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U.S. Food and Drug Administration, Bavencio prescribing information http://www.accessdata.fda.gov/drugsatfda_
docs/label/2017/761049s000lbl.pdf.
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docs/label/2017/761069s000lbl.pdf.
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Further reading 397
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12
Considerations in the development
of pluripotent stem cellebased
therapies
Justine J. Cunningham
1
, Alexandra Capela
2
,
Catherine Priest
3
and Eugene P. Brandon
4
1
REGENXBIO, Rockville, MD, United States;
2
Vita Ther apeutics, Baltimore, MD, United
States;
3
Neurona Therapeutics, South San Francisco, CA, United States;
4
BrainXell
Therapeutics, San Diego, CA, United States
OUTLINE
Introduction 400
Definitions, regulations, and therapeutic
applications 401
Human embryonic stem cells 401
Induced pluripotent stem cells 403
Regulations 403
Therapeutic applications 406
Other applications: In vitro
toxicology testing and disease
modeling 406
Important early decisions: Chemistry,
manufacturing, and controls 407
Manufacturing process 407
Raw materials 409
Testing 409
Manufacturing scale 409
Critical decisions in cell line selection 410
Cell line characterization 412
Product characterization 413
Pluripotency and the potential for
tumorigenicity 415
Determining a threshold for residual
stem cells 416
Kinetics, chromosomal stability,
differentiation status, and cellular
attributes 417
Potency assays 418
Product lot release specifications 419
Nonclinical development 419
Principles of nonclinical development 419
Selection of test articl e for nonclinical
studies and key manufacturing
considerations 420
CHAPTER
399
Nonclinical Development of Biologics, Vaccines and
Specialty Biologics, Second Edition
https://doi.org/10.1016/B978-0-443-13344-2.00004-3
© 2025 Elsevier Inc. All rights are reserved, including those for text
and data mining, AI training, and similar technologies.

Justification for route and method of
administration for nonclinical studies 421
Selection of animal model(s) and/or
species for nonclinical studies 422
Genetically immunocompromised
models 423
Pharmacologic efficacy assessments 425
Study design, dose selection and
justification of pharmacologic
endpoints 425
Pharmacologic mechanism of action 426
Pharmacodynamics and pharmacokinetics 426
Pharmacodynamics 426
Pharmacokinetics (absorption,
distribution, metabolism, and
excretion) 426
Human-specific markers 428
Reporter genes, edited cells, and Y
chromosomes 428
PET, SPECT, MRI, and
bioluminescence 429
Special considerations for species and
model selection for assessment of
toxicity 429
Safety pharmacology 430
Toxicity assessments 431
General toxicity 431
Reproductive and developmental
toxicity 433
Genetic toxicity 433
Tumorigenicity assessment 434
Local tolerability 435
Translating nonclinical data to clinical
application 436
Considerations for dose extrapolation 436
Clinical considerations and
endpoints 436
Global regulatory guidance 437
Ethical and political issues 437
Clinical studies of PSC-derived
therapeutic candidates 438
Pioneers in translating to human trials 438
Reflection on clinical investigations to
date and looking forward 441
Summary 441
References 443
Introduction
Since the first description of human pluripotent stem cells (PSCs) in 1998 (Thomson et al.,
1998), there has been tremendous excitement surrounding their potential to transform our un-
derstanding of cell and molecular biology, and to develop treatments for a wide array of dis-
eases with unmet medical need. The scientific significance of human PSCs was recognized
with the Nobel Prize in Physiology or Medicine in 2012 (Park, 2012).
This chapter is intended to provide an overview of key considerations for the nonclinical
development of PSC-based therapeutics. PSCs are cells that are capable of differentiating into
derivatives of all three primary germ layersdendoderm, mesoderm, and ectodermdand
maintain such pluripotency through multiple passages or cell divisions (Thomson et al.,
1998). They can be differentiated into virtually any cell type in the body, although they
can only give rise to a limited range of extraembryonic tissues and cannot form placenta.
12. Considerations in the development of pluripotent stem cellebased therapies400
III. Specialty biologics and indications

Since PSCs can be differentiated into a multitude of cell types, they have the potential to be
applied to a virtually unlimited number of human disease and injury states.
There are two main types of PSCsdembryonic stem cells (ESCs; sometimes called hESCs
to distinguish the human cells from mouse ESCs, for which significant data also exist) and
induced pluripotent stem cells (iPSCs). PSC-derived cellular therapies are expected to restore
function or ameliorate disease by two main mechanisms: (1) Replacement of diseased cells/
tissues and/or (2) secretion of factors that support the endogenous environment. It is worth
noting, that CAR-T cells may be derived from PSCs and employ a third mechanism whereby
the expression of the target cell receptor is genetically modified to bind and then lyse the
target population (Zhou et al., 2022). This application highlights the fantastic versatility of
PSCs, and that the future likely holds many other possible ways they may be utilized and
mechanisms of action. Theoretically, PSC-derived cells can be used at various points in matu-
ration to differentiated progeny, from an early precursor state to a progenitor state, or to a
terminally differentiated state. A recurring theme in the field is that determined or committed
progenitors may provide advantages for cell therapeutics as they tend to be more robust and
still retain some modest mitotic potential postadministration, relative to terminally differen-
tiated counterparts.
Adult stem cells have been used therapeutically for decades, starting with hematopoietic
transplants in the 1960s (Thomas et al., 1957; Becker et al., 1963; Thomas and Epstein, 1965;
Buckner et al., 1970). Numerous types of adult stem cells, such as hematopoietic and more
recently mesenchymal stem cells (MSCs), have been identified and are used clinically for their
regenerative and repopulating properties, paracrine regulatory effects, and immune-
modulatory activity (Krampera et al., 2007). However, adult stem cells are multipotent, not
pluripotent, and can only give rise to tissues of the embryonic germ layer from which they
originate (ectoderm, mesoderm, or endoderm). They also exhibit limited proliferative capac-
ity, diminished differentiation potential and progressive loss of function upon in vitro expan-
sion and with increasing donor age, thus limiting their use in clinical applications (Zhou et al.,
2008; Wagner et al., 2008; Chambers et al., 2007; Bonab et al., 2006; Baxter et al., 2004).
Conversely, PSCs exhibit unlimited proliferation and differentiation potential.
The characteristics that make PSCs such a promising and powerful resource also present
the biggest challenges for nonclinical development and clinical translation. Researchers
must develop new methods to appropriately direct or control cell fate to assure pluripotency
is extin guished, eliminating the risk for potential tumorigenicity. Additionally, the field has
recognized that the conditions under which the cells are derived, propagated, and differen-
tiated can impact the genomic stability of the product and therefore the perceived risk for pa-
tients. See Table 12.1 for a comparison of the product attributes of different stem cell-based
therapies.
Definitions, regulations, and therapeutic applications
Human embryonic stem cells
ESCs are typically derived from the inner cell mass (ICM) of blastocys t stage embryos
(100e200 cells, 4e5 days postfertilization) generated by in vitro fertilization. They can also
be derived from late morula stage (30e40 cells) embryos that are incapable of further
Introduction 401
III. Specialty biologics and indications

TABLE 12.1 Product attributes based on source of cell-based therapies.
Product attributes
Mesenchymal stem
cells
Embryonic stem cells
(allogeneic)
Induced pluripotent
stem cells (autologous)
Induced pluripotent
stem cells (allogeneic)
Pluripotent stem cells
genetically engineered
Source material Bone marrow or
adipose (liposuction)
Blastocyst from IVF
clinic
Skin biopsy or blood draw Same as ESC or iPSC
Proliferative capacity Limited Unlimited
Differentiation
capacity
Restricted (may not
differentiate into cells
that are needed)
Unlimited (need to develop robust and reliable protocol for cell type of interest)
Therapeutic utility MSCs are the
therapeutic candidate
PSCs may be used to make a therapeutic candidate Correction of disease-
associated mutation or
generation of hypo-
immune “universal
donor” cells
Immunologic risk
(implant rejection)
Low (cells are transient
by design with no long-
term effects; MSC are
antiinflammatory)
Possible Little to none as the
patient is the donorda
match by definition
Possible (similar to
allogeneic ESC)
Hypo-immune cells are
designed to reduce or
eliminate need for
immunosuppression
Safety (transmission of
infectious agent(s))
Moderate risk Low risk Low risk Moderate risk Moderate risk
Safety (tumorigenicity) Little concern; cells do
not engraft or persist
Moderate to high
concern; though likely
HLA mismatch to
patient could facilitate
immune detection and
rejection
Moderate to high
concern
Moderate to high
concern though likely
HLA mismatch to
patient could facilitate
immune detection and
rejection
Moderate to high
concern if immune
rejection is not possible
due to genetic
modifications
Economic feasibility/
advantage
High cost Moderate cost Higher cost due to
longer manufacturing
and QC on each donor’s
batch
Moderate cost Higher cost due to
additional
manipulations and
CMC
Ethical/legal concerns “Stem cell clinics” may
thwart regulation and
cloud bona fide
therapeutic potential
Some jurisdictions Few
Adapted from Cavagnaro (2007).
12. Considerations in the development of pluripotent stem cellebased therapies402
III. Specialty biologics and indications

development, or from single blastomeres dissected from 8-cell embryos. The successful isola-
tion of ESCs was first described in 1998 by James Thomson and his team at the University of
Wisconsin, Madison (Thomson et al., 1998). Because they come from blastocysts, hESCs are
always allogeneic.
Induced pluripotent stem cells
iPSCs are adult somatic cells that have been genetically reprogrammed to an embryonic
stem cell-like state by artificially forcing the expression of genes or factors importan t for
maintaining pluripotency. Human iPSCs were first reported in 2007 by Shinya Yamanaka
and his team at Kyoto University, Japan, and were reprogrammed by the transduction of
genes encoding four defined transcription factorsdOct3/4, Sox2, Klf4, and c-Mycdnow
colloquially known as “Yamanaka or OSKM factors” (Takahashi et al., 2007). Yamanaka
was jointly awarded the Nobel Prize in Physio logy or Medicine in 2012 for this innovation
(Park, 2012). iPSCs demonstrate key characteristics of PSCs, namely the expression of stem
cell markers, the ability to form all three germ layers, and the ability to differentiate into
many different cell types. More recently, reprogramming cells to pluripotency has bee n
demonstrated to reset the biological “aging clock” and may hold promise for reprograming
epigenetic rejuvenation (Simpson et al., 2021). In the earliest versions of iPSC reprogramming,
viral vectors were used to deliver the pluripotency transcription factors, and consequently,
older iPSC lines may carry some risk regarding expression of proto-oncogenes and/or inser-
tional mutagenesis (Selvaraj et al., 2010). More recent reprogramming techniques, such as use
of nonintegrating vectors (Yu et al., 2009), recombinant protein transduction (Zhou et al.,
2009), induction using small molecules (Ichida et al., 2009), and synthetic mRNA (Kogut
et al., 2018; Warren and Lin, 2019), avoid some of these risks by creating “scarless” lines
(i.e., with no traces of reprogramming left behind in the host genome), thereby carrying fewer
off-target mutations that may affect the presumed safety of the cells. Because the source ma-
terial can be from the patient themselves, iPSC can be autologous, or if from another donor,
allogeneic.
Regulations
PSC-based therapeutics are regulated by the FDA’sOffice of Therapeutic Products (OTP)
within the Center for Biologics Evaluation and Research (CBER). Table 12.2 provides a list of
regulatory guidances that are applicable to PSC-based therapies. If the cell product is
intended to be used along with a medical device (e.g., matrix, encapsulation device) or a
drug (e.g., growth factors), it would be considered a combination product and therefore could
also be reviewed by the Center for Devices and Radiological Health (CDRH) and/or the Cen-
ter for Drug Evaluation and Research (CDER), respectively. The lead center for regulation
and review of a combination product is dictated by the candidate product’s primary mech-
anism of action (PMOA). If the intended PMOA is not obvious, a Request for Designation
can be submitted to the FDA. The same regulations and recommendations also apply to
iPSC-based products. However, iPSCs might also be considered a gene therapy product if
gene transfer via a vector- (such as a retrovirus, adenovirus, plasmid) based delivery system
was used to reprogram the cells. Regardless of the reprogramming method used, iPSCs
constitute gene therapy products if additional genetic engineering (such as editing) was
used to generate the final cell product.
Introduction 403
III. Specialty biologics and indications

TABLE 12.2 Resource documents for pluripotent stem cell-based therapies.
FDA guidances related to cellular therapies
Points to consider in the characterization of cell lines used to produce biologicals July 1993
FDA proposed approach to regulation of cellular and tissue-based products February 1997
Screening and testing of donors of human tissue intended for transplantation; applicable to cells
recovered before May 25, 2005
July 1997
Guidance for industry: Guidance for human somatic cell therapy and gene therapy March 1998
Guidance for industry: Eligibility determination for donors of human cells, tissues and cellular
and tissue-based products (HCT/Ps); applicable to cells recovered after May 25, 2005
August 2007
Guidance for FDA reviewers and sponsors: Content and review of chemistry, manufacturing, and
control (CMC) information for human somatic cell therapy investigational new drug applications
(INDs)
April 2008
Guidance for industry: Considerations for allogeneic pancreatic islet cell products September 2009
Guidance for industry: Cellular therapy for cardiac disease October 2010
Guidance for industry: Potency tests for cellular and gene therapy products January 2011
Guidance for industry: Current good tissue practice (CGTP) and additional requirements for
manufacturers of human cells, tissues, and cellular and tissue-based products (HCT/Ps)
December 2011
Guidance for industry: S6 Addendum to preclinical safety evaluation of biotechnology-derived
pharmaceuticals
May 2012
Guidance for industry: Preclinical assessment of investigational cellular and gene therapy
products
November 2013
Guidance for industry: Considerations for the design of early-phase clinical trials of cellular and
gene therapy products
June 2015
Guidance for industry: Source animal, Product, preclinical, and clinical issues concerning the use
of xenotransplantation products in humans
December 2016
Guidance for industry: Expedited programs for regenerative medicine therapies for serious
conditions
February 2019
Guidance for industry: Evaluation of devices used with regenerative medicine advanced
therapies
February 2019
Guidance for industry: Chemistry, manufacturing, and control (CMC) information for human
gene therapy investigational new drug applications (INDs)
January 2020
Guidance for industry: Studying multiple versions of a cellular or gene therapy product in an
early-phase clinical trial
November 2022
Draft guidance for industry: Potency assurance for cellular and gene therapy products December 2023
Guidance for industry: Considerations for the development of Chimeric antigen receptor (CAR)
T cell products.
January 2024
Guidance for industry: Human gene therapy products incorporating human genome editing January 2024
12. Considerations in the development of pluripotent stem cellebased therapies404
III. Specialty biologics and indications

This nascent field is rapidly progressing, and new discoveries may impact regulatory
requirements and guidances. Early discussions with the FDA well in advance of the Pre-
Investigational New Drug (Pre-IND) meeting are therefore strongly encouraged for the devel-
opment of PSC-based therapeutic products. In the US, the FDA provides a format for these
early interactions through INTERACT meetings; an INitial Targeted Engagement for
Other regulatory guidances and resources for development of cellular therapies
Q5D quality of Biotechnological/Biological products: Derivation and characterization of cell
substrates used for production of Biotechnological/Biological products; availability
March 1998
PHS guideline on infectious disease issues in xenotransplantation January 2001
FDA guidance: Estimating the safe starting dose in clinical trials for therapeutics in adult healthy
volunteers
July 2005
ICH S7B nonclinical evaluation of the potential for delayed ventricular repolarization (QT
interval prolongation) by human pharmaceuticalsdscientific guideline
May 2005
US National Academies’ guidelines for human embryonic stem cell research; with Amendments 2005
2007, 2008
Guidance for industry: CGMP for phase 1 investigational drugs July 2008
National Institutes of health guidelines for human stem cell Research (https://stemcells.nih.gov/
research-policy/guidelines-for-human-stem-cell-research)
2009
Guidance for industry: Animal ModelseEssential elements to address efficacy under animal rule February 2009
Final report of the National Academies’ human embryonic stem cell research Advisory
Committee and 2010 Amendments to the National Academies’ guidelines for human embryonic
stem cell research
2010
CFR 1271.75, 1271.80 and 1271.85 for donor screening and testing April 2010
Guidance for industry: ICH S6 [R1] nonclinical safety evaluation of biotechnology-derived
pharmaceuticals’
July 2011
EMEA guideline: Guideline on strategies to identify and Mitigate risks for first-in-human and
early clinical trials with investigational Medicinal Product [R1]
July 2017
Guidance for industry: Expedited programs for regenerative medicine therapies for serious
conditions
February 2019
Guidance for industry: Evaluation of devices used with regenerative medicine advance therapies February 2019
ICH S7A safety pharmacology studies for human pharmaceuticalsdscientific guideline January 2021
International Society for stem cell Research’s guidelines for the stem cell research and clinical
translation https://www.isscr.org/guidelines
2021
International Society for stem cell Research’s standards for human stem cell use in research.
https://www.isscr.org/standards-document
2023
NIH stem cell Registry https://grants.nih.gov/stem_cells/registry/current.htm
Introduction 405
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