BIO Comments on FDA Guidance: Considerations for the Development of Chimeric Antigen Receptor (CAR) T Cells Products

On Friday, June 10th, BIO submitted comments in response to the FDA’s draft guidance on Chimeric antigen receptor (CAR) T cell products (i.e., human gene therapy products in which the T cell specificity is genetically modified to enable recognition of a desired target antigen for therapeutic purposes). In the comments submitted, BIO expressed appreciation for the FDA’s statement that recommendations in the guidance will be applicable to other genetically modified lymphocytes. However, as the title of the guidance is limited to (CAR) T cells and there is little mention of therapies beyond (CAR) T, BIO raised the need for additional clarity on which principles within the guidance the Agency plans to apply more broadly. To that end, BIO urged FDA to expand the scope of the guidance and provide further detail on the breadth of products the guidance would apply to, especially given the unique scientific considerations presented by certain cell types. Finally, in addition to a number of specific line edits, BIO highlighted that the landscape of regenerative medicines is continually expanding and evolving and there are a number of topics where sponsors could benefit from the issuance of additional guidances.