EMA launches public consultation on draft Guideline concerning the development of GTMPs

On 20 May 2015, the European Medicines Agency (“EMA”) launched a three month consulting on a revised Guideline on the quality, non-clinical and clinical aspects of gene therapy curative products. Once finalised, the draft Guideline be inclined replace the 2001 Note for government on the quality, preclinical and clinical aspects of gene therapy medical products.

The draft Guideline is intended to exhibit advice on the development and evaluation of gene therapy therapeutical products that are submitted for marketing authorisation in the European Union (“EU”). In harmony with Article 2(a) of Regulation (EC) No 1394/2007 it is recalled that every advanced therapy medicinal product may be based on a gene therapy medicative product. The draft Guideline focuses attached issues related to gene therapy curative products (“GTMP”) containing (i) recombinant nucleic pungent sequences (e.g. DNA vectors); and (ii) genetically modified micro-organisms. GTMP containing genetically modified cells are excluded from the sweep of the draft Guideline. However, vectors used in the mode of genetically modified cells are included. The unbecoming mentioned information contains certain pertinent requirements and recommendations, which, if the draft Guideline is adopted in its current cut, must be taken into account by applicants.


The draft Guideline identifies certain potential barriers to the evolution of successful gene therapies that could be encountered by applicants. This consideration sourness be taken into account in the context of the design of the GMTP:

The genetic weighty of the medicinal substance must subsist characterised as thoroughly as possible judgment analysis and use;

The potential likelihood of cross-contamination during construction and recombination with endogenous sequences in the cell substrate used for the time of construction or in production must have existence evaluated;

Data on the control and permanence of the vector and the therapeutic sequence(s) during development and in work must be provided;

Evidence must have existence supplied to demonstrate that the correct sequence has been made and that this has been stably maintained for the time of amplification;

Cells used in the copious discourse of the genetic material must be characterised in accordance with the rough copy Guideline;

Details of the construction of ~ one packaging/producer cell line or help-fellow virus must be provided.

The make an outline of Guideline also provides examples of tests that mouldiness be conducted on different types of starting material. The following elements must be granted:

(i) description (including source);

(ii) characteristics; and

(iii) testing of whole the materials used during the manufacturing procedure.

Characterisation studies must be conducted from beginning to end the development process. Characterisation of the vector be bound to include all components, in particular, those attentive in the final product to have existence administered. The intended action and possible impurities must be demonstrated in the development phase. The specific properties to which the specification must reflect are also defined in the draft Guideline.

A sharp description of the manufacturing process and the in-transaction controls which the medicinal product has gone through be necessitated to be submitted in support of ~y application for marketing authorisation. This new wine be presented in the format of a pour diagram. Characterisation and specification of the excipients (i.e. the complexing corporeal(s) for formulating the medicinal products) are considered to subsist critical aspects of the CTD.

If GTMP are combined through a medical device at the on a ~ of the medicinal product, characterisation of the sanatory product must be provided.

The rough sketch Guideline identifies certain release specifications that the able medicinal product is expected to prove.

Process development and process validation since the medicinal substance and the medicinal product could require the support of in vivo studies. In vivo studies could exist considered necessary to demonstrate that series of measures changes incurred do not affect the close custody and efficacy profile of the harvest.

Details of the tests used during batch release must be provided, including analytical methods. Each relation material used in control tests much be described and demonstrated to subsist suitable for the intended purpose.

The selection Guideline also outlines the relevant fixedness studies that must support the therapeutical substance and the medicinal product.


Methods of resolution used in the non-clinical advertisement supporting an application for marketing authorisation be under the necessity of be technically validated with the proof article in the appropriate tissue matrix. Applicants are required to excuse the selection of assays used instead of these studies and their specificity and sensitivity. In explore of the specific bioactivity of GTMP, non-clinical studies must be provided using appropriate pharmacologically to the purpose in vitro and in vivo models. The pick of a specific animal model be obliged to be considered and justified in conformity with the elements laid down in the make an outline of Guideline.

The draft Guideline provides characteristic reference to the various pharmacology studies that must be supported. Proof of universal studies could be demonstrated by in vivo and/or in vitro studies. The rough sketch Guideline recommends the use of of the same ratio animal models to explore potential biological movables if this could be considered good. A clear explanation of the investigational hatch to address the objectives of security pharmacology is required. This must hold the effects of both the transgene ~ion and the vector.

Pharmacokinetic studies new wine focus on the distribution, persistence, acquittal and mobilisation of the GTMP and consign the risk of germline transmission. Dosing used in biodistribution studies is required to contemplate clinical use. In cases where the unbroken vector or part of it is intended instead of integration in the host genome, this outline of the vector must be supported ~ the agency of integration studies. The relevant issues to that integration studies must demonstrate are supposing in the draft Guideline. The selection Guideline recommends integrating shedding studies into the design of biodistribution studies or other non-clinical studies in what place appropriate.

In terms of pharmacokinetic studies, the behaviour of in ~ degree relevant part of the GTMP be bound to be investigated. Assessment of toxicity must focus on the whole GTMP and the transgene issue. Genotoxicity studies could be required subject to the creation of the GTMP.


Clinical studies conducive to GTMP are required to reflect the same principles as for any other medicative product. A benefit-risk assessment of the be at hand of the GTMP must be submitted fronting existing treatments in the clinical overview for the re~on that part of the application for marketing authorisation. It is recalled that lengthy-term efficacy and safety follow-up of each advance therapy medicinal product is a charge, which is provided in Regulation (EC) No 1394/2007. The make an outline of Guideline emphasises the importance of far-seeing term monitoring of patients treated by a GTMP. Pharmacokinetic studies could subsist required in certain cases where the gene product is a product or another module piteous protein metabolism. In such a state, the following studies must be carried exhausted:

(a) shedding studies;

(b) dissemination studies; and

(c) pharmacokinetic studies of the medicinal product and the gene expression moieties.

Efficacy studies must be designed to;

(i) demonstrate virtue in the target population;

(ii) comfort the proposed posology; and

(iii) evaluate the continuance of the therapeutic effect of the GTMP.

In assured cases, a validated surrogate parameter because a clinical endpoint could be considered considered in the state of an acceptable alternative to endpoints. It is, though, required that a clinical endpoint is investigated in the extended term. A safety database must have existence established to include adverse events, which are subsequently connected to the transgene issue and/or to the vector or the transduction machinery. Clinical safety precautions are also defined at which place medical devices are used for the giving up or implant of a combined GTMP.

Interested parties entitled to supply observations on the draft Guideline take in the pharmaceutical industry, academia, and developers of GTMP. The meeting for deliberation period will remain open until 31 August 2015. Comments may be submitted using the template form by stipulation to advancedtherapies@ema.europa.eu.

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