Therapeutic Product Immunogenicity Community

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  • 1.  Highest ADA incidence to justify reduce sampling

    Posted 07-26-2023 11:27

    Hi Immunogenicity Experts,

    Do you have examples where you dropped a sample collection (e.g. D15) either in phase 3 or by amendment in an on-going phase 2 because of no ADA +s or low incidence with no impact? If the latter, then what was the low incidence value? equal or lower than 3%? 4%? again with no impact.  I am asking for a study were asking the participants to come back only for ADA (and corresponding PK) seems like a huge burden.

    The idea is to keep the D15 for the first 100 participants and depending on incidence drop the collection, but I am unsure what is the highest incidence that we would still consider low enough (and no impact) to drop the collection.

    Thanks so much for your feedback!!

    Johanna



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    Johanna Mora Ph.D.
    Bristol-Myers Squibb
    Princeton NJ
    [email protected]
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  • 2.  RE: Highest ADA incidence to justify reduce sampling

    Community Leadership
    Posted 07-27-2023 10:18

    Hi Johanna,

     

    an interesting though and based on the immunogenicity risk profile worth checking with the agency. I think with a good justification this could be possible. The only examples I have was defining rules when to stop sampling and measuring IMG for high risk products and study subjects being positive.

     

    Best wishes,

    Martin






  • 3.  RE: Highest ADA incidence to justify reduce sampling

    Posted 07-27-2023 16:00

    Thanks @Martin Ullmann!  I heard from a couple of people that in cases where there were no schedule visits for D15, the IMG collection was simply removed.  I agree with you that it would depend on IMG risk.



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    Johanna Mora Ph.D.
    Bristol-Myers Squibb
    Princeton NJ
    [email protected]
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  • 4.  RE: Highest ADA incidence to justify reduce sampling

    Posted 07-31-2023 12:47

    Hi Martin,

    I noticed in your response that you have experience in defining rules of when to stop sampling for IMG testing for high-risk products. I have a project where the health authority has requested us to continue testing samples post end of study until the titers lower or drop to baseline. Could you share your experience on defining the rules for when to stop? 

    Thanks

    Elisa



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    C. Elisa Oquendo Cifuentes
    Senior Principal Scientist
    Boehringer Ingelheim Pharmaceuticals Inc
    Ridgefield CT
    [email protected]

    Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
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  • 5.  RE: Highest ADA incidence to justify reduce sampling

    Posted 07-28-2023 16:04

    Hi Johanna,

                    I understand if you are unable to share more information about this study on a public forum, but it would be good to know more details such as the sample size, frequency of administration, and the size of database used to determine immunogenicity of the drug in previous studies. Is Day 15 the first of several ADA timepoints or the only one proposed for the study? If there are more ADA timepoints later on, then dropping Day 15 should be easy to justify. In my experience, it's very unusual to see any impact of ADA 15 days after the first dose. If Day 15 is the only timepoint proposed for ADA assessment, then taking samples from a subset of patients requires needs a strong scientific justification based on risk analysis. You mentioned low ADA incidence and impact, so I assume the immunogenicity risk is also low, but I don't know anything about your drug or your patients. Perhaps you could answer your question by statistical methods: to estimate ADA incidence of x% with y% confidence N subjects are needed. Or it could be restated like this: how many subjects are needed to confirm with y% confidence that ADA incidence is the same or lower than that established previously? Unfortunately, the lower ADA incidence the more subjects you need to make confident statements about immunogenicity impact .

                    You may also be prepared for something unpleasant on the label like "actual incidence of ADA may be unreported due to inadequate sampling", but we make medicines for patients and not for pretty prescribing labels so it may be risk worth taking.

    Best regards,

    Robert Kubiak



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    Robert Kubiak PhD
    Senior Manager, R&D
    AstraZeneca PLC
    Gaithersburg MD
    [email protected]

    Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
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  • 6.  RE: Highest ADA incidence to justify reduce sampling

    Posted 07-31-2023 13:32

    Hi Robert,

    Thanks for your thoughts. Yes, I can't share much. Here is what I can say. Risk is low, based on structure, MoA and patient factors.  FIH has no treatment induced ADAs, but assay does not have adequate drug tolerance for most timepoints, we will improve this for upcoming study. There are other planned collections: pre-dose and D29 (inclusive) onwards that follow industry best practices. I left that information out because I figured others would benefit from information on other programs where perhaps other collections were also dropped/removed. Based on other feedback, shared privately with me, it seems like a sound approach would be to remove D15 from the phase 2 protocol instead of assessing in some participants. We plan to ask the agency but have heard about several not asking and simply removing the D15 collections.



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    Johanna Mora Ph.D.
    Bristol-Myers Squibb
    Princeton NJ
    [email protected]
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  • 7.  RE: Highest ADA incidence to justify reduce sampling

    Posted 08-01-2023 20:36

    Hi Jahanna,

       Thanks. Removing D15 seems perfectly rational to me, especially if you have drug tolerance problem. 

    Robert



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    Robert Kubiak PhD
    Senior Manager, R&D
    AstraZeneca PLC
    Gaithersburg MD
    [email protected]

    Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
    ------------------------------



  • 8.  RE: Highest ADA incidence to justify reduce sampling

    Posted 09-07-2023 17:58

    Hi Johanna,

    We have example(s) of not only dropping time points, but some immunogencity analyses all together (e.g. Nab) for late-stage clinical studies where low incidence was observed (e.g. <5-10%). In addition to incidence, I think an important metric is clinical relevance. If there are no safety events associated with the ADA and no impact to PK/PD/efficacy of the drug, then there is quite strong rationale for minimizing and/or eliminating some (especially early timepoint) analyses. Hope that helps!

    Kind regards,

    Marie



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    Marie Printz
    Exec. Director, Bioanalytical & Nonclinical Sciences
    Halozyme Therapeutics Inc.
    San Diego CA
    [email protected]

    Disclaimer: Opinions expressed are solely my own and do not express the views or opinions of my employer.
    ------------------------------



  • 9.  RE: Highest ADA incidence to justify reduce sampling

    Posted 09-08-2023 15:55

    Well, I think that the answer is "it depends". Perhaps the most important factor is the immunogenicity risk of the molecule. That depends on the molecule itself, the disease, the route of administration, impurities, etc. And it includes the likelihood of an immune response as well as the potential clinical consequences in case of ADAs or NAbs. Assuming that you are referring to a monoclonal antibody, in general the risk tends to be low, and it seems to me that eliminating a Day 15 assessment should not be a problem (although it depends of what is the next timepoint.... you should have an assessment after 1 month, as a rule of thumb).  It also depends on the reason why the Day 15 timepoint was there in the first place. If it is a different kind of molecule, it may be considered too risky to remove an early timepoint, regardless of the ADA incidence observed so far, and also regardless of the observed impact. In any case, eliminating a timepoint after the FDA has approved the protocol poses somewhat of a regulatory risk,  so you should have your rationale ready. And that should include the immunogenicity risk assessment of the molecule.

    Good luck!



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    Francesca Civoli
    Principal
    Francesca Civoli Consulting LLC
    Half Moon Bay CA
    [email protected]
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