Manufacturing Cellular Products for International Clinical Trials



Similar documents
Valentina Gualato, Ph.D. Process Development Scientist

Document Review: Centers for Medicare and Medical Service (CMS) What Do I Need to Do to Assess Personnel Competency?

GMP Issues for Start-Ups, quality in the supply chain and role of the Qualified Person (QP)

How To Inspect A Blood Bank

EUROPEAN COMMISSION HEALTH AND CONSUMERS DIRECTORATE-GENERAL. EudraLex. The Rules Governing Medicinal Products in the European Union

Qualification of an Environmental Monitoring Program

GMP ANNEX 1 REVISION 2008, INTERPRETATION OF MOST IMPORTANT CHANGES FOR THE MANUFACTURE OF STERILE MEDICINAL PRODUCTS

Extemporaneously Prepared Early Phase Clinical Trial Materials

Combination Products. Presented by: Karen S. Ginsbury For: IFF March PCI Pharma

Guidance for Industry: Starting Material Supplier Management

Comparative analysis between the possible regulatory approaches to GMP compliance TITOLO PRESENTAZIONE

Design, Operation and Management of GTP/GMP Cell Engineering Facilities

Manufacturing process of biologics

EUROPEAN COMMISSION HEALTH AND CONSUMERS DIRECTORATE-GENERAL. EudraLex. The Rules Governing Medicinal Products in the European Union

EUROPEAN COMMISSION HEALTH AND CONSUMERS DIRECTORATE-GENERAL. EudraLex The Rules Governing Medicinal Products in the European Union

GLP vs GMP vs GCP Dominique Pifat, Ph.D., MBA The Biologics Consulting Group

Presented by Rosemarie Bell 24 April 2014

Luca Romagnoli, Ph.D. Business Development Manager

Annex 2. WHO good manufacturing practices for pharmaceutical products: main principles 1

Diane Kadidlo MT(ASCP) SBB University of Minnesota Joanna Stanson, M.S. University of Pittsburgh

Annex 9 Guide to good storage practices for pharmaceuticals 1

Recent Updates on European Requirements and what QPs are expected to do

US Regulations for Import and Export of Cell Therapy Products

Quality Assurance. Disclosure for Lilli Møller Andersen. No relevant financial relationships exist for any issue mentioned in this presentation

Public Cord Blood Bank

5th Edition NetCord-FACT International Standards for Cord Blood Collection, Banking, and Release for Administration. Summary of Changes

Library Guide: Pharmaceutical GMPs

BIOTECHNOLOGY OPERATIONS

Validation and Calibration. Definitions and Terminology

Site visit inspection report on compliance with HTA minimum standards. Belfast Cord Blood Bank. HTA licensing number

MeriCal Quality Profile

Preparing for the Pre-Approval Inspection What to do Before the FDA Arrives. Barry A. Friedman, Ph.D. Consultant

Quality Systems Appropriate for Extemporaneously Prepared Early Phase Clinical Trial Materials. Agenda Topics for Discussion

Table of Contents. FACT Quality Handbook, Second Edition. Table of Contents

Cord Blood Banking and Biologic License Application (BLA) November 19, 2010

TRANSATLANTIC TRADE AND INVESTMENT PARTNERSHIP

ASSESSMENT OF QUALITY RISK MANAGEMENT IMPLEMENTATION

Guide to Regulatory Requirements for the Procurement of Human Tissues and Cells intended for Human Application

Risk-Based Environmental Monitoring. Marsha Stabler Hardiman Senior Consultant Concordia ValSource Wednesday September 17, 2014 FDA/PQRI

Comparability of Cord Blood Units

Author General Management Quality Assurance

EU DIRECTIVE ON GOOD CLINICAL PRACTICE IN CLINICAL TRIALS DH & MHRA BRIEFING NOTE

INSPECTION OF TISSUE AND CELL PROCUREMENT AND TISSUE ESTABLISHMENTS. Operational Manual for Competent Authorities. Version 1.0

Pharmaceutical Wholesaler Site Inspection Checklist

CMC Writing for IND Applications. David H. McKenna, Jr., M.D. University of Minnesota April 10-11, 2007 Workshop

GMP Pharma BV. Netherlands

Non-clinical development of biologics

cgmp Challenges for Cord Blood Banks

Working Party on Control of Medicines and Inspections. Final Version of Annex 16 to the EU Guide to Good Manufacturing Practice

SMF Awareness Seminar 2014

[DOCKET NO.96N-0002] DRAFT

ROLE OF THE RESEARCH COORDINATOR Study Start-up Best Practices

Audit Report in the framework of the APIC Audit Programme

The FDA recently announced a significant

Quality Agreement. by and between. Supplier Name. Address: and. Client Name: Address:

ToxBank Requirements Analysis

Regulation and Risk Management of Combination Products

PROCEDURE FOR HANDLING RAPID ALERTS AND RECALLS ARISING FROM QUALITY DEFECTS

The Quality System for Drugs in Germany

CHAPTER 7 QUALITY ASSESSMENT

New Guidelines on Good Distribution Practice of Medicinal Products for Human Use (2013/C 68/01)

Registries and Biobanks for Human Stem Cell Lines Glyn Stacey, UK Stem Cell Bank, NIBSC ESHRE Course, Valencia, 8 th November 2010

Quality Management System MANUAL. SDIX, LLC Headquarters: 111 Pencader Drive Newark, Delaware 19702

Regulations for Handling Samples and Laboratory Testing from R&D through Phase III Clinical Trials

"Act" means the National Health Act, 2003 (Act No 61of 2003);

Quality Management System MANUAL. SDIX, LLC Headquarters: 111 Pencader Drive Newark, Delaware 19702

Clinical Trial Logistics

Licensing Your Cord Blood

Site visit inspection report on compliance with HTA minimum standards. SCI Oxford. HTA licensing number Licensed for the

Cord Blood Licensure. Session 2C: Advanced Cell Therapies April 11, 2013

Effective Training for Cell Therapy Laboratories. Diane Kadidlo MT(ASCP) University of Minnesota Molecular and Cellular Therapeutics Facility

GUIDE TO GOOD MANUFACTURING PRACTICE FOR MEDICINAL PRODUCTS ANNEX 15 *

Guidance for Industry Quality Systems Approach to Pharmaceutical CGMP Regulations

Integrating Good Manufacturing Practices During the Transition from Clinical Trials to Commercial Manufacturing

PHARMACEUTICAL QUALITY SYSTEM Q10

Guidance for Industry and FDA Staff

ASTRAZENECA GLOBAL POLICY QUALITY AND REGULATORY COMPLIANCE


Annex 4 Good Manufacturing Practices for pharmaceutical products: main principles

Human Tissue Authority. Guide to Quality and Safety Assurance for Human Tissues and Cells for Patient Treatment

Introduction The Role of Pharmacy Within a NHS Trust Pharmacy Staff Pharmacy Facilities Pharmacy and Resources 6

The use of risk assessment tools for microbiological assessment of cleanroom environments. by Tim Sandle

Good Clinical Laboratory Practice (GCLP) An international quality system for laboratories which undertake the analysis of samples from clinical trials

The Study Site Master File and Essential Documents

Guide to Fees for Veterinary Products

Guide to Master Formulae WHO/FWC/IVB/QSS/VQR

Biobanking Pluripotent Stem Cell Lines: UK and EU regulations Glyn Stacey, UK Stem Cell Bank, NIBSC

SERVICES FOR. Devices and Combination Products

Roche Position on Human Stem Cells

Title:: Effective GMP AUDITS for APIs and Formulation Pharma Companies By G.Sundar-Director/Consultant PharmQA Compliance solutions

World Health Organization Prequalification of Medicines

Leila Kakko Tampere University of Applied science TRADITIONAL FOOD IN COMBATING FOODBORNE PATHOGENS 2011

The New EU Clinical Trial Regulation Potential Impacts on Sites

Welcome Computer System Validation Training Delivered to FDA. ISPE Boston Area Chapter February 20, 2014

Best Practices In Ensuring Quality Standards When Outsourcing To Contract Manufacturers, Licensees And Consultants

PHARMACEUTICAL OUTSOURCING:

Guideline on good pharmacovigilance practices (GVP)

Auditing as a Component of a Pharmaceutical Quality System

Conducting a Gap Analysis on your Change Control System. Presented By Miguel Montalvo, President, Expert Validation Consulting, Inc.

Transcription:

Manufacturing Cellular Products for International Clinical Trials Q U A L I T Y A N D O P E R A T I O N S T R A C K 7 4 / 2 5 / 1 4 1 3 : 4 5-1 5 : 1 5 Olive J Sturtevant, MHP,MT (ASCP)SBB, CQA Director of CTQA Dana Farber Cancer Institute, Boston, Ma

Objectives: To provide an overview of some of considerations and challenges with multi-center / international clinical trials especially for US Academic Institutions & Manufacturing Facilities To review some challenges with the EU PICs and API regulations especially for a US Academic CT manufacturers Discuss the use of new tools to share and capture important trial information and outcome data

Brief Overview of Cells Manufactured by DFCI-CMCF Product Volumes and Types Stem Cell Products YEAR 2013 2014 Proj Bone Marrow Products 70 74 Apheresis Products 1106 1161 Cord Products 10 11 DLI Products 22 23 Total Products 1208 1268 Novel CT 2013 2014 Proj Gene Therapy-HSCT 8 17 Cancer Vaccines 230 490 Immunotherapy CAR-T cells 1 15 CD4Treg 5 15 TCRab/CD19 1 8 Viral CTL 8 other T and NK cells 4 Regenerative Med MSC 3 36 Limbal SC 4 DC 5 10 Renal 3 8 Other Other 94 105 Totals 350 720

DFCI-CMCF Active Protocols

Ambiguous definitions, as identical terms may be interpreted differently from one country to another, or even within the same country. Taken from recent work on clinical research wwww.esf.org/fileadmin/links/emrc/fl_idct.pdf), Difficulties Identified By European Medical Research Councils (EMRC) Three major issues are emerging: Persisting differences in administrative processes and in the interpretation of existing regulations and other processes have led to even higher levels of complexity especially in multinational clinical trials. Today, the sponsor of a clinical trial needs to have a very detailed knowledge of every country s requirements for clinical trial authorizations from both competent authorities and ethics committees. The sponsor has to integrate different national requirements to the protocol and may need parallel submission in multinational trials.

Eight Major Issues Lack of knowledge of and applying legislation regulations amongst different countries Differing Ethic Committees /IRBs Lack of expertise/resources across all centers Lack of standard definition of roles and responsibilities of investigators and sponsors Payment for Insurance Standard of care Different rules for ADRx (Adverse Events) Importation of Drug Products Requirements & Compliance with GMPs for Manufacturing of Advance Therapy Medicinal Products

Moving Applications and Protocols through Regulatory and Review Boards FDA and EU authorities, local authorities Gene Therapy trials RAC (Recombinant DNA Activities Committee) US Academic based Scientific Review Committees, Biohazard, Institutional Review Boards, Institutional Biosafety committee, etc.

Multiple Sites or One? Clinical Patient screening and assessments Collections Donor screening, assessments or testing Manufacturing Processing QC testing Special release testing Treatment Administration of the products Assessment post infusion Immediate and long term follow-up Outcome data gathering

Qualifying Other Sites Develop Selection Criteria Site Selection & Feasibility Questionnaire (SSFQ) Send to prospective participating sites to determine if they are able to meet DF/HCC and protocol requirements. Review SSFQs by the DF/HCC Sponsor prior to extending protocol participation to an external site. A Protocol Feasibility Questionnaire(PFQ) may be used for sites that have previously participated in a Multi-Center Protocol conducted by the same disease group and have previously completed the SSFQ for their site within the past year. Prospective participating sites that have satellite sites that will also be participating in the research must complete a Satellite Feasibility Questionnaire for each satellite site.

Use of a Similar Questionnaire for Collection and Manufacturing Services Quality Systems Facility Master File Facility site qualifications Classified vs not classified space Equipment Personnel qualifications Accreditations requirements Manufacturing and testing ability Ability to accommodate manufacturing and testing volumes

Special Requirements for Testing and Manufacturing Services Ability to screen and tests donors according to local and international regulations Use of a centralized site for some tests Pathology and Genetic assessments Radiological services Similar for QC testing Centralized specialized testing, CFUs, VCN, etc. Centralize testing for product characterization, Sterility, Mycoplasma, Endotoxin

PICs Pharmaceutical Inspection Co-operation Scheme (Guide to GMP for Medicinal Products) 20-Sections (Annexes) Relevant sections to Cellular Therapy Manufacturing Annex 1: Manufacture of Sterile Medicinal Products Annex 2 Manufacture of Biological Medicinal Substances and Products for Human Use Annex 8: Sampling of Staring and Packaging Materials Annex 11: Computerized Systems Annex 13: Manufacture of Investigational Medicinal Products Annex 14: Manufacture of Medicinal Product Derived from Human Blood or Plasma Annex 15: Qualification and Validation Annex 18: GMP Guide for Active Pharmaceutical Ingredients Annex 19: Reference and Retention Samples Annex 20: Quality Risk Management Website: http://www.picsheme.org

Novel Cell Therapy Products Fall Under PICs GMPs

Annex 1: Manufacture of Sterile Medicinal Products Facility standards - Classifications Air HVAC requirements In operation classification may be demonstrated during normal operations, simulated operations or during media fills as worst-case simulation is required for this. EN ISO 14644-2 provides information on testing to demonstrate continued compliance with the assigned cleanliness classifications.

Environmental Monitoring Aseptic Processing Frequent monitoring methods such as settle plates, volumetric air and surface sampling (e.g. swabs and contact plates). Results from monitoring should be considered when reviewing batch documentation for finished product release. Surfaces and personnel should be monitored after critical operations. Additional microbiological monitoring is also required outside production operations, After validation of systems, cleaning and sanitization. Three media fills per person repeated every 6 months Recommended limits for microbiological monitoring of clean areas during operation: If alert and action limits are exceeded operating procedures should prescribe corrective action.

Annex 1 Manufacture of Sterile Medicinal Products Validation of aseptic processing should include a nutrient media fill Process simulation should mimic the actual manufacturing steps as closely as possible Three consecutive satisfactory simulation tests per shift and repeated at defined intervals and after any significant modifications to HVAC Normally at least twice per year per shift / process / person

EudraLex Rules Governing Medicinal Products in the EU Vol 4, EU Guidelines to GMP Medicinal Products for Human and Veterinary Use, Part 1, Chapter 3 Quality Management General 3.5 Preventing Unauthorized Entry Premises and Equipment Not only for manufacturing space Manufacturing Badge in and out Limited Access by room

EudraLex The Rules Governing Medicinal Products in the European Union Volume 4 EU Guidelines for Good Manufacturing Practice for Medicinal Products for Human and Veterinary Use Part 1 Chapter 3: Premises and Equipment 3.18 Storage of sufficient capacity to allow orderly storage of various categories of materials and products: starting and packaging materials, intermediate, bulk and finished products, products in quarantine released, rejected or recalled materials

or Use of Per Institutional SOPs or Controlled Procedures Consents and protocols Screening tools SOPs Batch Records Labels Data repositories CRF What language(s) or dialect(s) Date format (dd/mm/yyyy) Patient identifiers Name / no name Surname, Study IDs Naming convention

Site Master File Part III of the GMP (Good Manufacturing Practice) guidelines on the preparation of the site master file Site master File: document describing the GMP related activities of the manufacturer http://ec.europa.eu/enterprise/newsroom/cf/itemd etail.cfm?&item_id=3944

Develop Clinical Protocol Specific Data and Safety Monitoring Plan (DSMP) DF/HCC Multi-Center International Data and Safety Monitoring Plan (DSMP) template. The DSMP should be tailored to the study and serves as a reference for the Participating Site(s) outlining the expectations for participating in a DF/HCC Multi-Center Protocol. DSMP as Attachment/appendix to the protocol.

Annex 2 - Part A. General guidance Documentation Biological starting materials Auto and Donor Matched the manufactured product is a batch Full traceability (30 years) For ATMPs, traceability requirement regarding human cells including hematopoietic cells must comply with the principles laid down in national legislation (In the EEA, these are Directives 2004/23/EC and 2006/86/EC) Research and Quality Agreements between the responsible parties should define traceability and retention periods Production -Full traceability of Biological Starting Materials

Production Starting Materials Raw Materials (e.g. cryoprotectants, feeder cells, reagents, culture media, buffers, serum, enzymes, cytokines, growth factors) should be clearly defined. Source, qualifications and testing, along with source documents Qualify before use Have process in place to reject CT product batch if QC testing of raw material fail Identification testing of all starting materials Compliance with the requirements appropriate to manufacturing stage Reference: Part I and Annex 8 for biological medicinal products and Part II for biological substances

Production Starting Materials (e) The transport of human tissues and cells to the manufacturing site must be controlled by a written agreement between the responsible parties. The manufacturing sites should have documentary evidence of adherence to the specified storage and transport conditions. (f) Continuation of traceability requirements started at tissue establishments through to the recipient(s), and vice versa, including materials in contact with the cells or tissues, should be maintained. (g) A technical agreement should be in place between the responsible parties (e.g. manufacturers, tissue establishment, Sponsors, MA Holder) which defines responsibilities of each party, including the RP.

Production Starting Materials for Gene Therapy (a) For products consisting of viral vectors, the starting materials are the components from which the viral vector is obtained, master virus seed or the plasmids to transfect the packaging cells and the MCB of the packaging cell line (b) For products consisting of plasmids, non-viral vectors and genetically modified micro-organisms other than viruses or viral vectors, the starting materials are the components used to generate the producing cell, the plasmid, the host bacteria and the MCB of the recombinant microbial cells (c) For genetically modified cells, the starting materials are the components used to obtain the genetically modified cells, the starting materials to manufacture the vector and the human or animal cell preparations. (d) The principles of GMP apply from the bank system used to manufacture the vector or plasmid used for gene transfer

Quality Control for Release Testing Process Control in place for Batch Certification or COA prior to completion of final product QC tests The procedure for batch certification and release may be carried out in stages before and after full QC analytical test results are available: Use of rapid microbiological tests may help Designated review Assessment of batch processing records, Results from environmental monitoring (where available), Deviations from normal procedures, Available analytical results Conditional certification / Sign-off by the Responsible Person.

Training Do you train and standardize the whole process patient selection to infusion or just in-lab manufacturing? Patient selection criteria Esoteric markers, pathology slides, radiology, etc Collection Processing Infusion Follow up care

Validations How to compare performance Product assessments Single QC lab for all sites vs each processing facility All tests or just esoteric test (RCR, RCL) Source material Supplies/reagents/equipment Periodic reassessments Proficiency testing

Same or Equivalent Supplies & Reagents Critical Supplies / Reagents / Study drug Equipment QC tests / methods CLIA approved lab Central lab or each site Flow Cytometry Gating strategies CFU assays ELISA, PCR, etc Pathology Proficiency samples

Challenges in Exporting Products to EU Countries Multiple and varying regulations Shipping Advance Therapy Medicinal Products Need of a broker / Competent Authority to accept ATMP Product on your behalf Need to establish a process to qualify US Academic Manufacturing Facilities as EU acceptable GMP facilities

Communication is Vital, yet Challenging Face to face vs WebEx Frequency Time zones Language and cultural differences Technical differences

Use of Centralized Documents and Clinical Research Documents SOPs, batch records, CRF Measuring performance - Dashboards e-trial Master File documents Inspection ready Audits

Challenges of Shared e-information Systems / Data Base Annex -11 Applications should be validated and infrastructure qualified Documented Risk Management System for both clinical and lab based systems Formal agreements with 3 rd party providers (including in-house IT departments) 21 CFR part 11 Compliance Need appropriate Risk Management Patient safety and protection of PHI Data integrity Product quality

Cloud Technology vs Portal system etrial Master Files Cloud allows academic centers as well as small and medium businesses with technology Working together in a collaborative space Web-base document management systems Document management, exchange and tracking across all centers and groups (CRO, investigators, sponsors, manufacturing sites, etc) Web-base data capture systems Outsource or not Overcoming IT security

Need for Web Based Regulatory Repository Create a common web-based repository of information about national laws and regulations for performing clinical trials. Provide a list the key information and documents; How to start, conduct a clinical trial How to report events List of key contacts and links to the Internet sites of national competent authorities.

International Collaborations for Novel CT Trials Continue to work together setting up and managing multi-center clinical trials is complex Academic researchers for non-commercial purposes form a substantial and critical role in medical research and there is an increasing need for Academic Centers to participate in / or run Multicenter Cell Therapy Clinical Trials Rare Diseases Personalized Medicine trials Advancement of Science This will not be possible without national or local support and it is vital to keep patients and general public actively involved to partner and push for national support for the advancement of these novel trials