With over 220 investigational new drug applications currently active, gene
therapy represents one of the fastest growing areas in biotherapeutic resea
rch. Initially conceived for replacing defective genes in diseases such as
cystic fibrosis or inborn errors of metabolism with genes encoding the norm
al, or wild-type, gene product, gene therapy has expanded into other novel
applications such as treatment of cancer or cardiovascular disease, where t
he risk:benefit profiles may be more acceptable in relation to the severity
of the disease. Different types of vectors, including modified retroviruse
s, adenoviruses, adenovirus-associated viruses, and herpesviruses and plasm
id DNA, are used to transfer foreign genetic material into patients' cells
or tissues. Developing a toxicology program to determine the safety of thes
e agents, therefore, requires a modified approach that encompasses the phar
macology and toxicity of both the gene product itself and the vector system
used for delivery in the context of the application for the clinical trial
. In general, the issues involved in designing and developing appropriate p
reclinical testing to determine the safety of these products are similar to
those encountered for other recombinant molecules, including protein bioth
erapeutics. Limitations to some of the typical toxicology studies conducted
for a traditional drug development program may exist for these agents, and
nontraditional approaches may be required to demonstrate their safety. Man
y factors may affect the safety and clinical activity of these agents, incl
uding the route, frequency, and duration of exposure and the type of vector
employed. Other safety considerations include quantitation of the duration
and degree of expression of the vector in target and other tissues, the ef
fects of gene expression on organ pathology and/or histology, evaluation of
trafficking of gene-transduced cells or vector after injection, and intera
ctions of the host immune system with the transduced cell population. Becau
se of the unique concerns regarding each of these therapies, the Center for
Biologics Evaluation and Research encourages sponsors to obtain toxicity d
ata whenever possible while evaluating the pharmacologic activity of the ve
ctor in a species or animal model relevant to their clinical indication. Sp
onsors are encouraged to discuss preclinical study design and results with
the Center during product development to facilitate early identification of
safety concerns prior to entry of these novel agents into the clinical set
ting and to ensure an uninterrupted course of development while addressing
issues required for licensure.