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352
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
of genetic material which produces therapeutic proteins [4]. Typi­cally, this circumvents the restrictions related to the therapeutic use of recombinant peptides, including low bioavailability, clearance rates, and exorbitant production cost [5]. Tissue therapies aim to mend and restore injury to organs and tissues through the engi­neering of components involving cells and tissue architectures [6], combining cells from a patient with scaold biomaterials [7], which can potentially plug the severe shortage in donated organs. Cur­rently, there are over a hundred thousand potential recipients on the waiting list in the United States alone [8].
CTGTPs have been defined and classified dierently by various regulatory bodies, where a product will go through the regulatory pathway according to the definition that they fall under. In some countries, CTGTPs are also known as advanced therapy medicinal products (ATMPs) or regenerative medicines (RM). In other coun­tries, they may be further classified under categories such as cell therapy medicines, gene therapy medicines, tissue-engineered med­icines, or combined products, with dierent variations in naming the respective product categories. These definitions take into consid­eration the degree of processing from the starting materials as well as the purpose of the product, such as the restoration of function or prevention of disease, which determines the extent of regulation a product is subject to. However, there are also some countries where little or no regulations for CTGTPs exist.
With rapid progress and strong interest in CTGTPs, as evident from the increase in investments in these novel products over the last dec­ade [7], many challenges have also arisen. These come from a lack of knowledge regarding these novel products, where conventional modes of manufacturing and regulation have not been adequately adapted to ensure the safety and ecacy of CTGTPs. Considering
Cells, Tissues, and Gene Therapy Products
the lack of studies on CTGTPs, this article aims to juxtapose the characteristics of CTGTPs with conventional biologicals, where existing manufacturing trends from the latter will serve as a basis for proposing solutions to solve the challenges faced in manufac­turing and regulation. This article also aims to present the man­ufacturing processes and regulatory frameworks that CTGTPs are subjected to in dierent countries.
CTGTPs and their principles of action
Cell therapy products use cells to repair or replace injured tissue or cells in the body. Cells used may include mesenchymal stem cells (MSCs), T cells, and pancreatic islet cells [9]. Cell therapy products may contain only cells alone or exist as a part of gene therapy or tissue therapy.
353
These products can be further categorized according to autologous therapies or allogeneic therapies. Autologous therapies obtain cells directly from the patient, thus circumventing immune reactions. However, this also means that these cells are not suitable for use in mass manufacturing as ‘o-the-shelf’ products. In contrast, alloge­neic therapies utilize donated cells to treat multiple patients. These cells are collected from healthy donors, rather than directly from the patient to create a master cell bank (MCB). Consequently, the risk of immunogenic reactions is higher [16]. Products for gene therapies are manufactured via ex vivo or in vivo processes. An in vivo process is one where a viral vector carrying the gene of interest is directly transferred into the body via infusions, whereas an ex vivo process involves removing a patient’s cells to be altered and then re-infus­ing the genetically modified cells back into the patient’s body [17].
354
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
For tissue engineering, current strategies include recreating organ and tissue structure via scaold fabrication, 3D bioprinting and self-assembly, integration of grafts to host via vascularization and changing the host environment to create therapeutic responses [6].
Regulators often decide on the stringency of manufacturing require­ments by considering if the therapy product is intended for homolo­gous use, where the therapy product is administered at an identical anatomical site and fulfils the same function in the recipient as in the donor [1]. In addition, the extent of manipulation the cells or tissues have undergone is also considered, where minimal manipu­lation implies that biological traits or functions of the cell or tissue are unchanged [1].
Dierences between CTGTPs and conventional biologicals
The type of therapy has an immense impact on the type of manu­facturing style and challenges encountered. Conventional biologi­cals are biotherapeutic protein products made with recombinant DNA technology, where cells are reprogrammed genetically to pro­duce proteins that are insuciently produced in the body [10]. An example includes synthetic insulin for the treatment of diabetes and monoclonal antibodies for cancer treatment. The key dierence between conventional biologicals and CTGTPs is that while proteins are the final products in conventional biologicals, cells are the final products in CTGTPs. Cells can produce specific proteins continu­ously as compared to the fixed number of specific proteins, which may be degraded and thus depleted in the body. Hence, the cells can potentially allow for longer lasting or permanent prophylaxis.
Cells, Tissues, and Gene Therapy Products
In general, the manufacturing process for chimeric antigen receptor T (CAR-T) cell therapy products, one of the most common CTGTPs, involves steps to preserve the cells and focus on purifying specific target cells, while biologicals manufacturing involves an additional step of isolation and purification of the protein. Since cells are rela­tively more sensitive to their environment, a more stringent process in terms of the manufacturing environment must be in place to maintain the quality and safety of the CTGTP. Overall, cell ther­apy products are generally not as well characterized as compared to conventional biologicals, thus having dierent biomarkers in test­ing for ecacy.
Table 1 shows examples of the dierent types of products and how they work. Figure 1 focuses on the manufacturing process of CAR-T cell therapy product and conventional biologicals. Table 2 gives fur­ther details regarding the manufacturing, quality control storage and transport between CTGTPs and conventional biologicals.
355
Ocial definitions of CTGTPs
In general, most countries adopt a risk-based approach in deciding if a product is a CTGTP before subjecting it to licensing require­ments. In countries such as the United States (US), the European Union (EU), and South Korea, minimally manipulated and homol­ogous use products are not subject to marketing authorization. For CTGTPs which require marketing authorization, the extent of regulatory requirements depends on the type of products manufac­tured. Countries such as Singapore include minimally manipulated and homologous products under its definition of CTGTPs, and spe­cifically exclude other products of the same type, e.g. bone marrow,
Product
Product name
category How it works Ref.
Spherox Autologous
cell therapy product
Kymr ia h Autologous
cell-based gene ther­apy product
Zolgensma In vivo gene
therapy product
Vergenix™FG Tissue engi-
neered ther­apy product
Table 1: Examples of products and their mechanism of action
Spherox (Co.Don AG) is a product used to fix defects in the knee cartilage.
It contains spheroids of chondrocytes, derived from MSCs, and found in healthy cartilage. A sample is extracted from the patient’s own tissues via arthroscopy, cultivated in the laboratory to form a suspension of chon­drocyte spheroids and then reintroduced into the patient’s cartilage. The chondrocytes then attach to the cartilage to fill the defect
Kymriah (tisagenlecleucel) is indicated to treat of refractory B cell precursor
acute lymphoblastic leukemia (ALL). The patient’s T cells are genetically modified by introducing deoxyribonucleic acids. These modified T cells express chimeric antigen receptors (CARs), which facilitate the targeted killing of CD19+ B cells by binding to them while stimulating the prolifer­ation of the CAR-T cells. These CAR-T cells are dubbed a living drug as they continue to exist in the body to fight cancer long after their infusion
Zolgensma (onasemnogene abeparvovec) is a one-time intravenous infusion
indicated for the treatment of spinal muscular atrophy (SMA) due to genetic alterations in the SMN1 gene. The therapy replaces the missing/defective SMN1 gene with a new copy of the SMN gene using the AAV9 virus carrier
Vergenix™FG is indicated for the management of acute and chronic wounds,
such as diabetic and pressure ulcers, and surgical wounds Vergenix™FG provides a scaold for cellular and capillary growth and is supplied as a lyophilized material contained in a syringe
356
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
[11]
[12],
[13]
[14]
[15]
Cells, Tissues, and Gene Therapy Products
Comparison of Manufacturing Processes for CTGTP and Biological Product
357
CTGTP (CAR-T-Cell)
Apheresis collection
Apheresis product wash/fractionation
T-cell selection
T-cell activation
Viral vectors, transposons, mRNA electroporation
Gene transfer
CAR-T cell expansion
CAR-T cell formulation
CAR-T cell cryopreservation
Infusion into patient
Biological (Therapeutic Protein)
Isolation of gene of interest
Introduction of gene to expression vector
Transformation into host cells
Cell banking system master cell bank,
working cell bank
Selection of the required sequence & propagation of cells
Extraction (lysis), clean-up, enrichment/isolation of protein
Downstream Upstream
Isolation & purification of protein
Formulation, packaging of protein product and QC
Sterilization, viral decontamination, pyrogen removal
Figure 1: Comparison of manufacturing process between CTGTP (CAR-T cell) and biological (therapeutic protein) [18, 19]
CAR-T: chimeric antigen receptor T; CTGTPs: cell, tissue and gene therapy products; mRNA:
messenger ribonucleic acid; QC: quality control.
peripheral blood, cord blood and vaccines, without further classify­ing them as CTGTPs. Other countries such as China and India have no formal definitions for CTGTPs.
Table 3 states the definitions and classifications by the US, EU, Aus­tralia, Japan, China, India, Malaysia, Thailand, Singapore, South Korea, the World Health Organization (WHO) and the Interna­tional Council for Harmonization of Technical Requirements for Pharmaceuticals for Human Use (ICH). These countries have been chosen to represent a heterogeneous regulatory environment with diering levels of capacity and maturity.
358
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
Manufacturing of CTGTPs
In the manufacture and commercialization of CTGTP, two main modes of manufacturing styles exist. Decentralized manufacturing spreads production over dierent locations, allowing for a more amenable response to demands [41]. An example of a decentralized manufacturing process is the integration of good manufacturing practice (GMP) facilities into a hospital setting to produce autolo­gous therapies for patients. However, certain risks are associated with this model, including diculty in quality control due to a lack of central oversight and contamination risk [42]. On the other hand, centralized manufacturing has been the prevalent way of manufac­turing as it enables an economy of scale, due to well-established processes and machinery to produce large, standardized batches of the same product at a single location [41]. Some examples include chemical drugs, allogeneic products and biologicals. However, this characteristic makes it dicult for manufacturers to customize products for specific patients. Currently, centralized manufactur­ing is utilized for licensed CTGTPs such as Kymriah (Novartis) and Yescarta (Gilead), with a substantial interest in moving towards decentralized manufacturing for autologous products at the point of care [8]. The advantages and disadvantages of the manufacturing methods will be further discussed in the subsequent sections.
As mentioned, the unique nature of CTGTPs as compared to con­ventional biologicals makes the manufacturing of safe and eca­cious CTGTPs a challenge. So far, there has been a clear distinction between manufacturing for product development and conducting clinical trials for academic research, with the former taking place in pharmaceutical companies and the latter in hospitals. However, in recent developments, personalized CTGTPs have demanded a higher
Cells, Tissues, and Gene Therapy Products
involvement of hospitals in the development of CTGTPs due to their manufacturing process [20], which must be near to the patient due to the sensitivity of the product, thus necessitating hospital prem­ises to be of GMP standard. The problems of quality control in cell therapies produced in the academic setting and industry, coupled with strict regulations and diculty in harmonizing a standard­ized manufacturing process, hinder the availability of treatments to patients [43] through manufacturing process challenges.
The manufacturing process of CAR-T cells is shown in Figure 2. Peripheral blood mononuclear cells are first collected from the patient via leukapheresis. This is followed by T-cell selection, remov­ing adulterants such as gross red blood cells and platelets, while simultaneously enriching T cells [18]. The T cells are then activated using technologies involving antibody-coated nanobeads before being transduced with a viral vector, which contains the anti-CD19 CAR transgene. The T cells are then expanded in bioreactors to pro­duce doses for sucient therapeutic eect. Finally, the T cells are removed from the beads, washed, cryopreserved in infusion bags, and tested for the critical quality attributes of the product before it is released and thawed for infusion into the patient [44].
359
In the case of tissue engineering and regenerative medicine (TERM) therapies, multiple types of materials are required to come together. As such, the manufacturing workflow is dierent for each compo­nent, including cells, scaolds or bio-printed therapies. The man­ufacturing workflow for cells is as shown in Figure 2, whilst the manufacturing workflow for scaolds and bio-printed materi­als are shown in Figure 3. Bioprinting involves the fabrication of three- dimensional anatomical structures to be used in therapies [45] and in in vitro models since they can be engineered to mimic
Table 2: Comparison of manufacturing, quality control, storage and transport between CTGTPs and conventional biological
Biologicals Autologous CTGTP Allogeneic CTGTP Comments Ref.
Sterility Sterility assurance
through aseptic
processing involving
protein products
Closed/open
system
Batch Scale; Batch
number
Stability in
processing
(between batch/
final product)
Stability of
product
(expiration
time)
QC test methods Relatively well established Less well established Both biologicals and CTGTPs may require
Closed Closed There is a move towards automated, closed sys-
Large batch scale;
Multiple
Relatively stable and
uniform
A few days to a month
(after reconstitution)
Sterility assurance through aseptic pro-
cessing involving live cells. All starting
materials and processes must be sterile
Individual patient
basis; Single
Cells are non-robust and sensitive to
environment
A few hours [21]
Small batch scale;
Multiple
Live cells are unstable under heat, radiation, or
chemicals. They also need to be manufactured
aseptically with sterile filtration. Inadequate
time to complete sterility tests due to short
shelf life/ urgent medical need
tems to reduce variability of both biolog icals
and CTGTPs
Ty pic al ly, allogeneic therapies utilize scale-up
approaches while autologous therapies utilize
scale-out approaches
For biologicals, substitution and chemical
modification of protein or cha nging solvent
properties may improve stability of product
without compromising activity
new and specific quality control testing
methods
[20]
[20]
[20] ,
[21]
[20]
[20]
360
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
QC sampling
strategy
Purification Protein structure may
No minimum sample
volume
be altered during
elution steps Rapid
purification necessary
to prevent cleavage by
protease released by
lysed bacteria.
Elimination of residual
DNA (from hybridoma
of mammalian cell) is
required
Minimum sample volume The test results from minimum sample volume
for quality control may not accurately reflect
the properties of the batch. Reference samples
are not required to be retained due to the
small quantities of final CTGTP manufactured
for use by patient(s)
Vec tor s:
Dicult to separate vectors that have
taken up genetic material from those
that have not, or f rom empty capsids,
due to similar measurable biophysical
properties
Due to larger size, vectors also diuse
more slowly than proteins and hence
bind to bead surfaces of solid-phase base
chromatog raphy rather than diuse
into pore
Technology for the separation of cells:
Magnetic-Activated Cell Sorting
(MACS): separates cells via a single
surface antigen Fluorescence-activated
cell sorting (FACS): separates cells via
multiple sur face markers
Purification methods may aect transduction
ability, infectivity, and structural integrity.
Impurities can potentially cause immunogenic
reactions. The presence of empty capsids can
also reduce the therapeutic dose
Target cells may share common cell surface mark-
ers, necessitating multiple separations, leading
to decreased throughput and increased cost
The throughput of FACS is too low to achieve
manufacturing-scale quantities and is dicult
to integ rate into aseptic, closed systems
[20]
[18],
[19],
[22],
[23]
Cells, Tissues, and Gene Therapy Products
(Continued )
361