Glybera
alipogene tiparvovec
Sources:EMA assessment report ↗
Species
MouseRabbit
Longest study
26 wk
Genotox
Not conducted Not conducted
Carcinogenicity
Not conducted Not conducted
Repro
Conducted Conducted
First dose
Partial / alternative Partly stated
Speciesopen answer page →
Species
Wild-type mouse only for GLP tox; PD in LPL-/- mice and LPL-deficient cats; biodistribution in cats, mice, rabbits
“All toxicity studies were performed in wild type mice in accordance with GLP.”
Why that species
Single species accepted per EU gene therapy guidelines; LPL-deficient mice and cats used as disease models
“The use of a single species for toxicity evaluation is in accordance with the guideline for gene therapy medicinal products EMEA/CHMP/GTWP/587488/2007 and the guideline on the non-clinical studies required before first clinical use of gene therapy medicinal products (EMEA/CHMP/GTWP/12459/2006).”
Surrogate molecule
No surrogate; clinical vector AMT-011 (baculovirus) and earlier plasmid-derived AMT-010 tested in mice
“Studies were conducted with AMT-010 (plasmid derived) and several different batches of AMT-011 (baculovirus derived) and doses ranged from 1x1011 – 1x1013 gc/kg.”
Species: general tox
Wild-type mouse only (single-dose IM/IV studies)
“All toxicity studies were performed in wild type mice in accordance with GLP.”
Species: DART
Mouse (pregnant mice: female reproduction and fetal development)
“Reproductive toxicity was studied in pregnant mice in whom no effects of female reproduction or fetal development were detected.”
Species: carcinogenicity
Not conducted; integration studies argued sufficient
“Carcinogenicity studies have not been conducted. The applicant argues that the studies conducted to assess integration are sufficient to address risk of carcinogenicity.”
Surrogate used in
No surrogate; plasmid-derived AMT-010 and clinical baculovirus-derived AMT-011 both tested
“Studies were conducted with AMT-010 (plasmid derived) and several different batches of AMT-011 (baculovirus derived) and doses ranged from 1x1011 – 1x1013 gc/kg.”
Study lengthopen answer page →
Longest pivotal study
26 weeks
“Moreover, the long-term expression of the therapeutic gene has been taken into account by including an extended follow-up period of 6 months in one of the single dose toxicity studies performed with AMT-011.”
Pivotal GLP studies
Single-dose IM mouse studies: AMT-010 (90-day), AMT-011 (180-day, 105-day with immunosuppression); combined repro/breeding study
“The non-clinical toxicology programme of Glybera included one single dose toxicity study performed with AMT-010 with a 90-day observation period, two single dose toxicity studies performed with AMT-011 with a 180-day and 105-day observation period, respectively, and a combined reproductive toxicology and breeding study performed with AMT-011.”
Route in tox
Intramuscular (clinical route); intravenous as worst case
“The single dose toxicity studies reflect the clinical dosing situation by addressing the toxic effects following either IM (clinical use) or IV (worst case scenario) administration of AMT-011 at a single occasion.”
Skipped studiesopen answer page →
Genotoxicity
Not conducted (standard tests not relevant); integration studies (LAM-PCR, nrLAM-PCR) instead
“Standard genotoxicity studies, as applied to a conventional chemical drug, are not relevant for this type of product and were not performed.”
Carcinogenicity
Not conducted; integration analyses argued sufficient (97% episomal, <2% near-random integration)
“Carcinogenicity studies have not been conducted. The applicant argues that the studies conducted to assess integration are sufficient to address risk of carcinogenicity.”
Instead of carcinogenicity
Integration analysis: no risky hotspots or clonal skewing, integration events detectable (<2%) and close to random
“Integration analysis did not identify any risky integration hotspots or clonal skewing that might indicate risk of mutagenesis on insertion of AMT-011 into the genome. Integration events were detectable (<2%) but were close to random in the genome.”
DRG histopathology
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
Reproductive & developmental
Mouse repro study: no effects on female reproduction or fetal development; male breeding study showed no paternal germline transmission
“Reproductive toxicity was studied in pregnant mice in whom no effects of female reproduction or fetal development were detected.”
Safety pharmacology
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
Genotox: Ames
Not conducted (standard genotoxicity tests not relevant for this product)
“Standard genotoxicity studies, as applied to a conventional chemical drug, are not relevant for this type of product and were not performed.”
Genotox: in vitro mammalian
Not conducted (standard genotoxicity tests not relevant for this product)
“Standard genotoxicity studies, as applied to a conventional chemical drug, are not relevant for this type of product and were not performed.”
Genotox: in vivo
Not conducted (standard genotoxicity tests not relevant for this product)
“Standard genotoxicity studies, as applied to a conventional chemical drug, are not relevant for this type of product and were not performed.”
Carcinogenicity model
Not conducted; replaced by vector integration analyses: 97% of vector not integrated (episomal)
“Studies using techniques to selectively digest genomic DNA showed that the majority (97%) of AMT-011 is not integrated into the genome, implying their presence episomally.”
Carcinogenicity timing
Not conducted: no study design accepted as relevant to assess insertional mutagenesis and oncogenicity
“In vivo carcinogenicity studies have not been conducted. The applicant argued that there is no existing study design that would be accepted as relevant to assess insertional mutagenesis and the risk of oncogenicity”
hERG / QT
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
First doseopen answer page →
First-in-human starting dose
Not explicitly justified; clinical 1x10^12 gc/kg lies within active range in LPL-/- mice (10^11-10^13); tox covered 10x
“Activity was demonstrated in the dose range 1011-1013 gc/kg compared to the proposed human dose of 1x1012 gc/kg.”
NOAEL / key findings
NOAEL 1x10^11 gc/kg IM (mouse); dose-related injection-site myodegeneration and sub-acute inflammation, reversible; no systemic toxicity
“At the injection sites, histopathological findings including myodegenerative changes and sub-acute inflammation were consistently found in all three single dose toxicity studies upon IM administration of either 1x 1012 or 1 x1013 gc/kg AMT-010 and AMT-011, respectively.”
Risksopen answer page →
Immune & cytokine safety
Neutralising anti-AAV1 capsid antibodies blocked readministration; no CD8+ T cells in infiltrates; no anti-LPL antibodies
“on readministration, the second dose was not able to elicit a response, an effect attributable to formation of neutralising antibodies to AAV1 capsid.”
Biodistribution & persistence
Injected muscle, liver, spleen, inguinal lymph nodes; gonads/semen positive; incomplete clearance by 180 days in mice
“The main tissues where vector DNA was detected were the injected muscle, liver, spleen and inguinal lymph nodes.”
Modality-specific risk
Tumourigenicity via rAAV integration and WPRE (WHV X protein); local muscle toxicity from LPL overexpression; germline transmission
“The consensus view is that rAAV vector genomes remain episomal with minimal integration into the mammalian genome with no association with oncogenicity.”
Anti-drug antibodies: animals
Neutralising anti-AAV1 capsid antibodies blocked response to a second dose in LPL-/- mice
“on readministration, the second dose was not able to elicit a response, an effect attributable to formation of neutralising antibodies to AAV1 capsid.”
Anti-drug antibodies: patients
Antibody responses in all treated patients, precluding re-treatment
“High rates of immune response in terms of antibody development were seen in all cases thereby precluding retreatment.”
Tox packageopen answer page →
Before first-in-human
First-in-human: where
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
Repeat-dose tox before first-in-human
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
First-in-human starting dose
Not explicitly justified; clinical 1x10^12 gc/kg lies within active range in LPL-/- mice (10^11-10^13); tox covered 10x
“Activity was demonstrated in the dose range 1011-1013 gc/kg compared to the proposed human dose of 1x1012 gc/kg.”
Longest repeat-dose systemic studies
Longest repeat-dose study and recovery
No repeat-dose study (single administration at multiple intramuscular sites)
“Repeated dose toxicity studies were not conducted as Glybera will be administered once at multiple sites intramuscularly.”
Pivotal GLP studies
Single-dose IM mouse studies: AMT-010 (90-day), AMT-011 (180-day, 105-day with immunosuppression); combined repro/breeding study
“The non-clinical toxicology programme of Glybera included one single dose toxicity study performed with AMT-010 with a 90-day observation period, two single dose toxicity studies performed with AMT-011 with a 180-day and 105-day observation period, respectively, and a combined reproductive toxicology and breeding study performed with AMT-011.”
DART package
Species: DART
Mouse (pregnant mice: female reproduction and fetal development)
“Reproductive toxicity was studied in pregnant mice in whom no effects of female reproduction or fetal development were detected.”
Reproductive & developmental
Mouse repro study: no effects on female reproduction or fetal development; male breeding study showed no paternal germline transmission
“Reproductive toxicity was studied in pregnant mice in whom no effects of female reproduction or fetal development were detected.”
PPND / ePPND: when
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
Carcinogenicity
Species: carcinogenicity
Not conducted; integration studies argued sufficient
“Carcinogenicity studies have not been conducted. The applicant argues that the studies conducted to assess integration are sufficient to address risk of carcinogenicity.”
Carcinogenicity model
Not conducted; replaced by vector integration analyses: 97% of vector not integrated (episomal)
“Studies using techniques to selectively digest genomic DNA showed that the majority (97%) of AMT-011 is not integrated into the genome, implying their presence episomally.”
Carcinogenicity timing
Not conducted: no study design accepted as relevant to assess insertional mutagenesis and oncogenicity
“In vivo carcinogenicity studies have not been conducted. The applicant argued that there is no existing study design that would be accepted as relevant to assess insertional mutagenesis and the risk of oncogenicity”
Safety marginopen answer page →
Safety margin at NOAEL
No margin: dose-related muscle toxicity at the recommended clinical dose (mouse)
“There appears to be progressive and dose-related muscle toxicity at the recommended clinical dose. This has been shown to be reversible.”
NOAEL / key findings
NOAEL 1x10^11 gc/kg IM (mouse); dose-related injection-site myodegeneration and sub-acute inflammation, reversible; no systemic toxicity
“At the injection sites, histopathological findings including myodegenerative changes and sub-acute inflammation were consistently found in all three single dose toxicity studies upon IM administration of either 1x 1012 or 1 x1013 gc/kg AMT-010 and AMT-011, respectively.”
Efficacy evidenceopen answer page →
Efficacy evidence
LPL-/- mice and LPL-deficient cats: triglyceride-lowering pharmacodynamic activity
“Overall, the applicant showed relevant pharmacodynamic activity of AMT-010 and AMT-011 in LPL-/- mice and/or cats.”
Why that model
Genetic LPL-deficient models available, but LPL-/- mice do not develop acute pancreatitis, the key human complication
“However, LPL-/- mice do not develop acute pancreatitis, which is the most severe complication observed in humans suffering from LPLD.”
Reviewer's view of the efficacy data
Long-lasting LPL expression with marked triglyceride lowering accepted as pharmacological surrogate for efficacy
“A single dose was able to induce a long-lasting expression of transgene, human LPL, which was associated with a clear effect to reduce raised triglycerides very markedly. This is considered to be an acceptable pharmacological surrogate for efficacy.”
Test articleopen answer page →
Test article vs clinical lot
Plasmid-derived AMT-010 batches and the baculovirus-derived commercial product AMT-011 both used in non-clinical studies. Bridging: AMT-011 qualified independently of AMT-010 on non-clinical data; toxicology and pharmacology studies were repeated with AMT-011
“Different batches of AMT-010 (plasmid derived) were used and the applicant intended to compare AMT-010 and AMT-011 (baculovirus derived) in non clinical bridging studies.”
Vector and route
Given intramuscularly, expressing the transgene within the muscle
“Studies to investigate absorption have not been conducted. The product is given intramuscularly and the expectation is that Glybera expresses the transgene within the muscle.”
First approval
Not stated in public reviews
Not reported in the public reviews. Reviewers summarise selectively, so this usually means it wasn't discussed publicly, not that it wasn't studied.
Flexibilityopen answer page →
Flexibility accepted
SpeciesAccepted
Toxicity evaluated in a single species (wild-type mice) only
Why: In accordance with EU gene therapy guidelines · Within the guideline
“The use of a single species for toxicity evaluation is in accordance with the guideline for gene therapy medicinal products EMEA/CHMP/GTWP/587488/2007 and the guideline on the non-clinical studies required before first clinical use of gene therapy”
“The use of a single species for toxicity evaluation can be accepted for Glybera.”
CarcinogenicityAcceptedBeyond the letter
No in vivo carcinogenicity studies; vector integration analyses and literature review instead
Why: No relevant study design exists for insertional mutagenesis and oncogenicity; integration and literature data do not substantiate a tumourigenicity concern · Weight of evidence
“The applicant argued that there is no existing study design that would be accepted as relevant to assess insertional mutagenesis and the risk of oncogenicity: the validity of any study design is questionable.”
“Overall, the CAT and CHMP finally agreed with the applicant that the data do not substantiate a concern for tumourigenicity.”
OtherQuestioned
Nonclinical bridging between plasmid-derived and baculovirus-derived vector used too few mice to be conclusive
“Different batches of AMT-010 were compared and the applicant intended to compare AMT-010 and AMT-011 in bridging studies, but as so few mice were used in each test, the conclusions from these tests very limited.”
Safety marginVerdict not stated
No margin: progressive dose-related muscle toxicity in mice at the recommended clinical dose
Why: Muscle toxicity shown to be reversible
“There appears to be progressive and dose-related muscle toxicity at the recommended clinical dose. This has been shown to be reversible.”
OtherCriticised but acceptedBeyond the letter
No study with a control AAV to separate LPL overexpression from vector effects in muscle toxicity
Why: Such a study would not remove the evidence of concern · Other reason
“The CAT did not fully agree with the applicant’s justification for lack of further experimental evidence to compare the effect of a control adeno-associated virus and AMT-011 to study the significance of LPL overexpression.”
“Such a study would however not remove the evidence of concern and therefore was finally not further requested and the issue considered solved.”
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