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References 427
https://t.me/medicina_free
6 Food and Drug Administration (FDA) (2022). Premarket Notification 510(k).
https://www.fda.gov/medicalpreparing- correct- submission/premarket- notification- 510k (accessed
17 October 2023).
7 Food and Drug Administration (FDA) (2016). Premarket approval (PMA). https://
www.fda.gov/medicalcorrect- submission/premarket- approval- pma (accessed 17 October 2023).
8 Food and Drug Administration (FDA) (2003). Guidance for industry and FDA
staff premarket approval application modular review. November 2003.
9 Food and Drug Administration (FDA) (2019). Acceptance and filing reviews for
premarket approval applications (PMAs) guidance for industry and food and
drug administration staff. December 2019.
10 Food and Drug Administration (FDA) (2022). Humanitarian device exemption.
October 3, 2022. https://www.fda.gov/medical- devices/premarket- submissionsselecting- and- preparing- correct- submission/humanitarian- device- exemption
(accessed 17 October 2023).
11 Food and Drug Administration (FDA) (2019). Humanitarian device exemption
(HDE) program guidance for industry and food and drug administration staff.
September 6, 2019.
12 Food and Drug Administration (FDA) (2023). Requests for feedback and
meetings for medical device submissions: the Q‐submission program. June 2023.
13 Regulation (EU) 2017/746 of the European Parliament and of the Council of
5 April 2017 on invitro diagnostic medical devices and repealing Directive 98/79/
EC and Commission Decision 2010/227/EU2017/746.
14 European Union Commission (2021). Regulation (EU) 2017/746 of the European
Parliament and of the Council of 5 April 2017 on invitro diagnostic medical
devices and repealing Directive 98/79/EC and Commission Decision
2010/227/EU. October 2021.
15 Medicines & Healthcare products Regulatory Agency (2023). Standard
implementation of the future regulations. https://www.gov.uk/government/
publications/implementationextension- of- standstill- period/implementation- of- the- future- regulations
(accessed 27July 2023).
16 Government of Canada (2016). Guidance document: guidance for the risk‐based
classification system for invitro diagnostic devices (IVDDs). https://www.canada
.ca/en/health- canada/services/drugs- health- products/medical- devices/
application- information/guidance- documents/guidance- document- guidancerisk- based- classification- system- vitro.html (accessed 17 October 2023).
17 Pharmaceutical and Food Safety Bureau (2013). Ministry of Health, Labour and
Welfare. Notification on approval application for invitro companion diagnostics
and corresponding therapeutic products. July 2013.
devices/premarket- submissions- selecting- and- preparing-
devices/premarket- submissions- selecting- and-
of- the- future- regulation- of- medical- devices- and-

https://t.me/medicina_free
428
18 National Medical Products Administration (NMPA) (2023). http://english.nmpa
.gov.cn/ (accessed 17 October 2023).
19 Food and Drug Administration (FDA) (2020). Human gene therapy for rare
diseases guidance for industry. January 2020.
20 Food and Drug Administration (FDA) (2020). Human gene therapy for
hemophilia guidance for industry. January 2020.
21 Food and Drug Administration (FDA) (2015). Considerations for the design of
early‐phase clinical trials of cellular and gene therapy products guidance for
industry. June 2015.
22 Food and Drug Administration (FDA) (2023). List of cleared or approved
companion diagnostic devices (invitro and imaging tools). May 23, 2023. https://
www.fda.gov/medicalcompanion- diagnostic- devices- in- vitro- and- imaging- tools (accessed 6
October 2023).
devices/in- vitro- diagnostics/list- cleared- or- approved-

Section V
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Regulatory Perspectives onGene Therapy
429

18
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Current Regulatory Landscape forGene Therapy
Product Development and theRole ofBiomarkers
Laura I. Salazar-Fontana PhD1 and Mike Havert PhD
1
LAIZ Regulatory Science Consulting, Lausanne, Switzerland
2
Gene Therapy Partners, LLC, Arlington, Virginia, USA
2
18.1 Introduction
Scientists have long ago linked genes to biological traits and features. Hershey and
Chase demonstrated in 1952 that DNA was the basis for inheritance and the early
experiments that followed provided the basic understanding of how DNA is
passed from parent to progeny and used as a set of instructions for a cell[1].
Visionary scientists hypothesized that genetic modification through the introduction of exogenous DNA could be the basis for disease treatments[2]. By providing
new genetic coding sequences, one could reprogram cells to perform a new function or restore a missing function. Instead of providing a protein, a chemical drug,
or a metabolite, these scientists were dreaming of ways to alter genes. It was in
July of 2012 that the European Medicines Agency (EMA) granted approval for the
first gene therapy product, Glybera®, an adeno‐associated viral vector engineered
to deliver a corrected form of the enzyme lipoprotein lipase to the muscle tissue of
patients suffering from a severe deficiency in this enzyme. Five years later, three
approvals by the U.S. Food and Drug Administration (FDA) marked a breakout in
which two exvivo gene‐modified products (Kymriah®, Yescarta®) and one direct
in vivo gene transfer product (Luxturna®) were approved. Collectively termed
gene therapy (GT), these products established a new pharmaceutical classification and the formal recognition of genetic modification of human cells as a new
treatment paradigm.
431
Drug Development for Gene Therapy: Translational Biomarkers, Bioanalysis, and Companion
Diagnostics, First Edition. Edited by Yanmei Lu and Boris Gorovits.
© 2024 John Wiley & Sons, Inc. Published 2024 by John Wiley & Sons, Inc.

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Yet, making changes to the genome of living human cells does not come without
risk. The path to these GT approvals was long and winding. The development of
gene delivery vectors, such as replication‐defective retrovirus and adenovirus,
coupled with encouraging results in preclinical disease models, led to early initiation of several National Institutes of Health (NIH) funded clinical trials in the
1990s. Unfortunately, these early trials exposed serious treatment‐related toxicities, such as inflammatory responses to in vivo administered viral vectors and
malignancies caused by retroviral‐mediated insertional activation of proto‐
oncogenes[3, 4]. These setbacks fueled more basic research in virology, immunology, cell biology, and model development, which ultimately led to successful
clinical translation using engineered lentiviral (LVV) and adeno‐associated viral
(AAV) vectors. In the time since 2012, we have had 19 gene therapy approvals
worldwide, including genetically modified cell therapy products, and 28 GT are
currently under regulatory evaluation[5]. These approved products have had to
meet a high standard for demonstrating that clinical benefit clearly outweighted
the potential risks associated with genetic modification and the potential long‐
term consequences of this new pharmaceutical modality.
This chapter provides an overview of the biomarkers that have been used from
the start of gene therapy trials in support of regulatory filings and how they have
evolved over time. The future for GT remains promising as we are better able to
design and select safer and more effective product candidates based on the knowledge gained from multiple biomarkers. The value of evaluating new, particularly
those related to immune toxicities, is further discussed.
18.2 What is Gene Therapy?
Gene therapy products (GTP) are a diverse group of biotherapeutics that are generally developed to treat conditions for which there are limited or no effective
treatments[6].
The FDA has regulated what it calls human gene therapy as biologic products
since 1993[7]. FDA guidance describes gene therapy as products seeking to modify or manipulate the expression of a gene or to alter the biological properties of
living cells for therapeutic use[8, 9, 10, 11]. Through the transcription or the
translation of transferred genetic material, or by specifically altering host (human)
genetic sequences. Some examples of gene therapy products include nucleic acids
(e.g. plasmids, invitro transcribed ribonucleic acid (RNA)), genetically modified
microorganisms (e.g. viruses, bacteria, fungi), engineered site‐specific nucleases
used for human genome editing (e.g. CRISPR/Cas9), and exvivo genetically modified human cells. Whereas EMA defines gene therapy medicinal products (GTMP)

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as a biological medicinal product that consists of a recombinant nucleic acid that
once administered to human beings can regulate, repair, replace, add, or delete a
genetic sequence; thus, GTMP mediate their therapeutic, prophylactic, or diagnostic effect through the recombinant nucleic acid sequence they contain, or
through the product of genetic expression of this sequence[12]. Although there is
no universal definition of GTP, the World Health Organization (WHO) has
recently published a document aimed to achieve worldwide regulatory consensus
on this definition [13]. For now, both developers and regulatorsdistinguish GTP
from therapeutic proteins (so‐called “biotech” products) by categorizing them as
“advanced” therapy products, and regulatory agencies anticipate the same level of
quality, safety, and efficacy evidence to attain a positive benefit:risk assessment to
support the approval and commercialization of a new GTP/GTMP[6].
18.3 Biomarkers Defined
Biomarkers are objective and quantifiable characteristics of biological processes[14]. The first definition was formally proposed by the National Institutes
of Health (NIH) biomarkers working group back in 1998 and amended by the
International Program on Chemical Safety, led by the WHO in coordination with
the United Nations (UN), in 2001. The NIH working group defined biomarkers as
a “characteristic that is objectively measured and evaluated as an indicator of
normal biological processes, pathogenic processes, or pharmacological responses
to a therapeutic intervention”[15]. Whereas, the WHO definition added to the
NIH definition the utility that these measurements could have to predict the outcome and/or incidence of a disease by taking into consideration the effects of
treatment, interventions, and environmental factors, such as pollutants, in the
biological processes, and classified them into biomarkers of exposure, effect, and
susceptibility[16].
But it was not until 2004with the announcement of FDA’s critical path initiative, that biomarkers could be accepted as part of the preliminary proof of safety
and effectiveness of new therapeutic products with the goal of accelerating product development. The aim of this initiative was to enable the combination of new
scientific and predictive methods to ease the transition between the laboratory
concept to clinical development culminating in product commercialization[17].
Biomarkers can provide researchers and regulators with interim evidence concerning the safety and efficacy of a given treatment while more definitive clinical
data are collected. For example, surrogate endpoints can be accepted as a preliminary proof of efficacy if they have been well‐characterized for any given biological
process. Yet for a biomarker to be considered a surrogate endpoint, there must be

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solid scientific evidence (e.g. epidemiological, therapeutic, and/or pathophysiological) demostrating that the chosen biomarker can also consistently and accurately predict a clinical outcome, either a benefit or a harm. In this case, the
biomarker can be proposed as a surrogate
support product development, but acceptance will be granted on a case‐by‐case
basis, and very rarely to replace a clinical endpoint.
The use of biomarkers in the development of gene therapy products is further
discussed in the following sections.
endpoint to the regulatory agencies to
18.4 Early Gene Therapy Biomarkers
The first human GT clinical protocol approved by the NIH involved the genetic
marking of exvivo expanded lymphocytes. Researchers at the National Cancer
Institute (NCI) used a murine gamma retrovirus (Maloney murine leukemia
retrovirus, produced using PA317/LNL6‐c8) encoding a bacterial neomycin
resistance gene (NeoR) to tag tumor‐infiltrating lymphocytes (TILs) extracted
from a metastatic melanoma tumor sample[18]. As the first openly deliberated
gene transfer into humans, a number of practical, safety and ethical considerations were pondered before NIH approved and initiated this study. These considerations actually paved the road to future studies by and define three key
biological response signals that have ever since used as relevant biomarkers
for GTP.
The first of the biological responses was and still is the detection of replication‐
competent virus. Because, GTP has traditionally relied on modified viral vectors
(for gene transfer and genetic modification of human cells they may revert to
virulence and possibly become pathogenic when administered to humans. As
such, it is important to understand whether these GTP contain self‐replicating
viruses that might harm patients or others exposed to treatments, such as caregivers or family contacts, specially if the chosen viral vector is an engineered
retrovirus. The presence of replication‐competent virus may be difficult to
detect in the final drug product as is the persistence of vector sequences with the
potential for mobilization and/or activation through recombination due to environmental triggers. Therefore, replication‐competent virus testing has been
used as a quality attribute and as required patient safety biomarker for all
retroviral/lentiviral vector GT investigational studies. Currently, screening for
replication‐competent retrovirus (RCR) or replication‐competent lentivirus
(RCL) infection in study subjects is performed by either serologic detection of
retroviral specific antibodies or analysis of patient peripheral blood mononuclear
cells (PBMC) by PCR for retroviral specific DNA sequences. Positive screen tests
are followed by a direct coculture assay to obtain and characterize the infectious

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viral isolate[19]. Recommendations for sample collection include a pretreatment
time, followed by collection after three (3), six (6), and twelve (12) months post
administration, and yearly for up to fifteen (15) years (FDA) or until data indicate
that there is no longer risk to be followed with a minimum of 5 years for viral
vectors with no risk for integration, latency or reactivation potential (EMA)[20].
All commercial products approved so far have assessed long‐term impacts on
secondary malignancies and the potential for RCR/RCL generation in 15/20‐year
patient registry studies that consisted of 500 and 2500 patients[21]. The Center
for International Blood and Marrow Transplant Research (CBMTR) has managed registry studies in for the United States and Japan and similarly the
European Bone Marrow Transplant (EBMT) has outlined plans for registry studies in the European Union (EU)[22]. To date, substantial amount of data on the
safety of retroviral vectors in clinical applications has been collected. To date, no
RCR/RCL or delayed adverse event related to replication‐competent virus has
been reported in subjects who have received retroviral vector‐based treatments[23]. Current guidance by FDA suggests that sponsors may discontinue
RCL/RCR testing at some point after some initial data has been collected with
some limited exemptions.
A second biomarker used in this first NIH‐approved study was aimed to track
the exogenous nucleic acid contained in the genetically modified lymphocytes.
Both Southern blot and PCR for the bacterial NeoR transgene were used as overlapping semi‐quantitative assays to distinguish exogenous nucleic acid (the bacterial neomycin resistance gene) inserted into marked lymphocytes from sequences
present in the human genome. The investigators found that the genetically modified TILs were able to survive at the tumor site and in circulation for months,
although the results were somehow limited in their ability to compare and quantitatively assess TIL numbers.
Nowadays, improvements to the early PCR assays allow more quantitative
assessments. Real‐time PCR, or quantitative PCR (qPCR), is now a well‐
established technology that measures the accumulation of DNA products amplified during a PCR reaction. Also, digital PCR (dPCR) offers further improvements
in the sensitivity and precision of this approach. These quantitative PCR methodologies have become the regulatory standard for today’s biodistribution and
shedding studies.
Evaluating the biodistribution of a gene therapy vector is also an important first
step in the design and understanding of a GT to support its potential therapeutic
effect and safety risk. Biodistribution studies are performed to determine the dissemination and the GT persistence in both target and non‐target tissues upon
direct invivo administration. Two FDA guidance documents outline the need for
biodistribution studies and there is a current effort underway to draft an ICH
document to harmonize approaches [8, 24, 25]. FDA guidance suggests that a

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biodistribution study be done in combination with an animal toxicology study
because the location and persistence of the GT vector can help with the interpretation of toxicology assessments. In addition, the extent of long‐term follow‐up
(LTFU) in patients may be guided by product biodistribution studies in animals.
It also recommends developers to sample a panel of tissues, at a minimum (blood,
injection site(s), gonads, brain, liver, kidneys, lung, heart, and spleen) and assess
vector copy number with a sensitivity of not less than 50 copies per microgram of
cellular DNA (or about 10e5 cells). General recommendation is that five (5)
animals/sex/timepoint and for collections to include tissues prior to peak, steady‐
state (i.e. plateau), and declining (if feasible)[8, 25]. Similar considerations for the
concurrent evaluation of biodistribution and toxicity in pre‐clinical studies are
contemplated by EMA with a clear recommendation to adequately justify the
choice of endpoints and biomarkers predictive of toxicity in animals[26].
Many GT developers now go beyond a minimal biodistribution assessment and
screen different product candidate to select those with optimal cell/tissue targeting in an animal model. In these situations, developers will likely assess not only
vector uptake but also gene expression using a variety of tissue imaging, immunohistochemistry, and in situ hybridization techniques to ensure that not only is the
vector delivered to the correct tissue but also that a target efficacy threshold for
transgene (TG) expression can be reached.
Non‐clinical biodistribution studies may also inform the design of clinical shedding studies. Clinical shedding studies may be used to understand potential environmental release of a gene‐modified product and potential transmission to
others within the environment. Many times, the most practical means to determine whether a GT is shed is by PCR.
As the application of detection methods, such as quantitative PCR, has evolved
since the first GT trials to include biodistribution and shedding, so has the ability
to detect the location of a TG and its integration sites within a host genome.
Southern blot analysis and restriction fragment length polymorphism have been
used in early gene mapping studies. Early retroviral insertion site analysis began
with the isolation of genomic DNA, digestion by sequence‐specific restriction
endonucleases, and linear PCR amplification using a retroviral‐specific primer
(LAM‐PCR). The measurement of the clonality of insertion sites is a current FDA
recommendation to assess oligoclonality and blood dysplasia, which could be a
potential early indication for cancer.
A third important biomarker was the detection of a biological activity of the
genetically‐marked cells. Although in the TIL study, demonstrating that the
modified T cells had anti‐tumor activity or retained Neo resistance could not be
assessed, it was hypothesized that Neo resistance could be used as a selection
marker for more potent tumor‐directed lymphocytes in the future. Demonstration
of invivo functional activity for the genetically modified cells would have to wait

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for the second NIH‐approved human gene transfer study. Shortly after the 1988
TIL approval, a second protocol was approved by the NIH that involved the gene
correction of peripheral blood cells for the treatment of severe combined immune
deficiency (SCID) caused by the adenosine deaminase (ADA) deficiency. As
before with the gene marked TIL, this approach used retroviral‐mediated gene
transfer and careful consideration was given to the risks associated with a genetically modified virus and the generation of RCR. As with the TIL study, biomarkers
for RCR indicated no RCR was generated in study subjects and the biodistribution
and persistence of genetically modified cells was assessed for up to 10
humans. Interestingly, a biomarker of functional activity of the gene‐modified
cells was assessed by measuring ADA activity present in peripheral blood samples[27]. This second study reported results for all three biomarkers and it has set
the standard for many years to come. It was not until the mid‐2010s that this set
of biomarkers was substantially reevaluated and expanded with the introduction
of high‐dose systemic AAV gene therapy and the expansion of LVV gene‐modified
cell products.
years in
18.5 Current Expectations forGeneTherapy
Biomarkers
Gene therapy has evolved significantly since the early 1990’s, and in vivo gene
delivery has moved from a concept to reality. Initial experiments with invivo gene
therapy suggested that the immunotoxicity of the delivery system was a significant
concern and limited the effectiveness of the gene therapy[28]. Currently, AAV vectors are widely used for invivo GT because they are non‐pathogenic in humans, are
replication‐defective, mostly non‐integrative (episomal localization), and can
transduce a large variety of tissues depending on the selected serotype [29, 30].
Five AAV‐mediated gene therapies are available to patients as of 2023, these
include Luxturna®, Zolgensma®, Roctavaria®, Hemgenix® and Elevidys®. Even with
this promising set of approvals, treatment‐emergent serious adverse events
(TESAEs) have fuel interest in understanding and developing immune toxicity
related biomarkers (discussed below under “Immune‐toxicity biomarkers”).
The field has continued to make progress with ex vivo gene‐modified cells as
well. It was apparent from early clinical trials that genetically modified cells could
be detected for long periods of time (up to 10 years), and in fact tracking the expansion and persistence of gene‐marked anti‐CD19‐CAR T cells has correlated with
treatment responses and appears to be the best predictor of CAR T efficacy[31].
However, gene‐modified cell products also had the potential to trigger delayed
adverse events, including cancer and autoimmunity. The field has moved to
“safer” approaches that cause less genotoxicity. Even still, for all gene therapy
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