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1536   Part IX  Cell-Based Therapies


        which tests are required for certain products. Establishing postship-  have a centralized independent data safety monitoring board (DSMB)
        ment acceptance criteria is critical for the use of many cell therapy   that  is  often  convened  by  the  sponsor  (NIH  or  a  pharmaceutical
               20
        products.   Practice  runs  are  recommended  for  shipment  of  the   company). A monitoring plan must be developed for the collection
        product, especially if the timing of the administration is crucial. For   and reporting of adverse events to the SMC/DSMB and the FDA.
        example, if a product is to be administered during a surgical proce-  This is another step where good communication is essential. The trial
        dure, it will be important to know the product viability if there are   investigator  and  the  cell-processing  facility  must  meet  regularly  to
        delays in shipment or postshipment testing, or during the surgical   discuss  any  adverse  events  and  events  that  occur  during  product
        procedure.                                            administration to determine if they are attributable to the cellular
           In addition to a product meeting the appropriate release criteria,   product or the subject’s underlying disease. The FDA and the SMC/
        the product administration process needs to be monitored. Patient   DSMB must be informed of these events to determine if a prespeci-
        baseline and postadministration evaluations are conducted, adverse   fied stopping boundary has been crossed.
        events are documented, and any deviations from the product admin-
        istration procedures/processes are recorded. Such documentation can
        allow  the  cell-processing  laboratory  to  evaluate  common  elements   CONCLUSIONS
        across  different  products  as  well  as  observe  any  product-specific
        trending.                                             The development of novel cellular therapeutics is a long and complex
                                                              process requiring an IND. There are many translational steps to be
                                                              completed before exposure to humans is feasible. These steps range
        Quality Control/Quality Assurance                     from practical issues such as the shipment of cells to the complicated
                                                              issues  of  setting  acceptable  product  specifications  and  conducting
        A  parallel  process  to  the  manufacturing  process  and  pre-clinical   pre-clinical studies in animal models to predict product safety profile.
        studies  is  QC  and  QA.  QA  begins  before  the  manufacture  of  the   Investigators need to develop good working relationships with the
        cellular therapeutic begins. It is based on the manufacturing process   cell-processing facility staff and statistical staff in order to conduct a
        and  confirms  that  each  step  from  raw  material  procurement  to   technical and scientifically robust clinical trial. The key to a successful
        product  release  can  be  performed  in  a  consistent  and  regulation-  IND is early and frequent communication with the FDA.
        compliant manner. QC is product based and confirms whether or
        not the final cell therapy product satisfies the preestablished specifica-
        tions for final release. Managers and third-party auditors are respon-  SUGGESTED READINGS
        sible  for  QA  through  the  development  of  process  documentation,
        establishing SOPs, conducting audits, and training. Inspectors and   Gee  A,  editor:  Cell  therapy  cGMP  facilities  and  manufacturing,  New York,
        area supervisors perform QC by performing and receiving inspection   2009, Springer-Verlag.
        reports at all points throughout the manufacturing process.  Gee AP, Sumstad D, Stanson J, et al: A multicenter comparison study between
                                                                 the  Endosafe®  PTS™  rapid-release  testing  system  and  traditional
                                                                 methods  for  detecting  endotoxin  in  cell-therapy  products.  Cytotherapy
        Data and Adverse Event Monitoring                        10:427, 2008.
                                                              Guidance  for  Industry:  Eligibility  Determination  for  Donors  of  Human
        In addition to the QC/QA of the cellular therapeutic, there is also   Cells, Tissues, and Cellular and Tissue-Based Products (HCT/P’s) Final
        the QC of data collection. Case report forms must be tailored to the   Guidance, August 2007.
        study and need to be linked to the source data collected during the   Guidance  for  Industry:  Guidance  for  Human  Somatic  Cell  Therapy  and
        manufacture and delivery of the cells, and throughout the clinical   Gene Therapy, March 1998.
        trial. The forms should be tested for ease of completion so that data   Preti  RA:  Bringing  safe  and  effective  cell  therapies  to  the  bedside.  Nature
        coming in from the clinical sites will be easy to collect and interpret.   Biotechnol 23:801, 2005.
        Data coordinators and/or research nurses should be given rigorous
        training on the completion of these forms and should know how long
        each form takes to complete so they will be able to give a reasonable   REFERENCES
        estimate of how many subjects they can follow within a given time
        period. 21                                            For the complete list of references, log on to www.expertconsult.com.
           Single-center trials are often monitored by an institutional safety
        monitoring  committee  (SMC),  whereas  multicenter  trials  typically
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