Reduced Genotoxicity Testing Is Possible for Noncoding Oligonucleotide-Based Therapeutics Containing
Clara Stock1, Britt Duijndam1, Christine L E Siezen1
1Dutch Medicines Evaluation Board, Utrecht, The Netherlands.
Abstract:
There is a current lack of harmonized regulatory guidance in evaluating the genotoxic potential of oligonucleotide-based therapeutics (ONTs). In particular, guidance has not established the circumstances under which it is acceptable to deviate from the standard test battery. In this study, we analyzed genotoxicity testing strategies and supporting rationales for 91 noncoding ONTs receiving European Scientific Advice between 2004 and 2024. While the standard test battery was performed for the majority of ONTs, reduced test approaches were proposed for 10 products. Furthermore, we examined both the positions of applicants and corresponding European Union (EU) regulatory opinions to identify critical considerations in evaluating genotoxicity. Our findings show that EU regulators see opportunities to deviate from the standard test battery for ONTs if sufficient evidence for class experience can be demonstrated. This was confirmed for several ONTs with well-characterized chemical modifications (ie, phosphorothioate, 2'-methoxyethyl, and 2'-Omethyl), making the standard battery redundant in these cases. Although all reported genotoxicity tests have been uniformly negative, uncertainty remains for future modifications. Ideally, what constitutes sufficient evidence for class experience should be defined in the upcoming International Council for Harmonisation guideline addressing the nonclinical safety evaluation of ONTs (ICH S13), which would allow regulators to accept reduced testing. Together with the industry sharing more knowledge and underlying data that support growing class experience, this development can promote a harmonized approach for future genotoxicity testing of noncoding ONTs.
Insights
Regulatory guidance for oligonucleotide-based therapeutics (ONTs) genotoxicity testing is lacking. Regulators accept reduced testing for ONTs if sufficient class experience is demonstrated, particularly for established chemical modifications.
Area of Science:
- Pharmacology
- Toxicology
- Regulatory Science
Background:
- Harmonized regulatory guidance for evaluating the genotoxic potential of oligonucleotide-based therapeutics (ONTs) is currently lacking.
- Specific circumstances for deviating from the standard genotoxicity test battery are not well-established.
Purpose of the Study:
- To analyze genotoxicity testing strategies and rationales for noncoding ONTs that received European Scientific Advice.
- To identify critical considerations for genotoxicity evaluation by examining applicant positions and EU regulatory opinions.
Main Methods:
- Retrospective analysis of genotoxicity testing data for 91 noncoding ONTs.
- Review of European Scientific Advice documentation (2004-2024).
- Examination of applicant submissions and European Union regulatory feedback.
Main Results:
- The standard genotoxicity test battery was used for most ONTs, but reduced testing strategies were proposed for 10 products.
- European Union regulators permit deviations from the standard battery when substantial evidence of class experience exists.
- Well-characterized modifications (e.g., phosphorothioate, 2'-methoxyethyl, 2'-Omethyl) supported reduced testing, rendering the standard battery redundant in these instances.
Conclusions:
- EU regulators accept reduced genotoxicity testing for ONTs based on demonstrated class experience.
- Clear definition of 'sufficient evidence for class experience' in upcoming ICH S13 guidelines is crucial for harmonized reduced testing.
- Increased industry data sharing will foster a harmonized approach to noncoding ONT genotoxicity assessment.
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