Strimvelis
autologous CD34+ cells transduced with ADA (no INN)
Sources:EMA assessment report ↗
Species
Mouse
Longest study
16 wk
Genotox
Not conducted Not conducted
Carcinogenicity
Not conducted Not conducted
Repro
Not conducted Not conducted
First dose
Partial / alternative Partly stated
Speciesopen answer page →
Species
NSG immunodeficient mouse only (xenograft of transduced human CD34+ cells)
“The use of NSG mouse strain (deficient in mature T/B/NK cells) for the non-clinical biodistribution/single-dose toxicology study after engraftment of CD34+ cells derived from healthy human UCB, transduced with GSK3336223 vector, was endorsed by the CAT/CHMP prior to MAA submission.”
Why that species
NSG supports human HSPC engraftment with longer survival and fewer spontaneous tumours than ADA-/- mice; no cross-reactivity issue (human cells)
“Subsequently, the results of two bio-distribution studies were submitted using the NSG mouse based on the reports presented that indicate this is a valid model for immunodeficient mice, which can be used as recipient of HSPC transplantation, with longer survival rates and reduced frequency of spontaneous tumours as compared to ADA-/- mice.”
Surrogate molecule
Yes: healthy-donor cord blood CD34+ cells transduced with clinical RV (GSK3235757A); murine lin- BM cells for oncogenicity pilots
“The test item used in the biodistribution studies (referred to as GSK3235757A) comprised of CD34+ cells derived from healthy human UCB transduced with GSK3336223 vector and is accepted as representative of Strimvelis.”
Species: general tox
NSG immunodeficient mouse only (single-dose IV biodistribution/toxicology)
“Toxicology was evaluated in a single dose (IV) mouse (NSG) biodistribution/toxicology studies.”
Species: DART
Not conducted
“No reproductive or developmental toxicity studies were conducted with GSK2696273.”
Species: carcinogenicity
Not conducted (no adequate model; long-term engraftment of transduced cells not achievable in mice)
“Accordingly, the SmPC states that carcinogenicity studies have not been conducted as no adequate animal model was available to evaluate the tumourigenic potential of Strimvelis due to the inability to achieve long-term engraftment of transduced cells in mice.”
Surrogate used in
Yes: healthy human UCB cells (GSK3235757A) and murine lin- BM cells (GSK2959346) transduced with the clinical vector
“GSK3235757A stands for Healthy human UCB transduced with GSK3336223 vector; GSK2959346 stands for Murine lin- BM cells transduced with GSK3336223 vector.”
Study lengthopen answer page →
Longest pivotal study
16 weeks
“The observation time to determine survival, engraftment and clinical signs in this combined biodistribution/toxicology study was 16 weeks.”
Pivotal GLP studies
One GLP combined biodistribution/toxicity study: busulfan-conditioned NSG mice, single IV dose of transduced UCB CD34+ cells, 16 weeks
“In this study, NSG mice (n=10/sex/group) were pre-conditioned with busulfan [40 mg/kg total dose over 2 days; intraperitoneal (IP)] prior to dosing transduced cells”
Route in tox
Intravenous (single dose); busulfan conditioning IP
“Toxicology was evaluated in a single dose (IV) mouse (NSG) biodistribution/toxicology studies.”
Skipped studiesopen answer page →
Genotoxicity
Not conducted (conventional assays cannot detect insertional events)
“Conventional genotoxicity assays are inappropriate to detect insertional events and would not provide additional information to inform a quantitative risk assessment in humans and hence no studies have been conducted.”
Carcinogenicity
Not conducted (no adequate model; long-term engraftment of transduced cells in mice not achievable); relies on clinical follow-up
“Accordingly, the SmPC states that carcinogenicity studies have not been conducted as no adequate animal model was available to evaluate the tumourigenic potential of Strimvelis due to the inability to achieve long-term engraftment of transduced cells in mice.”
Instead of carcinogenicity
Tumourigenicity risk assessment based on clinical data and literature on similar vectors instead of a full tumourigenicity study
“In summary, in previous scientific advice, it was agreed that the tumourgenicity risk assessment for GSK2696273 could be based on clinical data and literature on similar vectors if tumourgenicity/general toxicity studies were unsuccessful in allowing for the determination of optimal conditions for a full tumourgenicity study.”
DRG histopathology
Not applicable: ex vivo HSC product, no vector administered to patients
Reproductive & developmental
Not conducted; gonad histopathology in biodistribution study (busulfan-related atrophy); germline risk via clinical monitoring
“No reproductive or developmental toxicity studies were conducted with GSK2696273.”
Safety pharmacology
Not conducted (not feasible or relevant; ADA expressed at or below physiological levels)
“As per the applicant’s statement, no safety pharmacology studies were considered feasible in animals or relevant to the administration of GSK2696273 to humans.”
Genotox: Ames
Not conducted (conventional assays cannot detect insertional events)
“Conventional genotoxicity assays are inappropriate to detect insertional events and would not provide additional information to inform a quantitative risk assessment in humans and hence no studies have been conducted.”
Genotox: in vitro mammalian
Not conducted (conventional assays cannot detect insertional events)
“Conventional genotoxicity assays are inappropriate to detect insertional events and would not provide additional information to inform a quantitative risk assessment in humans and hence no studies have been conducted.”
Genotox: in vivo
Not conducted (conventional assays cannot detect insertional events)
“Conventional genotoxicity assays are inappropriate to detect insertional events and would not provide additional information to inform a quantitative risk assessment in humans and hence no studies have been conducted.”
Carcinogenicity model
Not conducted; pilot tumorigenicity studies could not achieve long-term engraftment of transduced cells in mice
“Conducted pilot studies indicate that a tumourgenicity study is not feasible since it was not possible to demonstrate long-term engraftment of transduced cells in mice.”
Carcinogenicity timing
Not required; tumorigenicity risk assessment based on clinical data and literature on similar vectors
“In summary, in previous scientific advice, it was agreed that the tumourgenicity risk assessment for GSK2696273 could be based on clinical data and literature on similar vectors if tumourgenicity/general toxicity studies were unsuccessful in allowing for the determination of optimal conditions for a full tumourgenicity study.”
hERG / QT
Not conducted; safety pharmacology not considered feasible or relevant
“As per the applicant’s statement, no safety pharmacology studies were considered feasible in animals or relevant to the administration of GSK2696273 to humans.”
First doseopen answer page →
First-in-human starting dose
No nonclinical dose justification stated; first (investigator-initiated) protocol based on nonclinically optimised transduction conditions
“The first ADA/SCID clinical protocol for Study Number AD1117054 was based on the optimised transduction conditions from the nonclinical studies described above.”
NOAEL / key findings
No test-item-related adverse effects at 10x10^6 CD34+ cells/kg (about half max clinical dose); busulfan-related gonadal atrophy, deaths
“In this study, mice were administered 10 x106 CD34+ cells/kg (approximately the midpoint of the dose range to be infused in human subjects) without test-item-related adverse effects.”
Risksopen answer page →
Immune & cytokine safety
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.
Biodistribution & persistence
Engraftment in BM, spleen, thymus, blood; low human DNA/RV in non-target organs and gonads (residual blood); no non-target transduction
“Biodistribution analysis did not show any evidence of transduction of non-target cells: vector DNA was only detected in the presence of donor cells.”
Modality-specific risk
Gamma-retroviral insertional oncogenesis (LMO2-type integrations) and clonal expansion; undeterminable nonclinically, 15-year clinical follow-up
“From a non-clinical perspective, the carcinogenic potential due to insertional mutagenesis and the potential for subsequent clonal expansion cannot be determined at the time of assessment.”
Anti-drug antibodies: animals
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.
Anti-drug antibodies: patients
Not tested; immunogenic response to autologous cells with intracellular ADA considered unlikely
“No immunogenicity testing has been conducted. The applicant stated that GSK2696273 is comprised predominately of autologous-derived cells with intracellular ADA, in which an immunogenic response of any sort would be unlikely.”
Tox packageopen answer page →
Before first-in-human
First-in-human: where
Israel: first administered in 2000 to one ADA-SCID patient at Hadassah University, Jerusalem (pilot study)
“GSK2696273 was first administered to humans in 2000 in a pilot clinical study with one subject with confirmed ADA-SCID who had no HLA-identical sibling or prior ERT therapy received treatment and follow-up at Hadassah University (Jerusalem, Israel), with the cooperation of HSRTIGET.”
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
No nonclinical dose justification stated; first (investigator-initiated) protocol based on nonclinically optimised transduction conditions
“The first ADA/SCID clinical protocol for Study Number AD1117054 was based on the optimised transduction conditions from the nonclinical studies described above.”
Longest repeat-dose systemic studies
Longest repeat-dose study and recovery
No repeat-dose study (single administration of patient-derived cells)
“Due to the nature of Strimvelis, repeat dose toxicity studies were not conducted since GSK2696273 consists of patient-derived cells that are intended to consist of the ADA gene, to allow for expression of the related ubiquitous protein at or below physiological levels.”
Pivotal GLP studies
One GLP combined biodistribution/toxicity study: busulfan-conditioned NSG mice, single IV dose of transduced UCB CD34+ cells, 16 weeks
“In this study, NSG mice (n=10/sex/group) were pre-conditioned with busulfan [40 mg/kg total dose over 2 days; intraperitoneal (IP)] prior to dosing transduced cells”
DART package
Species: DART
Not conducted
“No reproductive or developmental toxicity studies were conducted with GSK2696273.”
Reproductive & developmental
Not conducted; gonad histopathology in biodistribution study (busulfan-related atrophy); germline risk via clinical monitoring
“No reproductive or developmental toxicity studies were conducted with GSK2696273.”
PPND / ePPND: when
Not conducted; busulfan conditioning is known to be gonadotoxic
“No reproductive or developmental toxicity studies were conducted with GSK2696273. Patients will receive a low dose of busulfan as pre-conditioning treatment.”
Carcinogenicity
Species: carcinogenicity
Not conducted (no adequate model; long-term engraftment of transduced cells not achievable in mice)
“Accordingly, the SmPC states that carcinogenicity studies have not been conducted as no adequate animal model was available to evaluate the tumourigenic potential of Strimvelis due to the inability to achieve long-term engraftment of transduced cells in mice.”
Carcinogenicity model
Not conducted; pilot tumorigenicity studies could not achieve long-term engraftment of transduced cells in mice
“Conducted pilot studies indicate that a tumourgenicity study is not feasible since it was not possible to demonstrate long-term engraftment of transduced cells in mice.”
Carcinogenicity timing
Not required; tumorigenicity risk assessment based on clinical data and literature on similar vectors
“In summary, in previous scientific advice, it was agreed that the tumourgenicity risk assessment for GSK2696273 could be based on clinical data and literature on similar vectors if tumourgenicity/general toxicity studies were unsuccessful in allowing for the determination of optimal conditions for a full tumourgenicity study.”
Safety marginopen answer page →
Safety margin at NOAEL
Mouse dose without test-item-related effects only about half the highest human dose (cells/kg)
“The doses administered provide only safety margin of approximately half the highest dose administered in humans (20 x106 CD34+ cells/kg).”
NOAEL / key findings
No test-item-related adverse effects at 10x10^6 CD34+ cells/kg (about half max clinical dose); busulfan-related gonadal atrophy, deaths
“In this study, mice were administered 10 x106 CD34+ cells/kg (approximately the midpoint of the dose range to be infused in human subjects) without test-item-related adverse effects.”
Efficacy evidenceopen answer page →
Efficacy evidence
SCID-hu xenograft mice: transduced CD34+ cells engrafted and produced vector-marked, transgene-expressing T and B cells
“In vivo: Immunodeficient mice were implanted with human hematolymphoid tissues (SCID-hu mice), irradiated and transplanted with a single dose of cultured/transduced CD34+ cells. The transduced CD34+ cells engrafted in mice, produced vector-marked and transgene expressing T and B cells and maintained in vivo lymphoid reconstitution capacity.”
Why that model
Ethical limits on harvesting human bone marrow; human-to-mouse xenotransplantation models used instead
“Because ethical restrictions of harvesting of human bone marrow for experimental purposes limit in vivo studies of the human hematolymphoid system, substitute human to small animal xenotransplantation models has been employed.”
Reviewer's view of the efficacy data
CAT/CHMP: gene expressed at relevant sites at an appropriate level with functional activity realised
“Pharmacology studies indicated that the gene is expressed at the relevant site(s) at an appropriate level and that functional activity is realised.”
Test articleopen answer page →
Test article vs clinical lot
CD34+ cells from healthy human umbilical cord blood transduced with the GSK3336223 vector, used instead of patient cells. Bridging: The test item was accepted as representative of Strimvelis
“The test item used in the biodistribution studies (referred to as GSK3235757A) comprised of CD34+ cells derived from healthy human UCB transduced with GSK3336223 vector and is accepted as representative of Strimvelis.”
Vector and route
Autologous CD34+ cells transduced with a retroviral vector encoding adenosine deaminase; administered on a single occasion by infusion
“GSK2696273 consists of an autologous CD34+ enriched cell fraction that contains CD34+ cells transduced with retroviral vector that encodes for the human adenosine deaminase complementary DNA sequence. It is intended to be administered on a single occasion since after infusion CD34+ cells migrate to the bone marrow where they engraft”
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
CarcinogenicityAcceptedBeyond the letter
No tumorigenicity study: long-term engraftment of transduced cells in mice not achievable; risk assessed from clinical data and vector literature
Why: Agreed in scientific advice that tumorigenicity risk could rely on clinical data and literature on similar vectors · Human data · Class precedent
“Accordingly, the SmPC states that carcinogenicity studies have not been conducted as no adequate animal model was available to evaluate the tumourigenic potential of Strimvelis due to the inability to achieve long-term engraftment of transduced cells in mice.”
“In summary, in previous scientific advice, it was agreed that the tumourgenicity risk assessment for GSK2696273 could be based on clinical data and literature on similar vectors if tumourgenicity/general toxicity studies were unsuccessful in allowing for the determination of optimal conditions for a full tumourgenicity study.”
Safety marginAcceptedBeyond the letter
Mouse biodistribution/toxicology dose only about half the highest human dose (cells/kg)
Why: Proposed indication and risk evaluation; vector copy number kept as low as possible · Serious disease
“The doses administered provide only safety margin of approximately half the highest dose administered in humans (20 x106 CD34+ cells/kg).”
“Although it is not possible to establish a safe VCN, this has been maintained at a lowest possible degree that results in sufficient transduction efficiency. Taking into account the proposed indication and the evaluation of the risk of use of the product, the CAT/CHMP considered this issue resolved.”
OtherAcceptedBeyond the letter
Toxicology test item was healthy cord-blood CD34+ cells transduced with the clinical vector, not patient product; test item preparation non-GLP
Why: Test item accepted as representative of the product · Other reason
“Preparation of the test items (transduced and mock-transduced) was performed by MolMed and was not conducted to GLP.”
“The test item used in the biodistribution studies (referred to as GSK3235757A) comprised of CD34+ cells derived from healthy human UCB transduced with GSK3336223 vector and is accepted as representative of Strimvelis.”
BiodistributionAccepted
No nonclinical germline transmission studies of the genetically modified human cells
Why: Low germline transfer risk; animal testing of human cells not meaningful; patients mostly treated before puberty · Low-risk modality · Within the guideline
“It is noted that the risk of germline transfer associated with the administration of genetically modified human cells is considered to be low and animal testing of human cells may be difficult if not meaningful; hence non-clinical germline transmission studies of human genetically modified cells are generally not recommended.”
“However, most ADA-SCID patients are treated within the first few years of life before puberty begins. No further studies with GSK2696273 were conducted and the absence of any additional studies is adequately justified.”
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