17.1. Introduction
For registration dossiers of high-technology drugs, the format requirements (Module 1, 2, 3, 4 and 5) described in Part I of this annex must be observed.
The technical requirements for Modules 3, 4 and 5 should be applied to high-tech biological drugs, as described in Part I of this annex. The specific requirements for high-tech medicinal products described in Sections 17.3, 17.4 and 17.5 of this part, explain how the requirements in Part I apply to high-tech medicinal products.
In view of the specific nature of high-tech medicines, a risk-based approach can be applied to determine the amount of information required and the quality requirements, preclinical and clinical studies, for inclusion in the registration dossier in accordance with applicable guidelines of the EAEU or, in their absence, in accordance with the guidelines of the member states of the EAEU.
Risk analysis may include the entire development. Risk factors that may be considered include: the origin of cells (autologous, allogeneic, xenogeneic), the ability to proliferate and / or differentiate, and the ability to induce an immune response, manipulation of cells, a combination of cells with bioactive molecules or medical products, the nature of the gene therapeutic drug preparation, the ability to replicate viruses or multiply microorganisms used in vivo, the degree of integration of nucleic acid or gene sequences into the genome, continuity of operation (existence), the risk of oncogenicity and the mode of administration or use.
Relevant existing non-clinical and clinical data or experience with other related high-technology medicines may also be considered in risk analysis.
Any deviation from the requirements of this annex should be scientifically justified in Module 2 dossier. If a risk analysis is carried out as it described above, it should be included and described in Module 2. In this case, it is necessary to consider the methodology used, the nature of the risks identified and the impact of the results of the risk-based approach to the drug development and evaluation program. It is also necessary to describe any deviations from the requirements of this application due to the results of the risk analysis.
17.2. Definitions
17.2.1. Gene therapy drugs.
The gene therapy drug is a biological medicinal product:
(a) containing an active substance comprising or consisting of a recombinant nucleic acid used or administered to a human for the purpose of regulating, restoring, replacing, adding or removing a genetic sequence;
(b) the therapeutic, prophylactic or diagnostic effects of which are directly attributable to the sequence of the recombinant nucleic acid it contains, or to the product of the genetic expression of that sequence.
Gene therapy drugs do not include vaccines against infectious diseases.
17.2.2. Medicines based on somatic cells
A medicinal preparation based on somatic cells is a biological medicinal product:
(a) containing or consisting of cells or tissues that have undergone significant manipulation, such that their biological characteristics, physiological functions or structural properties significant for clinical use have been altered; or consisting of cells or tissues that are not intended for use in order to perform the same basic functions in the recipient and donor;
(b) used in humans for the purpose of treating, preventing or diagnosing a disease by means of the pharmacological, immunological or metabolic effects of its cells or tissues.
Within the framework of point (a), manipulations such as cutting, grinding, shaping, centrifugation, treatment with solutions of antibiotics or antiseptics, sterilization, irradiation, cell separation, concentration or purification, filtration, lyophilization, freezing, cryopreservation, vitrification, are not considered significant manipulations.
17.3. Special requirements for the Module 3
17.3.1. Special requirements for all high-tech medicines.
It is necessary to provide a description of the traceability system that the applicant undertakes to establish and maintain in order to trace the sources of origin, production, packaging, storage, transportation and delivery to the medical organization of a separate medicinal product and its raw materials and raw materials, including all substances that contacted the contained in it by cells or tissues.
The traceability system must complement and harmonize with the requirements for traceability systems, the member states of the EAEU, relative to human cells and tissues.
17.3.2. Special requirements for gene therapy drugs.
17.3.2.1. Introduction: medicinal product, active substance and starting materials.
17.3.2.1.1. Gene therapeutic drugs containing a sequence (s) of recombinant nucleic acids or a genetically modified microorganism (s) or virus (s).
The drug should consist of a nucleic acid sequence (s) or genetically modified microorganism (s) or virus (s), and be packaged in a primary packaging for medical use. A medicinal preparation can be combined with a medical product.
The active substance must consist of a nucleic acid sequence (s) or a genetically modified microorganism (s) or virus (s).
17.3.2.1.2. Gene therapy products containing genetically modified cells.
The drug should consist of genetically modified cells, and be packaged in a primary package for medical use. A medicinal preparation can be combined with a medical product.
The active substance should consist of cells genetically modified by one of the products described in section 17.3.2.1.1.
17.3.2.1.3. For products consisting of viruses or viral vectors, the starting materials are the components from which the viral vector is derived: the main bank (seed) of the viral or plasmid vector used to transfect the recipient cells (packing cells) and the main bank of the cell line of the recipient (the cell packing line).
17.3.2.1.4. For products consisting of plasmids, non-viral vectors and genetically modified organism (s) other than viruses and viral vectors, the starting materials are the components used to produce the producer cells: plasmids, bacterial host cells and the main bank of recombinant microbial cells.
17.3.2.1.5. For genetically modified cells, the starting materials are the components used to produce genetically modified cells, i. E. source materials for vector production, vector and human and animal cells. The principles of good manufacturing practices should be applied starting with the system of banks used to produce the vector and then to the finished product.
17.3.2.2. Special requirements.
In addition to the requirements set out in Section 3.2.1 and 3.2.2 of Part I of this annex, the following requirements shall apply:
a) Information should be provided on all raw materials used for the production of the active substance, including products necessary for the genetic modification of human and animal cells and, if necessary, subsequent cultivation and conservation of genetically modified cells, taking into account the possible absence of purification steps;
b) for products containing microorganisms (including viruses), it is necessary to provide data on genetic modification, sequencing, attenuation of microorganisms, tropism for certain types of tissues and cells, the dependence of microorganism properties on the cell cycle, pathogenicity and characteristics of the parental strain;
c) it is necessary to describe in the relevant sections of the dossier production and related impurities and, in particular, contaminating agents in the form of replication-capable viruses, if the vector must be incapable of replication;
d) for plasmids, it is necessary to quantify various forms of plasmids throughout the shelf life of the product;
e) for genetically modified cells, it is necessary to test cell characteristics before and after genetic modification, and before and after any subsequent freezing / storage procedure.
For genetically modified cells, in addition to certain requirements for gene therapy drugs, quality requirements for drugs based on somatic cells and tissue engineering products should be applied (see Section 17.3.3.).
17.3.3. Special requirements for somatotherapeutic drugs and tissue engineering preparations.
17.3.3.1. Introduction: medicinal product, pharmaceutical substance and starting materials (substances).
The medicinal preparation must consist of a pharmaceutical substance enclosed in a primary package for the purpose of the proposed medical use, and in its final combination, if it is a combined high-tech medicinal product.
The pharmaceutical substance must consist of cells and (or) tissues subjected to engineering.
Additional substances (for example, scaffolds, matrices, products, biomaterials, biomolecules and (or) other components) that are combined with the processed cells, with which they form a single whole, are the starting materials, even if they are not of biological origin.
Materials used in the manufacture of a pharmaceutical substance (for example, a nutrient medium, growth factors) that are not intended to be included as a component of a pharmaceutical substance are raw materials.
17.3.3.2. Special requirements.
In addition to the requirements described in sections 3.2.1 and 3.2.2 of Part I of this Annex, the following requirements apply:
17.3.3.2.1. Source materials.
(a) A summary of the receipt, preparation and testing of human tissues and cells used as starting materials should be provided. It is necessary to provide a justification if unhealthy cells or tissues (for example, cancer cells) were used as starting materials.
(b) If allogeneic cell populations have been pooled, it is necessary to describe the pooling strategy and take measures to ensure tracking.
(c) When validating the production process, the description of the properties
pharmaceutical substance and drug,
analytical techniques used in the development, specification and determination of stability, it is necessary to take into account the potential variability due to the use of human and animal tissues and cells.
(d) With respect to xenogenic cellular medicinal products
(eg geographical origin, livestock farming, age), special eligibility criteria, measures for preventing and monitoring infections in animal donors, testing animals for infectious agents, including vertically transmitted microorganisms and viruses, and confirmations suitability of the conditions of animal maintenance.
(e) With respect to cellular medications derived from genetically modified animals, it is necessary to describe the specific properties of cells due to their genetic modification. It is necessary to provide a detailed description of the method of creating and describing the properties of transgenic animals.
(e) For genetically modified cells, the requirements described in Section 17.3.2 should also be considered.
(g) It is necessary to describe and justify the test conditions for all additional substances (frameworks, matrices, products, biomaterials, biomolecules and (or) other components) that were combined with cells subjected to engineering.
For frameworks, matrices and products falling within the definition of a medical device or an active implantable medical device, the information listed in section 17.3.4, required for the examination of combination medicines for advanced therapy, should be provided.
17.3.3.2.2. Manufacturing process
(a) In order to ensure the uniformity of series and production process, the functional integrity of cells during production and transport (up to the point of application or introduction) and the proper state of differentiation, it is necessary to validate the production process.
(b) If the cells are directly grown inside or on a matrix, framework or article, it is necessary to provide information about the validation of the process of obtaining a cell culture in terms of cell growth, the function and integrity of such a combination.
17.3.3.2.3. Strategy description of properties and quality control.
(a) Information should be provided on the description of the properties of the cell population or cell mixture from the point of view of their authenticity, purity (eg, the presence of extraneous microbial agents or cellular contaminants), viability, activity, karyology, tumorigenicity and suitability for the proposed medical use. It is necessary to confirm the genetic stability of cells.
(b) It is necessary to provide qualitative and, if possible, quantitative information on production and related impurities, as well as information on all materials that may lead to the formation of degradation products during production. It is necessary to justify the degree of study of impurities.
(c) It should be justified that certain tests of the issuing quality control with a pharmaceutical substance or drug can not be made, but this is possible with key intermediate products and / or within the framework of internal control.
(d) If biologically active molecules (for example, growth factors, cytokines) are contained as components of cellular medicinal products, their influence and interaction with other components of the pharmaceutical substance must be described.
(e) If the three-dimensional structure is part of the intended function, the state of differentiation, the structural and functional organization of the cells and, if applicable, the resulting extracellular matrix, should become part of the description of the properties of such cellular medications. If necessary, a description of the physico-chemical properties should complement the preclinical studies.
17.3.3.2.4. Excipients.
For the excipients used in somatotherapeutic drugs and tissue engineering preparations (for example, transport medium components), the requirements for the new excipients listed in Part I of this Annex apply, if there is no data on the interaction between cells or tissues and excipients.
17.3.3.2.5. Research on development.
When describing the development program, it is necessary to present a rationale for the choice of materials and processes. In particular, it is necessary to analyze the integrity of the population of cells in the finished medicinal product.
17.3.3.2.6. Standard materials.
It is necessary to document and describe the properties of standard samples that are significant and specific for the pharmaceutical substance and / or the finished medicinal product.
17.3.4. Special requirements for high-technology medicines containing medical products
17.3.4.1. High-tech medicinal products containing medical products.
It is necessary to provide a description of the physical properties and effect of the drug and a description of the methods of its construction.
It is necessary to describe the interaction and compatibility between genes, cells and (or) tissues on the one hand and structural components on the other.
17.3.4.2. Combined high-tech medications.
By "combined high-tech medicinal product" is meant a high-tech drug that meets the following conditions:- it should include one or more medical products as part of the preparation in determining the EAEU legislation on medical devices or one or more active implantable medical devices in determining the EAEU legislation on medical devices and
- its cellular or tissue part should contain viable cells or tissues or
- its cellular or tissue part containing non-viable cells or tissues, must have the ability in the human body to exert an action that can be considered as primary in relation to the said products.
To the cellular or tissue part of the combined high-tech medicinal product, special requirements are imposed for somatotherapeutic drugs and tissue engineering products, presented in Section 17.3.3, if the cells have been genetically modified, special requirements for gene therapy drugs are presented in Section 17.3.2.
A medical device or an active implantable medical device may be an integral part of a pharmaceutical substance. If a medical device or an active implantable medical device is combined with cells during the manufacture, use or administration of a medicinal product, they are recognized as an integral part of the finished medicinal product.
It is necessary to provide information relating to a medical device or an active implantable medical device (which is an integral part of a pharmaceutical substance or medicinal product) necessary for the examination of combined high-tech medicinal products. Such information includes:
(a) information on the choice and intended function of the medical device or implantable medical device and the confirmation of the compatibility of the product with other components of the preparation;
(b) confirmation of the compliance of the medical device with the key requirements established by the EAEU legislation on medical devices or the compliance of the active implant with key requirements established by the EAEU legislation on medical devices;
(c) if applicable, confirmation of compliance of the medical device or implantable medical device with the requirements for transmissible spongiform encephalopathies;
(d) if applicable, the results of any evaluation of a medical device or active implantable medical device by a notified body in accordance with the EAEU legislation on medical devices.
The notified person who conducted the assessment referred to in paragraph "d" of this section shall, at the request of the authorized body conducting the examination of the application, submit all information related to the results of the evaluation in accordance with the EAEU legislation on medical devices. These may include information and documents contained in the conformity assessment of the application in question, if necessary for the purpose of studying a combined high-tech medicinal product as a whole.
17.4. Special requirements for the Module 4
17.4.1. Special requirements for all high-tech drugs.
In view of the unique and diverse structural and biological properties of high-technology drugs, the requirements of Module 4 of this Annex for pharmacological and toxicological studies of medicinal products are not always applicable. The technical requirements of sections 17.4.1, 17.4.2 and 17.4.3 explain how to comply with the requirements of Part I of this Annex for high-tech medicinal products. If appropriate, taking into account the specifics of high-tech medicinal products, additional requirements are established for them.
In the pre-clinical review, it is necessary to provide a scientific justification and analysis of preclinical development and selection criteria for the relevant animal species and models (in vitro and in vivo). Selected animal models can be immunocompromised, knockout, humanized or transgenic animals. Consideration should be given to the possibility of using homologous models (for example, the analysis of mouse cells in mice) or models that mimic the disease, especially in studies of immunogenicity and immunotoxicity.
In addition to the requirements of Part I, it is necessary to provide data on the safety, suitability and biocompatibility of all structural components (eg matrices, frameworks and products) and any additional substances (eg cell products, biomolecules, biomaterials and chemicals) contained in the medicinal product. It is necessary to take into account their physical, mechanical, chemical and biological properties.
17.4.2. Specific requirements for gene therapy drugs.
To determine the scope and types of preclinical studies necessary for the proper description of preclinical safety, the design and type of the gene therapy drug should be considered.
17.4.2.1. Pharmacology.
(a) The results of in vitro and in vivo studies of the effects relating to the declared indication (i.e. pharmacodynamic studies of the mechanism of action) should be presented in which models and suitable animal species are used to confirm that the nucleic acid sequence reaches the target organ or cells) and provides the necessary function (the degree of expression and functional activity). It is necessary to describe the duration of the function of the nucleic acid sequence and the proposed dosage regimen in clinical trials.
(b) Selectivity of the target. If the gene therapy drug should have selectivity or functionality limited by the target, it is necessary to present the results of studies confirming the specificity and duration of the functionality and activity of the target cells and tissues.
17.4.2.2. Pharmacokinetics.
(a) In biodistribution studies, it is necessary to study persistence, clearance and mobilization. In addition, they need to clarify the risk of generative transmission.
(b) If there is no rationale based on the type of medicinal product in the registration dossier, it is necessary to present the results of the dissemination and transmission risk studies to third parties, as well as the results of the environmental risk assessment.
17.4.2.3. Toxicology.
(a) The toxicity of the prepared
gene therapy drug. In addition, depending on the type of drug, it is necessary to conduct a separate test of the pharmaceutical substance and excipients taking into account the in vivo effect of the expression products of the nucleic acid sequence not designed to evaluate their physiological function.
(b) It is allowed to combine toxicity studies with a single injection with pharmacological safety studies and pharmacokinetic studies, for example, to study persistence.
(c) If repeated administration of the drug to a human is contemplated, it is necessary to present the results of toxicity studies with repeated administration. The mode and mode of administration should be consistent with those in clinical use. If a single administration may result in prolonged functionality of the nucleic acid sequence in a human, toxicity studies may be required for repeated administration. Depending on the persistence of the gene therapy drug and the expected potential risks, the duration of the study may exceed standard toxicological studies. It is necessary to provide a justification for the duration of the research.
(d) Genotoxicity needs to be studied. However, standard genotoxicity studies should only be carried out if a particular impurity or component of the delivery system is tested.
(e) Carcinogenicity should be studied. Standard lifelong carcinogenicity studies in rats are not required. However, depending on the type of drug, the tumorigenic potential needs to be studied in suitable in vivo / in vitro models.
(f) Reproductive and ontogenetic toxicity. If the registration dossier lacks an appropriate rationale based on the type of drug in question, it is necessary to present the results of studies on the study of fertility and the overall reproductive function. It is necessary to present the results of studying embryo-fetal and perinatal toxicity, generative transmission.
(g) Additional toxicology studies.
- Integration Studies. For all gene therapy drugs, it is necessary to present the results of studies of their integration if the lack of such results is not scientifically justified, for example, because there is no penetration of the nucleic acid sequences into the nucleus of the cell. If, based on the results of biodistribution studies, the risk of generative transmission is detected, in relation to gene therapy drugs, presumably not capable of integration, it is necessary to conduct integration studies.
- Immunogenicity and immunotoxicity. Potential immunogenic and immunotoxic effects should be investigated.
17.4.3. Specific requirements for somatotherapeutic drugs on the basis of somatic cells and preparations of tissue engineering.
17.4.3.1. Pharmacology.
(a) In order to confirm the mechanism of action, it is necessary to carry out appropriate studies of primary pharmacology. It is necessary to study the interaction of cellular preparations with surrounding tissues.
(b) The amount of medicinal product necessary to achieve the desired effect / effective dose and, depending on its type, the dosing regimen.
(c) In order to evaluate potential physiological effects that are not related to the therapeutic effect of a somatotherapeutic drug or a tissue engineering preparation or additional substances, it is necessary to present the results of a secondary pharmacology study because, in addition to the necessary proteins, biologically active molecules can be formed, or the necessary proteins may have unwanted targets.
17.4.3.2. Pharmacokinetics.
(a) Standard pharmacokinetic studies to study absorption, distribution, metabolism and excretion are not required. However, if there is no proper justification based on the type of drug under consideration in the registration dossier, it is necessary to study parameters such as viability, longevity, distribution, growth, differentiation and migration.
(b) With respect to somatotherapeutic drugs and tissue engineering products that produce active biomolecules on a continuous basis, it is necessary to study the distribution, duration and volume of expression of such molecules.
17.4.3.3. Toxicology.
(a) The toxicity of the finished medicinal product must be studied. It is necessary to consider the possibility of a separate study of the pharmaceutical substance, auxiliary substances, additional substances and all industrial impurities.
(b) The duration of the observations may exceed those in standard toxicological studies, so the expected life cycle of the drug, as well as its pharmacodynamic and pharmacokinetic properties, should be taken into account. It is necessary to provide a justification for the duration of the research.
(c) Standard carcinogenicity studies
and genotoxicity is not required, except for the tumorigenic potential of the finished drug.
(d) Immunogenic and immunotoxic potential must be studied.
(e) For cellular medicines containing animal cells, the safety issues associated with them, such as the risk of transmission of xenogenic pathogens to humans, need to be studied.
17.5. Special requirements for Module 5
17.5.1. Special requirements for high-tech medicinal products.
17.5.1.1. The special requirements of this section are additional to those presented in Module 5 of Part I of this Annex.
17.5.1.2. If for clinical use high-tech drugs require special supportive therapy or surgical procedures, the whole complex of therapeutic measures should be studied as a single whole. It is necessary to provide information on standardization and optimization of such procedures during clinical development.
If medical products used during surgical procedures for use, implantation, or administration high-tech medicinal product may affect the effectiveness and safety of the latter, it is necessary to provide information about such products.
It is necessary to provide a separate analysis aimed at assessing the application, implantation, administration and follow-up. If necessary, a plan for the training of medical personnel in the procedures for use, application, implantation and administration should be provided.
17.5.1.3. Considering that due to the properties of high-tech drugs during the clinical development process of their production may undergo changes, additional studies may be needed that confirm comparability.
17.5.1.4. In the course of clinical development, it is necessary to study the risks posed by potential infectious agents or the use of material obtained from animal sources and describe measures aimed at reducing such risks.
17.5.1.5. With the help of studies on the selection of a dose, it is necessary to determine the dose and dosage regimen.
17.5.1.6. Efficacy according to the declared indications should be confirmed by appropriate results of clinical studies in which clinically relevant endpoints were used for the intended application. In certain clinical conditions, it may be necessary to confirm long-term effectiveness. It is necessary to present a strategy for assessing long-term effectiveness
17.5.1.7. In terms of risk management, it is necessary to provide a strategy for long-term monitoring of safety and efficiency.
17.5.1.8. Safety and efficiency studies combined drugs for advanced therapy should be planned and carried out on the whole combined preparation.
17.5.2. Specific requirements for gene therapy drugs.
17.5.2.1. Pharmacokinetic studies in humans.
In pharmacokinetic studies in humans, the following should be considered:
(1) Shedding studies aimed at studying the excretion of gene therapy drugs;
(2) biodistribution studies;
(3) pharmacokinetic studies of the drug and gene expression products (eg, expressed proteins or genomic signatures).
17.5.2.2. Pharmacodynamic studies in humans.
In pharmacodynamic studies, it is necessary to study the expression and functions of the nucleic acid sequence after administration of the gene therapy drug.
17.5.2.3. Security Studies.
In security studies, the following should be considered:
(1) the emergence of vectors capable of replication;
(2) the emergence of new strains;
(3) reassortment of existing genomic sequences;
(4) tumor proliferation due to insertion mutagenesis.
17.5.3. Specific requirements for medicines based on somatic cells.
17.5.3.1. Medicines based on somatic cells, the mechanism of action of which is based on the production of certain active biological molecules.
If the mechanism of action of somatotherapeutic drugs is the production of certain active biomolecules (s), it is necessary, if possible, to describe the pharmacokinetic properties (especially the distribution, duration and extent of expression) of such molecules.
17.5.3.2. Biological distribution, persistence and long-term engraftment of components of somatotherapeutic drugs.
In the course of clinical development, it is necessary to study the biodistribution, persistence and long-term engraftment of components of a somatotherapeutic drug.
17.5.3.3. Security Studies.
In security studies, the following should be considered:
(1) distribution and engraftment after administration;
(2) ectopic engraftment;
(3) oncogenic transformation and compliance with the properties of the corresponding cell / tissue line.
17.5.4. Specific requirements for tissue injection products.
17.5.4.1. Pharmacokinetic studies.
If standard pharmacokinetic studies for tissue engineering preparations are not significant, then in the course of clinical development it is necessary to study the biodistribution, persistence and degradation of their components.
17.5.4.2. Pharmacodynamic studies.
The design of pharmacodynamic studies should be based on the characteristics of tissue engineering preparations. It is necessary to provide evidence of the "proof of concept" and the kinetics of the drug required to achieve the expected regeneration, repair, or replacement. It is necessary to take into account the appropriate pharmacodynamic markers associated with the function and structure under consideration.
17.5.4.3. Security Studies.
Follow the requirements of section 17.5.3.3.