assessing the need for virus / vector transmission studies.

Biological Properties of the Virus / Vector

Information on the known properties of the wild-type strain from which the virus / vector under consideration was derived is essential in guiding the design of shedding studies.

In practice, most viral / vector products currently under investigation are replication incompetent or conditionally replicative. It is likely that virus / vector shedding in these cases would be of a much shorter duration, and, depending on the route of administration, would display a different shedding profile as compared to shedding following infection with the wild-type counterpart.

Other property of the replication-competent virus / vector that should be considered when designing shedding studies would be whether infection is expected to be short- or long-term.

Analytical Assay Considerations

Having suitably qualified analytic assays in place for shedding studies is very important. Assays should be specific, sensitive and reproducible. Quantitative assays are preferred as these will aid in quantifying the probability of transmission. Assessment of interference from the biological sample matrix is important and it might be appropriate to dilute the sample prior to analysis to avoid extensive interference.

Polymerase chain reaction (PCR) and infectivity are the two assays typically used for the detection of shed virus / vector. Use of a quantitative PCR (qPCR)-based assay to detect viral / vector genetic material is recommended.

To accurately assess the potential for transmission of shed material, the use of an infectivity assay is considered important as this will allow for an accurate assessment of the nature of the shed material (e.g., intact virus / vector vs. fragments of virus / vector).

Non-Clinical Considerations

Non-clinical shedding studies help guide the design of clinical shedding studies. The aim of a nonclinical shedding study is to determine the secretion / excretion profile of the virus / vector.

Animal Species

One of the difficulties of investigating virus / vector products in non-clinical studies is the relevance of the animal species as a large number of virus / vector products under clinical evaluation are derived from parental strains which do not readily infect and rarely replicate in non-human species.

Dose and Route

Wherever possible the dose and route of administration used in non-clinical shedding studies should reflect those intended for use in the clinical setting.

Sampling Frequency and Study Duration

Known biological properties of the wild-type strain can be used to guide the frequency of sampling after virus / vector administration. In general, one might need to take samples more frequently in the first days following administration in order to detect a transient shedding profile.

Sample Collection

The characteristics of the virus / vector, the route of administration, and animal species should be taken into consideration in determining the samples to be collected. Examples of collected samples most commonly include urine and faeces, but could include other sample types such as buccal swabs, nasal swabs, saliva, and bronchial lavage. It is worth considering the samples that should be taken and the volumes that should be collected in order to perform quantitative, suitably qualified analytical assays. For certain secreta or excreta, such as urine, it can be difficult to collect sufficient sample material. Pooling of samples from several animals at the same time point receiving the same dose might be an option so that sufficient sample size or volume can be obtained.

Interpretation of Non-Clinical Data and Transmission Studies

It is important to keep in mind that data from non-clinical shedding studies are useful in guiding the design of clinical shedding studies, particularly as to sample types, sampling frequency, and duration.

Clinical Consideration

The considerations raised above for non-clinical studies are relevant to the design of virus / vector shedding studies in a clinical setting (i.e., route of administration, duration of shedding observed, sample types to be taken and frequency). The known biological properties of the parental virus / vector, the replication competence of the product, dose, route of administration, and patient population will be key factors to consider in the design of clinical shedding studies.

Interpretation of Clinical Shedding Data

There are a number of factors to take into account when assessing the clinical shedding data and the potential risk associated with transmission from shed virus / vector. An important factor to consider is to identify and characterize what is being shed. Specifically, if the assay used does not distinguish intact from degraded or non-infectious virus / vector, then the data might not be informative as to the potential risk associated with transmission.

Determining how virus / vector is shed is an important factor when assessing the potential risk associated with transmission. One should also consider how much is being shed and the duration of shedding.

Third Party Transmission

In some cases, when shedding is observed, the potential for transmission to third parties might need to be investigated. These investigations would involve evaluation of persons that come into close contact with virus / vector recipients (e.g., family members, healthcare workers) for evidence of transmission. The immunological status of the third party should be considered. A high proportion of the population might already have pre-existing immunity to the virus / vector; in this case, clearance should be effective in those individuals. However, the immune status of the third party contacts could be compromised, e.g., in the elderly or very young, and so clearance mechanisms might be inefficient. Thus the consequences of infection might be more significant in these individuals.

If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

Drug Regulators Publish Reflection Paper – Development of Similar Interferon Alfa

The Drug Regulator, EMEA, has published Guidance on developing Generic Interferon Alfa

The EMEA, published a reflection paper on the Non-Clinical and Clinical Development of Similar Medicinal Products Containing Recombinant Interferon Alfa.  in 2007, and has re-published the document on their website again.

This reflection paper lays down considerations on the non-clinical and clinical development of recombinant Interferon alfa-containing medicinal products claiming to be similar to another such product already authorised. Human interferon-alfa 2a or 2b are well-known and characterized proteins consisting of 165 amino acids. The non-glycosylated protein has a molecular weight of approx. 19,240 D. It contains two disulfide bonds, one between the cysteine residues 1 and 98, and the other between the cysteine residues 29 and 138. The sequence contains potential O-glycosylation sites. Physico-chemical and biological methods are available for characterisation of the proteins.

Recombinant Interferon Alfa 2a or 2b is approved in a wide variety of conditions such as viral hepatitis B and C, leukaemia, lymphoma, renal cell carcinoma and multiple myeloma. The sub-types Interferons alfa 2a and 2b have different clinical uses. IFN-alfa is used alone or in combination. Interferon alfa may have several pharmacodynamic effects. The relative importance of these effects in the different therapeutic indications is unknown. In general, interferon-alfa 2a or 2b use in oncology indications has reduced considerably and been superseded by other treatments.

Scope

This product specific reflection paper presents the current view of the CHMP on the non-clinical and clinical data for demonstration of comparability of two recombinant, on-pegylated, Interferon alfa containing medicinal products and should be read in conjunction with the requirements laid down in the EU Pharmaceutical legislation and other relevant CHMP guidelines (see References).

Non-Clinical Studies

Before initiating clinical development, non-clinical studies should be performed. These studies would be comparative in nature and designed to detect differences in the pharmaco-toxicological response between the similar Interferon alfa and the reference Interferon alfa and not just assess the response per se. The approach taken will need to be fully justified in the non-clinical overview.

Pharmacodynamics Studies

In order to compare differences in biological activity between the similar and the reference medicinal product, data from a number of comparative bioassays could be provided.

To support the comparability exercise for the sought clinical indications, the pharmacodynamic activity of the similar and the reference medicinal product could be quantitatively compared in an appropriate pharmacodynamic animal model, a suitable animal tumour model OR a suitable animal antiviral model.

Toxicological Studies

Data from at least one repeat dose toxicity study in a relevant species should be considered (for example, human Interferon alfa may show activity in the Syrian golden hamster). The study duration should be at least 4 weeks. Data on local tolerance in at least one species should be provided in accordance with the “Note for guidance on non-clinical local tolerance testing of medicinal products” (CPMP/SWP/2145/00).

Clinical Studies

Pharmacokinetic Studies

The pharmacokinetic properties of the similar and the reference medicinal product could be compared in single dose crossover studies using subcutaneous and intravenous administration in healthy volunteers. The recommended primary pharmacokinetic parameter is AUC and the secondary parameters are Cmax and T1/2 or CL/F.

Pharmacodynamic Studies

There are a number of PD markers, such as β2 microglobulin, neopterin and serum 2´, 5´-oligoadenylate synthetase activity, which are relevant to the interaction between Interferon -alfa and the immune system. The selected doses should be in the linear ascending part of the dose-response curve. Whereas the relative importance of these effects in the different therapeutic indications is unknown a comprehensive comparative evaluation of such markers following administration of test and reference products could provide useful supporting data.

Efficacy

Patient Population

The mechanism of action of interferon comprises of several different unrelated effects. Demonstration of similar efficacy between test and reference products is required. This could be performed in treatment-naïve patients with chronic hepatitis C (HCV) as delineated by the indication for the reference product. Other patient population(s) might be studied depending on the indications desired.

Study Design and Duration

A randomised, parallel group comparison against the reference product over at least 48 weeks is recommended. If possible, the study should be double-blind at least until data to complete the primary analysis have been generated. If this is not feasible, justification should be provided and efforts to reduce/eliminate bias should be clearly identified in the protocol.

Endpoints

Primary: Virologic response as measured by the proportion of patients with undetectable levels of HCV RNA by quantitative PCR at week 12. The assay used to measure HCV RNA and the cut-off applied should be justified. A 2-log decrease in viral load may be a co-primary endpoint. Secondary: virologic response at week 4 and end-of-treatment; sustained virologic response (24 weeks after completion of treatment); change in liver biochemistry including transaminase levels and morbidity.

Safety

Safety data should be collected from patients after repeated dosing in a comparative clinical trial over the treatment period plus 24 weeks of follow-up. The number of patients should be sufficient for the comparative evaluation of the adverse effect profile. Laboratory abnormalities for immune mediated disorders should be included. The safety profile should be similar to the reference products for the common adverse events (such as flu-like illness, alopecia, myalgia, leucopenia, anaemia and thrombocytopenia).

Immunogenicity

Comparative immunogenicity data (antibody levels) should be presented during the treatment period plus 24 weeks of follow-up according to the principles described in the “Guideline on similar biological medicinal products containing biotechnology-derived proteins as active substance: nonclinical and clinical issues” (EMEA/CPMP/42832/05/) and the “Guideline on immunogenicity assessment of biotechnology-derived therapeutic proteins” (EMEA/CHMP/BMWP/14327/2006).

Extrapolation of Evidence

In principle extrapolation from one therapeutic indication to another is appropriate where the mechanism of action and/or the receptor are known to be the same as the condition(s) for which similarity in efficacy has been established. If indication(s) are sought, where the mechanism of action is not known to be the same, such extrapolation
should be adequately justified.

Pharamcovigilance Plans

Within the authorisation procedure the applicant should present a risk management programme/pharmacovigilance plan in accordance with current EU legislation and pharmacovigilance guidelines. Attention should be paid to immunogenicity and potentially rare and/or delayed serious adverse events, especially in patients undergoing chronic administration. Safety should be collected from patients representing all approved indications.

If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

Drug Development Regulations and Guidance from EMEA – Clinical Evaluation of Antifugals

Drug development regulations and guidance from the EMEA has been published in draft for comment on Clinical Evaluation of Antifungals, as a replacement for points to consider on the clinical evaluation of new agents for invasive fungal infections which came into force in November 2003. it is intended to address the clinical developm,ent of anti-fungal agents for the treatment and prophylaxis of invasive fungal disease . The Guidance includes:

  • Non-clinical data on anti-fungal activity that should be generated prior to and during the clinical development programme.
  • Clinical study design recommendations for studies that evaluation anti-fungal agents for the treatment of invasive fungal disease
  • Drug development guidance for; drug combinations, salvage therapy, studies in neutropenic patients and the assessment of prophylaxis
  • Bio-marker guidance for patient selection
  • paediatric development plans (a regulatory requirment discussed extensively on this site)
  • Clinical Safety Assessment
  • SPC sections 4.1 and 5.1 layout and content

Background

Clinical and drug development of anti-fungal agents for the treatment and prophylaxis of invasive fungal disease (IFD) requires special attention because IFD occurs in a heterogeneous group of patients most of whom have evidence of debilitation and/or immunosuppression. IFD may occur with or without detection of fungi in the blood cultures, and in some cases it is detected in the blood but source of infection can’t be found.

Factors such as infection site and fungal pathogen, complexity of the underlying illness, variable degree and duration of immunosuppression and its mode of management and incidence of concomitant infections with bacteria and viruses may affect the mycological response to therapy and the overall clinical outcome.

Changes in the clinical practice has prompted these updated guidelines:

  • Increased availability of anti-fungal agents
  • Prophylaxis use has increased
  • Emergence of rapid diagnostic tests
  • Revised definitions of IFD published by the Invasive Fugal Infections Co-operative Group (IFIG) of the European Organization for Research and Treatment of Cancer, and the Mycosis Study Group of the National Institute of Allergy and Infections Disease (NIAID)
  • Anti-fungal susceptibility testing standardisation published by The European Committee on Antimicrobial Susceptibility Testing (EUCAST)

Drug Development Guidance Scope

The guideline is primarily concerned with the content of clinical development programmes to assess the safety and efficacy of anti-fungal agents administered by oral or parenteral routes for the treatment and prophylaxis of IFD. The guidance includes:

  • Consideration of the non-clinical data on anti-fungal activity that should be generated prior to and during the clinical development programme
  • Criteria for enrolment and criteria for assessing the certainty of diagnosis
  • The assessment of clinical efficacy including the design of studies that evaluate antifungal agents for treatment or prophylaxis of IFD.
  • The assessment of clinical safety.
  • Reflection of the mycological and clinical data in the SPC.

Clinical Evaluation

Assessment of antifungal activity is required:

  • Spectrum of in-vitro antifungal activity.
  • Mode of action
  • Mechanism(s) of resistance
  • Cross-resistance within and between anti-fungal drug classes.
  • Synergy or antagonism with antifungal agents of different classes
  • Efficacy in animal models
  • Pharmacokinetic/pharmacodynamic (PK/PD) relationship.

Assessment of Efficacy:

  • All fungi that are isolated and considered to be causative of IFD should be forwarded to one or more designated reference laboratories for confirmation of identity and susceptibility testing
  • Clinical and mycological outcomes should be analysed in the light of in-vitro susceptibility and patient pharmacokinetic data to further assess the PK/PD relationship
  • It is recommended that at least some of the in-vitro data should be generated using susceptibility testing methodologies published by EUCAST since this will facilitate the setting of EUCAST-recommended breakpoints.
  • Any available EUCAST-recommended susceptibility testing breakpoints for common Candida species and Cryptococcus species should be included in the SPC
  • Susceptibility and resistance should be further assessed in the post-approval period

Patient Selection Criteria

  • Sponsors may choose to enrol patients who already have proven or probable IFD
  • studies may enrol patients who are considered likely to have the type of IFD under investigation.
  • Patient Selection Criteria:
    • Clinical history, signs and symptoms
    • Imaging studies
    • Microscopic findings in suitable specimens
    • Rapid antigen or nucleic acid detection tests.
    • Culture results from suitable specimens
    • Histological findings
    • The presence (degree and prior duration) or absence of neutropenia at baseline.
    • Prior IFD within a defined timeframe and/or during a previous period of neutropenia
    • Specific pre-disposing factors for IFD (e.g. HIV infection, type of immunosuppressive therapy).

Treatment Regimens

Monotherapy – The selection of proposed regimen(s) to be studied in confirmatory studies of clinical efficacy should be based on all the available non-clinical data, human pharmacokinetic data and exploration of the PK/PD relationship. Whenever possible the active comparative therapy should be restricted to a single regimen. The protocol should pre-define a minimum duration of therapy for patient evaluability and a maximum duration beyond which patients who have not met the response criteria should be considered to have failed therapy.

Combination Therapy

The choice of antifungal agents to be co-administered should take into account the in-vitro activity of the combination against target genera/species. if possible, the selection of combination regimens to treat specific types of IFD should also be supported by a demonstration of benefit for co-administration over each agent given alone in an animal model. Consideration should also be given to the potential for significant drug-drug pharmacokinetic or pharmacodynamic interactions to occur, which may preclude co-administration or may indicate a need for dose adjustment of one or both agents.

The guidance goes on to give plenty of details of the study designs. Outcomes testing and specific patient groups, its a detailed guidance that needs careful consideration for anybody working in the area.

    If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

    Guidline on Quality, Non-Clinical and Clinical Aspects of Live Recombinant Viral Vectored Vaccines

    EMEA publishes new guidelines, “Guideline on Quality, Non-Clinical and Clinical Aspects of Live Recombinant Viral Vectored Vaccines” . Vaccines against infectious diseases based on a viral vector expressing the antigen infectious agent have been under development for some time.This guideline ap pplies to such live recombinant vaccines for the prevention and treatment of infectious disease, and provides guidance on quality, non-clinical and clinical aspects.

    The objective of this guideline is to provide recommendations on the quality, nonclinical and clinical studies should be performed in order to obtain marketing authorisation of a live recombinant viral vector vaccine intended to use in the prophylaxis of infectious disease in humans. This guideline is intended products entering the marketing authorisation procedure. However, the principles laid down in this guideline should be considered by applicants entering into clinical trials.

    In this guideline, the emphasis is placed upon safety issues, such as:

    • The phenotype of recombinant virus
    • The extent of pre-immunity to the vector, the extent of community induced to the vector and the potential for reuse of the vector,
    • Genetic stability of the recombinant virus, reversion to the virulence or the combination with wild type strains
    • Clinical follow up in healthy patient populations
    • Chromosomal germline integration.

    These aspects will drive the selection a number of different relevant toxicological pharmacological models. Emphasis is also placed on first in man studies as the vaccines within the scope of this guideline and novel laboratory derived viruses obtained by recombinant DNA technology and clinical assessment will represent their first contact with humans.

    The guideline goes on to give detailed descriptions of what is expected in the following areas:

    • Quality aspects
      • General considerations
      • Genetic development
      • Vaccine seed lots
        • General
        • Characterisation of vaccine seed lots
        • Adventitious agent safety
      • Vaccine manufacture
        • Vaccine production
        • Harvesting
        • Virus pools
        • Final bulk vaccine (drug substance)
      • Control of final vaccine (drug product)
        • Identity
        • Potency assays
        • Stability
        • Consistency of production
    • Nonclinical immunological and safety requirements
      • General considerations
      • Pharmacodynamic studies (protection and immunogenicity)
      • Nonclinical safety studies (toxicity testing)
        • Single and repeated dose toxicity
        • Distribution studies
        • Reproduction and development toxicity studies
        • Local tolerance
    • Clinical
      • Immunogenicity
      • Safety

    These are a detailed set of guidelines that cover most of the process of development and are required reading for anybody working in the area.

    If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

    EMEA re-posts Points to Consider on Missing Data

    The EMEA has re-posted points to consider on missing data, this points to consider was formally adopted in 2001, however the EMEA has chosen to re post this on the website. It does not appear to have changed since its last posting.

    The EMEA a considered missing data as a potential source of bias when analysing clinical trials, interpretation of the results of a trial is always problematic when the number of missing values is substantial. There are many possible sources of missing data, affecting either complete subjects or specific items, missing data violate the strict Intend To Treat principals: measurement of patient outcomes regardless of protocol adherence and analysis performed by treatment assigned, regardless of which treatment patients actually received.  If missing values are handled simply by excluding any patients with missing outcomes from analysis, the following problems may affect the interpretation of the trial results.

    The sample size and variability of outcomes affects the power of the clinical trial, power is greater the larger sample size and smaller variability. The reduction in the number of cases available for analysis, completeness of data add ot the resulting reduction of the statistical power.

    Bias is the most important concern resulting from the missing data may affect: Designation of the treatment effect, The comparability of the treatment groups, The representativeness of the study sample in relation to the target population. Bias occurs in the estimation of the treatment effect when the relationship between missing this treatment outcomes exists. In most cases it is difficult or impossible to elucidate whether the relationship between missing values and unobserved outcome variable is completely absent. Thus it is sensible to adopt a conservative approach, considering missing values as potential sources of bias.

    A possible way of handling incomplete data is to ignore them and perform statistical analysis with complete data only. However, complete case analysis violates intention-to-treat principal. More importantly it is subject to bias, and thus cannot become recommended as the primary analysis confirmatory trial.

    The statistical analysis of the clinical trial requires imputation of values to those data that have not been recorded. Many techniques have been used for the imputation of missing data, but none of them can be considered as the gold standard in every situation. The guidance goes on to discuss the many options available:

    To cope with situations where response collection is interrupted at one point, the widely used method is last observation carried forward. This method is likely to be acceptable if measurements are expected to be relatively consistent over time.

    Best worst case imputation, assigning the worst possible value of the outcome to dropouts are a negative reason (treatment failed) and the best possible value to positive dropouts (kills), is another approach that can be considered, provided it is applied conservatively.

    Another simple approach of inputting missing data is to replace the unobserved measurements by values derived from other sources. Possible sources include information from the same subject, from other subject of similar baseline characteristics, the predictive value from an empirically developed model, historical data, etc.

    Most methods faced the risk of bias in the standard error downwards by estimating central value and ignoring its uncertainty. This risk can be avoided by some techniques based upon maximum likelihood methodology and with multiple imputation methods. Maximum likelihood methodologies have been proposed that imputation of missing values, as have multiple imputation methods. Maximum likelihood method strategies fit the model by an iterative process. Multiple input methods generate multiple copies of the original dataset replacing missing values by randomly generated values, and analysing is complete sets.

    Unfortunately, there is no universally accepted methodological approach and the missing values.the best process of all is the avoidance of missing data in the first place.

    If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

    Damien Bové works as a drug development consultant (pharmaceutical or biotechnology) and regulatory consultant, we work with our clients to define a drug  development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

    ida consultants freestrategyconsultation 515x64 EMEA re posts Points to Consider on Missing Data

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    EMEA re-post Draft Guidance on the Clinical Evaluation of Anti-virals intended for HepC

    The EMEA has reposted draft guidance on the “Clinical Evaluation of Direct Acting Antivial Agents Intended for the Treatment of Chronic Hepatitis C”. the guidance was originaly posted in April 2008, but the EMEA has re-posted it.  the contents don’t appear to have altered and in summary:

    • The guidlines are focused on testing new therapies as add-on to current gold standard (Pegalated-interferon alpha 2a and 2b).
    • A special concers is the high mutation rate of HepC with the attendant risk of selection of drug resistant variants.
    • Initial studies should enrol subjects naive to Standard of Care who do not have advanced fibrosis or HIV co-infection.
    • The next study coudl enrole patients with genotype 1 infections who have had a sub-optimal response to standard of care or relapsed.
    • Once effect of the add-on therapy have been described later studies can look at specific groups such astumour types, HIV infected patients and mornull  responders to standard treatments

    There is also discussion of epidemiology of infection  quoting around 3% of the worlds population has been infected and around 200 million people at risk of developing serious liver morbidity. The natural course of infection is also discussed around 60 to 80% of infected individuals becoming chronic carriers.and after about 20 years 20 to 30% of them have progressed cirrhosis, the five-year risk of hepatic decompensation is around 15 to 20% and that of hepatocellular carcinoma around 10%.

    Guidance is provided on the design of exploratory and confirmatory clinical studies considered to be of relevance for the evaluation of direct acting anti-hepatitis C compounds as add on to standard of care in different populations. Guidance is given on subjects characteristics and selection of subjects, guidance is also provided on genotyping, primary endpoints the recommendation in this case sustained virological response defined as undetectable virus RNA six months after completion of therapy. Secondary endpoints are also described, end of treatment response and time to confirmed undetectable viral load, rapid viral response and early viral response, liver histology guidance is also provided.

    Guidance goes on to describe the pharmacokinetic studies that are required the pharmacodynamic studies that are required, the guidance then goes on to describe appropriate for one studies in special populations; transplant patients and  studies in children.

    If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

    Damien Bové works as a drug development consultant (pharmaceutical or biotechnology) and regulatory consultant, we work with our clients to define a drug  development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

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    PhRMA Issues Revised Principles on Conduct of Clinical Trials and Communication of Clinical Trial Results

    On April the 20th the Pharmaceutical Research and Manufactures of America (PhRMA) issued a revised “Principles on Conduct of Clinical Trials and Communication of Clinical Trial Results” – These guidelines outlines a number of elements including: Principles on the conduct of clinical research, registration of clinical trials and disclosure of study result summaries. Some of the more important changes include:

    Registration of Clinical Trials – PhRMA advises member companies to register on a public database timely summary information about all clinical trials that study products in patients.  PhRMA defines timely as 21 days of enrollment of the first patient in the clinical trial. (this includes phase 1 studies), the PhRMA guidance is more stringent and goes further than FDA rules.

    Submission of Summary Results - As it did in its prior version, PhRMA promises to disclose summary results of all clinical trials for approved drugs, regardless of the study’s outcome.  In a major change from its prior version, however, PhRMA also promises to post timely summary results of all clinical trials if the sponsor discontinues development of the drug.  PhRMA defines timely as 12 months after the trial ends, 30 days within drug approval or a year after a company discontinues the drug development program.

    Disclosure of Conflict of Interest in Articles - The revision urges sponsors to encourage physicians and researchers to disclose conflict of interest information when authoring manuscripts to medical journals.  Authors that submit a manuscript to a medical journal, according to PhRMA, should disclose “all financial and personal relationships that might bias their work,” and explicitly state whether potential conflicts exist.

    Increased Qualifications Needed for Authorship – The revised Principles would make it more difficult to be listed as an author of an article in a medical journal.  These more stringent guidelines adhere to the standards of the International Committee of Medical Journal Editors.

    Provision of Study Results to Investigators and Participating Patients – PhRMA directs sponsors to provide all investigators with a full summary of the study results even if an investigator does not contribute to the publication of the study.

    Sponsors Right To Review – PhRMA also confirms that sponsors have the right to review manuscripts, presentations, or abstracts that result from the sponsor’s studies or use the sponsor’s data prior to publication or presentation.

    If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

    Damien Bové works as a drug development consultant (pharmaceutical or biotechnology) and regulatory consultant, we work with our clients to define a drug  evelopment target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.

    New FDA Draft Guidance – Non Clinical evaluation for Anticancer Pharmaceuticals

    The FDA has produced some draft guidance aimed at establishing an internationally accepted objectives and / or recommendations on the design and conduct of nonclinical studies to support the development of anticancer pharmaceuticals in patients with advanced disease and limited therapeutic options.

    Because malignant tumours are life-threatening, the death rate from these diseases is high, and existing therapies have limited effectiveness, it is desired to provide new effective anticancer drugs to patients more expeditiously. Nonclinical evaluations are intended to 1)identify the pharmacological properties of a pharmaceutical, 2) establish a safe initial dose and 3) understand the toxicological profile.

    These new guidlines only apply to pharmaceuticals intended to treat cancer in patients with late stage or advanced disease regardless of the route of administration, including both small molecule and biotechnology-derived pharmaceuticals.

    Studies to support nonclinical evaluation

    Pharmacology – prior to phase I studies, preliminary characterization of the mechanism(s) of action, resistance, and schedule dependencies as well as anti-tumour activity should have been made. appropriate models should be selected based on the target and mechanism of action but need not be studied using the same tumour types intended for clinical evaluation. these studies can provide proof of principle, guide schedules and dose escalation schemes, provide information for selected test species, and aid starting dose selection.

    Safety Pharmacology – as assessment of vital organ function should be available before initiation of clinical studies. Stand alone safety pharmacology studies need not be conducted to support studies in pateiutne with late stage cancer or advanced disease.

    Pharmacokinetics – the evaluation of limited kinetic parameters, e.g. peak plasma levels, AUC and half life in the animal species used for non-clinical studies can facilitate dose escalation during phase I.

    General Toxicology – The primary objective of Phase I clinical trials in patients with cancer is to assess the safety of the pharmaceutical. This can include dosing to a maximum tolerated dose (MTD) and dose limiting toxicity (DLT). Therefore, determination of a no observed adverse effect level (NOAEL) or no effect level (NOEL) in the toxicology studies is not considered essential to support clinical use of an anticancer pharmaceutical. To support Phase I clinical trials at least one nonclinical study should incorporate a recovery period at the end of the study to assess for reversibility of toxicity findings or the potential that toxicity continues to progress after cessation of drug treatment. Toxicokinetic evaluation should be conducted as appropriate.

    Reproduction Toxicology – These studies are not considered essential to support clinical trials intended for the treatment of patients with late stage or advanced cancer. These studies are also not considered essential for pharmaceuticals which target rapidly dividing cells in general toxicity studies or belong to a class which has been well characterized in causing developmental toxicity. Generally no fertility study is warranted to support the treatment of patients with late stage or advanced cancer. A peri- and postnatal toxicology study is generally not warranted to support the treatment of patients with late stage or advanced cancer.

    Genotoxicity – Genotoxicity studies are not considered essential to support clinical trials for therapeutics intended to treat patients with late stage or advanced cancer.

    Immunotoxcity – For anticancer pharmaceuticals the design components of the general toxicology studies are considered sufficient to evaluate immunotoxic potential and support marketing.

    The guidelines go on to describe how you can use the pre-clinical data in designing you clinical trial: start dose for first administration in man, dose escalation and the highest dose in clinical trials. the guidelines also provide guidance on duration and schedule of toxicology studies to support initial clinical trials, the duration of toxicology studies to support continued clinical development and marketing, how to manage combination pharmaceuticals and Finlay the non clinical studies to support trials in pediatric populations. Other considerations addressed in the guidelines include conjugated agents, liposomal products, evaluation of drug metabolites, and evaluation of impurities.

    Table – Example schedules for anticancer pharmaceuticals to support initial clinical trials. (reproduced from FDA guidelines S9)

    moz screenshot 1 New FDA Draft Guidance   Non Clinical evaluation for Anticancer Pharmaceuticals

    table1 300x182 New FDA Draft Guidance   Non Clinical evaluation for Anticancer Pharmaceuticals

    If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

    Damien Bové works as a drug development consultant (pharmaceutical or biotechnology) and regulatory consultant, we work with our clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch


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    ea featured 4 New FDA Draft Guidance   Non Clinical evaluation for Anticancer Pharmaceuticals

    Cardiovascular Toxicity (QT prolongation) in Drug Development Overview

    Nobody working in drug development can fail to be aware of the issue that is QT prolongation, however some people are finding they need a little more information if they are going to tackle and plan for it within their drug development programmes.

    There are three main ways that cardiovascular toxicity can present itself:

    1. Changes to heart rate
    2. Changes to conductivity within the heart
    3. Changes to the repolarization of the heart (QT prolongation)

    It is this QT prolongation that is obviously the hottest issue and is a consequence of impacting the repolarization of the cardiomyocytes. The pathway is the hERG channels are blocked, which increased the action potential of the cells in the heart, which in turn causes the QT prolongation.

    This problem has been seen in a large number of drugs and has impacted on a great many drug development programmes, from complete removal of a drug from the market, to prescribing restrictions, delays in approval and a huge number of drugs killed at an early stage. It is also worth noting that there is not a pattern to those drugs affected and it appears to affect a large number of different drugs.

    But what can be done to manage this risk? Well there are a wide variety of early discovery screens, In-vitro, Ex-vivo, and In-vivo.

    The most common In-vitro study is the Patch Clamp – this is actually the gold standard study and involves measuring the current through the hERG channel (Ikr Chanel) to give an IC50 for the drug, this IC50 will give you an indication if you are going to see effects at therapeutic dose levels. Whilst this is the gold standard it is not a test that lends itself well to high throughput screening.

    Another test is the hERG binding assay, this is a competitive assay that tests your drug against a radio labeled standard, this is a good test which can be used in high throughput screening, and is well correlated to the Patch Clamp test.

    Another is the Rubidium Flux assay, where you load the cells with rubidium add your compound and KCl, this allows you to measure the rubidium excreted from the cell and from this judge hERG channel activity. This once again lends itself to even fast screening but there is some drop off in relation to the gold standard.

    The final test is the membrane potential dye test, where cells are loaded with dye and as the hERG channel functions dye is flushed from the cell, this is the fastest test but least accurate.

    The tests most commonly used are the hERG binding assay and Rubidium flux tests

    In terms of Ex-vivo models the most popular are pukinji fiber tests and isolated heart tests, these whole tissue and whole organ tests are expensive but do provide a lot more information on what is going on and provide a wider insight.

    In-vivo tests include dogs, non-human-primates, and pigs, rodents are not a good model for the human heart and should not be used. Again the expense of these models is made up for by the excellent data they provide. The studies are generally conducted in conscious animals which are remotely monitored, single dose cross over study designs are used, time and duration of effect is looked for and compared with systemic drug levels. Heart rate, ECG, Blood Pressure, Body Temperature, and activity levels are all monitored.

    One of the most important things to look at is left ventricular pressure as this gives the greatest insight into normal function, Charles Rivers have done a great deal of work to validate this with Atenolo and Pimobedam. With both drugs systolic BP, diastolic BP and heart rate remained the same but changes in left ventricular pressure alluded to issues that needed to be addressed.

    There are two guidelines that need to be referred to when planning these studies ICH57A (general safety pharmacology) and ICH57B (Specific QT prolongation regulations).

    When assessing the Pre-clinical it is important to take a good look at the data and consider the following; what was actually observed as the assays are not 100% effective, any small flags will impact on clinical trial design, how will the expected PK/PD profiles impact on the results, will you expect patients to get into affected dose levels?

    Before commencing human trials there are guidelines that need to be considered ICH E14 which gives instruction on the evaluation of QT prolongation in man, in some regions its now compulsory, but in others you can argue away from it with pre-clinical data.  In the clinic QT prolongation is tested in healthy volunteers at therapeutic doses and multiples thereof, metabolic inhibition may be needed to raise drug levels levels high enough, positive controls are also used (moxifloxacin).

    Where QT prolongation is seen the following guidelines are provided:

    • <5 msec – no risk
    • 6-10 msec unlikely risk
    • >10 msec possible risk

    These regulations are the same for cardiovascular drugs as for other therapy areas.

    Another important thing to consider is that QT prolongation is not an issue that affects biologicals, as demonstrated by Vergas, Boss et al 2008 (J Pharmacol and Tox Method 58;72-76)

    If you would like more detail in this area please get in touch with Damien Bové damien.bove@idaconsultants.com

    Damien Bové works as a drug development consultant (pharmaceutical or biotechnology) and regulatory consultant, we work with our clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.


    ea featured 3 Cardiovascular Toxicity (QT prolongation) in Drug Development Overview