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Copyright © 2014 Covance. All Rights Reserved
Paving the way for
Non-Clinical
Bioanalytical
Partnerships
Louise Angell
Copyright © 2014 Covance. All Rights Reserved
Content
Overview of non-clinical immunogenicity testing
for biologics
Regulatory guidance
Bioanalytical considerations
Risk based approach
CRO Pharma
Copyright © 2014 Covance. All Rights Reserved
Overview of Immunogenicity Testing
All biologics (recombinant therapeutic proteins) will induce an immune response
Immunogenicity can be either wanted (vaccine) or
unwanted Binding (Ab binds to the drug but has no apparent impact of PK and
PD)
Sustaining (Ab binds to the drug and prolongs its half-life, increasing
drug exposure)
Clearing (Ab binds to the drug and accelerates clearance from
circulation, decreasing drug exposure)
Neutralizing (Ab binds to the drug and prevents pharmacological
activity)
Unwanted ADA response has
potential safety implications
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Overview of Immunogenicity Testing
Test during non-clinical and clinical programs Immunogenic response in non-clinical study is not predictive of an
immune response in humans
Novel Therapeutic Protein May assume humanised protein to have less immunogenicity risk
than prokaryotic engineered protein
Humanised protein will have greater homology to native
sequence than non-humanised, however immunogenicity
frequency is still variable
Understand BioCMC and in vitro data
Assess in repeat dose non-clinical studies, multiple species to
enable interpretation of non-clinical data
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Regulatory Guidelines - Summary
Regulatory agencies in the US and EU are consistent in their recommendation that immunogenicity be evaluated from a patient safety perspective due to non-predictability of data from non-clinical studies
Immunogenicity testing is required for novel compounds
Regulatory guidance for bioanalytical method validation is well defined for PK assays, with multiple white papers published for ADA assays, although ADA interpretation is evolving
For Biosimilar products, there is no global guidance for immunogenicity testing, and EMA infer in vivo testing is not required due to lack of predictability
in vivo studies may be considered reasonable markers for potential immunogenicity assessment due to differences in product specification (quality and manufacturing)
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Regulatory Limitations
Potential for differing interpretation of the
guidelines by companies
Biosimilar (ADA Assays) Criteria for comparison of data?
It is not clear if one assay or two assay approach is optimal
Reference material?
One assay - additional assessments (cut point and drug tolerance?)
Pre-existing antibodies There is no regulatory guidance on how to deal with this
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Bioanalytical Considerations
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Overview of ADA assay
biotin-labeled drug
labelled drug
Streptavidin coated
plate
anti-drug antibody (ADA)
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Overview of ADA assay
Qualitative screening assay, confirmation, titre quantification
Cut Point
-ve samples +ve samples
Assay signal
Re
spo
nse
Mean
5% False Positives
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Insulin BioSimilar Case Study
EMA Guideline on non-clinical and clinical development of similar
biological medicinal products containing recombinant insulin and
insulin analogues (draft April 2014)
Risk based approach for toxicology studies
Presence of pre-existing antibodies against insulin is well
documented
biotin-labeled drug
Capture reagent
Streptavidin coated
plate
Anti-Drug Antibody
Anti-insulin antibody
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Insulin Biosimilar Case Study Cut point set using naïve individuals however this included “positive” samples
Assay sensitivity was high (close to 1000ng/mL)
Some samples confirmed positive with both biosimilar and insulin
Potential to falsely report naïve background samples as confirmed positive
At risk of missing low concentration, true positives with high affinity binding
Many hours of Client communication to discuss concerns and risks
Rat sample analysis study: ~5% samples screened positive and no impact
upon TK profile
Learnings
Buffer cut point (sample with background greater than buffer would be
positive)
Pre-incubate cut point sample with insulin to remove pre-existing anti-
insulin Ab whilst capturing biological matrix variation
Skip confirmation step
Titre pre and post dose for comparison
Scientists came together to discuss potential issues
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Non-Clinical Study Design
Some Clients have well defined BioCMC package and good
prediction of immunogenicity risk
Other Clients have limited experience with developing biologics
Dosing Human protein into mouse led to a high level of immunogenicity (60%)
Non-clinical program designed in 1 species
Immunogenicity response could not be correlated to the decrease in TK profile
because ADA samples were collected from different animals to TK samples
PD data subsequently generated to justify administration of human protein in
mouse model was responsible for apparent immunogenicity
Subsequently, ELISA method transferred and validation using Gyros to generate
ADA data from TK samples. This confirmed TK reduction correlated to ADA
response
These data were used to support absence of 2nd rodent model
Cyno study later demonstrated reduced/no immunogenicity
Enhanced relationships help to guide projects
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Non-Clinical Study Design
Learnings for non-clinical sample collection and testing
Importance of pre-dose samples
Align ADA with TK sampling
Collect enough sample to allow tier testing (screen, confirmation, titer, nAb)
Design to account for sample volume limitations (rodents)
Choice of bioanalytical assay
Drug interference (extend wash-out period so drug is BLQ)
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Bioanalytical Considerations
ADA In-Lab Analytical Time
Transfer 1-2 weeks
Development 2-3 weeks
Validation 3-4 weeks
Transfer Innovator + Biosimilar 1-2 weeks
Development Innovator + Biosimilar 2-3 weeks
Validation Innovator + Biosimilar 3-5 weeks
In 2014, ADA transfer studies lasted an average 6 week
in-life period
Not just analytical time, time is required for data
review, Client discussions, Client internal debate
What are Client (submission) timelines
Additional time for positive control generation
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Improved Communication
Who is involved in a non-clinical drug development program?
Non-Clinical Program
Safety Assessment
Bioanalysis
Manufacturing
BioCMC
DMPK Client Study
Monitor
Discovery group
QA
Are
communications
well defined?
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Risk Based Approach for ADA Testing
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Interpretation of Immunogenicity
Immunogenicity must be considered with other endpoints
ADA…onset of immune response & change in PK
PK….pharmacokinetics (drug exposure)
PD….pharmacodynamics (drug activity)
AE….adverse events/observations (drug toxicity)
….all are important when interpreting study results!
ADA + PK + PD + AE = Immunogenicity Assessment
CRO challenge to generate data
Pharma challenge to consider all data and make
immunogenicity assessment
Pharma could increase efficiency of CRO by
ensuring data are shared
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Risk Based Approach for ADA Testing Regulatory agencies consistently recommend that immunogenicity be
evaluated from a patient safety perspective
As such, companies should utilize a risk-based approach in evaluating
potential immunogenicity of their drug products
Immunogenicity is difficult to predict
– Potential immunogenicity of the protein
– Biological function of the protein
– Endogenous counterparts
– Route of administration
– Dose and frequency of administration
– Health status of subjects
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Bioanalytical Cost Limitations
Is ADA testing required?
Is a fully validated method required?
Trastuzumab (Herceptin Biosimilar)
Supported several full validations (~3 weeks)
Assay sensitivity can be affected by drug tolerance
Cannot confirm ADA response in presence of several mg drug
Acid dissociation can affect sensitivity
Is it necessary to change non-clinical design?
Typical ADA sampling 0, 1, 4, 13 weeks
IgG t ½ = 6 weeks after 8 day response time
Costly to include wash out periods (TK trough samples)
Use risk based approach to understand BioCMC and in vitro data
Plan in vivo studies and consider commitment to ADA assay
Copyright © 2014 Covance. All Rights Reserved
Summary
Regulatory agencies in the US and EU are consistent in their
recommendation that immunogenicity be evaluated from a patient
safety perspective, however this is open to interpretation
CROs can be well placed to advise Clients of potential bioanalytical
limitations
Pre-existing antibodies
Non-clinical study design
Consideration to bioanalytical timelines
Increased communications between Pharma and CRO can benefit
Use risk based approach to consider extent of bioanalytical testing
required
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Thank You
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Additional info for reference as required
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Regulatory Guidelines?
ICH ICH S6 Preclinical Safety Evaluation of Biotechnology-Derived
Pharmaceuticals (R1)
Q5E Comparability of Biotechnological/Biological Products Subject to
Changes in Their Manufacturing Process
Q2B Guideline Validation of Analytical Procedures Methodology
US Immunogenicity Assessment for Therapeutic Protein Products, August 2014
Scientific Considerations in Demonstrating Biosimilarity to a Reference
Product, February 2012 (draft)
Bioanalytical Method Validation, September 2013
23
“Many biotechnology-derived pharmaceuticals intended for human are immunogenic
in animals. Therefore, measurement of antibodies associated with administration of
these types of products should be performed when conducting repeated dose
toxicity studies in order to aid in the interpretation of these studies. Antibody
responses should be characterised (e.g. titer, number of responding animals,
neutralising or non-neutralising), and their appearance should be correlated with any
pharmacological and/or toxicological changes. …………“
“Animal immunogenicity assessments generally do not predict potential
immunogenic responses to protein products in humans. However, when differences
in manufacturing (e.g., impurities or excipients) between the proposed product and
the reference product may result in differences in immunogenicity, measurement of
anti-protein antibody responses in animals may provide useful information relevant
to patient safety.”
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Regulatory Guidelines?
EU
Immunogenicity Assessment of Biotechnology-Derived Therapeutic
Proteins, 2007 (revision due)
Guideline on Similar biological medicinal products containing monoclonal
antibodies: non-clinical and clinical issues, 2010
Guideline on Similar biological medicinal products containing
biotechnology-derived proteins as active substance: non-clinical and clinical
issues , 2005
Guideline on Bioanalytical Method Validation (2011)
24
“……..the predictivity of non-clinical studies for evaluation of immunogenicity is considered low. Non-
clinical studies aiming at predicting immunogenicity in humans are normally not required. However,
ongoing consideration should be given to the use of emerging technologies …which might be used as
tools. Measurement of antibodies in non-clinical studies are however requested as part of repeated dose
toxicity studies, in order to aid in the interpretation of these studies ……….. the comparison of the antibody
response to the reference product in an animal model may be part of the comparability exercise both for
similar biological medicinal products ………. and for changes in manufacturing………
“Due to the different production processes used by the biosimilar and reference product manufacturers,
qualitative differences of process related impurities will occur……... Qualitative or quantitative difference(s)
of product-related variants ……may affect biological functions of the mAb and are expected to be
evaluated by appropriate in vitro assays. These quality differences may have an effect on immunogenic
potential and potential to cause hypersensitivity. It is acknowledged that these effects are difficult to predict
from animal studies and should be further assessed in clinical studies. Immunogenicity assessment in
animals is generally not predictive for immunogenicity in humans, but may be needed for interpretation of
in vivo studies in animals. Blood samples should be taken and stored for future evaluations if then
needed.”
“Non-clinical toxicity as determined in at least one repeat dose toxicity study, including
toxicokinetic measurements. ……………”
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Immunogenic Classes of Therapeutic
Proteins
Class
Description Human
Protein
Homology
Immunogenicity
Frequency
Examples
A Prokaryotic Low High Staphylokinase
B Mammalian Low High OKT-3
C
Novel Construct Medium Variable High: Denileukin
Low: human
growth hormone
D Chimeric Human High Variable H: chMuL6
L: rituximab
E
Humanized High Variable L: Campath-1
H: Human anti-
CD3
F
Human
Identical
Variable H: GM-CSF
L: Human insulin
Bugleski and Treacy, Cur Opinion Mol Ther 6: 10-16, 2004
Strong
Weak
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Animal Data Not Predictive
Protein Therapeutic Preclinical
Immunogenicity?
Clinical
Immunogenicity?
Streptokinase and
Staphlyokinase
High High
Keyhole Limpet Hemocyanin High in rodents High
Human interferon α- 2a High in rodents Low
Human Growth Hormone High in rodents Low
Human Interferon-λ High in Cynomolgus
monkeys
Low
Human Interleukin-3 High in Rhesus monkeys Low
Bugleski and Treacy, Cur Opinion Mol Ther 6: 10-16, 2004
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Estimated Risk and Study Design Risk Level Drug Characteristics Examples Consequences
Low • Not structurally identical
to endogenous protein
• Non agonistic
• Enzymes
• Antibody drugs
• Infusion site reactions
• Loss of efficacy
• Mild allergic reactions
Medium • Partially or completely
identical to endogenous
protein
• Endogenous
counterpart is either
missing or redundant
or
• Not structurally
identical to endogenous
protein/agonistic
• Replacement therapy,
such as Factor VIII
• Antibody drugs
• Same as Low Risk
• Overstimulation of
endogenous mechanism
• Immune complex
formation
High • Partially or completely
identical to endogenous
protein
• Endogenous
counterpart is not
redundant
• Erythropoeitin
• GM-CSF
• Same as Medium Risk
• Neutralization of
endogenous counterpart
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Estimated Risk and Study Design Bioanalytical Testing Strategy
Risk Level Sampling Frequency Assessment ADAs
Low More frequently earlier in
development, less frequently in
Phase III (baseline, end of study and
possibly follow-up)
Screen / Confirm
Titer assessment
Further characterization may be
helpful Nab, Mapping ADA
Medium More frequently earlier in
development, less frequently in
Phase III (baseline, end of study and
possibly follow-up)
Screen / Confirm
Titer assessment
Further characterization may be
helpful Nab, Mapping ADA
High More frequently throughout all
phases of clinical trails.
Consider real-time testing of ADA
and Nab
Screen / Confirm / Titer / NAb
Further characterization of ADA by
mapping, isotyping etc.
Sequential patient dosing rather
than cohort model for first-in-human
studies
Rosenberg and Worobec; Biopharm. Int. 17, 17, 18 (2004)