Stem Cells and Cell-Based Products

Stem cells are undifferentiated cells of the human body that are able to differentiate into any cell of an organism and have the ability of self-renewal. Based on the cell type/tissue of origin, stem cells are classified as Somatic Stem Cells and Pluripotent Stem Cells.


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Stem Cells and Cell-Based Products

Categorization of Research Involving Stem Cells

Stem cell research is broadly categorized in three major areas, based on the ethical and/or safety concerns regarding the source of stem cells and levels of manipulation:

  • Permissible

    – Research involving the establishment of new embryonic stem cell/induced pluripotent stem cell lines

  • Restrictive

    – Research involving human preimplantation embryos processed by in vitro fertilization (IVF)/intracytoplasmic sperm injection/somatic cell nuclear transfer to derive ESC lines

  • Prohibited

    – Research involving human germline gene therapy and reproductive cloning, in vitro studies of human embryos beyond 14 days of fertilization or formation of primitive streak, studies involving xenogeneic cells or hybrids, genome-modified embryos for developmental propagation, implantation of any type of processed human cells/embryos into uterus of humans/primates, or the development of chimeric gonadal cells.

In 2017, the Department of Biotechnology and the Indian Council of Medical Research released the National Guidelines for Stem Cell Research (NGSCR). As per the NGSCR, all clinical use of stem cells and their products needs to be supported by clinical trials to prove safety and efficacy, and require licenses for manufacture and sale.

For research involving stem cells, two levels of monitoring mechanism have been established: one at the national level focussing primarily on policy – the National Apex Committee for Stem Cell Research and Therapy (NAC-SCRT) and the other, the Institutional Committee of Stem Cell Research (IC-SCR) is a more self-regulatory system of review at the institutional level. It is mandatory for the IC-SCR to register with NAC-SCRT and submit periodic report on their scientific activities for effective functioning.

Clinical Trials Involving Stem Cells

Clinical trials undertaken with Stem Cell and Cell based Product come under the ambit of Central Drugs Standard Control Organisation (CDSCO). All sponsors /clinics/hospitals who intend to develop and utilise stem cells therapies have to meet the rigorous standards prescribed for clinical trials.

Like all new drugs, stem cell products should go through preclinical testing and clinical trials – Phase I- IV.

Preclinical testing

Preclinical testing would require prior approvals from IEC, Institutional Animal Ethics Committee (small animals), and Committee for the Purpose of Control and Supervision of Experiments on Animals (large/nonhuman primates).

Product testing must include safety, biodistribution (local and systemic), and immune rejection studies. Single- and repeated-dose toxicity studies should be performed in relevant animal models. The risk for tumorigenicity, genotoxicity, and developmental toxicity must be assessed on the intended clinical use.

Clinical Trials

for Stem Cell Products

Clinical trial for stem cell products requires prior clearances from IC-SCR, IEC, and CDSCO. The trial needs to be registered with the Clinical Trials Registry- India (CTRI). Any protocol amendments/deviations must have clearances from Institutional Committee for Stem Cell Research (ICSCR), Institutional Ethics Committee (IEC) and CDSCO. Any stem cell based product already approved and marketed outside India (or for concurrent clinical trial in India) will require approval of CDSCO after clearance from IC-SCR and IEC.

Sponsors intended to initiate a clinical trial for stem cell products shall submit application in Form CT-04 along with all other necessary documents to the Central Licencing Authority. Once satisfied with the submitted documents, the Central Licencing Authority shall grant the permission to conduct clinical trial in Form CT-06. For the review and approval of clinical trial applications, fixed timelines have been put down - 90 working days for global clinical trials and 30 working days for drugs being developed in India.

Follow-up of trial participants is required depending on nature of the experimental stem cell-based intervention and the persistence potential of cellular products. For each indication, a minimum of two years of post-trial follow-up is mandatory with respect to the safety data. Follow-up can be extended by one year or more depending on the type/source of the cells and the degree of their manipulation.

A separate Data Safety Monitoring Board (DSMB) should be established for clinical trial involving stem cells. All adverse events occurring during clinical trials must be reported to IEC, CDSCO, and NAC-SCRT through IC-SCR.

CliniExperts provide full spectrum services for the following types of Drug Clinical Trials:

  • Local Clinical Trial - Phase I Trial, Phase II Trial, Phase III Trial and Phase IV Trial or Post Marketing Studies (PMS) (exclusively in India)

  • Global Clinical Trial - Phase I Trial, Phase II Trial and Phase III Trial

Dealing with stem cells products can be daunting due to the numerous rules and strict regulatory pathways – Make Cliniexperts your partners to ease the process.

Procurement and Exchange of Stem Cells Products and Derivatives

The procurement of Stem Cells Products is strictly regulated to prevent misuse and commercialization of unproven stem-cell therapy. The major provisions related to procurement of Stem Cells Products are as follows:

  • Import of any type of Stem Cells Products mandates license from CDSCO as per the established regulations.

  • Clinical trials sponsored by multinationals, employing the cell products developed outside India, should have clearances from the regulatory authorities of the country of the origin and shall need prior approval from the CDSCO following clearance from both IC-SCR and IEC of the trial site.

  • Import of stem-cell lines for clinical trials and originating oversees requires import clearance from the CDSCO. For export of indigenously developed cell lines, IEC and IC-SCR clearances must be obtained and submitted along with the Material Transfer Agreement during the review of such research proposals.

Summary

  • All clinical use of stem cells and their products needs to be supported by clinical trials to prove safety and efficacy, and require licenses for manufacture and sale.

  • Like all new drugs, stem cell products should go through preclinical testing and clinical trials – Phase I- IV.

  • Clinical trial for stem cell products requires prior clearances from IC-SCR, IEC, and CDSCO. The trial needs to be registered with CTRI.

References

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Frequently Asked Questions

Which mechanism has been established for granting approval for research and development activities on recombinant DNA products, and monitoring and evaluation of research activities involving recombinant DNA technology?

A three-tier mechanism has been established for granting approval for research and development activities on recombinant DNA products and monitoring and evaluation of research activities involving recombinant DNA technology.

Any person who intends to manufacture a biological product as well as substance for CT shall submit application in CT-10 for obtaining permission from the CLA to manufacture such biological product. Any person who intends to manufacture a formulation of a biological product after obtaining biological substance from an approved source for CT shall submit application in CT-10 for obtaining permission from the CLA in Form CT-11 to manufacture such biological product. Any person who intends to manufacture a biological product after obtaining biological substance from an unapproved source for shall submit application in CT-12 for obtaining permission from the CLA in Form CT-14 to manufacture such biological product. In such case, the biological substance manufacturer is also required to submit application to CLA in Form CT-13 for obtaining permission in Form CT-15 to manufacture and supply the unapproved biological substance to the formulator for development of the biological product. Any person who intends to manufacture an investigational biological product after obtaining the unapproved biological substance from another manufacturer for CT shall submit application in CT-12 for obtaining permission from the CLA in Form CT-14 to manufacture such investigational biological product. In such case the biological substance manufacturer is also required to submit application to CLA in Form CT-13 for obtaining permission in Form-CT15 to manufacture and supply the unapproved biological substance to the formulator for development of the investigational biological product.

After evaluating the Form CT-16 and documents, if satisfied, that the requirements of these rules have been complied with, grant the licence to import the biological product for CT in Form CT-17 within a period of 90 working days from the date of receipt of the application.

Yes. Any sponsor or investigator intended to initiate a clinical trial for biological product shall obtain permission from CLA in Form CT-06. The applicant shall submit application in Form CT-04 along with all other necessary documents specified under Second Schedule and fees as specified under Sixth Schedule of CT Rules 2019.

The license granted in Form CT-17 shall remain valid for a period of 3 years from the date of its issue, unless suspended or cancelled by CLA. In exceptional circumstances the CLA may extend the period of the license granted under rule 68 for a further period of 1 year.

The extrapolation of the safety and efficacy data of a particular clinical indication (for which clinical studies has been done) of a similar biologic to other clinical indications may be possible if following conditions are met: Similarity with respect to quality has been proven to reference biologic Similarity with respect to preclinical assessment has been proven to reference biologic Clinical safety and efficacy is proven in one indication Mechanism of action is same for other clinical indications Involved receptor(s) are same for other clinical indications New indication not mentioned by innovator will be covered by a separate application.

The permission to initiate clinical trial granted in Form CT-06 or automatic approval in Form CT 4A shall remain valid for a period of 2 years from the date of its issue, unless extended by the CLA.

Yes. Before enrolment of first participant in any clinical trial, registration in CTRI is mandatory.

The three tier mechanism comprises the following authorities: 1. Institutional Biosafety Committee (IBSC) at the Institute/ company – To ensure biosafety on-site . 2. Review Committee on Genetic Manipulation (RCGM) in the Department of Biotechnology - Managed genetically engineered cell banks. 3. Genetic Engineering Appraisal Committee (GEAC) in the Ministry of Environment & Forests (MoE&F)- for genetically modified organisms/ living modified organisms.

Any person or institution or organisation having permanent establishment in India who intends to conduct clinical trial of a biological product can submit application for clinical trial.


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