Ema Guideline Clinical
Ema Guideline Clinical
Ema Guideline Clinical
22 July 2010
EMA/CHMP/BPWP/94033/2007 rev. 2
Committee for Medicinal Products for Human Use (CHMP)
Draft Agreed by Blood Products Working Party following consultation February 2010
Adoption by Committee for Medicinal Products for Human Use for release 18 March 2010
for consultation
This guideline replaces Note for Guidance on the Clinical investigation of human normal
immunoglobulin for intravenous administration (IVIg) (CPMP/BPWG/388/95 rev. 1)
© European Medicines Agency, 2010. Reproduction is authorised provided the source is acknowledged.
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
2/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
Definitions ................................................................................................. 14
References ................................................................................................ 14
3/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
Executive summary
This Guideline describes the information to be documented when an application is made for a
marketing authorisation for a human normal immunoglobulin for intravenous use (IVIg). The guidance
covers biological data, clinical trials and patient follow-up. Quality aspects are outside the scope of this
guideline.
Guidance is also provided for authorised products where a significant change in the manufacturing
process has been made.
1. Introduction (background)
The purpose of this Guideline is to provide applicants and regulators with harmonised guidance for
applications for marketing authorisation for IVIg.
2. Scope
This guideline describes the information to be documented when an application for a marketing
authorisation for IVIg is made, including biological data, pharmacokinetics, clinical trials and patient
follow-up.
2. authorised products where a significant change in the manufacturing process has been made (e.g.
additional viral inactivation/removal steps or new purification procedures).
The clinical trials described in this Guideline should be performed according to the ICH Note for
Guidance on Good Clinical Practice (CPMP/ICH/135/95).
This Guideline covers normal human immunoglobulin for intravenous administration defined by the
European Pharmacopoeia monograph 0918. The Guideline does not relate to fragmented or chemically
modified products.
3. Legal basis
This Guideline should be read in conjunction with the introduction and general principles (4) and part I
of the Annex I to Directive 2001/83 as amended.
4. Background
The first use of polyvalent intravenous immunoglobulin preparations was as replacement therapy in
humoral immunodeficiency situations. As human normal immunoglobulin for intravenous
administration (IVIg) is prepared from plasma collected from a high number of healthy blood donors,
the spectrum of antibody specificity expressed by the IgG is large. Among the antibody specificity
spectrum, IVIg recognises a large number of bacterial, viral and other infectious agent antigens, and
also a large number of self antigens. Besides the therapeutic effect in replacement, IVIg has thus also
been used for its immunomodulatory activity.
4/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
Indications of IVIg are described in two main sections referred to as “replacement therapy” and
“immunomodulatory effect”. While the immunodeficient conditions covered by the replacement effect
of IVIg are quite well-defined, the immunomodulatory effect of IVIg has been demonstrated in a
limited number of diseases only. Lists of such auto-immune-related diseases have been established by
various national and international bodies and are constantly updated.
Timeline history of guideline: The original guideline (EC III 581/94, CPMP/388/95) came into operation
on 14 August 1996. The first revision (CPMP/BPWG/388/95 rev. 1) came into operation in December
2000.
5. Efficacy
Biological data and clinical evidence of efficacy and safety in primary/secondary humoral
immunodeficiencies and ITP are the key elements required for the licensing of IVIg in the following
claimed indications:
IVIg can be used in all age ranges, unless otherwise specified below.
x Children and adolescents with congenital AIDS and recurrent bacterial infections.
x Primary immune thrombocytopenia * (ITP) in patients at high risk of bleeding or prior to surgery to
correct the platelet count
x Kawasaki disease
The listed indications are considered as “established” for IVIg and this guideline outlines the general
principles for design of clinical trials.
For other auto-immune disorders (in particular multifocal motor neuropathy (MMN), chronic
inflammatory demyelinating polyradiculoneuropathy (CIDP), myasthenia gravis exacerbations)
confirmatory data are required, see 7.3.5.
*
The term idiopathic thrombocytopenic purpura has been exchanged for primary immune thrombocytopenia according to
the recommendations of an International Working Group (IWG) in “Standardization of terminology, definitions and outcome
criteria in immune thrombocytopenic purpura of adults and children”1. The acronym will remain the same.
5/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
6. Safety
All adverse events in clinical studies must be recorded and analysed with regard to causality,
seriousness, outcome and expectedness (see 7.4.1.). A detailed protocol of the studies specifying the
intervals and methods for collection of the data, and duration of follow up is requested.
Safety data from trials in indications not claimed in the application can be used as supportive data.
Manufacturers of plasma-derived products, including IVIg, are obliged to optimise viral safety by
selection of donors, screening of individual donations and plasma pools for specific markers of infection
and the inclusion of effective steps for the inactivation/removal of viruses in the manufacturing
processes.
The above-mentioned procedures are now considered to be highly effective and demonstrative of the
viral safety of the product with respect to enveloped viruses.
These procedures may be of limited value against non-enveloped viruses, such as hepatitis A virus and
parvovirus B19. There is reassuring clinical experience regarding the lack of hepatitis A or parvovirus
B19 transmission with immunoglobulins and it is also assumed that the antibody content makes an
important contribution to the viral safety.
The applicant is nevertheless required to provide all available data gathered on patients treated with
the product in clinical trials. Investigators should continue with their normal clinical practice of
monitoring patients. The applicant should demonstrate that there are systems in place to collect
information on patients treated with the product and to respond rapidly to any reports of infection with
a full investigation.
For products with an entirely novel manufacturing process other principles may apply. These
applications should be discussed with the Regulatory Authorities prior to submission.
Similar principles to those outlined in 6.2.1 apply for safety with regard to other transmissible agents
including TSE and other emerging pathogens. Manufacturers should follow the respective guidance
documents and position statements. Information can be found in the section “Guidelines on Plasma-
derived Medicinal Products” on the Agency website:
http://www.ema.europa.eu/ema/index.jsp?curl=pages/regulation/general/general_content_000330.js
p&murl=menus/regulations/regulations.jsp&mid=WC0b01ac058002956b.
The effect of passive transmission of haemagglutinins (anti-A/anti-B), and anti-D should be evaluated
in patients receiving high doses of IVIg.
6/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
Adequate documentation with regard to batch to batch consistency is provided in Module 3 of the
dossier and should follow the Ph. Eur. Monograph 0918 requirements.
However, specific data are needed to support the pharmacodynamic and therapeutic activities as well
as the safety profile of the IVIg preparation. The data should include the following parameters and be
summarised in Module 5 of the dossier along with the cross-reference to Module 3 (wherever
applicable).
i) Biological characteristics
General
viruses, such as: hepatitis A and B viruses; cytomegalovirus; varicella-zoster virus; rubella
virus; measles virus; parvovirus B19; poliomyelitis virus type I.
Other
x Anti-complementary activity
x Anti-D antibodies
x Prekallikrein activator.
7/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
7.2. Pharmacokinetics
Pharmacokinetic (PK) data are essential to support the pharmacological activity and efficacy of the
product, and may differentiate one product from another. Therefore, they must be provided in each
application dossier (see PK study chart).
PK parameters
1. IgG trough levels should be studied in 40 patients with primary immunodeficiency syndromes
(PID), whereby 20 of these should be children or adolescents with an age distribution
representative of this patient population. The IgG trough levels of the investigational product
should be assessed prior to each infusion over a period of 6 months, starting after 5-6
administrations of the product. The IgG trough levels obtained and treatment intervals should be
compared to either the trough levels and treatment intervals of the former product (in previously
treated patients) or to literature data (in patients naïve to IVIg treatment), whereby predefined
comparability limits should be justified by the applicant.
2. Other PK parameters including plasma concentration-time curve, half-life, area under the curve,
volume of distribution, Cmax, Tmax, and elimination rate constant(s) should be measured in 20
adult PID patients assessed by repeated blood sampling after approximately 5-6 administrations of
the product until immediately before the next infusion. The other PK parameters obtained should
be discussed by the applicant in the light of the literature data.
PK population
Pharmacokinetic data set can be derived from patients with primary immunodeficiency syndromes
(PID) who are either already stabilised on IVIG treatment (group A) or naïve to IVIG treatment (group
B) or the set can contain both patient groups.
In patients already stabilised with another IVIg preparation, trough levels and treatment intervals
should be documented for at least two previous infusions, prior to the introduction of the new IVIg
preparation. After a period of approximately 5-6 administrations of the new IVIg product, trough levels
and treatment intervals should be measured.
In patients naïve to IVIg the pharmacokinetic profile should be assessed when steady state (Tss) is
reached.
8/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
PK study chart
7.3. Efficacy
IVIg is used as replacement therapy for the treatment of primary and secondary immunodeficiencies.
Efficacy should be proven in an open clinical trial of one year duration in primary immunodeficiency
syndromes. The patients selection should take into account statistical considerations (see below).
At least 40 patients should be included; approximately half of these patients should be children and
adolescents with an age distribution representative of this patient population. The patients should be
followed over 12 months to avoid a seasonal bias (due to a greater rate of infections in the winter
months).
The recommended primary endpoint is the number of serious bacterial infections (less than 1.0
infection/subject/year). The protocol should prospectively provide specific diagnostic criteria for each
type of serious infection to be included in the primary efficacy analysis. Serious bacterial infections
include:
x bacteraemia or sepsis,
x bacterial meningitis,
x bacterial pneumonia,
x visceral abscess.
Secondary endpoints are IgG trough levels (see section 7.2), all other infections, antibiotic treatment,
days lost from school/work, hospitalisations and fever episodes.
Statistical considerations
The number of subjects to be included into the study might exceed 40 patients as the study should
provide at least 80% power to reject the null-hypothesis of a serious infection rate greater or equal 1
by means of a one-sided test and a Type I error of 0.01.
9/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
The secondary endpoints should be prospectively defined and their statistical analyses provided in the
study protocol.
The efficacy results from this study would apply to all types of primary immunodeficiency syndromes
due to deficiency of functional IgG.
3. Children and adolescents with congenital AIDS and recurrent bacterial infections.
The above indications would be granted as long as efficacy has been proven in primary
immunodeficiency syndromes (see 7.3.1). Standard doses are 0.2-0.4 g/kg every three to four weeks.
If other dosage regimens are requested, they should be supported by clinical data.
7.3.3. ITP
IVIg is used for the treatment of ITP in children, adolescents or adults at high risk of bleeding or prior
to surgery to correct the platelet count.
There are no data to support the equivalence of different IVIg preparations, especially with regard to
immunomodulatory activities. Thus a clinical efficacy study is required to establish the product efficacy
in this indication.
Efficacy study
An open, study with the investigational IVIg should be performed in 30 chronic (> 12 months duration)
adult ITP patients with a baseline platelet count of <30 x 109/l. The results should be compared to data
from the literature. Standard doses should be studied (0.8 - 1 g/kg on day one, which may be
repeated once within 3 days, or 0.4 g/kg/day for 2-5 days). If other dosage regimens are applied for,
they should be supported by clinical data.
Baseline data on splenectomy and co-medication (especially affecting bleeding or platelets) should be
provided. Patients included in the study may have refractory ITP i.e. the failure to achieve a response
or loss of response after splenectomy and the need of treatment(s) to minimize the risk of bleeding
considered as clinically significant by the investigator. In clinical practice refractory patients may need
on demand IVIG to temporarily increase the platelet count sufficiently to safely perform invasive
procedures or in case of major bleeding or trauma; the platelet count to be reached will depend on the
nature of the invasive procedure
Corticosteroids are permitted if the patient is either on long-term stable doses of corticosteroids or the
platelet count falls below 30 x 109/l again after IVIg treatment, but should not to be given as a pre-
treatment to alleviate potential tolerability problems. Patients with increases in corticosteroid doses
during the duration of the response period of the study should be regarded as treatment failures. Any
concomitant medication during the trial should be documented and possible confounding impact on the
outcome of the trial assessed.
10/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
Efficacy parameters:
Number and % of patients with response (R), complete response (CR), no response (NR) and loss of
response as well as time to response and duration of response.
These patient parameters are defined according to the proposals of an International Working Group1:
x patients with R: platelet count >30 x 109/l and at least 2-fold increase of the baseline count,
confirmed on at least 2 separate occasions at least 7 days apart, and absence of bleeding.
x patients with CR: platelet count >100 x 109/l, confirmed on at least 2 separate occasions at least 7
days apart, and absence of bleeding.
x patients with NR: platelet count < 30 x 109/l or less than 2-fold increase of baseline platelet count,
confirmed on at least 2 separate occasions approximately 1 day apart, or bleeding.
x patients with loss of CR or R: platelet count below 100 x 109/l or bleeding (from CR) or below 30 x
109/l or less than 2-fold increase of baseline platelet count or bleeding (from R). Platelet counts
confirmed on at least 2 separate occasions approximately 1 day apart.
x Time to response: time from starting treatment to time of achievement of CR or R. (Late responses
not attributable to the investigated treatment should not be defined as CR or R).
x Wherever possible, platelet parameters should be provided as mean (and standard deviation) and
median (and minimum and maximum) values for each patient, as well as for summary data.
In the absence of specific clinical trial data in these indications, the efficacy in primary
immunodeficiency syndromes and in ITP should be established.
Published literature in Guillain Barré syndrome and Kawasaki should be provided. The applicability of
these data, including the dosage regimen, to the IVIg should be justified in the expert report. If other
dosage regimens are requested, they should be supported by clinical data.
In Kawasaki disease, patients should receive concomitant treatment with acetylsalicylic acid.
Published literature indicates a positive effect of IVIgs in some auto-immune disorders in particular
multifocal motor neuropathy (MMN), chronic inflammatory demyelinating polyradiculoneuropathy
†
(CIDP), and myasthenia gravis exacerbations . For these indications the efficacy in primary
immunodeficiency syndromes and in ITP should be established. The applicant should also provide
x Confirmatory data with the applicant’s IVIg (see also ‘Guideline on Clinical Trials in Small
Populations’, CHMP/EWP/83561/2005), This should include a justification for the
scope of the confirmatory dataset (sample size, dose, time frame, patient population),
† The existing legislation provides various incentives for the development of new indications through orphan medicinal products, paediatric-use
marketing authorisations, and an additional year of data exclusivity for a new indication of an existing product.
11/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
choice of the neurological scale and clinically meaningful differences within the chosen scale
x The investigation of other auto-immune indications should be in accordance with the Paediatric
Regulation (EC) No 1901/2006
Other possible indications cannot be granted without relevant specific clinical data. Biological and
pharmacokinetic data alone are not sufficient to support clinical efficacy.
Controlled clinical trials comparing the IVIg preparation with placebo or with an established therapy are
thus required to substantiate marketing authorisation in other indications.
The investigation of other indications should be in accordance with the Paediatric Regulation.
7.4. Safety
Product safety is evaluated based on all pertinent safety findings. A comprehensive risk management
plan (RMP) has to be submitted as part of the dossier (see Guideline on ‘risk management systems for
medicinal products for human use’, EMEA/CHMP/96268/2005).
Comprehensive baseline data and patient histories are essential to compare the safety signals arising
from the studies. The safety signals should be compared with data and frequencies described in the
literature. Any deviation from known signals and rates should be discussed. Adverse events (AEs) and
serious adverse events (SAEs) from all subjects followed throughout the clinical studies should be
recorded and reported regardless of whether the AE is determined to be related to the product or not.
The reporting should be in accordance with the ICH Guidelines on “Structure and content of clinical
study report”, CPMP/ICH/137/95 E3. Preferably the reporting should apply the terminology used in the
Medical Dictionary for Regulatory Activities (MedDRA).
Safety evaluation should include monitoring of short term tolerance (blood pressure, heart rate,
temperature, and monitoring of other adverse events) at repeated intervals following the infusion of
the new product. All AEs that begin during or within 72 hours after an infusion should be classified and
analysed as infusional AEs.
AEs should be evaluated with regard to the infusion rates. Renal function should be monitored,
particularly in patients at risk and in those receiving high doses of IVIg.
All safety data should include a separate evaluation of the safety dataset in children and adolescents.
This should be compared to the adult dataset and relevant discrepancies listed in the SmPC.
Post-marketing safety data collection in children should be proposed in the risk management plan.
A separate safety evaluation of the excipients should be provided, which should encompass a summary
of the non-clinical and literature data.
12/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
Compliance with CHMP recommendations with regard to viral safety and other transmissible agents
under 6.2 above is necessary for all plasma-derived products and is verified by information supplied in
Module 3 of the dossier.
A pre-treatment serum sample from each patient included in the clinical trials should be stored
at -70˚C for possible future testing.
The effect of passive transmission of haemagglutinins and haemolysins (anti-A/anti-B), and anti-D
should be evaluated in patients receiving high doses of IVIg, by searching for haemolysis and
performing a Direct Antiglobulin Test (DAT; direct Coombs’ test) in the patient.
Where a paediatric investigation plan is required in order to comply with the Paediatric Regulation (EC)
No 1901/2006, the applicant should provide a plan that includes the recommendations described in
this guideline for the paediatric population.
When a change is introduced to the manufacturing process of a given product, the marketing
authorisation holder will have to demonstrate that the “post-change” and the “pre-change” product are
comparable in terms of Quality, Safety and Efficacy (see ICH Q5E Guideline on "Comparability of
Biotechnological Products (CPMP/ICH/5721/03). This will be a sequential process, beginning with
investigations of quality and supported, as necessary, by non-clinical and/or clinical studies.
The extent of clinical data to be provided has to be judged on a case-by-case basis depending on the
anticipated impact of the changes and could vary from a pharmacokinetic trial comparing “pre-change”
versus “post-change” product up to the full clinical data set as outlined for a new product.
If the biological data and/or pharmacokinetics data are significantly different from the parent
preparation, then the product should comply with the requirements for a new product as defined in
section 7.
13/14
CHMP_94033_2010.pdf
Octagam 10% - Solution for Infusion
5.4 - Literature References
The effects of changes in the manufacturing process (e.g. viral inactivation steps, changes in pH,
changes of excipients, changes in dimer content or new purification procedures) on the biological
characteristics and activity of the product should be investigated.
Thus, it is important to provide full data on antibody integrity and function as for new products (see
section 7.1).
8.3. Pharmacokinetics
Plasma concentration-time curve, half-life, area under the curve, volume of distribution, Cmax, Tmax,
and elimination rate constant(s) should be measured in 20 adult PID patients assessed by repeated
blood sampling after approximately 5-6 administrations of the product until immediately before the
next infusion. These PK parameters should be compared to data obtained with the predecessor
product.
For ITP, since the biological rationale for efficacy is not completely elucidated, a further clinical study is
required as outlined above in 7.3.3.
The remaining indications that were granted for the parent product (i.e. prior to the changes in the
manufacturing procedures) can be granted by reference to the literature, provided that efficacy has
been established in ITP for the changed product.
PID patients included in the limited PK study (8.3) and ITP patients should be evaluated for safety
according to the principles outlined in 7.4.
Requirements for viral safety and other transmissible agents are the same as for the parent product
(see 7.4.2).
Definitions
CIDP Chronic inflammatory demyelinating polyradiculoneuropathy
MM Multiple myeloma
References
1 Rodeghiero F. et al. Standardization of terminology, definitions and outcome criteria in immune
thrombocytopenic purpura of adults and children: report from an international working group.
Blood. 2009;113:2386-2393
14/14
CHMP_94033_2010.pdf