Title: Pharmacology and Toxicology Information in Support of Protein Therapeutics
1Pharmacology and Toxicology Information in
Support of Protein Therapeutics
- Anne M. Pilaro, Ph.D.
- FDA/CDER/ODE VI/DTBOP
- NCI Small Business Initiative
- Workshop on Clinical Development
- June 24, 2004
2Objectives for Todays Presentation
- Summarize some differences between small
molecules and protein therapeutics - Brief review of pharmacology and toxicology
information in support of IND application for
protein therapeutics - Introduce current guidance for toxicology testing
of protein biotherapeutics
3What Does ODE VI Regulate?
- Classes of Biological Products
- Natural
- leukocyte-derived (IFNs, interleukins)
- enzymes, other cell-derived proteins
- Biotechnology-derived
- recombinant proteins (E. coli, CHO, yeast)
- monoclonal antibodies (in vivo, in vitro)
- recombinant proteins produced in transgenic
animals - Synthetic
4What Does ODE VI Regulate?
- Recombinant proteins
- cytokines
- enzymes
- hematopoietic growth factors
- neuroactive peptides
- Thrombolytics and fibrinolytics
- Monoclonal Abs (diagnostic, therapeutic,
preventative) - Peptides greater than 20 amino acids
- Other non-vaccine immunotherapies
5Some Basic Differences Between Drugs and Biologics
- Traditional Drugs
- Low molecular weight
- Previous examples
- Historical data base
- Maximal tolerated dose
- Species-independent
- Specific mechanisms
- Metabolized
- Guidelines
- Biologic Therapies
- High molecular weight
- Unique
- Concurrent controls
- Optimal biologic dose
- Species-specific
- Pleiotropic mechanisms
- Degraded
- Guidances
6Traditional Drugs are small
- FLUDARA (fludarabine phosphate)
- Molecular weight 365.2 daltons
- Chemical formula C10H13FN5O7P
7Biological Drugs are BIG!
- RITUXAN (rituximab)
- Molecular weight 145,000 daltons
- Chemical formula (non-glycosylated IgG1k)
C3264H5002N840O998S20
8Review of Preclinical Studies for Small Molecule
Drugs vs. Biologics
- Small molecule drugs
- pharmacology establishes rationale, but proof
is in clinical trial - toxicology testing by standard paradigms
- two test animal species to maximize chances of
detecting toxicities - duration of tox testing gt support clinical use
- genotoxicity testing required before first in man
- ADME studies generally useful
- demonstration of safety ultimate goal
9Review of Preclinical Studies for Small Molecule
Drugs vs. Biologics
- Protein therapeutics
- pharmacology establishes rationale
- allows selection of pharmacologic active dose
- used to establish therapeutic window
- toxicology testing has no standard paradigm
- toxicities are often extensions of pharmacologic
activity - follows the principles set forth by ICH S6
guidance - margins of safety are frequently lt 10-fold
- demonstration of safety ultimate goal
10The ICH S6 Document
- Title Preclinical Testing of Biotechnology-Derive
d Pharmaceuticals - usage of relevant vs. nonrelevant species
- usage of animal models of disease
- immunogenicity testing and its implications
- genotoxicity testing
- chronic toxicity testing
- carcinogenicity testing
- preclinical study design
11Toxicology Testing of Biotech-Derived Agents
ICH-S6
- General Principles
- sufficiently well-characterized products
- rely on purification processes to remove
impurities/contaminants - comparability of test material demonstrated
throughout development - conventional approaches to toxicity studies often
NOT appropriate to address unique issues - GLP compliance
12Characterization of General Toxicity
- Administration/Dose Selection
- ROA, dosing regimen should mimic proposed
clinical use - alternative routes/regimens acceptable in some
cases - attainment of toxic dose NOAEL desirable
- multiples of human dose needed to determine
adequate safety margins can vary with product
class clinical indication - Sec 3.5
13Animal Species/Model Selection
- Standard toxicology paradigms often not adequate
or appropriate - Use of relevant species
- single relevant species with justification
- limited toxicology in a single nonrelevant
species - Alternative approaches
- transgenic animals
- homologous proteins
- animal models of disease Sec 3.3
14Single/Repeat Dose Toxicity Studies
- use relevant animal species
- include TK, Ab measurement, recovery period
- short-term clinical use/acute life-threatening
disease toxicology studies of up to 2 weeks
duration - chronic use toxicology studies up to 6 months
duration - Sec 4.4
15Characterization of Specific Toxicities
- Genotoxicity
- Chronic toxicity
- Immunogenicity
- Repro/Developmental Toxicity
- Carcinogenicity
16Characterization of Specific Toxicities
- Genotoxicity
- for protein therapeutics
- standard mutagenicity assays not applicable
- effects on proliferation, transformation in human
cell lines may be more appropriate for in vitro
testing - integration not usually an issue for proteins
- scientific basis to justify method selection
- most sensitive, appropriate technique available
- use data to predict risk of mutagenesis in vivo
- frequency/risk analysis
17Characterization of Specific Toxicities
- Chronic Toxicity
- designed to assess potential cumulative toxicity
- support long-term administration in the clinic
- most protein therapies are of limited duration
- single, or small number of administrations over
short time span - limited number for lifetime replacement therapies
18Characterization of Specific Toxicities
- Chronic Toxicity, contd
- need for chronic toxicology determined by
product-specific issues, patient indication - assess potential delayed or extended toxicity
- daily, repeat administrations probably not
feasible - antibody development/host response
(immunogenicity) - limits duration of pharm/tox effects
- limits duration of administration
19Characterization of Specific Toxicities
- Repro/Developmental Toxicity
- need for studies determined individually
- dependent on product class, patient population,
duration of treatment - studies expected for product used in pregnant
females, WCBP - species-specificity limits testing to Seg 2/3
- stand-alone fertility studies not useful with
NHP - small litter size (n 1) with NHP means large n,
- alternative approaches are encouraged, e.g.
hormone surrogates - ODE VI works with sponsors to design studies to
address specific safety questions as needed
20Characterization of Specific Toxicities
- Carcinogenicity
- standard rodent models not likely appropriate
- species-specificity
- lifetime administration of protein not feasible
- immunogenicity limits duration of treatment
- immune effects may also affect tumor response
- product-specific studies case-by-case
- dependent on product class, duration of clinical
dosing, patient population, risks of long-term
exposure - may be obviated by long-term, clinical follow-up
- ODE VI works with sponsors to design studies to
address specific safety questions as needed
21Review so far
- Preclinical studies for therapeutic proteins have
no set study paradigm - design and implementation must consider clinical
indication, population, and product
characteristics - Traditional animal toxicology models may not be
appropriate or feasible - Often studies have to be individualized to
address specific safety concerns
22Safety Issues Will Vary With Each Product Class
- Monoclonal antibodies (naked or conjugated)
- cross-reactivity with normal tissue
- immunogenicity/antibody production
- conjugate and/or linker toxicity
- bystander toxicity of radiolabeled species
23Safety Issues Will Vary With Each Product Class
- Cytokines and/or growth factors
- frequency/duration of therapy
- species-specificity
- interaction with host endogenous cascade
- tumor-promoting potential
- immunogenicity/antibody production
24Summary
- Toxicology programs for therapeutic proteins
require novel approaches to obtain data - no one size fits all paradigm for biologics
- traditional animal toxicology models may not be
appropriate or feasible - studies may have to be individualized to
address specific safety concerns
25Summary
- Toxicology studies for therapeutic proteins
should be - rational , scientifically designed, and problem
solving - based on the best available technology, methods
to date - follow guidance set forth by ICH S6
- careful design, judicious use of animals
26Summary
- Current approach is to design preclinical
toxicology studies to consider - basic biology of the product
- clinical indication, e.g. life-threatening or not
- patient population under study
27Summary
- Animal studies to determine safety are selected
based on - body of information available
- question being asked
- Information may be obtained in alternative animal
models - non-human primates are not a priori necessary
28Summary
- but... animal studies really only give you a
best guess of what to expect - no animal model, including humans is 100
predictive of response in man - sometimes animal studies can give a false sense
of security - however, these models may be useful in evaluation
of mechanism, other toxicities
29Some Further Resources
- ICH Guidances
- ICH S6 Safety Studies for Biotechnological
Products - ICH M3 Timing of Pre-clinical Studies in
Relation to Clinical Trials - ICH S5a Detection of Toxicity to Reproduction
for Medicinal Products - ICH S2b Standard Battery of Genotoxicity Testing
- Available at www.ich.org/ich5s.html
30Some Further Resources
- Points to Consider
- http//www.fda.gov/cber/guidelines
- Points to Consider in the Manufacture and Testing
of Monoclonal Antibody Products for Human Use -
2/28/97 - Points to Consider in the Manufacture and Testing
of Therapeutic Products for Human Use Derived
from Transgenic Animals - 1995
31Some Further Resources
- Guidance Documents
- http//www.fda.gov/cber/gdlns.htm
- Guidance for Industry Clinical Development
Programs for Drugs, Devices, and Biological
Products for the Treatment of Rheumatoid Arthritis
32Toxicology Staff in ODE VICAPT M. David Green
Ph.D., Chief
- DTBOP Staff
- Wen-Yi Gao, M.D., Ph.D.
- Melanie Hartsough, Ph.D.
- Anne M. Pilaro, Ph.D.
- Andrea Weir, Ph.D.
- Alexandra Worobec, M.D.
- (301) 827-5097
- DTBIMP Staff
- Hanan Ghantous, Ph.D.
- Anita OConnor, Ph.D.
- Barbara Wilcox, Ph.D.
- (301) 827-5096