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Atlas/Gene therapy/First dose

How was the first-in-human dose set for approved gene therapies?

From the FDA and EMA reviews of all 26 approved gene therapies. Each answer links to the regulator's own sentence.

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Short answer
4 of 26 public reviews say how the first human dose was set; 5 more say it partly.
Stated4/26
Partly stated5/26
Not stated publicly17/26

Precedent by precedent

26 approved gene therapies, with the reviewers' own words.

Itvisma

onasemnogene abeparvovec (intrathecal) · SMN1 (AAV9, intrathecal)
First-in-human starting dose
NHP-tolerated 1.2x10^13 vg/animal scaled 10-fold by CSF volume to human starting dose 1.2x10^14 vg/patient
“In vivo toxicology/safety studies conducted in NHPs utilized a single IT administration of OAV101 at 1.2 x 1013 vg/animal, considered equivalent to the proposed starting clinical dose level for ITVISMA of 1.2x1014 vg/patient based on a 10-fold difference in CSF volume between NHP and human.”
✓ VerifiedFDA summary basis for approval, p. 15Source ↗
NOAEL / key findings
NOAEL not determined; minimal-moderate DRG/neuronal degeneration, inflammation, spinal axonopathy, transient liver enzymes; resolved by 12 months
“At 6 weeks post-administration, all dose levels resulted in acute, minimal to moderate mononuclear cell inflammation and neuronal degeneration across multiple anatomical sites, including the cerebrum, cerebellar white matter, brain stem, dorsal root ganglia, and various nerve structures (trigeminal, dorsal spinal, spinal, and peripheral nerves).”
✓ VerifiedUS prescribing informationSource ↗

Kebilidi

eladocagene exuparvovec · AADC
First-in-human starting dose
Prior adult PD rAAV2-hAADC clinical doses (up to 3x10^11 vg) scaled by brain mass; 1.8x10^11 vg (~60%)
“The applicant justified this dose on the basis that clinical studies in adult PD using rAAV2-hAADC reported that doses up to 3x 1011 vg of rAAV2-hAADC in a volume of 4×50 μl were well tolerated following bilateral, intraputaminal infusions during a single operative session.”
✓ VerifiedEMA assessment report, p. 34Source ↗
NOAEL / key findings
Rat NOAEL 7.5x10^9 vg (highest dose; ~21x margin by brain weight); no significant adverse findings
“Since there were no toxicologically significant findings at the high dose, the no observed adverse effect level (NOAEL) was set at the high dose (7.5x109 vg).”
✓ VerifiedEMA assessment report, p. 36Source ↗

Otarmeni

lunsotogene parvec · OTOF (AAV, intracochlear)
First-in-human starting dose
PD Emax modeling of mouse ABR data: plateau >2e13 vg/mL; clinical 3e13 vg/mL (1.5x), concentration-scaled NOAEL margins 2.2-2.4x
“The selection of the proposed clinical dose concentration of 3 x 1013 vg/mL is supported by the pharmacodynamic modeling (OTOF-10116) of ABR improvements in the Otof-Q828X hom mouse model as well as the safety profile established in the GLP toxicology studies.”
✓ VerifiedFDA pharmacology/toxicology review, p. 28Source ↗
NOAEL / key findings
NOAEL = highest dose (1.3e11 vg/ear mouse; 4.4e12 vg/ear monkey); adverse findings procedure-related (facial paralysis, cochlear damage)
“The 6-month GLP study in monkeys at dose levels up to 4.4 × 1012 vg/ear demonstrated no DB-OTO-related toxicity, with a NOAEL of 4.4 × 1012 vg/ear.”
✓ VerifiedFDA summary basis for approval, p. 15Source ↗

Zolgensma

onasemnogene abeparvovec · SMN1
First-in-human starting dose
Mouse efficacy: doses doubling (7.4e13) and fully restoring (1.2e14 vg/kg) SMNdelta7 lifespan; MTD 1.5e14 set retrospectively
“The applicant noted that for phase 1 clinical trials, clinical dose identification was based on 2 criteria identified in animal studies: doubling Delta 7 SMA mouse life span (7.4e+13 vg/kg ) and restoring full life (1.2e+14 vg/kg ) in delta 7 SMA mice.”
✓ VerifiedEMA assessment report, p. 28Source ↗
NOAEL / key findings
NOAEL not identified (mouse); MTD 1.5x10^14 vg/kg; heart (atrial thrombosis, myocarditis) and liver toxicity; mortality >=2.4x10^14
“Based on the lack of similar cardiovascular toxicities resulting in Zolgensma-related mortality, the low dose of 1.5 x 1014 vg/kg was defined as the maximum tolerated dose (MTD).”
✓ VerifiedEMA assessment report, p. 37Source ↗

Glybera

alipogene tiparvovec · LPL (AAV1)
First-in-human starting dose
Not explicitly justified; clinical 1x10^12 gc/kg lies within active range in LPL-/- mice (10^11-10^13); tox covered 10x
“Activity was demonstrated in the dose range 1011-1013 gc/kg compared to the proposed human dose of 1x1012 gc/kg.”
✓ VerifiedEMA assessment report, p. 25Source ↗
NOAEL / key findings
NOAEL 1x10^11 gc/kg IM (mouse); dose-related injection-site myodegeneration and sub-acute inflammation, reversible; no systemic toxicity
“At the injection sites, histopathological findings including myodegenerative changes and sub-acute inflammation were consistently found in all three single dose toxicity studies upon IM administration of either 1x 1012 or 1 x1013 gc/kg AMT-010 and AMT-011, respectively.”
✓ VerifiedEMA assessment report, p. 28Source ↗

Hemgenix

etranacogene dezaparvovec · Factor IX
First-in-human starting dose
Not stated for FIH; later clinical dosing informed by predecessor AMT-060 clinical data
“The supporting clinical data from the predecessor product that used a similar vector (AAV5) as HEMGENIX was used to inform dosing for later clinical studies, and assessments of vector viral kinetics.”
✓ VerifiedFDA summary basis for approval, p. 12Source ↗
NOAEL / key findings
NOAEL 9x10^13 gc/kg NHP (4.5x clinical), 5x10^13 mice; transient ALT/AST rise, clotting changes, mouse pulmonary thrombi
“The identified no-observed-adverse-effect-level was 9x1013 gc/kg.”
✓ VerifiedFDA summary basis for approval, p. 11Source ↗

Luxturna

voretigene neparvovec · RPE65
First-in-human starting dose
FIH start dose basis not stated; clinical dose chosen over broad efficacious range using safety data (NHP NOAEL 5x clinical dose)
“Because the pharmacology data indicated that efficacy could be achieved over a broad dose range, the determination of the optimal therapeutic dose also relied on safety data.”
✓ VerifiedEMA assessment report, p. 21Source ↗
NOAEL / key findings
NHP NOAEL 7.5e11 vg/eye (5x clinical); ocular inflammation/retinal degeneration in dogs at 1.5e12 vg/eye; no systemic toxicity
“The no-observed-adverse-effect-level (NOAEL) in NHPs was 7.5 x 1011vg/eye, which is 5-fold higher than the proposed clinical dose level”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Papzimeos

zopapogene imadenovec · HPV6/11 antigens (gorilla adenovirus)
First-in-human starting dose
Not explicitly stated; mouse repeat-dose 1x10^10 VP gives ~5-fold safety factor over clinical 5x10^11 PU dose
“Repeat administration of a dose level approximately 5-fold higher than the intended clinical dose, assuming a 60-kilogram adult of 5x1011 PU (1x1010 VP/mouse/dose) of PRGN-2012 once weekly on Days 0, 7, and 14 was well tolerated in WT C57BL/6 mice with no safety findings reported at termination after 21 Days.”
✓ VerifiedFDA pharmacology/toxicology review, p. 4Source ↗
NOAEL / key findings
No test article-related findings at 1x10^10 VP/dose (~5x clinical); no local or systemic toxicity
“There were no test article-related findings reported.”
✓ VerifiedFDA pharmacology/toxicology review, p. 13Source ↗

Strimvelis

autologous CD34+ cells transduced with ADA (no INN) · ADA (gamma-retroviral, ex vivo HSC)
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.”
✓ VerifiedEMA assessment report, p. 21Source ↗
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.”
✓ VerifiedEMA assessment report, p. 26Source ↗

Adstiladrin

nadofaragene firadenovec · IFN-alpha2b (adenovirus, intravesical)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
Local NOAEL not set (urinary tract changes at all doses, reversible); highest non-severely toxic dose 1.25e13 vp rAd-IFN with 25 mg Syn3; bladder/ureter/urethra inflammation
“25 mg Syn3NODA and 1.25x1013 vp rAd-IFN could be considered the highest non-severely toxic dose.”
✓ VerifiedEMA assessment report, p. 37Source ↗

Beqvez

fidanacogene elaparvovec · Factor IX
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
NHP 1-5x10^12 vg/kg (2-10x clinical): no adverse findings, no thrombosis; mouse deaths linked to brain/skin findings
“No test article-related adverse findings were observed in this study, including any findings of thrombosis by microscopic histopathology.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Casgevy

exagamglogene autotemcel · BCL11A enhancer (CRISPR-Cas9, ex vivo HSC)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
1x10^6 cells/mouse well tolerated; minor non-adverse red cell changes and spleen/thymus round-cell infiltration; no tumors
“The single dose GLP toxicology study with an observation period of 20 weeks revealed that the single IV injection of 1 x 106 cells/animal of unedited or SPY101-RNP-edited CD34+ hHSPCs into non-lethally irradiated NSG mice was well-tolerated.”
✓ VerifiedEMA assessment report, p. 44Source ↗

Elevidys

delandistrogene moxeparvovec · Micro-dystrophin
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
NOAEL 4.01x10^14 vg/kg (WT, mdx, neonatal mice); 1.33x10^14 in mdx 12-wk study (hydrocephalus); non-adverse minimal liver findings
“This study identified NOAELs of 4.1 × 1014 vg/kg in WT mice and 1.33 × 1014 vg/kg in mdx mice.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Fayuvi

rebisufligene etisparvovec · SGSH (AAV9)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
NOAEL 5.0x10^13 vg/kg (6-month) and 2.0x10^14 vg/kg (3-month); non-adverse, reversible clinpath/histopath findings
“The NOAEL was assigned at 2.0x1014 vg/kg.”
✓ VerifiedFDA summary basis for approval, p. 11Source ↗

Genglycos

pariglasgene brecaparvovec · G6PC (AAV8)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
NOAEL 1.0x10^13 gc/kg adult mouse (hepatic necrosis, Kupffer cell changes above); 7.0x10^13 juvenile mouse; ~1.3x10^14 gc/kg NHP
“identified a NOAEL equivalent to 1.3 × 1014 gc/kg of GENGLYCOS”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Imlygic

talimogene laherparepvec · GM-CSF (oncolytic HSV-1)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
Single SC dose NOAEL 1e7 PFU/kg in mice (~1.7x max clinical dose); transient injection-site inflammation; HSV-1-related findings
“a no-observed-adverse-effect-level (NOAEL) of 107 PFU/kg was achieved, which is approximately 1.7-fold higher than the maximum clinical dose level”
✓ VerifiedFDA pharmacology/toxicology review, p. 99Source ↗

Kresladi

marnetegragene autotemcel · ITGB2 (LVV, ex vivo HSC)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
No adverse findings; testis degeneration and liver infiltrates attributed to irradiation/background; NOAEL not defined
“No premature mortality or unexpected deaths were observed over the course of the study period in recipient mice.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Lenmeldy

atidarsagene autotemcel · ARSA (LVV, ex vivo HSC)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
No formal NOAEL; no test-article toxicity or malignancy at 1x10^6 cells/mouse (40-50x10^6 cells/kg); findings from As2-/- phenotype and irradiation
“No test article-related mortality, toxicity or hematologic malignancy was observed, with study findings primarily attributed to the As2-/- phenotype, irradiation, and incidental age-related findings.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Lyfgenia

lovotibeglogene autotemcel · HBB T87Q (LVV, ex vivo HSC)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
Applicant designated single tested dose (11x10^6 cells/kg) NOAEL; no test article-related deaths or adverse findings through 6 months; lymphomas background
“In the secondary transplantation study, no deaths or adverse findings attributed to the BB305 LVV-transduced cells occurred through 6 months post-transplantation of 6×106 cells/mouse.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Roctavian

valoctocogene roxaparvovec · Factor VIII
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
No NOAEL stated; CD1 mice >=6.53x10^13 vg/kg: mortality, cardiac hemorrhage/necrosis from anti-hFVIII antibodies; NHP: APTT prolongation
“ROCTAVIAN-related mortality, adverse clinical observations, and changes in gross pathology were observed at dose levels of 6.53 × 1013 vg/kg and higher, and were associated with fibrosis, hemorrhage, and necrosis in the heart.”
✓ VerifiedFDA summary basis for approval, p. 12Source ↗

Skysona

elivaldogene autotemcel · ABCD1 (LVV, ex vivo HSC)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
True NOAEL not determined; ~5x10^7 CD34+ cells/kg (max feasible, 10x minimum clinical dose); early deaths in both test and control groups
“Although a true no observed adverse effect level (NOAEL) could not be determined, the dose level administered in this study, approximately 5x107 CD34+ cells/kg, represents the maximum feasible dose”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Tudriqev

vusolimogene oderparepvec · GALV-GP + GM-CSF (oncolytic HSV-1)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
NOAEL = highest dose tested of mRP1 in rats, 1x10^7 PFU/animal/injection; no adverse findings
“was 1x107 plaque-forming units (PFU)/animal/injection, which was the determined no-observed-adverse-effect level for all studies.”
✓ VerifiedFDA summary basis for approval, p. 13Source ↗

Vyjuvek

beremagene geperpavec · COL7A1 (HSV-1, topical)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
NOAEL 6.9e6 pfu (low dose) in mouse intradermal study; dose-site scabbing, inflammatory lymphocyte hyperplasia; no adverse findings per FDA
“The low dose of 6.9 x 106 pfu was considered as the NOAEL.”
✓ VerifiedEMA assessment report, p. 32Source ↗

Waskyra

etuvetidigene autotemcel · WAS (LVV, ex vivo HSC)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
No NOAEL; no increased mortality, tumorigenicity or toxicity related to transduced HSPCs; lymphomas were of host origin
“results do not reveal any increased mortality, tumorigenicity, or other forms of toxicity related to the transduction of mouse SV129 WKO Lin- HSPCs with w1.6W LVV.”
✓ VerifiedEMA assessment report, p. 35Source ↗

Zevaskyn

prademagene zamikeracel · COL7A1 (RV-modified keratinocyte sheets)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
No gross or histopathological findings in any tissue, including explanted products; no NOAEL stated
“There were no gross or histopathological findings in any tissue assessed, including the explanted nonclinical products.”
✓ VerifiedFDA summary basis for approval, p. 13Source ↗

Zynteglo

betibeglogene autotemcel · HBB T87Q (LVV, ex vivo HSC)
First-in-human starting dose
Not stated in public reviews
NOAEL / key findings
No NOAEL defined; no test-article-related mortality or adverse effects at 42x10^6 cells/kg; lymphomas judged incidental (radiation/strain background)
“No test article-related mortality or adverse effects on any parameter was observed.”
✓ VerifiedFDA pharmacology/toxicology review, p. 12Source ↗