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Atlas/Gene therapy/Safety margin

What safety margins were accepted 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
14 of 26 reviews state the margin; median 5× human exposure at the NOAEL, 3 below 1×.
Neurology: median 16× (10×–21×); 2 below 1×4/26
Hematology: median 4.5× (1.6×–10×)3/26
Oncology: median 37× (3.1×–70×)2/26
Cardiometabolic: 1 below 1×1/26
Ophthalmology: median 5×1/26
Rare & genetic disease: median 2.2×1/26
Respiratory: median 5×1/26
Immunology & dermatology: median 0.5×1/26
Not stated in public reviews12/26
0.3×1×3×10×30×100×
Neurology
Hematology
Oncology
Cardiometabolic
Ophthalmology
Rare & genetic disease
Respiratory
Immunology & dermatology

Multiple of human exposure at the recommended dose, at the pivotal NOAEL (HNSTD for oncology), as stated by the regulator. Left of 1× = below human exposure; reviews that say "below human exposure" without a number sit at <1×.

Precedent by precedent

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

Glybera

alipogene tiparvovec · LPL (AAV1)
Safety margin at NOAEL
No margin: dose-related muscle toxicity at the recommended clinical dose (mouse)
“There appears to be progressive and dose-related muscle toxicity at the recommended clinical dose. This has been shown to be reversible.”
✓ VerifiedEMA assessment report, p. 30Source ↗
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 ↗

Itvisma

onasemnogene abeparvovec (intrathecal) · SMN1 (AAV9, intrathecal)
Safety margin at NOAEL
No margin: NHP neural toxicity findings precluded determination of a NOAEL
“These toxicity findings precluded the determination of a no-observed”
✓ 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 ↗

Strimvelis

autologous CD34+ cells transduced with ADA (no INN) · ADA (gamma-retroviral, ex vivo HSC)
Safety margin at NOAEL
Mouse dose without test-item-related effects only about half the highest human dose (cells/kg)
“The doses administered provide only safety margin of approximately half the highest dose administered in humans (20 x106 CD34+ cells/kg).”
✓ VerifiedEMA assessment report, p. 26Source ↗
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 ↗

Zolgensma

onasemnogene abeparvovec · SMN1
Safety margin at NOAEL
No NOAEL in mice; liver/heart lesions at 0.7- to 1.4-fold the clinical dose, mortality at 2-3 times the clinical dose
“occurrence of tissue lesions (primarily liver and ventricle) already found in doses 0.7- to 1.4-fold the clinical dose and the striking mortality in mice at doses 2-3 the clinical dose required discussion.”
✓ VerifiedEMA assessment report, p. 39Source ↗
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 ↗

Casgevy

exagamglogene autotemcel · BCL11A enhancer (CRISPR-Cas9, ex vivo HSC)
Safety margin at NOAEL
NSG mouse toxicity dose gave only a 1.6-fold margin over the maximum human cell dose
“The dose level of 1 x 106 CD34+ hHSPCs/mouse administered in the single dose toxicity study is acceptable, despite the fact that there is only a 1.6-fold safety margin as compared to the max. human dose level of 20 x 106 cells/kg.”
✓ VerifiedEMA assessment report, p. 49Source ↗
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 ↗

Otarmeni

lunsotogene parvec · OTOF (AAV, intracochlear)
Safety margin at NOAEL
NOAEL concentrations ~2.2x (mouse) and ~2.4x (monkey) the clinical dose concentration (vg/mL)
“In the toxicology studies, the NOAELs were identified as the highest concentrations evaluated (6.5 x 1013 vg/mL in mice and 7.3 x 1013 vg/mL in monkeys), which provides safety margins of approximately 2.2-fold and 2.4-fold, respectively.”
✓ 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 ↗

Adstiladrin

nadofaragene firadenovec · IFN-alpha2b (adenovirus, intravesical)
Safety margin at NOAEL
Monkey-to-human local exposure multiple (dose-based) 3.11x for nadofaragene firadenovec, 1.87x for Syn3
“The local exposure multiples between monkeys and humans are low with 3.11 for nadofaragene firadenovec and 1.87 for Syn3NODA based on dose.”
✓ VerifiedEMA assessment report, p. 40Source ↗
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 ↗

Hemgenix

etranacogene dezaparvovec · Factor IX
Safety margin at NOAEL
NHP no-adverse-effect dose (9x1013 gc/kg) is 4.5-fold the recommended human dose
“Findings in animals dosed at 9x1013 gc/kg included prolonged prothrombin time, decreased activated partial thromboplastin time, and decreased heart rates; however, these changes were not statistically significant, and no adverse effects were observed. This dose level is 4.5-fold higher than the recommended dose level for HEMGENIX.”
✓ VerifiedFDA summary basis for approval, p. 11Source ↗
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
Safety margin at NOAEL
NHP NOAEL (vg/eye) is 5-fold the proposed clinical dose
“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 specified in the applicant’s ‘Dosage and Administration’ section of the label.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
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)
Safety margin at NOAEL
Mouse repeat-dose level without findings gives ~5-fold safety factor over the clinical dose
“The dose level assessed in this non-GLP toxicology study provides a 5-fold safety factor for the clinical dose level with the caveat that the processing and binding sequences in wildtype mice is likely different than the peptides recognized by human T cells .”
✓ VerifiedFDA pharmacology/toxicology review, p. 13Source ↗
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 ↗

Beqvez

fidanacogene elaparvovec · Factor IX
Safety margin at NOAEL
NHP: no adverse findings at doses 2- to 10-fold the recommended clinical dose
“No test article-related adverse findings were observed in this study, including any findings of thrombosis by microscopic histopathology. The dose levels in this study were between 2 to 10-fold higher than the recommended clinical dose level for BEQVEZ.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
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 ↗

Skysona

elivaldogene autotemcel · ABCD1 (LVV, ex vivo HSC)
Safety margin at NOAEL
Maximum feasible mouse dose (cells/kg) ~10-fold the minimum recommended human dose; NOAEL not determined
“Although a no observed effect level (NOAEL) could not be determined, a dose level of 1x106 CD34+ cells/animal or 5x107 CD34+ cells/kg provides an approximately 10-fold safety margin to the recommended minimum dose level to be administered in humans (5x106 CD34+ cells/kg).”
✓ VerifiedFDA pharmacology/toxicology review, p. 20Source ↗
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 ↗

Kebilidi

eladocagene exuparvovec · AADC
Safety margin at NOAEL
Rat highest dose (NOAEL) gives a safety margin of 21 over the clinical dose, scaled by brain weight
“Based on the study results, the highest dose administered (7.5×109 vg) in the study provides a safety margin of 21 over the human dose used in clinical studies, as calculated by the applicant.”
✓ VerifiedEMA assessment report, p. 40Source ↗
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 ↗

Imlygic

talimogene laherparepvec · GM-CSF (oncolytic HSV-1)
Safety margin at NOAEL
Mouse repeat-dose SC NOAEL ~70x the recommended maximum dose (PFU/kg basis)
“A dose level of 1x107 PFU/mouse/injection was 88-fold higher than the maximum human dose level (on a PFU/kg basis) administered in the first-in-human clinical trial (Document No. 4648-00028), and 70-fold higher than the recommended maximum dose level (on a PFU/kg basis) listed in the label for T-VEC.”
✓ VerifiedFDA pharmacology/toxicology review, p. 74Source ↗
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 ↗

Elevidys

delandistrogene moxeparvovec · Micro-dystrophin
Safety margin at NOAEL
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)
Safety margin at NOAEL
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)
Safety margin at NOAEL
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 ↗

Kresladi

marnetegragene autotemcel · ITGB2 (LVV, ex vivo HSC)
Safety margin at NOAEL
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)
Safety margin at NOAEL
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)
Safety margin at NOAEL
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
Safety margin at NOAEL
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 ↗

Tudriqev

vusolimogene oderparepvec · GALV-GP + GM-CSF (oncolytic HSV-1)
Safety margin at NOAEL
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)
Safety margin at NOAEL
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)
Safety margin at NOAEL
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)
Safety margin at NOAEL
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)
Safety margin at NOAEL
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 ↗