Regulatory Requirements for ATMPs

In general, the product life cycle of an ATMP is considered in a risk-based manner. A risk-based approach provides flexibility to the ATMP manufacturer, but also obliges him to name and assess the existing risks of the manufacturing process, product quality, safety, and efficacy and to implement appropriate measures. The use of the risk-based approach can facilitate compliance with regulatory requirements, but does not relieve the manufacturer of its obligation to meet them. However, this is reflected in a very extensive documentary effort, as well as the obligation to keep the documentation for 30 years. While the responsibility for the application of the risk-based approach lies with the manufacturer, it is recommended to seek the advice of the competent authorities (scientific advice) when implementing the risk-based approach for investigational ATMPs (iATMPs). The application of the risk-based approach should be closely related to the provisions of the clinical trial authorization.

For approved ATMPs, the application of the risk-based approach should be consistent with the provisions of the medicinal product authorization. The application for medicinal product approval may highlight the specific characteristics of the product or manufacturing process to justify the adaptations or deviations from the standard requirements. This applies to managing specific limitations that exist related to the manufacturing process, including control of raw and starting materials, manufacturing facilities, manufacturing equipment, acceptance criteria, process validation, release specifications, or stability data.

ATMPs require due to their often reduced stability and sometimes short lifetime an individual handling, additional stability tests and quality controls. The quality differences of the starting material often require high demands on incoming controls. The manufacturing process is often carried out manually in complex processes. The particular challenge is the often limited and heterogeneous starting and final material, batch sizes are small up to personalized individual therapy.

However, ATMP vigilance is also a challenge, as ATMPs, due to their origin and handling, may pose an increased risk of contamination compared to conventional medicinal products, immunological secondary reactions or still unknown risks to patients. Possible risks and side effects cannot always be predicted from preclinical data and clinical studies conducted, as the therapies are too individual.

Automation of the manufacturing process will only possible in subsequent further development or can be ruled out altogether due to the small batch sizes. In addition, ATMPs are sometimes prepared in such a way that they have to be reconstituted after release and before application.

However, it must be ensured that certain specifications are met. These include:

• Identity – it must be ensured that the medicinal product to be administered has the properties that it should have according to the latest scientific and technical knowledge
• Purity – the preparations must not be contaminated by foreign substances, including contamination with chemical substances as well as foreign organisms
• Functionality – no preparation will be considered for subsequent use whose functional suitability cannot be demonstrated by appropriate surrogate tests

Valicare supports you in the development of a GMP-compliant manufacturing process!

The journey of an ATMP from the laboratory bench to the bedside takes a long time, during which methods and processes of manufacturing and quality controls must be established and stabilized. A great deal of knowledge must be available or generated until the idea is ready for development. The instructions used must be laid down in standard operating procedures (SOPs) and their implementation in corresponding protocols and reports. As a rule, development reports are written about the lengthy preclinical phase of development.

The path from the bench to the bedside is a challenge. Valicare will support you.

So far, there are no mandatory requirements for good laboratory practice (GLP) but this may change in the near future. In this case, it is usually useful to introduce documents that are already controlled, that show responsibilities and that allow the development of the processes to be identified by means of versioning. Process validation is necessary to show the stability of the processes. From the results of the development, it can be deduced whether the product corresponds to the state of science and technology and whether the specifications defined in advance for the ATMP are achieved. In parallel, the test methods must be correspondingly valid. These requirements are essential for an application for a manufacturing authorization.

Beyond that, however, more is needed: A sterile environment is also required for the manufacturing of ATMPs. Many university hospitals have clean room facilities. As in the pharmaceutical environment, the rooms are regulated according to DIN EN ISO 14644 and have appropriate high efficiency particulate air (HEPA) filters, predetermined temperature and humidity control and pressure cascades depending on the cleanroom class. These are intended to help exclude particles and contaminants on them. In a required particle monitoring (at rest and in operation) as well as a defined air and surface germ determination, it has to be shown that the particle and germ input is below a defined threshold value. In the GMP environment, devices are required whose suitability has been demonstrated within a qualification (including the installation qualification, operational qualification and performance qualification phases).

If a process is transferred to a clean room in a GMP environment, the requirements of the ATMP GMP Guideline must be addressed and appropriate technical runs and validation of aseptic procedures must be performed. In addition, the validation of sterile process control (Media Fills)  must be presented. After completion of all measures and compilation of the documentation, an application for manufacturing authorization can be submitted to the regional council.

The first major challenge for a developer is to obtain a manufacturing authorization according to § 13 AMG. However, this manufacturing authorization is the basic prerequisite for the manufacturing of iATMPs. It must already be available for the manufacturing of iATMPs as phase I test product, i.e. for the first application in humans. Valicare will gladly support you in applying for such a manufacturing authorization at the responsible regional council and in meeting the requirements. According to § 4 Abs. 14 AMG, the term “manufacturing” includes the manufacturing, preparation, processing, decanting including filling, packaging, labelling, and release of a medicinal product. The corresponding GMP certificate must be renewed every three years by means of a repeat inspection by the competent authority.

The development of a new medicinal product can basically be divided into several stages: First, the characterization and standardized manufacture of the product are performed to ensure quality, followed by the safety and efficacy demonstrations in non-clinical models. In the final phase, the product is tested in clinical trials to determine its safety and efficacy in humans. The Paul Ehrlich Institute (PEI), the responsible higher federal authority, offers a needs-oriented, step-by-step consulting concept, in which Valicare will gladly support and accompany you in the pre- and post-trial phases. Within the scope of this consultation, product-specific questions in the quality, non-clinical and clinical areas can be discussed with regard to regulatory requirements, e.g. questions about the manufacturing process, microbiological or viral safety as well as pharmacokinetics, toxicology, biodistribution, inclusion, and exclusion criteria or the study population. Many ATMPs offer therapeutic concepts for the treatment of rare diseases, which often mean small patient populations and thus limitations in patient recruitment. This contingency must be considered when planning the pharmaceutical development of the ATMP. In such cases, orphan designation status may be sought from the European Medicines Agency (EMA). 

The testing of clinical trials in the field of vaccines and biomedical medicinal products is also the responsibility of the PEI in Germany. Already from phase I of the clinical trial, a manufacturing authorization according to § 13 AMG is required, and these preparations may then be used on patients if the responsible ethics committee has also examined the procedure and assessed it as ethically justifiable.

Valicare offers comprehensive services in investigational product management.

According to Article 28 of Regulation (EC) No. 1394/2007, individual member states of the EU may approve their ATMPs on a national basis under a derogation. Within the scope of the 15th AMG amendment, a corresponding regulation was also implemented in the German AMG. All requirements for an ATMP specified in § 4b  AMG,  Abs. 3 must be met so that such an approval can be obtained. The ATMP must correspond to the state of scientific knowledge, fulfill the intended function and have a balanced benefit-risk ratio. In addition, the following requirements for a classified ATMP must be met:

• Individual preparation for a single patient, prescribed by a physician
• Non-routine manufacturing in accordance with specific quality standards
• Administration in a health care facility under the professional responsibility of the physician

Quality, efficacy and safety are assessed through an approval process. In this context, the specific quality standards must correspond to the specifications at community level that apply to ATMPs requiring central authorization, for which reason a manufacturing authorization is required in accordance with § 13 AMG . Furthermore, the holder of such an authorization has a documentation and reporting obligation to the PEI at regular intervals and must report on the extent of manufacture and on the knowledge gained of the medicinal product and its pharmacovigilance. With regard to the traceability of medicinal products derived from human tissue or cells, Art 15. of Regulation (EC) No. 1394/2007,§ 13c of the Transplantation Act (Transplantationsgesetz, TPG) and the Tissue Ordinance (Transplantationsgesetz-Gewebeverordnung, TPG-GewV apply. Valicare has also been able to support customers with special requirements in this area on several occasions.

Valicare guides and supports clients in complying with and implementing the specific requirements of the National Exemption. 

Only after a pharmaceutical development of the preparation and the securing of a market supply, a central registration with the European Medicines Agency takes place. The documents required for a submission can be prepared by Valicare with the help of your information. The minimum documents required for approval are:

• Description of the manufacturing environment with naming of the premises and responsibilities, the validation master plan (VMP), documents on the qualification and validation status as well as specifications on hygiene and monitoring
• Presentation of the GMP system (pharmaceutical risk management, GMP documentation, procedural instructions for GMP-relevant processes, change and deviation management, corrective actions and preventive actions (CAPA) system, qualifications and training of personnel, as well as personnel in responsible positions)
• Reports on the development of manufacturing and quality control methods
• Specifications of starting materials including supplier qualification 
• Investigational medicinal product dossier (IMPD)
• Preclinical trials
• Clinical trials
• Measures to secure market supply
• Documents on subcontracted procedures, if applicable