Добавил:
kiopkiopkiop18@yandex.ru t.me/Prokururor I Вовсе не секретарь, но почту проверяю Опубликованный материал нарушает ваши авторские права? Сообщите нам.
Вуз: Предмет: Файл:
Ординатура / Хирургия / Библиотека им академика М.И. Перельмана / Книга_5855_Библиотеки_им_академика_М_И_Перельмана.pdf
Скачиваний:
0
Добавлен:
30.08.2026
Размер:
45 Мб
Скачать
Expedited
pathways
Exempted from
licensing
Authorization
procedure/
comments
US FDA Europe EMA
• Conditional approval
• Fast-track approach
Minimally manipulated, for
homologous use.
Issued the ‘Guidelines for Stem
Cell Research’ in 2017, covering
only research rather than ther-
apeutic applications of stem
cells. There is currently no law
regulating the use of stem cells
and violators are not liable to
punishment
Regulated as a drug. Genetically
modified human cells (Class 4
biologicals) must be submitted
under the CTX scheme, unless
a trial with the same product
for the same indication has
been approved in a comparable
jurisdiction.
Table 5: (Continued)
• Abridged evaluation
• Priority review
• Special Access Route (import, supply)
Minimally manipulated, for homologous use. Class I CGTPs.
For product registration of Class 2 CTGTPs,
the company has to be local and regis-
tered with the Accounting and Corporate
Regulatory Authority (ACRA). Pre-sub-
mission notification must be given to
HSA, and application dossier organized in
ICH/ ASEAN CTD format. Applicants may
choose to have a pre-market consultation
session, to be booked 5 months before the
consultation
Therapy products are eligible for the abridged
evaluation route if it has been approved
by at least a single drug regulatory agency
during submission. For priority review,
the therapy product would have to be used
for serious life-threatening conditions or
disease conditions of local public health
concern.
• Standard review
• Fast-track review
CGTPs are classified as medicinal
products.
Class I CGTPs are not required
to be registered with any
authority but must be written
down at the clinical site of
the healthcare professional,
which must comply with Good
Tissue Practice and the Private
Healthcare Facilities and Ser-
vices Act 1998.
Class II CGTPs have to be
registered with the Drug
Control Authority (DCA), and
the dossier for submission to
be based on the ASEAN com-
mon technical dossier. The
criteria for fast-track review
382
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
Ref. [35], [72] [1] [7 3]
Thai FDA South Korea
Act/regulation Drug Act B.E. 2510 (1967) and its
amendments.
Expedited
pathways
Exempted from
licensing
• Standard review
• Priority review
• Abridged review
According to the law and regula-
tion, ATMPs require product
registration. They are not
MFDS
Advanced Regen-
erative Medi-
cine, Advanced
Biopharmaceu-
ticals Act
• Priority
Review Process
• Customized
Review System
• Conditional
Approval
Minimal manip-
ulation is per-
formed to the
ICH WHO
include the application of new
research therapy products tar-
geting public health concerns,
with an application evaluation
period of around 22 business
days as compared to 45 business
days in the standard review.
Cells, Tissues, and Gene Therapy Products
(Continued)
383
384
Authorization
procedure/
comments
US FDA Europe EMA
exempt from registration.
Priority review covers
life-threatening medicines
and medicines in urgent need
for public health problems.
Abridged review for new drugs/
biological products using refer-
ence drug regulatory authority
assessment where the product
has already been approved and
sold in the US, EU, United King-
dom (UK), Switzerland, Aus-
tralia, Canada and Japan. Both
priority review and abridged
review are considered under
registration pathway. They are
not exempted from registration
licensing.
Thai FDA Notification on Control
and Regulation of ATMPs as
well as Guideline on advanced
therapy medicinal product
(ATMP): Cell Therapy
Table 5: (Continued)
therapy during
surgical
operation/
treatment at a
medical center.
The Advanced
Biopharma-
ceuticals Act
allows the
separation of
advanced
Gene therapy medicinal
products: ICH guide-
line S12; ICH Consid-
erations — Oncolytic
Viruses
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
INN Nomenclature Scheme for
Cell Therapy Products (CTP).
Medicinal Product was issued
and implemented in 2018.
biophar-
maceutical
products from
the existing
Pharmaceutical
Aairs Act. Key
details include
the definition
of advanced
regenerative
medicine and
advanced
biopharma-
ceuticals and
aim to provide
quick response
to medical
demands while
developing the
biopharmaceu-
tical industry
Quality: Q5B; Q5D; Q5A;
Topic Q5E; 5QC; Q6B;
Q7; Q9; Q10 Ecacy:
E1; E3; E4; E6; E7;
E8; E11
Considerations: General
principles to address
the risk of inadvertent
germline integra-
tion of gene therapy
vectors; General
principles to address
virus and vector
shedding
Cell therapy and tissue
engineering:
Quality: Q2; Q5A; Q5C;
Q5D; Q5E; Q7; Q8; Q9;
Q10
Safety: S6
Ecacy: E1; E3; E4; E6;
E7; E8; E11
Cells, Tissues, and Gene Therapy Products
(Continued)
385
Table 5: (Continued)
US FDA Europe EMA
The product registration of
ATMPs is required. violators
are subject to law punishment.
Manufacturing and/ or import-
ing ATMPs for clinical trial
purpose is exempt for registra-
tion but permission from Thai
FDA is required according to
related Ministerial Notification
and Thai FDA Notification.
Ref. [38] [74] , [75] [76] [4 0]
ASEAN: Association of Southeast Asian Nations; CTGTP: cell, tissue and gene therapy product; FDA: Food and Drug
Administration; HCT/PS: human cells, tissues, and cellular and tissue-based; ICH: International Council for Harmonisa-
tion of Technical Requirements for Pharmaceuticals for Human Use; INN: International Nonproprietary Names; NMPA:
National Medical Products Administration; PMDA: Pharmaceutical and Medical Devices Agency; PRIME: PRIority MEdi-
cines; TGA: Therapeutic Goods Administration.
386
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
Cells, Tissues, and Gene Therapy Products
to drug withdrawal and subsequently a loss of profit. The post­marketing requirements issued by regulators are also scant on details [72, 77]. Robust post-market evidence is essential in facilitating the successful implementation of accelerated approval programmes for the verification of the safety and ecacy of CTGTPs. However, post­market studies largely utilize methods similar to pre-market trials with minimal patient numbers and brief follow-up periods rather than using real-world scenarios for approved ATMPs in the EU [72, 78]. As such, regulations need to achieve the balance between flexi­bility in accommodating new knowledge and at the same time spe­cific in terms of setting out requirements in data submission.
In terms of GMP standards, the characteristics of CTGTPs should be considered, such as smaller batch sizes and shorter half-lives. As such, it is important to establish GMP standards dierent from conven­tional drugs and biologicals that account for the inherent variability of CTGTPs, where out-of-specification (OOS) products may be antici­pated. An example would be the approved CAR-T cell therapy product Kymriah (Novartis), where 10% of products could not be shipped due to OOS issues or manufacturing failures. However, OOS Kymriah is still eective with no evidence of higher safety risk as supported by real-world data [79]. Currently, some countries such as Japan and China have already started to move towards incorporating real-world data into submission requirements, evident from China’s ‘Guideline for the use of Real-World Evidence for Research and Regulatory Review’.
387
International harmonization of definition and scope of policies
A key discussion in the enactment of Japan’s Act on the Safety of Regenerative Medicine (ASRM) highlighted the importance of
388
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
shaping the scope of the regulation and deciding what it would regu­late, as it could potentially exclude regulation of important develop­ing therapies [80]. The ASRM has also adopted the term ‘regenerative medicine et cetera’, with ‘et cetera’ providing the flexibility to include technologies not yet discovered and unapproved therapies [80]. Dis­crepancies in regulatory terminologies such as the definition of CTGTPs led to the approval of the same product under dierent defi­nitions. For example, tisagenlecleucel was approved as a cell therapy product in Australia and Japan yet approved as a gene therapy prod­uct in the US and EU [72]. The criteria for eligibility and application procedures for expedited programmes varied across dierent coun­tries, where no single product was granted expedited approval under the expedited programmes in the US, EU and Japan [72]. This could discourage manufacturers from seeking approval in foreign coun­tries as they would need to spend additional resources to maneuver dierent regulations, thus limiting patients’ access to therapies.
In line with the harmonization of regulations, there is also a need for greater communication between stakeholders. A study showed that only slightly more than half of companies in Malaysia understood the variances in registration requirements between dierent prod­uct classes [83]. Using the example of Kymriah, the US FDA required the product to consist of minimally 80% viable T-cells, dierent from the 70% which was set during clinical trials. However, real-world data revealed that patients receiving doses of viability below 80% also achieved complete response [79]. Thus, there is a need for more extensive communication between dierent stakeholders, and flexi­bility in adjusting parameter ranges when more data is received even after the product has been put out to the market.
Furthermore, no global unified regulatory standards are avail­able as a reference or guidance, especially for countries where the
Cells, Tissues, and Gene Therapy Products
technical reviewers lack experience. Also, there are countries which still do not have specific legislation for CTGTPs, including the lack of ethical laws and human rights protection, or having separate regulatory authorities for clinical trial application and marketing authorization [71] unlike the US or UK.
As such, there is a need for the convergence of international regula­tions. Social science research has shown that emerging markets are stabilized when consumer confidence is boosted through creating standardized regulations [81, 82]. Currently, international harmo­nization initiatives, including the Gene and Cell Therapy Working Group of the International Pharmaceutical Regulators Form (IPRF) and ICH, are taking place, with the ICH being the primary organ­ization in generating shared technical guidelines to be utilized by dierent countries in the harmonization process. However, this requires a long time, which may not be rapid enough in dealing with the speed of innovation in the CTGTP area. As such, conver­gence may be a more desirable option, where regulatory require­ments align across countries by utilizing internationally recognized guidance documents [73]. This also provides time for manufacturers to understand any changes to regulations and to adapt manufactur­ing processes accordingly. By fostering close international cooper­ation, less advanced countries can also learn from more advanced countries without the need to abruptly adopt regulation standards, since they may not have the capacity to do so currently without being penalized unnecessarily.
389
Conclusion
CTGTPs are novel therapy products that seek to address unmet medical needs using materials such as stem cells for a regenerative
390
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
eect, or through genetic engineering to improve the ability of cells to target cancer cells. Types of therapies include autologous thera­pies, where the starting material is derived from the patient, and allogeneic therapies, where the starting material is obtained from healthy donors. CTGTPs also dier from conventional biologicals in manufacturing process due to their specific characteristics, such as the need to preserve the quality of the entire cell as compared to conventional biologicals, where the focus is on the quality of the therapeutic protein product. Storage, transport and cryopreserva­tion of CTGTPs in the manufacturing cycle are also important since cells require more extreme cryopreservation temperatures, and additional heterogeneity has to be managed if the therapy product is autologous. As a result, a more stringent process is required in the manufacturing of CTGTPs. Some solutions to the challenges encoun­tered in manufacturing include ensuring appropriate accreditation of professionals handling CTGTPs, using automation and outsourc­ing to CDMOs to ensure better compliance to GMP standards.
In CTGTP regulation, jurisdictions have defined and categorized CTGTPs largely according to the extent of manipulation and whether it is for homologous use or not, where a larger extent of manipula­tion requires more stringent regulations. Considering the lack of data from clinical trials due to small clinical trial groups and disease severity, many jurisdictions have put in place expedited pathways to allow products to reach patients faster. In addition, regulations need to be flexible to accommodate new scientific knowledge as the CTGTP field advances. The dierent levels of regulation across coun­tries serve as a barrier to manufacturers seeking to export CTGTPs overseas. In addition, certain countries also do not have specific leg­islation in place for CTGTPs such as ethical laws and human rights protection. As such, there is a need for the convergence of inter­national regulations to serve as guidance in drafting new laws and
Cells, Tissues, and Gene Therapy Products
to provide clarity to manufacturers. Many guidance documents are already available, such as the ‘PIC/S Annex 2A for Advanced Ther­apy Medicinal Products’ to guide manufacturers, as new scientific knowledge continues to emerge and evolve. With the help of inter­national organizations, the harmonization of regulations across the world is slowly beginning to materialize, providing guidance and greater clarity to countries that lag on regulations. International harmonization can also minimize the duplication of clinical trials and streamline the process of granting marketing authorizations for CTGTPs, thereby fostering innovation. There should also be greater and more eective communication between the regulator and dif­ferent stakeholders such as manufacturers, with feedback and some degree of flexibility incorporated into regulations.
The COVID-19 pandemic has accelerated digital transformation and exposed weak areas in pharmaceutical supply chains. At the same time, this has also presented opportunities for manufactur­ers and regulators to utilize technology to tackle the challenges of CTGTP manufacturing through new and innovative ways, ulti­mately improving the accessibility of these ground- breaking medi­cines to patients.
391
Competing interests: None
Provenance and peer review: Not commissioned; externally peer
reviewed.
Authors
Adjunct Associate Professor Sia Chong Hock, BSc (Pharm), MSc Christine Koh, BSc (Pharm) (Hons)