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Atlas/Cell therapy/Skipped studies

Which nonclinical studies did approved cell therapies skip?

From the FDA and EMA reviews of all 27 approved cell therapies. Each answer links to the regulator's own sentence.

Check my plan against these
Short answer
27 of 27 skipped carcinogenicity; 26 of 27 skipped dedicated reproductive tox.
No genotoxicity studies24/27
No carcinogenicity study27/27
No dedicated repro tox26/27

Precedent by precedent

27 approved cell therapies, with the reviewers' own words.

Abecma

idecabtagene vicleucel · BCMA CAR-T
Genotoxicity
Not conducted (traditional); insertion site analysis of 20 clinical lots
“No traditional genotoxicity assays and carcinogenicity assessments were performed for bb2121.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Carcinogenicity
Not conducted; in vitro IL-2-independent growth assay showed no transformation
“No carcinogenicity or tumorigenicity studies were conducted for bb2121. However, the applicant evaluated IL-2 independent growth in Study #10.”
✓ VerifiedFDA pharmacology/toxicology review, p. 27Source ↗
Reproductive & developmental
Not conducted (product characteristics)
“No animal reproductive and developmental toxicity studies were conducted for bb2121 which is acceptable based on the product characteristics.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Alofisel

darvadstrocel · Allogeneic adipose MSC
Genotoxicity
Not conducted; cell-based product does not interact with DNA
“Genotoxicity studies are not applicable for the product, considering the cell-based nature of the product, which precludes interaction directly with DNA or other chromosomal material.”
✓ VerifiedEMA assessment report, p. 24Source ↗
Carcinogenicity
Not conducted (conventional); in vitro senescence/karyotype/soft agar and mouse tumourigenicity, no tumours
“In in vivo tumourigenicity tests, nude mice administered a subcutaneous injection of eASC at various population doubling levels, equal to levels of product for clinical use, all survived to scheduled sacrifice and no tumour-formation was observed.”
✓ VerifiedEMA assessment report, p. 24Source ↗
Reproductive & developmental
Not conducted; no migration into reproductive organs in biodistribution
“Reproductive and developmental toxicity studies have not been performed for Alofisel because preclinical biodistribution studies indicated no migration and integration of eASC into reproductive organs”
✓ VerifiedEMA assessment report, p. 24Source ↗

Amtagvi

lifileucel · TIL therapy
Genotoxicity
Not conducted (not warranted given product characteristics and biological activity)
“No genotoxicity studies were conducted for AMTAGVI. Given the characteristics and biological activity of AMTAGVI, this omission is acceptable.”
✓ VerifiedFDA pharmacology/toxicology review, p. 14Source ↗
Carcinogenicity
Not conducted (expanded TILs free of tumor cells; residual tumor cell release controls; no clinical tumorigenicity signal)
“No tumorigenicity studies were conducted for AMTAGVI. This is acceptable since Studies #3 and #4 provided evidence that the expanded human TIL cultures in the studies were free of tumor cells.”
✓ VerifiedFDA pharmacology/toxicology review, p. 14Source ↗
Reproductive & developmental
Not conducted (product characteristics and biological activity)
“No DART studies were conducted for AMTAGVI. Given the characteristics and biological activity of AMTAGVI, this omission is acceptable.”
✓ VerifiedFDA pharmacology/toxicology review, p. 14Source ↗

Aucatzyl

obecabtagene autoleucel · CD19 CAR-T
Genotoxicity
Not conducted (third-generation SIN lentiviral vector, release criterion, long-term clinical monitoring for insertional mutagenesis)
“No nonclinical genotoxicity studies were conducted with obe-cel based on the genotoxic risks associated with the third-generation self-inactivating lentiviral vector used to produce obe-cel, acceptable release criterion, and inclusion of long-term clinical monitoring for insertional mutagenesis and clonality.”
✓ VerifiedFDA pharmacology/toxicology review, p. 10Source ↗
Carcinogenicity
Not conducted (ICH S9; no murine CD19 cross-reactivity; murine T cells resist LV transformation)
“Carcinogenicity studies are not needed for indications falling under ICH S9 scope (advanced cancer). In addition, there is no cross-reactivity of the CD19-CAR T cells from Aucatzyl with the murine antigen.”
✓ VerifiedEMA assessment report, p. 38Source ↗
Reproductive & developmental
Not conducted (ICH S9; no pharmacologically relevant species)
“DART studies are not needed for indications falling under ICH S9 scope (advanced cancer) and no pharmacologically relevant animal species is available.”
✓ VerifiedEMA assessment report, p. 38Source ↗

Breyanzi

lisocabtagene maraleucel · CD19 CAR-T
Genotoxicity
Not conducted (traditional); lentiviral integration site mapping instead
“Traditional genotoxicity assays and carcinogenicity assessments were not performed for JCAR017.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Carcinogenicity
Not conducted (ICH S9); GLP in vitro 60-day IL-2-independent growth study instead
“Consistent with regulatory guidance under “Nonclinical Evaluation for Anticancer Pharmaceuticals” (ICH S9, 2009) carcinogenicity studies were not conducted.”
✓ VerifiedEMA assessment report, p. 36Source ↗
Reproductive & developmental
Not conducted (no survival in immunocompetent rodents; GvHD in immunodeficient mice)
“JCAR017 does not survive in immunocompetent rodents and induces graft-versus-host disease in immunocompromised mice; therefore, traditional DART studies were not conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 38Source ↗

Carvykti

ciltacabtagene autoleucel · BCMA CAR-T
Genotoxicity
Not conducted (classical); lentiviral integration site analysis instead
“No classical genotoxicity studies have been performed.”
✓ VerifiedEMA assessment report, p. 34Source ↗
Carcinogenicity
Not conducted (ICH S9; no mouse BCMA cross-reactivity)
“As indicated in the ICH S9 guidance, carcinogenicity studies are not warranted to support marketing for therapeutics intended to treat advanced cancer.”
✓ VerifiedEMA assessment report, p. 35Source ↗
Reproductive & developmental
Not conducted; binding domain not detected in human reproductive organs
“Therefore, traditional DART studies were not conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 26Source ↗

ChondroCelect

characterised viable autologous cartilage cells · Autologous chondrocytes
Genotoxicity
Not conducted (per cell-based product guideline)
“The omission of genotoxicity studies in the development program for ChondroCelect is in line with EMEA/CHMP/410869/2006.”
✓ VerifiedEMA assessment report, p. 12Source ↗
Carcinogenicity
Not conducted; in vitro serial passaging senescence study instead
“In view of these results, the absence of standard carcinogenicity studies was considered to be acceptable.”
✓ VerifiedEMA assessment report, p. 12Source ↗
Reproductive & developmental
Not conducted; risk considered negligible
“the omission of reproductive and developmental toxicity studies in the development program for ChondroCelect is acceptable”
✓ VerifiedEMA assessment report, p. 12Source ↗

Ebvallo

tabelecleucel · EBV-specific allogeneic T cells
Genotoxicity
Not conducted (ICH S6(R1)); non-genetically engineered cells
“In accordance with ICH S6(R1), genotoxicity studies with tabelecleucel were not conducted.”
✓ VerifiedEMA assessment report, p. 29Source ↗
Carcinogenicity
Not conducted (ICH S6(R1)); in vitro EBV transmission/transformation co-culture assay done
“standard carcinogenicity bioassays are generally inappropriate for”
✓ VerifiedEMA assessment report, p. 29Source ↗
Reproductive & developmental
Not conducted; highly species-specific pharmacology
“Due to the highly species-specific nature of the pharmacology associated with tabelecleucel, nonclinical reproductive/developmental toxicity studies were not submitted with this application.”
✓ VerifiedEMA assessment report, p. 29Source ↗

Encelto

revakinagene taroretcel · CNTF (encapsulated RPE cell implant)
Genotoxicity
Done: ISO-10993 battery (bacterial, mammalian cell, mouse micronucleus on device extracts), negative
“No genotoxicity was observed in these studies.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗
Carcinogenicity
Not conducted (waived based on toxicological risk assessments)
“Studies to evaluate the carcinogenicity/tumorigenicity of ENCELTO were not conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗
Reproductive & developmental
Four DART studies of SC rhCNTF in rats and rabbits; no teratogenicity; exemption for device via margin of exposure
“There were no rhCNTF-related teratologic changes reported in the fetuses.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Gintuit

allogeneic cultured keratinocytes and fibroblasts in bovine collagen · Allogeneic keratinocytes + fibroblasts
Genotoxicity
Not conducted (nature of product and clinical experience)
“The toxicology study designs as discussed in the International Conference on Harmonisation (ICH) Safety (‘S’) guidelines, consisting of pharmacokinetics, acute toxicology, chronic toxicology, genotoxicity, carcinogenicity, reproductive and”
✓ VerifiedFDA pharmacology/toxicology review, p. 49Source ↗
Carcinogenicity
Not conducted (nature of product and clinical experience)
“were not conducted due to the nature of Apligraf® and the extensive clinical experience in the cutaneous indications.”
✓ VerifiedFDA pharmacology/toxicology review, p. 49Source ↗
Reproductive & developmental
Not conducted (nature of product and clinical experience)
“were not conducted due to the nature of Apligraf® and the extensive clinical experience in the cutaneous indications.”
✓ VerifiedFDA pharmacology/toxicology review, p. 49Source ↗

Holoclar

autologous corneal epithelial cells containing limbal stem cells · Autologous limbal stem cells
Genotoxicity
Not conducted (classical); in vitro karyotype analysis of cells
“The analysis demonstrated a consistent karyotypic profile throughout the tested cell cultures.”
✓ VerifiedEMA assessment report, p. 18Source ↗
Carcinogenicity
Not conducted (conventional); in vitro tumorigenicity assays instead
“While conventional carcinogenicity studies have not been performed, the potential for transformation and formation of tumours by the human corneal epithelial cells in Holoclar was investigated in in vitro assays.”
✓ VerifiedEMA assessment report, p. 18Source ↗
Reproductive & developmental
Not conducted; no systemic exposure and autologous product
“As no systemic exposure was to be expected and since the product was autologous in nature, the risk for product-related toxicity to the reproductive system was considered to be negligible”
✓ VerifiedEMA assessment report, p. 21Source ↗

Kymriah

tisagenlecleucel · CD19 CAR-T
Genotoxicity
Not conducted (classical); lentiviral integration site analysis on 14 donor products
“Genotoxicity Studies: Classical genotoxicity studies were not conducted. The provided LV integration site analysis may be relevant for evaluation of potential genotoxicity.”
✓ VerifiedFDA pharmacology/toxicology review, p. 12Source ↗
Carcinogenicity
Not conducted (rodent models not appropriate for insertional mutagenesis of modified cells)
“Genotoxicity assays and carcinogenicity studies in rodents are not appropriate to assess the risk of insertional mutagenesis for genetically modified cell therapy products.”
✓ VerifiedEMA assessment report, p. 40Source ↗
Reproductive & developmental
Not conducted
“No preclinical reproductive studies were conducted with CTL019 to assess whether it can cause fetal harm when administered to a pregnant woman.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Lantidra

donislecel · Allogeneic pancreatic islets
Genotoxicity
Not conducted
“No genotoxicity studies with LANTIDRA were conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 21Source ↗
Carcinogenicity
Not conducted; literature hepatic tumors in rats with low islet numbers, risk considered low
“Thus, the carcinogenic risk of LANTIDRA in transplanted patients is considered low.”
✓ VerifiedFDA pharmacology/toxicology review, p. 25Source ↗
Reproductive & developmental
Not conducted
“No DART studies with LANTIDRA were conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 21Source ↗

Laviv

azficel-T · Autologous fibroblasts
Genotoxicity
Not conducted (autologous nature, prior human experience)
“were not conducted by the sponsor due to the autologous nature of IT and the previous human experience.”
✓ VerifiedFDA pharmacology/toxicology review, p. 24Source ↗
Carcinogenicity
Not conducted (autologous, minimally manipulated); tumorigenicity listed as a gap
“were not conducted by the sponsor due to the autologous nature of IT and the previous human experience.”
✓ VerifiedFDA pharmacology/toxicology review, p. 24Source ↗
Reproductive & developmental
Not conducted (autologous nature, prior human experience)
“were not conducted by the sponsor due to the autologous nature of IT and the previous human experience.”
✓ VerifiedFDA pharmacology/toxicology review, p. 24Source ↗

MACI

autologous cultured chondrocytes on porcine collagen membrane · Autologous chondrocytes
Genotoxicity
Not conducted on cells; four studies on collagen membrane were non-mutagenic
“Four studies ( in vitro and in vivo ) were conducted to assess the genotoxic potential of the collagen membrane.”
✓ VerifiedUS prescribing informationSource ↗
Carcinogenicity
Not conducted (avascular local site, differentiated cells, no systemic distribution)
“Studies to evaluate the carcinogenicity or impairment of fertility potential of MACI have not been performed.”
✓ VerifiedUS prescribing informationSource ↗
Reproductive & developmental
Not conducted (local administration, minimal systemic entry, mature autologous cells)
“Per the applicant, studies were not conducted to evaluate this safety endpoint because the product is administered locally in the knee with minimal to no product entry systemically.”
✓ VerifiedFDA pharmacology/toxicology review, p. 24Source ↗

Omisirge

omidubicel · Expanded cord blood HPC
Genotoxicity
No standard genotox; cytogenetic/karyotype analyses of CF and NF showed no clonal aneuploidy
“The genomic integrity was evaluated using cytogenic and karyotype analysis. Results showed no difference in the occurrence of chromosomal abnormalities between the CF, NF, and control cells and no evidence of clonal aneuploidy.”
✓ VerifiedFDA summary basis for approval, p. 13Source ↗
Carcinogenicity
Not conducted (not warranted based on known safety profile)
“No carcinogenicity/tumorgenicity studies were conducted with the test article and were not warranted based on the known safety profile.”
✓ VerifiedFDA pharmacology/toxicology review, p. 30Source ↗
Reproductive & developmental
Not conducted (no reproductive organ findings; conditioning regimen already affects fertility)
“Per the applicant, developmental and reproductive toxicology studies were not conducted because there were no test article-related toxicity findings in reproductive organs as assessed by histopathological analyses”
✓ VerifiedFDA pharmacology/toxicology review, p. 28Source ↗

Provenge

sipuleucel-T · PAP-GM-CSF (autologous APC)
Genotoxicity
Not conducted (autologous nature of product)
“Toxicology studies, as described in the International Conference on Harmonization (ICH) Safety (‘S’) guidelines”
✓ VerifiedFDA pharmacology/toxicology review, p. 25Source ↗
Carcinogenicity
Not conducted (autologous nature of product)
“No genotoxicity, reproductive toxicity, mutagenicity and carcinogenicity studies were provided”
✓ VerifiedEMA assessment report, p. 33Source ↗
Reproductive & developmental
Not conducted
“No genotoxicity, reproductive toxicity, mutagenicity and carcinogenicity studies were provided”
✓ VerifiedEMA assessment report, p. 33Source ↗

Rethymic

allogeneic processed thymus tissue · Allogeneic thymus tissue
Genotoxicity
Not conducted
“No genotoxicity studies were conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 22Source ↗
Carcinogenicity
Not conducted; published mouse thymus-transplant literature reviewed
“No carcinogenicity/tumorigenicity studies were conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 22Source ↗
Reproductive & developmental
Not conducted; published thymectomy literature suggests minimal risk
“No DART studies were conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 21Source ↗

Ryoncil

remestemcel-L · Allogeneic BM-MSC
Genotoxicity
Not conducted (not warranted)
“Genotoxicity, carcinogenicity and reproductive and developmental toxicity studies were not performed for remestemcel-L.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗
Carcinogenicity
Not conducted; 6-week nude mouse tumorigenicity study showed no tumors
“There was no evidence of neoplastic tissue formation attributable to ceMSC over the six-week duration of the study.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗
Reproductive & developmental
Not conducted (not warranted)
“Genotoxicity, carcinogenicity and reproductive and developmental toxicity studies were not performed for remestemcel-L.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Spherox

spheroids of autologous matrix-associated chondrocytes · Autologous chondrocyte spheroids
Genotoxicity
Not conducted (per cell-based product guideline)
“No genotoxicity, conventional carcinogenicity and reproductive- and developmental toxicity studies were performed”
✓ VerifiedEMA assessment report, p. 32Source ↗
Carcinogenicity
Not conducted (conventional); 6-month GLP mouse tumourigenicity part and in vitro senescence studies
“No genotoxicity, conventional carcinogenicity and reproductive- and developmental toxicity studies were performed”
✓ VerifiedEMA assessment report, p. 32Source ↗
Reproductive & developmental
Not conducted; autologous cells with local action and limited biodistribution
“Reproductive and developmental toxicity studies were not conducted.”
✓ VerifiedEMA assessment report, p. 34Source ↗

StrataGraft

allogeneic cultured keratinocytes and dermal fibroblasts in murine collagen · Allogeneic keratinocytes + fibroblasts
Genotoxicity
Not conducted
“No genotoxicity studies were conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 10Source ↗
Carcinogenicity
No carcinogenicity study; tumorigenicity assessed in nude mice and in vitro, no tumors
“No tumor formation was observed for the 20-week study duration.”
✓ VerifiedFDA summary basis for approval, p. 12Source ↗
Reproductive & developmental
Not conducted
“No DART studies were conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 10Source ↗

Tecartus

brexucabtagene autoleucel · CD19 CAR-T
Genotoxicity
Not conducted (traditional); vector integration site analysis performed instead
“Traditional genotoxicity studies were not conducted using KTE-X19, however, given the use of a murine γ-retroviral vector to stably integrate the anti-CD19 CAR into the T cell genome, a risk associated with insertional mutagenesis exists.”
✓ VerifiedFDA pharmacology/toxicology review, p. 5Source ↗
Carcinogenicity
Not conducted
“No carcinogencity/tumorigenicity studies were conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 6Source ↗
Reproductive & developmental
Not conducted (product characteristics, safety profile)
“No animal reproductive and developmental toxicity studies were conducted with KTE-X19, which is acceptable based on the product characteristics and safety profile.”
✓ VerifiedFDA summary basis for approval, p. 12Source ↗

Tecelra

afamitresgene autoleucel · MAGE-A4 TCR-T
Genotoxicity
Not conducted (no test models or relevant species); integration site analysis showed polyclonal products, no selective insertion
“Conventional genotoxicity studies were not conducted with afamitresgene autoleucel, due to the lack of appropriate test models and pharmacologically relevant species.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
Carcinogenicity
Not conducted (no relevant animal models for human TCR-engineered T cells)
“Afamitresgene autoleucel is a human TCR engineered T-cell product, therefore conventional carcinogenicity studies were not performed due to the lack of relevant animal models.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
Reproductive & developmental
Not conducted; theoretical testis/placenta risk (MAGE-A4 expression) judged mitigated by immune privilege, labeling, pharmacovigilance
“MAGE-A4 is known to be expressed in testes and placenta, and so there is a theoretical risk of embryotoxicity or toxicity to the testes.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗

Tregzi

allogeneic Treg immunotherapy with HSPC and T cells (Orca-T) · Allogeneic Treg + HSPC + Tcon
Genotoxicity
Not conducted
“No nonclinical studies were conducted to evaluate genotoxicity of TREGZI.”
✓ VerifiedFDA pharmacology/toxicology review, p. 37Source ↗
Carcinogenicity
Not conducted
“No nonclinical studies were performed to evaluate the effect of TREGZI on carcinogenesis, mutagenesis, or impairment of fertility.”
✓ VerifiedUS prescribing informationSource ↗
Reproductive & developmental
Not conducted
“No animal reproductive and developmental toxicity studies have been conducted with TREGZI to assess whether it can cause fetal harm when administered to a pregnant woman.”
✓ VerifiedUS prescribing informationSource ↗

Yescarta

axicabtagene ciloleucel · CD19 CAR-T
Genotoxicity
Not conducted; literature review of retroviral-transduced T-cell transformation risk instead
“No in vitro and in vivo genotoxicity and carcinogenicity assessments for KTE-C19 were conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗
Carcinogenicity
Not conducted; literature suggests T cells resistant to retroviral transformation
“The data suggest that T cells are relatively resistant to malignant transformation by retroviral vectors.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗
Reproductive & developmental
Not conducted
“Developmental and Reproductive Toxicology Studies (DART) No DART studies were conducted.”
✓ VerifiedFDA pharmacology/toxicology review, p. 17Source ↗

Zalmoxis

allogeneic T cells modified with HSV-TK / dLNGFR (nalotimagene carmaleucel) · HSV-TK suicide-gene T cells
Genotoxicity
Not conducted; in vitro retroviral integration site analysis instead
“Genotoxicity studies have not been submitted.”
✓ VerifiedEMA assessment report, p. 20Source ↗
Carcinogenicity
Not conducted in vivo (species-specific product); in vitro clonality, integration, IL-2 dependence, RCR
“Therefore, no specific in vivo carcinogenicity studies were performed for the MM-TK to date.”
✓ VerifiedEMA assessment report, p. 22Source ↗
Reproductive & developmental
Not conducted; justified
“The lack of studies on reproductive and development toxicity is justified.”
✓ VerifiedEMA assessment report, p. 26Source ↗

Zemcelpro

dorocubicel · UM171-expanded cord blood CD34+
Genotoxicity
Done for residual UM171 only (Ames, CHO micronucleus negative) plus cytogenetics of treated cells; none for cells
“An AMES and a micronucleus test were conducted to assess the genetic safety of UM171”
✓ VerifiedEMA assessment report, p. 35Source ↗
Carcinogenicity
Not conducted
“Carcinogenicity studies were not submitted, which can be agreed.”
✓ VerifiedEMA assessment report, p. 37Source ↗
Reproductive & developmental
Not conducted
“No reproductive and developmental toxicity studies were presented.”
✓ VerifiedEMA assessment report, p. 37Source ↗