cancer immunotherapy: regulatory implications … with the immune response against specific caner...
TRANSCRIPT
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Pharmaceuticals and Medical Devices Agency
6 February 2015
Daisaku Sato, Ph.D.Director, Office of Cellular and Tissue based ProductsPharmaceuticals and Medical Devices Agency, Japan
DISCLAIMER : The contents of this presentation represent the view of this presenter only, and do not represent the views and/or policies of the PMDA
Cancer immunotherapy: Regulatory implications in Japan
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
CONTENTS
• PMDA’s Policy and Trend• R&D and approvals of cancer immunotherapy products
• Perspectives on cancer immunotherapy review (micro & micro)
• Accelerated Developing Programs (CMC Consideration)
• New Regulations for Cellular and Tissue‐based Products (incl. immuno‐cell therapy)
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Pharmaceuticals and Medical Devices Agency
2
Kansai Branch
Scientific Review for Drugs & Medical Devices
GCP, GMP Inspection Consultation on Clinical Trials Safety Measures Relief Services
Major Services
Unique Three‐pillar System Securing Nation’s Safety
Safety
Review
Relief
Japanese citizens
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
GlobalizationShortening the time to approvalHigh quality review/consultation services
Accelerated review process
(Improvement of approval predictability)
Advanced Review/Consultation System
Human Resources with excellent skills (751 staffs →1065 staffs)
Enhancing Enhancing safety
measures
Goal
•Activation of industry•Extending health and life span of Japanese people•Contribution to global medicine
consultation service
Drastic improvement of consultation service
•Improvement of pharmaceutical affairs consultation service on R&D strategy
•Improvement of clinical trial consultation service
Improvement of prior assessment
(substantial acceleration of approval review process)
Introduction of approval system with condition/ period for Regenerative Medicines
Readiness for introduction of
RMP•Development of Japan’s original innovative drugs and medical devices•Marketing of cellular and tissue‐based products
Utilization ofmedical inf. database
3rd 5‐year mid‐term Plan of PMDA (FY2014‐2018)Major challenges
Specific measures
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Accelerating Review Period
Target Period
Percentile Total Review Period2013 2014 2015 2016 2017 2018
Standard 50 60 70 70 80 80 12mo.Priority 50 60 60 70 70 80 9 mo.
6.7 6.4 5.1 4.2 4.6
10.57.6
6.3 5.7 6.7
19
16
12 12 12
92 9280 81
96
0
20
40
60
80
100
0
5
10
15
20
FY2009 FY2010 FY2011 FY2012 FY2013
6.4
3.4 2 1.53.8
3.6
4.94.2 3.8
3.6
1110
9 9 9
1520
50 53
42
0
10
20
30
40
50
60
0
2
4
6
8
10
12
FY2009 FY2010 FY2011 FY2012 FY2013
Total Review Period New Drug (Standard) (Priority)(mo.) (mo.)(No.) (No.)
Number of applicant
RegulatoryApplicant
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
319256
648
521
678
605
753
341
426
291
708
1065
PMDA Staff Size
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Paradigm shift of immunotherapy
•Conversion from old fashioned products (ex. BCG vaccine, interferons) to molecular target based medicines, gene‐cellular products
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Approval of nivolumab in July 2014
• Nivolumab was received orphan drug designation in Japan and is indicated for treatment of radical unresectable advanced or recurrent malignant melanoma patients of chemotherapy history (including dacarbazine)
• Approval was based on Phase II study conducted in Japan : ORR [90% CI](RECIST) : 22.9%[13.4%, 36.2%]
• Response rate of nivolumab exceeded reference threshold response rate of (12.5%), which was set on the basis of the clinical trial results of traditional dacarbazine.
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Foreign clinical trials(Phase III) of nivolumab
CheckMate ‐037• Phase 3 randomized, controlled open‐label study of Opdivo (nivolumab), versus investigator’s choice chemotherapy (ICC) in patients with advanced melanoma who were previously treated with Yervoy (ipilimumab).
• Based on a planned interim analysis of the co‐primary endpoint, the objective response rate (ORR) was 32% (95% CI = 24, 41) in the Opdivo arm (n=120) and 11% (95% CI = 4, 23) in the ICC reference arm (n=47) in patients with at least six months of follow up.
• ORR was based on RECIST criteria as evaluated by an independent radiologic review committee (IRRC). (ESMO 2014 Congress in Madrid BMS社 Sep 2014 より引用)
CheckMate ‐066• A randomized blinded comparative Phase 3 study evaluating nivolumab versus
dacarbazine (DTIC) in patients with previously untreated BRAF wild‐type advanced melanoma was stopped early because an analysis conducted by the independent Data Monitoring Committee (DMC) showed evidence of superior overall survival in patients receiving nivolumab compared to the control arm.
• The trial enrolled 418 patients who were randomized to receive either nivolumab 3 mg/kg every two weeks or DTIC 1000 mg/m2 every three weeks. The primary endpoint was overall survival. Secondary endpoints included progression free survival and objective response rate.(BMS社 release 資料 June 2014)
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices AgencyAs of September 1, 2013
No. of a
pproved recombina
nt protein produ
cts
0
40
60
70
80
90
100
1985‐2000 1985‐2013
Enzymes, 11
Coagulation factors, Albumin, 6
Hormones, 25
Vaccines, 4Interferons, 7EPOs, 5Cytokines, 8
mAbs, Fusion proteins, 28
10
20
30
50
mAbs & Fusion proteins account for more than 25%
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Pharmaceuticals and Medical Devices Agency
TcTc
TcCTL
Dendritic cellsCross-presentation
MHC Class1
MHC Class2MHC Class1
TAA-peptide
TCR
TCRTCR
Cancer
Anti-Cancer Immunotherapy
Naïve CD4
CD4+Cell
DCs
TAA(tumor-associated antigen) Peptide/protein
Virus vector (AdV, Vaccineavirusetc.)
Cellular vaccine (Irradiated Cancer cells with TAA)
TAA primed Dendritic cells (DC)
Idiotype antibody (TAA)
TAA DNA vaccine
Although the target of each category of product varies, common challenges on evaluating safety and efficacy of immunotherapy lay in the characteristics of immunotherapy modulating immune cellular system.
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Range of Cancer immunotherapy related Clinical Trials
• At this point, we have not observed a clinical anti‐tumor effect associated with the immune response against specific caner antigen.
11
As of January 2015
0
200
400
600
800
1000
1200
1400
peptide cell therapy Dentritic cell antibody Gene therapy DNA vaccine
Protocol numer for cancer vaccines
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Cancer Immunotherapy products to be developed for clinical application• Immuno‐checkpoint modulators
• PD‐1/PD‐L1 antibodies Nivolumab (Ono/BMS) Approval : JP =July 2014, US=Dec. 2014 Pembrolizumab (MSD) (US breakthrough therapy designated )
• CTLA‐4 antibodies ipilimumab (BMS) Approval : US=March 2011, JP= ?
• ? CCR‐4 antibodies ? Mogamulizumab (Kyowa‐Kirin) Approval : JP=March 2012
• others
• Peptide cancer vaccine• some peptide cocktails under clinical trials
• Immuno‐cellular therapy• T‐cell activation, TCR, CAR ‐gene induction
CTL019 (Novartis)(US breakthrough therapy designated )
• Dendritic cell activation autologous cellular immunotherapy “Provenge “(indicated for advanced prostate cancer )
approval : US=April 201012
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Review Regulations in Japan
• Antibodies (immuno‐checkpoint modulators)• Peptide vaccines
Regulated as “drug”• Processed cells (engineered T‐cells, Dendritic cells)
Regulated as “regenerative medical products”= ATMPs of EU regulation
An immunotherapy related product won’t alter the way of review and IND process from reviewers perspective.
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices AgencyAs of November 1, 2014
Office of Standards and Guidelines Development
Office of Vaccines and Blood Products
Offices of OTC/Quasi-Drugs
Office of Conformity Audit
Office of Regulatory Science
Office of Review Administration
Office of Review Management Director of Center forProduct
Evaluation
Associate Center Director
Associate Executive Director
Chief Executive
Office of Cellular and Tissue-based Products
Principal Senior Scientists
AuditOffice
Deputy Center Director (for Medical Devices)
Offices of New Drug I-V
Auditor
Auditor
Deputy Executive Director
Executive Director
Offices of General Affairs / Office of Financial Management / Office of Planning and CoordinationChief Management Officer
Chief Relief Officer
Chief Actuary
Office of Manufacturing/ Quality and Compliance
Offices of Safety I, II
Kansai Branch
Information Technology Promotion Group
Chief Safety Officer
Associate Center Director
Deputy Center
Director(for Cellular and Tissue-
based Products)
Senior Scientists
Associate Executive Director
Associate Center Director
Associate Center Director
Associate Executive Director
Offices of Medical Devices I-III
SeniorExecutive Director
Executive Director
Office of Relief Funds
Advanced Review with Electric Data Promotion Group
Office of International Programs
International Coordination/Liaison Officers
Office of Generic Drugs
Organization of PMDA
Associate Executive Director
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Micro‐perspective :review of cancer immunotherapy products
Cancer drug review philosophy and process won’t change, but will discuss some specific points, considering the natures of immunotherapy
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Cancer Immunotherapy related guidelines/guidance for development and review(including peptide vaccines, cellular therapies)
• US FDA• Potency Tests for Cellular and Gene Therapy Products (2011.01)• Clinical Considerations for Therapeutic Cancer Vaccines(2011.10)• Preclinical Assessment of Investigational Cellular and Gene Therapy Products(DRFAT 2012.11)
• Considerations for the Design of Early‐Phase Clinical Trials of Cellular and Gene Therapy Products (DRAFT 2013.07)
• Clinical Considerations for Therapeutic Cancer Vaccines(draft)(2009.9)
• EU EMA• GUIDELINE ON POTENCY TESTING OF CELL BASED IMMUNOTHERAPY MEDICINAL PRODUCTS FOR THE TREATMENT OF CANCER (2007.10)
• In Japan• Cancer therapeutic peptide vaccine guidance(2012.12 rev.) (Japan Society for Biological Therapy)
• Cancer Immunotherapy Guidance 2014 (early clinical trials consideration) (under development ) under the auspice of Ministry of Health, Labour and Welfare.
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Development of Cancer immunotherapy guidance
○ MHLW funded and contracted guidance development project to the leading academic research institutions since 2012 for appropriate and expedited R&D in regulatory point of view.
○ Beyond the “drug lag” issue, aiming at developing Japanese originated advanced medical technologies, toward the first clinical application in the world.
○ Cancer Immunotherapy Guidance 2014 draft has been developed for early clinical trial consideration and is to be submitted to MHLW
○ Guidance for CMC, Guidance for pre‐clinical study and Guidance for late clinical trials will follow.
Contract research organization : Prof. Dr Hiroshi Shiku, Mie University Hospital
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Pre‐clinical Discussions• To perform pharmacology (on target) studies, testing on tumor growth inhibitory effects, preclinical safety (off target) studies….
• Consider the species differences related to immune response (MHC) in the animal texting, using human cellular products, humanized antibody
• In‐vitro immunogenicity assay using human cells? Toxicity studies in animals close to human?
• Encourage to set up animal modeling to mimic the human mode of action
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I will just echo the challenges raised by other regulatory speakers
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
ORR discussion in early clinical trials
• RECIST criteria has been used for CR, PR, SD, PD in diagnostic imaging for assessing tumor shrinkage.
• When delayed effect is observed, how should we accommodate ORR?
• Is IrRC valuable and usable in the routine clinical trials for assessing immuno‐therapeutic substances and cells, instead of RECIST?
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Late phase clinical trials• Confirmatory trials (Phase III)
• Comparative efficacy with standard care, placebo (Same principle as conventional chemotherapy)
• Efficacy Endpoint (Same principle as conventional chemotherapy)
Hard endpoint such as overall survival (OS) should be recommended. (PFS will also be considered like conventional chemotherapy)
• Statistical test MethodDiscussion on taking into account of Delayed response(Wilcoxon test? Application of Harrington-Fleming?)
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
FDA’s guidance
“In general, time‐to‐event endpoints are measured from the time of randomization. Due to delayed effect of the vaccine, the endpoint curves of the trial results may show no effect for the initial portion of the study. If the treatment is effective, separation of the curves may occur later in the study after the vaccine effect has become established. This may violate the proportional hazard assumptions necessary when applying Cox modeling and may necessitate an increase in sample size to provide sufficient power to test a statistical hypothesis.”
(FDA: Clinical Considerations for Therapeutic Cancer Vaccines(draft)(2009.9)
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Successful combination therapy strategy
Ref. Wolchok JD. Et.al. Nivolumab plus Ipilimumab in Advanced Melanoma. NEJ Med 2013, 369: 122‐33
Higher ORRs were reported in combination of CTLA‐4 : ipilimumab and PD‐1 : nivolumab
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Potential combination therapies• Some Inter‐company co‐development programmeshave already been on‐going
• Conventional course of development: Individual safety assessment in Phase 1 Combined safety assessment in Phase 1 Discussion : If MOAs of two NMEs are different, can they can be exempted?
Justification of dosing of each drug product should be demonstrated in Phase 2
• Do we need to apply a new strategy for development or pursue the conventional process (for particularly dosing)?
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Macro‐perspective : review of cancer immunotherapy products
• In the oncology area, promising new products are awaited, including novel immunotherapy in the future.
• In response to the demand of access, regulators are streamlining review process of such products.
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
To what extent probability of effectiveness is to be pursued before Marketing authorization?
For :• A new product for life threatening disease, which is affected by the timing of access
• Breakthrough therapeutics for present unmet medical needs, longing for treatment, while paying particular attentions to the safety
Question is “What is the socially and scientifically acceptable level of effectiveness for approval?”
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Benefit and Risk Balance Assessment
•Discussion of acceptable level of clinical effectiveness vs. patient access to the new therapy
•Weighing acceptable risk against expected benefit
•Based on regulatory sciences in terms of social responsibility for pubic health
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Early Access schemes of ICH 3 parties
US EU JAPAN
Priority Review Priority reviewAccelerated approval forserious or life‐threatening illnesses
Conditional MAMA under exceptional circumstances
Approval forOncology drug, Orphan drug
Conditional & Time‐limited approval for
regenerative medicine Break through therapy& Fast Track designation
Pilot Project on Adaptive Licensing
Forerunner Review Assignment
Various agencies have various approaches to accommodate patient access.
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Pharmaceuticals and Medical Devices Agency
US Accelerated Approval
Phase IIIPhase IIIPhase IIPhase IIPhase I
28
ReviewReview
Accelerated approval
ConfirmedEffectiveness
Phase IV
Withdrawal
• To approve products based on the limited data, such as surrogate endpoints in exploratory study.
• It applies to certain new drug products in treating serious or life‐threatening illnesses and that provide meaningful therapeutic benefit to patients over existing treatments.
• Approval based on a surrogate endpoint or on an effect on a clinical endpoint other than survival or irreversible morbidity.
• The drug product has an effect on a surrogate endpoint that is reasonably likely to predict clinical benefit or on the basis of an effect on a clinical endpoint other than survival or irreversible morbidity..
• Approval will be subject to the requirement that the applicant study the drug further, to verify and describe its clinical benefit (such as OS).
• Postmarketing studies would usually be studies already underway. • FDA may withdraw approval, if a postmarketing clinical study fails to verify clinical benefit; ………….
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Revised guidelines for clinical evaluation of anti‐malignant tumor agents1 November 2009 MHLW ELD Notification No. 1101001
Principle
• Clinical benefit is investigated mainly with survival data in Phase III studies. When an agent is indicated for commonly occurring cancer, submission of Phase III study data, which mainly evaluate survival, is essential for the approval application.
• If clinical development if an anti-malignant tumor agent is in progress abroad, utilisation of foreign study data should be considered and a clinical development plan should be drawn referring to ICH E5 so that the development in Japan will be fast.
Exemption
• If the number of patients indicated for the treatment is considerably limited with a scientific justification, this does not apply.
• If the agent is applicable to an orphan medicinal product (Article 77-2 of PAL), it is possible to conduct a clinical study with the limited number of the available subjects.
• If there is an adequate reason for expecting a superior clinical benefit at the end of Phase II studies, it is possible to make an application before Phase III data become available and to obtain an approval. Within certain period of time, the clinical benefit and appropriateness of Phase II approval need to be verified with Phase III data.
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Pharmaceuticals and Medical Devices Agency
Current situation of adaptive licensing in Japan‐US‐EUMore in the future?
Japan
Overseas
Phase IPhase II
Phase I Phase II PM commitment
Phase IIIPhase IIIForeignPhase IIForeignPhase II
ForeignPhase I
LocalPhase I
LocalPhase II
30
ReviewReview
ReviewReview
Accelerated approval
Approval with condition (Postmarketing commitment) under Article 79 of PAL.
Crizotinib is one of the examples of PII approval with PM commitment of Phase III study
ConfirmedEffectiveness
・ Superior clinical benefit at Phase II study
・ Orphan designation applicable
Orphan drug designation is not difficult process for oncology field (except for cytotoxic substances) as long as rational explanation is made to scope the type of carcinoma, based on its expected effect.
Phase III
Withdrawal
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Pharmaceuticals and Medical Devices Agencyhttp://www.mhlw.go.jp/english/policy/health‐medical/pharmaceuticals/140729‐01.html
Forerunner Package Strategy(Sakigake)
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Pharmaceuticals and Medical Devices Agency
Designation Criteria
Medical products for diseases in dire need of innovative therapy and satisfies the following two conditions:1. Having developed firstly in Japan and anticipating an application
for approvals (desirable to have PMDA consultation from the beginning of R&D)
2. Prominent effectiveness (i.e. radical improvement compared to existing therapy), can be expected based on the data of mechanism of action from non‐clinical study and early phase of clinical trials (phase I to II)
Forerunner Review Assignment System is a system to put innovative medicines/medical devices/regenerative medicines originated from Japan into practice.
Not limited to life-threatening and regenerative medicine
Forerunner Review Assignment System (Sakigake)
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Pharmaceuticals and Medical Devices Agency
• Shorten review time, using rolling submission of data as “prior review” during P‐III
• Similar to break through therapy designation of USFDA• Come Into effect in early 2015
1 month
6 months
Priority Review
strengthening post‐marketing safety
【Review under FORRUNNER SCHEME】
Non‐clinical research/
Clinical research
Clinical Trial
Phase I/II
Consultation on Clinical
Trial
Clinical Trial Phase III
Consultation Forerunner Assignment
Prior Review(rolling submission) Review
reimbursement
Post‐Marketing
※May accept Phase III data during review, depending on conditions
Designation Advantage
Review ahead of schedule
General Timeframe of Forerunner Review Assignment
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Pharmaceuticals and Medical Devices Agency 34
Overall picture of CMC development
Non-Clinical Study
【Typical Development】
Establishment of Design Quality and Product Quality by CMC study
Clinical Study
Phase 1 Phase 2 Phase 3
Investigational Product GMP GMP
Post-Approval
Control strategy Control strategy Control strategy
Process Parameters CPP
CQAQuality Attributes
Knowledge Control/Quality Risk Management
Control Strategy
EquivalencyConsistency
Target product Profile
Process ValidationProcess
Validation
Approval
Accelerated approval review
timeline
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Product Quality Review
Report of Research and Development
Process Validation
Overall picture of CMC activities through the product life cycle
Cycle that connects development and commercial production
Commercial Production Development
TechnicalTransfer
Knowledge
QualityImprovement
Process Research
Post‐approval change
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
In case of immune cell therapy development in Japan
New regulations for cellular and tissue based products (“regenerative medical Products”) will be applied.
36
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
New Legislative Framework
These two acts were promulgated in November 2013 by the Japanese Diet (Parliament) in line with the Regenerative Medicine Promotion Act, in order to reform the pharmaceutical and medical regulation related to regenerative medicine
• Revision of the Pharmaceutical Affaires Law: The Pharmaceuticals, Medical Devices, and Other Therapeutic Products Act (PMD. Act)
• The Act on the Safety of Regenerative Medicine
Other related governmental policy:• Healthcare and Medical Strategy Promotion Act (2014.5)• Japan Medical Research Development Institution Act (2014.5)
These two acts were enacted on 25 November 2014
37
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Two Acts regulating regenerative medicine & cell therapy
38
Regenerative Medicine
All medical technologies using processed cells which safety and
efficacy have not yet been established
The Act on Pharmaceuticals and Medical Devices (PMD Act)*
* Two laws will be enacted on 25 November 2014
Production and marketing of regenerative and cellular therapeutic
products by firms
The Act on the Safety ofRegenerative Medicine
It may be similar to Hospital exemption system of thr EU
MHLW process PMDA process
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Definition of “Regenerative Medical Products” in Japanese Legislation
• Regenerative medical products are defined as processed cells that are intended to be used 1) for either (1) the reconstruction,repair, or formation of structures or functions of the human body or (2) the treatment or prevention of human diseases,or 2) for gene therapy.
Cellular and Tissue based Products and Gene therapy Products
Under the Revised PAL (=Pharmaceuticals and Medical Devices Act. (PMD Act.) )
=. .
=. .
Advanced‐therapy medicinal products (ATMPs) Regulation (EC) No 1394/2007
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
The Pharmaceuticals and Medical Devices Act (PMD Act)
Difficult to gather and evaluate the data for efficacy of regenerative medical products in a short time due to heterogeneity of cells
Separate category and definition of “regenerative medical products”
Expedited approval system for regenerative medical products
To secure timely provision of safe regenerative medicines,a new regulatory framework is needed
After the safety is confirmed and the results predict likely efficacy, the product will be given conditional, time‐limited marketing authorization in order to enable timely provision of the products to patients.
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
How to expedite R&D and review for cellular and tissue based product
• Designed for unmet needs under the present treatment: limited number of patients available for CT
• Difficult to conduct controlled study to demonstrate “true end point” of clinical benefit
• Heterogeneity of Quality affected by source materials
Would it take long time for CTs and review if regulator pursues the conventional drug pathway too much?
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Phased clinical trials(confirmation of efficacy and safety)
Marketing authorizati
on
Clinical study
[New scheme for regenerative medical products]
Post‐marketing safety measures must be taken, including prior informed consent of risk to patients
Marketing(Further confirmationof efficacy and safety)
Conditional/term‐limited authorization
Clinical study
Marketing authorization
or Revocation
Marketing
Marketing continues
Expedited approval system under PMD Act
Clinical trials
(likely to predict efficacy,
confirming safety)
[Traditional approval process]
< Drawback of traditional PAL approval system >Long-term data collection and evaluation in clinical trials, due to the
characteristics of cellular/tissue-based products, such as non-uniform quality reflecting individual heterogeneity of autologous donor patients
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Pharmaceuticals and Medical Devices Agency
Final Products
Intermediate(s)
Cell Bank
Cell Line
Somatic Cells/Stromal CellsSelection of Cells that are Suitable for Reprogramming etc.
Relevant Pluripotency to Differentiate into the Target Cells, Potency of Self‐Renewal
Potency of Differentiation to Next Target Cells, Potency of Self-Renewal, Stability
Relevant Cells Can Be Processed (e.g. differentiate).to Desired Product
Evaluation ofQ/S/E
Characterization、
Constant Supply, Stability&Renewal
Inactivation and/or Elimination of Un‐differentiated Cells
Serving Innovative treatments for Sevier Diseases, Marked loss of QOL or Lack of
Existing Relevant Therapies
Characteri-zation,Stability
Source,BiologicalFeaturesBiological 43
Cellular product specific quality considerations
I will just echo the challenges raised by other regulatory speakers
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Pharmaceuticals and Medical Devices Agency
Consultation System at PMDA
PI Study
Approval
PIII StudyPIIb StudyPIIa Study NDA REVIEW
Consultation Minutes
Pre-PI Pre-NDAPre-PII End-of-PII
pre-clinical
IND
Prior assessment consultation
Clinical trial consultation System at PMDA
4
support
Clinical trial consultations contribute to streamlining and expediting the expected review process of PMDA. Some critical points to be looked into during the expected review are shared with the consultation sponsors in advance, e.g. : • clinical endpoint justification in the PII & PIII studies, • number of subject population for that endpoint with statistical robustness, • dosing for Japanese in case of different Japanese/western tolerability, etc.
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Pharmaceuticals and Medical Devices Agency
Outcome of the PMDA Science Board
Cellular & Tissue-based Products Current Perspective on Evaluation of Tumorigenicity of Cellular and
Tissue-based Products Derived from iPSCs and iPSCs as Their Starting Materials (Aug. 21, 2013)
Pharmaceuticals, Biologics Summary of Discussion on Non-clinical Pharmacology Studies of
Anticancer Drugs (Dec. 10, 2013)
Summary of the discussion on assessment of the current status of personalized medicine relating to drug development and review (Mar. 11, 2014)
The Science board outcome is to be contributed to resolve questions expected in the scientific consultation during development.
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Pharmaceuticals and Medical Devices Agency
Pharmaceutical Affairs Consultation on R&D Strategy
Practical Use
Innovative Products
Basic ResearchPharmaceuticals and
Medical Devices candidates
Non-Clinical Study
Quality Study
Clinical Trial
Valley of Death -Shortage of funds, Knowledge on Regulation and developmental strategy
(Up to POC studies)
* Further studies are handled by the Regular Consultation
Consultation on quality and battery of pre‐clinical, including examining tumorigenicity,
biological ingredient safety
Consultation on endpoints or sample
size of early clinical trial
Strategic Consultation
Introductory Consultation(744)
Pre‐Consultation(900)
Face‐to‐Face Consultation(258)
Flow of Strategy
Consultation (7/1/2011 – 9/30/2014)46
For small biotech companies and academic research organizations
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Pharmaceuticals and Medical Devices Agency 47
International Collaboration(Win‐Win Relationship)
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
and more…
Abbreviation Official NameSummit International Summit of Heads of Medicines Regulatory Agencies ICH International Conference on Harmonization IMDRF International Medical Device Regulators Forum PIC/S Pharmaceutical Inspection Convention and Pharmaceutical Inspection
Co‐operation SchemeHBD Harmonization By DoingICDRA International Conference of Drug Regulatory Authorities APEC LSIF RHSC APEC Life Science Innovation Forum Regulatory Harmonization Steering
CommitteeOECD MAD OECD Mutual Acceptance of DataPDG Pharmacopoeial Discussion Group IGDRP International Generic Drug Regulators PilotICMRA International Coalition of Medicines Regulatory Authorities
Global ActivitiesICH
APEC LSIF RHSC
Summit
PDG IDGRP
PIC/S
OECD
IMDRF HBD ICDRA
ICMRA
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Pharmaceuticals and Medical Devices Agency
PMDA and the World
PMDATokyo & Osaka, JapanFDA, US
CFDA, China
Confidentiality Arrangement
Resident Staff Joint SymposiumMemorandum of Understanding (MOU)
Health Canada,Canada
ANVISA, Brazil
EMA(EU)
TGA, Australia
NADFC, Indonesia
TFDA, ThailandIMB,
IrelandMHRA, UK
ANSM, France
Swissmedic, Switzerland
AIFA, Italy
• MOU between the Chinese SFDA (present CFDA) and the Japanese MHLW, under which PMDA supports cooperative activities• ** MOU concluded between Interchange Association and East Asia Relations Commission, but is being implemented through
cooperation of related organizations.
*
HSA, Singapore
Taiwan FDA, ** Taiwan
CBG‐MEB,Netherlands
(forth coming)
Regular oncology sector teleconference among FDA,
EU, CA and PMDA
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Pharmaceuticals and Medical Devices AgencyPharmaceuticals and Medical Devices Agency
Thank you for your attention
Daisaku Sato, PhD.Director, Office of Cellular and Tissue‐based ProductsPharmaceuticals and Medical Devices Agency (PMDA), Japan
sato‐[email protected]
50
Regenerative medicine literature available in English Hara A. Sato D. Sahara Y. New Governmental Regulatory System for Stem Cell–Based Therapies in Japan. Therapeutic Innovation &
Regulatory Science. 2014; 48(6): 681‐688.
Special thanks to our staff members!