No relevant species; no in vivo tox. NSG xenograft (pharmacology) and human tissue cross-reactivity only
“Per the applicant, conventional nonclinical toxicology studies were not conducted because they do not yield clinically relevant information for a CAR T cell product.”
✓ VerifiedFDA pharmacology/toxicology review, p. 9Source ↗
Why that species
No pharmacologically responsive species; human autologous T cells will not engraft in immunocompetent animals; immunodeficient models uninformative
“Aucatzyl, a patient-specific product, is not appropriate for administration to immunocompetent animals, as the T cells will not engraft.”
No surrogate; nonclinical CAT19 CAR T cells from healthy-donor PBMCs with identical construct judged representative
“Despite minor differences between the nonclinical and clinical products, the constructs assessed, including the binding domain, were identical and therefore the nonclinical product is considered appropriate to assess safety and activity in the nonclinical program.”
✓ VerifiedFDA pharmacology/toxicology review, p. 5Source ↗
Species: general tox
None; general toxicity studies not conducted (no pharmacologically responsive species)
“The absence of general toxicity studies is accepted, considering that there are no pharmacologically responsive animal species (as also mentioned in the scientific advice, EMA/CHMP/SAWP/586752/2019).”
Not conducted (ICH S9; no pharmacologically relevant species)
“DART studies are not needed for indications falling under ICH S9 scope (advanced cancer) and no pharmacologically relevant animal species is available.”
Not conducted (ICH S9; no cross-reactivity with murine CD19)
“Carcinogenicity studies are not needed for indications falling under ICH S9 scope (advanced cancer). In addition, there is no cross-reactivity of the CD19-CAR T cells from Aucatzyl with the murine antigen.”
No surrogate used; nonclinical CAT19 CAR T cells with identical construct judged representative
“Despite minor differences between the nonclinical and clinical products, the constructs assessed, including the binding domain, were identical and therefore the nonclinical product is considered appropriate to assess safety and activity in the nonclinical program.”
✓ VerifiedFDA pharmacology/toxicology review, p. 5Source ↗