Priesner Christoph, Hildebrandt Martin
TUMCells Interdisciplinary Center for Cellular Therapies, Technical University of Munich, München, Germany.
Department of Internal Medicine III, Hematology and Oncology, Technical University of Munich Medical School, München, Germany.
Transfus Med Hemother. 2022 May 16;49(3):158-162. doi: 10.1159/000524392. eCollection 2022 Jun.
Academic institutions coin the ATMP landscape but do not possess an industry-like capacity to vigorously pursue the full developmental pathway to marketing authorization. At the same time, industry has fostered clinical trials with ATMPs, brought the first products to marketing authorization, and defined novel modes of interaction with academia. A regulatory niche for local manufacturing of ATMPs within an academic institution had been foreseen in Regulation (EU) 1394/2007 under the term "Hospital Exemption" but remained ill-defined. Manufacture in close proximity to the patient is difficult to accomplish, as "point of care" systems for the manufacture of ATMPs have encountered regulatory challenges hovering between process and product. The efforts and costs for the development of ATMPs continue to be dramatically underestimated, and few academic centers were persistent enough to invest in the GMP infrastructure needed and to recruit personnel trained in ATMP development. As a consequence, the contribution by hospitals to ATMP development has shifted from the finished ATMP toward the procurement of starting materials, selected manufacturing steps, storage of the product, clinical application, and participation in clinical trials. As the development and use of cell-based therapies and ATMPs continue to attract and challenge clinicians and scientists, this review aims to discuss logistical, financial, and regulatory issues that might contribute to the changing role of Academia in ATMP development, with an outlook into possible developments in the future and proposals for ways to reshape the academic environment under the auspices of what might truly have been meant by the hospital exemption clause.
学术机构塑造了先进疗法医药产品(ATMP)的格局,但却不具备类似行业的能力,无法大力推进通往上市许可的完整研发路径。与此同时,行业推动了ATMP的临床试验,将首批产品推向上市许可,并定义了与学术界互动的新模式。在(欧盟)第1394/2007号法规中,“医院豁免”条款预见了学术机构内ATMP本地生产的监管空间,但该条款仍定义不明确。由于ATMP生产的“即时护理”系统在工艺和产品之间面临监管挑战,因此很难实现靠近患者的生产。ATMP研发的努力和成本仍被严重低估,很少有学术中心有足够的毅力投资所需的GMP基础设施并招聘经过ATMP研发培训的人员。因此,医院对ATMP研发的贡献已从成品ATMP转向起始材料的采购、选定的生产步骤、产品储存、临床应用以及参与临床试验。随着基于细胞的疗法和ATMP的研发与应用继续吸引并挑战临床医生和科学家,本综述旨在讨论可能导致学术界在ATMP研发中角色转变的后勤、财务和监管问题,并展望未来可能的发展以及在医院豁免条款真正意图的支持下重塑学术环境的方法建议。