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Zalmoxis: what was done before first-in-human, and what came after?

allogeneic T cells modified with HSV-TK / dLNGFR (nalotimagene carmaleucel) · HSV-TK suicide-gene T cells

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 stated in public reviews
Why it's blank

The public FDA and EMA reviews of Zalmoxis don't say how the first human dose was chosen. That rationale is in the IND, which is confidential, so it is missing for most approved products.

How it's usually set for cell therapies

FDA expects preclinical proof-of-concept and toxicology studies to identify active dose levels and support the choice of starting dose and escalation. The 2013 guidance gives no numeric formula or scaling rule for the starting dose.

“Selection of potential starting dose level, dose-escalation schedule, and dosing regimen for clinical trials.”
✓ VerifiedFDA 2013: Preclinical Assessment of Investigational Cellular and Gene Therapy…, p. 7Source ↗
This product's starting point

NOAEL / key findings: No NOAEL; GvHD occurred in mice but with lower incidence/severity than unmanipulated PBL; limited safety assessment (EMA assessment report, p. 26)

Full method, every step sourced →

Longest repeat-dose systemic studies

Longest repeat-dose study and recovery
No repeat-dose study; single-dose toxicity assessed within immunodeficient-mouse GvHD pharmacodynamic studies
“Single dose toxicity has been assessed in the immunodeficient animal models in the pharmacodynamic studies. Repeat dose toxicity Repeat-dose toxicity studies were not submitted (See discussion on non-clinical aspects).”
✓ VerifiedEMA assessment report, p. 20Source ↗
Pivotal GLP studies
No GLP tox; two integrated PD/PK/tox NOD/SCID GvHD mouse studies (20x10^6 cells/mouse), up to ~3 weeks
“Single dose toxicity has been assessed in the immunodeficient animal models in the pharmacodynamic studies.”
✓ VerifiedEMA assessment report, p. 20Source ↗

DART package

Species: DART
Not conducted; absence considered justified
“The lack of studies on reproductive and development toxicity is justified.”
✓ VerifiedEMA assessment report, p. 26Source ↗
Reproductive & developmental
Not conducted; justified
“The lack of studies on reproductive and development toxicity is justified.”
✓ VerifiedEMA assessment report, p. 26Source ↗
PPND / ePPND: when
No reproductive toxicology studies; omission considered acceptable
“Conventional toxicology, carcinogenicity, mutagenicity and reproductive toxicology studies have not been performed, which is considered acceptable.”
✓ VerifiedEMA assessment report, p. 26Source ↗

Carcinogenicity

Species: carcinogenicity
Not conducted (species-specific product; rodent/NHP carcinogenicity studies not appropriate)
“The MM-TK DP is a species specific product and therefore standard carcinogenicity studies using rodents or non-human primates as described in the ICH guidelines are not appropriate.”
✓ VerifiedEMA assessment report, p. 22Source ↗
Carcinogenicity model
No in vivo study; in vitro clonality, insertion-site profile, growth-factor-independent growth and RCR assessments
“The in vitro studies pertain 1) evaluation of clonality of the transduced cell population, 2) characterisation of the insertional pattern, 3) evaluation of growth-factor independent growth, and 4) assessment of break out of replication competent retroviruses (RCR).”
✓ VerifiedEMA assessment report, p. 26Source ↗
Carcinogenicity timing
Not required: species-specific product, standard rodent/NHP carcinogenicity studies not appropriate; in vitro oncogenic-risk studies instead
“The MM-TK DP is a species specific product and therefore standard carcinogenicity studies using rodents or non-human primates as described in the ICH guidelines are not appropriate.”
✓ VerifiedEMA assessment report, p. 22Source ↗

Same question, other cell therapies

Abecma

idecabtagene vicleucel · BCMA CAR-T
Country not stated; first-in-human dose-finding study in patients with relapsed/refractory multiple myeloma (CRB-401)

Carvykti

ciltacabtagene autoleucel · BCMA CAR-T
Country not stated; first clinical trial in patients with relapsed/refractory multiple myeloma (LEGEND-2)

MACI

autologous cultured chondrocytes on porcine collagen membrane · Autologous chondrocytes
Outside the United States: all clinical studies ex-US (countries not named)

Tecelra

afamitresgene autoleucel · MAGE-A4 TCR-T
Country not stated; first-in-human dose-escalation and expansion study in HLA-A*02 patients with MAGE-A4-positive advanced tumors

Yescarta

axicabtagene ciloleucel · CD19 CAR-T
Country not stated; initial dose-finding study NCI 09-C-0082 in patients with advanced B-cell malignancies

Zemcelpro

dorocubicel · UM171-expanded cord blood CD34+
Canada: dose de-escalation study (Study 001) at 2 sites in patients needing allogeneic stem cell transplant

Alofisel

darvadstrocel · Allogeneic adipose MSC
Not stated in public reviews

Amtagvi

lifileucel · TIL therapy
Not stated in public reviews

Aucatzyl

obecabtagene autoleucel · CD19 CAR-T
Not stated in public reviews

Breyanzi

lisocabtagene maraleucel · CD19 CAR-T
Not stated in public reviews

ChondroCelect

characterised viable autologous cartilage cells · Autologous chondrocytes
Not stated in public reviews

Ebvallo

tabelecleucel · EBV-specific allogeneic T cells
Not stated in public reviews

Encelto

revakinagene taroretcel · CNTF (encapsulated RPE cell implant)
Not stated in public reviews

Gintuit

allogeneic cultured keratinocytes and fibroblasts in bovine collagen · Allogeneic keratinocytes + fibroblasts
Not stated in public reviews

Holoclar

autologous corneal epithelial cells containing limbal stem cells · Autologous limbal stem cells
Not stated in public reviews

Kymriah

tisagenlecleucel · CD19 CAR-T
Not stated in public reviews

Lantidra

donislecel · Allogeneic pancreatic islets
Not stated in public reviews

Laviv

azficel-T · Autologous fibroblasts
Not stated in public reviews

Omisirge

omidubicel · Expanded cord blood HPC
Not stated in public reviews

Provenge

sipuleucel-T · PAP-GM-CSF (autologous APC)
Not stated in public reviews

Rethymic

allogeneic processed thymus tissue · Allogeneic thymus tissue
Not stated in public reviews

Ryoncil

remestemcel-L · Allogeneic BM-MSC
Not stated in public reviews

Spherox

spheroids of autologous matrix-associated chondrocytes · Autologous chondrocyte spheroids
Not stated in public reviews

StrataGraft

allogeneic cultured keratinocytes and dermal fibroblasts in murine collagen · Allogeneic keratinocytes + fibroblasts
Not stated in public reviews

Tecartus

brexucabtagene autoleucel · CD19 CAR-T
Not stated in public reviews

Tregzi

allogeneic Treg immunotherapy with HSPC and T cells (Orca-T) · Allogeneic Treg + HSPC + Tcon
Not stated in public reviews

Summary across all 27 cell therapies →