TABLE OF CONTENTS

I. INTRODUCTION......................................................................................................................................................1

II. POTENTIAL SOURCES OF VIRUS CONTAMINATION ....................................................................................2

A. VIRUSES THAT COULD OCCUR IN THE MASTER CELL BANK (MCB)............................................................................2

B. ADVENTITIOUS VIRUSES THAT COULD BE INTRODUCED DURING PRODUCTION...........................................................2

III. CELL LINE QUALIFICATION: TESTING FOR VIRUSES.................................................................................3

A. SUGGESTED VIRUS TESTS FOR MCB, WORKING CELL BANK (WCB), AND CELLS AT THE LIMIT OF IN VITRO CELL AGE

USED FOR PRODUCTION............................................................................................................................................3

B. RECOMMENDED VIRAL DETECTION AND IDENTIFICATION ASSAYS..............................................................................4

C. ACCEPTABILITY OF CELL LINES.................................................................................................................................5

IV. TESTING FOR VIRUSES IN UNPROCESSED BULK..........................................................................................5

V. RATIONALE AND ACTION PLAN FOR VIRAL CLEARANCE STUDIES AND VIRUS TESTS ON

PURIFIED BULK ................................................................................................................................................................6

VI. EVALUATION AND CHARACTERIZATION OF VIRAL CLEARANCE PROCEDURES...............................8

A. THE CHOICE OF VIRUSES FOR THE EVALUATION AND CHARACTERIZATION OF VIRAL CLEARANCE ..............................9

B. DESIGN AND IMPLICATIONS OF VIRAL CLEARANCE EVALUATION AND CHARACTERIZATION STUDIES........................10

C. INTERPRETATION OF VIRAL CLEARANCE STUDIES; ACCEPTABILITY..........................................................................14

D. LIMITATIONS OF VIRAL CLEARANCE STUDIES ..........................................................................................................15

E. STATISTICS.............................................................................................................................................................16

F. REEVALUATION OF VIRAL CLEARANCE ....................................................................................................................16

VII. SUMMARY.........................................................................................................................................................16

GLOSSARY........................................................................................................................................................................18

APPENDIX 1......................................................................................................................................................................24

APPENDIX 2......................................................................................................................................................................25

APPENDIX 3......................................................................................................................................................................27

APPENDIX 4......................................................................................................................................................................29

APPENDIX 5......................................................................................................................................................................30

GUIDANCE FOR INDUSTRY1

Q5A Viral Safety Evaluation of Biotechnology Products

Derived From Cell Lines of Human or Animal Origin

This document is concerned with testing and evaluation of the viral safety of biotechnology products derived from characterized cell lines of human or animal origin (i.e., mammalian, avian, insect), and outlines data that should be submitted in the marketing application/registration package. For the purposes of this document, the term virus excludes nonconventional transmissible agents like those associated with bovine spongiform encephalopathy (BSE) and scrapie. Applicants are encouraged to discuss issues associated with BSE with the regulatory authorities.

The scope of the document covers products derived from cell cultures initiated from characterized cell banks. It covers products derived from in vitro cell culture, such as interferons, monoclonal antibodies, and recombinant deoxyribonucleic acid (DNA)-derived products including recombinant subunit vaccines, and also includes products derived from hybridoma cells grown in vivo as ascites. In this latter case, special considerations apply and additional information on testing cells propagated in vivo is contained in Appendix 1. Inactivated vaccines, all live vaccines containing self-replicating agents, and genetically engineered live vectors are excluded from the scope of this document.

The risk of viral contamination is a feature common to all biotechnology products derived from cell lines. Such contamination could have serious clinical consequences and can arise from the contamination of the source cell lines themselves (cell substrates) or from adventitious introduction of virus during production.

1 This guidance was developed within the Expert Working Group (Quality) of the International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH) and has been subject to consultation by the regulatory parties, in accordance with the ICH process. This document has been endorsed by the ICH Steering Committee at Step 4 of the ICH process, March 1997. At Step 4 of the process, the final draft is recommended for adoption to the regulatory bodies of the European Union, Japan, and the United States. This guidance was published in the Federal Register on September 24, 1998 (63 FR 51074), and is applicable to drug and biological products.

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 To date, however, biotechnology products derived from cell lines have not been implicated in the transmission of viruses. Nevertheless, it is expected that the safety of these products with regard to viral contamination can be reasonably assured only by the application of a virus testing program and assessment of virus removal and inactivation achieved by the manufacturing process, as outlined below. Three principal, complementary approaches have evolved to control the potential viral contamination of biotechnology products:

Selecting and testing cell lines and other raw materials, including media components, for the absence of undesirable viruses which may be infectious and/or pathogenic for humans; Assessing the capacity of the production processes to clear infectious viruses; Testing the product at appropriate steps of production for absence of contaminating infectious viruses.

Viral contamination of biotechnology products may arise from the original source of the cell lines or from adventitious introduction of virus during production processes.

Cells may have latent or persistent virus infection (e.g., herpesvirus) or endogenous retrovirus which may be transmitted vertically from one cell generation to the next, since the viral genome persists within the cell. Such viruses may be constitutively expressed or may unexpectedly become expressed as an infectious virus. Viruses can be introduced into the MCB by several routes such as: (1) derivation of cell lines from infected animals; (2) use of virus to establish the cell line; (3) use of contaminated biological reagents such as animal serum components; (4) contamination during cell handling.

Adventitious viruses can be introduced into the final product by several routes including, but not limited to, the following: (1) use of contaminated biological reagents such as animal serum components; (2) use of a virus for the induction of expression of specific genes encoding a desired protein; (3) use of a contaminated reagent, such as a monoclonal antibody affinity column; (4) use of a contaminated excipient during formulation; and (5) contamination during cell and medium handling. Monitoring of cell culture parameters can be helpful in the early detection of potential adventitious viral contamination.

An important part of qualifying a cell line for use in the production of a biotechnology product is the appropriate testing for the presence of virus.

Table 1 shows examples of virus tests to be performed once only at various cell levels, including MCB, WCB, and cells at the limit of in vitro cell age used for production.

Extensive screening for both endogenous and nonendogenous viral contamination should be performed on the MCB. For heterohybrid cell lines in which one or more partners are human or nonhuman primate in origin, tests should be performed in order to detect viruses of human or nonhuman primate origin because viral contamination arising from these cells may pose a particular hazard. Testing for nonendogenous viruses should include in vitro and in vivo inoculation tests and any other specific tests, including species-specific tests such as the mouse antibody production (MAP) test, that are appropriate, based on the passage history of the cell line, to detect possible contaminating viruses.

Each WCB as a starting cell substrate for drug production should be tested for adventitious virus either by direct testing or by analysis of cells at the limit of in vitro cell age, initiated from the WCB. When appropriate nonendogenous virus tests have been performed on the MCB and cells cultured up to or beyond the limit of in vitro cell age have been derived from the WCB and used for testing for the presence of adventitious viruses, similar tests need not be performed on the initial WCB. Antibody production tests are usually not necessary for the WCB. An alternative approach in which full tests are carried out on the WCB rather than on the MCB would also be considered acceptable.

The limit of in vitro cell age used for production should be based on data derived from production cells expanded under pilot-plant scale or commercial-scale conditions to the proposed in vitro cell age or beyond. Generally, the production cells are obtained by expansion of the WCB; the MCB could also be used to prepare the production cells. Cells at the limit of in vitro cell age should be evaluated once for those endogenous viruses that may have been undetected in the MCB and WCB. The performance of suitable tests (e.g., in vitro and in vivo ) at least once on cells at the limit of in vitro cell age used for production would provide further assurance that the production process is not prone to contamination by adventitious virus. If any adventitious viruses are detected at this level, the process should be carefully checked in order to determine the cause of the contamination, and should be completely redesigned if necessary.

Numerous assays can be used for the detection of endogenous and adventitious viruses. Table 2 outlines examples for these assays. They should be regarded as assay protocols recommended for the present, but the list is not all-inclusive or definitive. Since the most appropriate techniques may change with scientific progress, proposals for alternative techniques, when accompanied by adequate supporting data, may be acceptable. Manufacturers are encouraged to discuss these alternatives with the regulatory authorities. Other tests may be necessary depending on the individual case. Assays should include appropriate controls to ensure adequate sensitivity and specificity. Wherever a relatively high possibility of the presence of a specific virus can be predicted from the species of origin of the cell substrate, specific tests and/or approaches may be necessary. If the cell line used for production is of human or nonhuman primate origin, additional tests for human viruses, such as those causing immunodeficiency diseases and hepatitis, should be performed unless otherwise justified. The polymerase chain reaction (PCR) may be appropriate for detection of sequences of thioe human viruses as well as for other specific viruses. The following is a brief description of a general framework and philosophical background within which the manufacturer should justify what was done.

For the MCB and for cells cultured up to or beyond the limit of in vitro cell age used for production, tests for retroviruses, including infectivity assays in sensitive cell cultures and electron microscopy (EM) studies, should be carried out. If infectivity is not detected and no retrovirus or retrovirus-like particles have been observed by EM, reverse transcriptase (RT) or other appropriate assays should be performed to detect retroviruses that may be noninfectious. Induction studies have not been found to be useful.

In vitro tests are carried out by the inoculation of a test article (see Table 2) into various susceptible indicator cell cultures capable of detecting a wide range of human and relevant animal viruses. The choice of cells used in the test is governed by the species of origin of the cell bank to be tested, but should include a human and/or a nonhuman primate cell line susceptible to human viruses. The nature of the assay and the sample to be tested are governed by the type of virus which may possibly be present based on the origin or handling of the cells. Both cytopathic and hemadsorbing viruses should be sought.

A test article (see Table 2) should be inoculated into animals, including suckling and adult mice, and in embryonated eggs to reveal viruses that cannot grow in cell cultures. Additional animal species may be used, depending on the nature and source of the cell lines being tested. The health of the animals should be monitored and any abnormality should be investigated to establish the cause of the illness.

Species-specific viruses present in rodent cell lines may be detected by inoculating test article (see Table 2) into virus-free animals and examining the serum antibody level or enzyme activity after a specified period. Examples of such tests are the mouse antibody production (MAP) test, rat antibody production (RAP) test, and hamster antibody production (HAP) test. The viruses currently screened for in the antibody production assays are discussed in Table 3.

C. Acceptability of Cell Lines

It is recognized that some cell lines used for the manufacture of product will contain endogenous retroviruses, other viruses, or viral sequences. In such circumstances, the action plan recommended for manufacture is described in section V of this document. The acceptability of cell lines containing viruses other than endogenous retroviruses will be considered on an individual basis by the regulatory authorities, by taking into account a risk/benefit analysis based on the benefit of the product and its intended clinical use, the nature of the contaminating viruses, their potential for infecting humans or for causing disease in humans, the purification process for the product (e.g., viral clearance evaluation data), and the extent of the virus tests conducted on the purified bulk.

IV. TESTING FOR VIRUSES IN UNPROCESSED BULK

The unprocessed bulk constitutes one or multiple pooled harvests of cells and culture media. When cells are not readily accessible (e.g., hollow fiber or similar systems), the unprocessed bulk would constitute fluids harvested from the fermenter. A representative sample of the unprocessed bulk, removed from the production reactor prior to further processing, represents one of the most suitable levels at which the possibility of adventitious virus contamination can be determined with a high probability of detection. Appropriate testing for viruses should be performed at the unprocessed bulk level unless virus testing is made more sensitive by initial partial processing (e.g., unprocessed bulk may be toxic in test cell cultures, whereas partially processed bulk may not be toxic). In certain instances, it may be more appropriate to test a mixture consisting of both intact and disrupted cells and their cell culture supernatants removed from the production reactor prior to further processing. Data from at least three lots of unprocessed bulk at pilot-plant scale or commercial scale should be submitted as part of the marketing application/registration package. It is recommended that manufacturers develop programs for the ongoing assessment of adventitious viruses in production batches. The scope, extent, and frequency of virus testing on the unprocessed bulk should be determined by taking several points into consideration, including the nature of the cell lines used to produce the desired products, the results and extent of virus tests performed during the qualification of the cell lines, the cultivation method, raw material sources, and results of viral clearance studies. In vitro screening tests, using one or several cell lines, are generally employed to test unprocessed bulk. If appropriate, a PCR test or other suitable methods may be used.

Generally, harvest material in which adventitious virus has been detected should not be used to manufacture the product. If any adventitious viruses are detected at this level, the process should be carefully checked to determine the cause of the contamination, and appropriate actions taken.

V. RATIONALE AND ACTION PLAN FOR VIRAL CLEARANCE STUDIES AND

VIRUS TESTS ON PURIFIED BULK

It is important to design the most relevant and rational protocol for virus tests from the MCB level, through the various steps of drug production, to the final product including evaluation and characterization of viral clearance from unprocessed bulk. The evaluation and characterization of viral clearance plays a critical role in this scheme. The goal should be to obtain the best reasonable assurance that the product is free of virus contamination. In selecting viruses to use for a clearance study, it is useful to distinguish between the  need to evaluate processes for their ability to clear viruses that are known to be present and the desire to estimate the robustness of the process by characterizing the clearance of nonspecific model viruses (described later). Definitions of relevant, specific, and nonspecific model viruses are given in the glossary. Process evaluation requires knowledge of how much virus may be present in the process, such as the unprocessed bulk, and how much can be cleared in order to assess product safety. Knowledge of the time dependence for inactivation procedures is helpful in assuring the effectiveness of the inactivation process. When evaluating clearance of known contaminants, indepth, time-dependent inactivation studies, demonstration of reproducibility of inactivation/removal, and evaluation of process parameters should be provided. When a manufacturing process is characterized for robustness of clearance using nonspecific model viruses, particular attention should be paid to nonenveloped viruses in the study design. The extent of viral clearance characterization studies may be influenced by the results of tests on cell lines and unprocessed bulk. These studies should be performed as described in section VI below. Table 4 presents an example of an action plan in terms of process evaluation and characterization of viral clearance as well as virus tests on purified bulk, in response to the results of virus tests on cells and/or the unprocessed bulk. Various cases are considered. In all cases, characterization of clearance using nonspecific model viruses should be performed. The most common situations are Cases A and B. Production systems contaminated with a virus other than a rodent retrovirus are normally not used. Where there are convincing and well justified reasons for drug production using a cell line from Cases C, D, or E, these should be discussed with the regulatory authorities. With Cases C, D, and E, it is important to have validated effective steps to inactivate/remove the virus in question from the manufacturing process.

Case A: Where no virus, virus-like particle, or retrovirus-like particle has been demonstrated in the cells or in the unprocessed bulk, virus removal and inactivation studies should be performed with nonspecific model viruses as previously stated.

Case B: Where only a rodent retrovirus (or a retrovirus-like particle that is believed to be nonpathogenic, such as rodent A- and R-type particles) is present, process evaluation using a specific model virus, such as a murine leukemia virus, should be performed. Purified bulk should be tested using suitable methods having high specificity and sensitivity for the detection of the virus in question. For marketing authorization, data from at least three lots of purified bulk at pilot-plant scale or commercial scale should be provided. Cell lines such as Chinese hamster ovary (CHO), C127, baby hamster kidney (BHK), and murine hybridoma cell lines have frequently been used as substrates for drug production with no reported safety problems related to viral contamination of the products. For these cell lines in which the endogenous particles have been extensively characterized and clearance has been demonstrated, it is not usually necessary to assay for the presence of the noninfectious particles in purified bulk. Studies with nonspecific model viruses, as in Case A, are appropriate.

Case C: When the cells or unprocessed bulk are known to contain a virus, other than a rodent retrovirus, for which there is no evidence of capacity for infecting humans (such as those identified by footnote 2 in Table 3, except rodent retroviruses (Case B)), virus removal and inactivation evaluation studies should use the identified virus. If it is not possible to use the identified virus, relevant or specific model viruses should be used to demonstrate acceptable clearance. Timedependent  inactivation for identified (or relevant or specific model) viruses at the critical inactivation step(s) should be obtained as part of process evaluation for these viruses. Purified bulk should be tested using suitable methods having high specificity and sensitivity for the detection of the virus in question. For the purpose of marketing authorization, data from at least three lots of purified bulk manufactured at pilot-plant scale or commercial scale should be provided.

Case D: Where a known human pathogen, such as those indicated by footnote 1 in Table 3, is identified, the product may be acceptable only under exceptional circumstances. In this instance, it  is recommended that the identified virus be used for virus removal and inactivation evaluation studies and specific methods with high specificity and sensitivity for the detection of the virus in question be employed. If it is not possible to use the identified virus, relevant and/or specific model viruses (described later) should be used. The process should be shown to achieve the removal and inactivation of the selected viruses during the purification and inactivation processes. Time-dependent inactivation data for the critical inactivation step(s) should be obtained as part of process evaluation. Purified bulk should be tested using suitable methods having high specificity and sensitivity for the detection of the virus in question. For the purpose of marketing authorization, data from at least three lots of purified bulk manufactured at pilot-plant scale or commercial scale should be provided.

Case E: When a virus that cannot be classified by currently available methodologies is detected in the cells or unprocessed bulk, the product is usually considered unacceptable since the virus may prove to be pathogenic. In the very rare case where there are convincing and well justified reasons for drug production using such a cell line, this should be discussed with the regulatory authorities before proceeding further.

VI. EVALUATION AND CHARACTERIZATION OF VIRAL CLEARANCE

PROCEDURES

Evaluation and characterization of due virus removal and/or inactivation procedures play an important role in establishing the safety of biotechnology products. Many instances of contamination in the past have occurred with agents whose presence was not known or even suspected, and though this happened to biological products derived from various source materials other than fully characterized cell lines, assessment of viral clearance will provide a measure of confidence that any unknown, unsuspected, and harmful viruses may be removed. Studies should be carried out in a manner that is well documented and controlled. The objective of viral clearance studies is to assess process step(s) that can be considered to be effective in  inactivating/removing viruses and to estimate quantitatively the overall level of virus reduction obtained by the process. This should be achieved by the deliberate addition (spiking) of significant amounts of a virus to the crude material and/or to different fractions obtained during the various process steps and demonstrating its removal or inactivation during the subsequent steps. It is not considered necessary to evaluate or characterize every step of a manufacturing process if adequate clearance is demonstrated by the use of fewer steps. It should be borne in mind that other steps in the process may have an indirect effect on the viral inactivation/removal achieved. Manufacturers should explain and justify the approach used in studies for evaluating virus clearance.

The reduction of virus infectivity may be achieved by removal of virus particles or by inactivation of viral infectivity. For each production step assessed, the possible mechanism of loss of viral infectivity should be described with regard to whether it is due to inactivation or removal. For inactivation steps, the study should be planned in such a way that samples are taken at different times and an inactivation curve constructed (see section VI.B.5.). Viral clearance evaluation studies are performed to demonstrate the clearance of a virus known to be present in the MCB and/or to provide some level of assurance that adventitious viruses which could not be detected, or might gain access to the production process, would be cleared.

Reduction factors are normally expressed on a logarithmic scale, which implies that, while residual virus infectivity will never be reduced to zero, it may be greatly reduced mathematically. In addition to clearance studies for viruses known to be present, studies to characterize the ability to remove and/or inactivate other viruses should be conducted. The purpose of studies with viruses exhibiting a range of biochemical and biophysical properties that are not known or expected to be present is to characterize the robustness of the procedure rather than to achieve a specific inactivation or removal goal. A demonstration of the capacity of the production process to inactivate or remove viruses is desirable (see Section VI.C.). Such studies are not performed to evaluate a specific safety risk. Therefore, a specific clearance value need not be achieved.

A. The Choice of Viruses for the Evaluation and Characterization of Viral

Clearance

Viruses for clearance evaluation and process characterization studies should be chosen to resemble viruses which may contaminate the product and to represent a wide range of physico-chemical properties in order to test the ability of the system to eliminate viruses in general. The manufacturer should justify the choice of viruses in accordance with the aims of the evaluation and characterization study and the guidance provided in this document.

A major issue in performing a viral clearance study is to determine which viruses should be used. Such viruses fall into three categories: Relevant viruses, specific model viruses, and nonspecific model viruses. Relevant viruses are viruses used in process evaluation of viral clearance studies which are either the identified viruses, or of the same species as the viruses that are known, or likely to contaminate the cell substrate or any other reagents or materials used in the production process. The purification and/or inactivation process should demonstrate the capability to remove and/or inactivate such viruses. When a relevant virus is not available or when it is not well adapted to process evaluation of viral clearance studies (e.g., it cannot be grown in vitro to sufficiently high titers), a specific model virus should be used as a substitute. An appropriate specific model virus may be a virus which is closely related to the known or suspected virus (same genus or family), having similar physical and chemical properties to the observed or suspected virus.

Cell lines derived from rodents usually contain endogenous retrovirus particles or retrovirus-like particles, which may be infectious (C-type particles) or noninfectious (cytoplasmic A- and R-type particles). The capacity of the manufacturing process to remove and/or inactivate rodent retroviruses from products obtained from such cells should be determined. This may be accomplished by using a murine leukemia virus, a specific model virus in the case of cells of murine origin. When human cell lines secreting monoclonal antibodies have been obtained by the immortalization of B lymphocytes by Epstein-Barr Virus (EBV), the ability of the manufacturing process to remove and/or inactivate a herpes virus should be determined. Pseudorabies virus may also be used as a specific model virus.

When the purpose is to characterize the capacity of the manufacturing process to remove and/or inactivate viruses in general, i.e., to characterize the robustness of the clearance process, viral clearance characterization studies should be performed with nonspecific model viruses with differing properties. Data obtained from studies with relevant and/or specific model viruses may also contribute to this assessment. It is not necessary to test all types of viruses. Preference should be given to viruses that display a significant resistance to physical and/or chemical treatments. The results obtained for such viruses provide useful information about the ability of the production process to remove and/or inactivate viruses in general. The choice and number of viruses used will be influenced by the quality and characterization of the cell lines and the production process. Examples of useful model viruses representing a range of physico-chemical structures and examples of viruses which have been used in viral clearance studies are given in Appendix 2 and Table A-1.

Additional points to be considered are as follows:

a. Viruses which can be grown to high titer are desirable, although this may not always be possible.

b. There should be an efficient and reliable assay for the detection of each virus used, for every stage of manufacturing that is tested.

c. Consideration should be given to the health hazard which certain viruses may pose to the personnel performing the clearance studies.

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It is inappropriate to introduce any virus into a production facility because of good manufacturing practice (GMP) constraints. Therefore, viral clearance studies should be conducted in a separate laboratory equipped for virological work and performed by staff with virological expertise in conjunction with production personnel involved in designing and preparing a scaled-down version of the purification process.

The validity of the scaling down should be demonstrated. The level of purification of the scaled-down version should represent as closely as possible the production procedure. For chromatographic equipment, column bed-height, linear flow-rate, flow-rate-to-bed-volume ratio (i.e., contact time), buffer and gel types, pH, temperature, and concentration of protein, salt, and product should all be shown to be representative of commercial-scale manufacturing. A similar elution profile should result. For other procedures, similar considerations apply. Deviations that cannot be avoided should be discussed with regard to their influence on the results.

When viral clearance studies are being performed, it is desirable to assess the contribution of more than one production step to virus elimination. Steps that are likely to clear virus should be individually assessed for their ability to remove and inactivate virus and careful consideration should be given to the exact definition of an individual step. Sufficient virus should be present in the material of each step to be tested so that an adequate assessment of the effectiveness of each step is obtained. Generally, virus should be added to in-process material of each step to be tested. In some cases, simply adding high titer virus to unpurified bulk and testing its concentration between steps will be sufficient. Where virus removal results from separation procedures, it is recommended that, if appropriate and if possible, the distribution of the virus load in the different fractions be investigated. When virucidal buffers are used in multiple steps within the manufacturing process, alternative strategies such as parallel spiking in less virucidal buffers may be carried out as part of the overall process assessment. The virus titer before and after each step being tested should be determined. Quantitative infectivity assays should have adequate sensitivity and reproducibility and should be performed with sufficient replicates to ensure adequate statistical validity of the result. Quantitative assays not associated with infectivity may be used if justified. Appropriate virus controls should be included in all infectivity assays to ensure the sensitivity of the method. Also, the statistics of sampling virus when at low concentrations should be considered (Appendix 3).

Reduction in virus infectivity may be achieved by the removal or inactivation of virus. For each production step assessed, the possible mechanism of loss of viral infectivity should be described with regard to whether it is due to inactivation or removal. If little clearance of infectivity is achieved by the production process, and the clearance of virus is considered to be a major factor in the safety of the product, specific or additional inactivation/removal steps should be introduced. It may be necessary to distinguish between removal and inactivation for a particular step. For example, when there is a possibility that a buffer used in more than one clearance step may contribute to inactivation during each step, the contribution to inactivation by a buffer shared by several chromatographic steps and the removal achieved by each of these chromatographic steps should be distinguished.

For assessment of viral inactivation, unprocessed crude material or intermediate material should be spiked with infectious virus and the reduction factor calculated. It should be recognized that virus inactivation is not a simple, first order reaction and is usually more complex, with a fast phase 1 and a slow phase 2. The study should, therefore, be planned in such a way that samples are taken at different times and an inactivation curve constructed. It is recommended that studies for inactivation include at least one time point less than the minimum exposure time and greater than zero, in addition to the minimum exposure time. Additional data are particularly important where the virus is a relevant virus known to be a human pathogen and an effective inactivation process is being designed. However, for  inactivation studies in which nonspecific model viruses are used or when specific model viruses are used as surrogates for virus particles, such as the CHO intracytoplasmic retrovirus-like particles, reproducible clearance should be demonstrated in at least two independent studies. Whenever possible, the initial virus load should be determined from the virus that can be detected in the spiked starting material. If this is not possible, the initial virus load may be calculated from the titer of the spiking virus preparation. Where inactivation is too rapid to plot an inactivation curve using process conditions, appropriate controls should be performed to demonstrate that infectivity is indeed lost by inactivation.

Over time and after repeated use, the ability of chromatography columns and other devices used in the purification scheme to clear virus may vary. Some estimate of the stability of the viral clearance after several uses may provide support for repeated use of such columns. Assurance should be provided that any virus potentially retained by the production system would be adequately destroyed or removed prior to reuse of the system. For example, such evidence may be provided by demonstrating that the cleaning and regeneration procedures do inactivate or remove virus.

a. Care should be taken in preparing the high-titer virus to avoid aggregation which may enhance physical removal and decrease inactivation, thus distorting the correlation with actual production.

b. Consideration should be given to the minimum quantity of virus which can be reliably assayed.

c. The study should include parallel control assays to assess the loss of infectivity of the virus due to such reasons as the dilution, concentration, filtration or storage of samples before titration.

d. The virus spike should be added to the product in a small volume so as not to dilute or change the characteristics of the product. Diluted, test-protein sample is no longer identical to the product obtained at commercial scale.

e. Small differences in, for example, buffers, media, or reagents can substantially affect viral clearance.

f. Virus inactivation is time-dependent; therefore, the amount of time a spiked product remains in a particular buffer solution or on a particular chromatography column should reflect the conditions of the commercial-scale process.

g. Buffers and product should be evaluated independently for toxicity or interference in assays used to determine the virus titer, as these components may adversely affect the indicator cells. If the solutions are toxic to the indicator cells, dilution, adjustment of the pH, or dialysis of the buffer containing spiked virus might be necessary. If the product itself has anti-viral activity, the clearance study may need to be performed without the product in a mock run, although omitting the product or substituting a similar protein that does not have anti-viral activity could affect the behavior of the virus in some production steps. Sufficient controls to demonstrate the effect of procedures used solely to prepare the sample for assay (e.g., dialysis, storage) on the removal/inactivation of the spiking virus should be included.

h. Many purification schemes use the same or similar buffers or columns repetitively. The effects of this approach should be taken into account when analyzing the data. The effectiveness of virus elimination by a particular process may vary with the manufacturing stage at which it is used.

i. Overall reduction factors may be underestimated where production conditions or buffers are too cytotoxic or virucidal and should be discussed on a case-by-case basis. Overall reduction factors may also be overestimated due to inherent limitations or inadequate design of viral clearance studies.

The object of assessing virus inactivation/removal is to evaluate and characterize process steps that can be considered to be effective in inactivating/removing viruses and to estimate quantitatively the overall level of virus reduction obtained by the manufacturing process. For virus contaminants, as in Cases B through E, it is important to show that not only is the virus eliminated or inactivated, but that there is excess capacity for viral clearance built into the purification process to assure an appropriate level of safety for the final product. The amount of virus eliminated or inactivated by the production process should be compared to the amount of virus that may be present in unprocessed bulk. To carry out this comparison, it is important to estimate the amount of virus in the unprocessed bulk. This estimate should be obtained using assays for infectivity or other methods such as transmission electron microscopy (TEM). The entire purification process should be able to eliminate substantially more virus than is estimated to be present in a single-dose-equivalent of unprocessed bulk. See Appendix 4 for calculation of virus reduction factors and Appendix 5 for calculation of estimated particles per dose. Manufacturers should recognize that clearance mechanisms may differ between virus classes. A combination of factors should be considered when judging the data supporting the effectiveness of virus inactivation/removal procedures. These include:

· The appropriateness of the test viruses used;

· The design of the clearance studies;

· The log reduction achieved;

· The time dependence of inactivation;

· The potential effects of variation in process parameters on virus inactivation/removal;

· The limits of assay sensitivities;

· The possible selectivity of inactivation/removal procedure(s) for certain classes of viruses.

Effective clearance may be achieved by any of the following: Multiple inactivation steps, multiple complementary separation steps, or combinations of inactivation and separation steps. Since separation methods may be dependent on the extremely specific physicochemical properties of a virus which influence its interaction with gel matrices and precipitation properties, model viruses may be separated in a different manner than a target virus. Manufacturing parameters influencing separation should be properly defined and controlled. Differences may originate from changes in surface properties such as glycosylation. However, despite these potential variables, effective removal can be obtained by a combination of complementary separation steps or combinations of inactivation and separation steps. Therefore, well-designed separation steps, such as chromatographic procedures, filtration steps, and extractions, can be effective virus removal steps provided that they are performed under appropriately controlled conditions. An effective virus removal step should give reproducible reduction of virus load shown by at least two independent studies. An overall reduction factor is generally expressed as the sum of the individual factors. However, reduction in virus titer of the order of 1 log10 or less would be considered negligible and would be ignored unless justified. If little reduction of infectivity is achieved by the production process, and the removal of virus is considered to be a major factor in the safety of the product, a specific, additional inactivation/removal step or steps should be introduced. For all viruses, manufacturers should justify the acceptability of the reduction factors obtained. Results would be evaluated on the basis of the factors listed above.

Viral clearance studies are useful for contributing to the assurance that an acceptable level of safety in the final product is achieved but do not by themselves establish safety. However, a number of factors in the design and execution of viral clearance studies may lead to an incorrect estimate of the ability of the process to remove virus infectivity. These factors include the following:

· Virus preparations used in clearance studies for a production process are likely to be produced in tissue culture. The behavior of a tissue culture virus in a production step may be different from that of the native virus, for example, if native and cultured viruses differ in purity or degree of aggregation.

· Inactivation of virus infectivity frequently follows a biphasic curve in which a rapid initial phase is followed by a slower phase. It is possible that virus escaping a first inactivation step may be more resistant to subsequent steps.

For example, if the resistant fraction takes the form of virus aggregates, infectivity may be resistant to a range of different chemical treatments and to heating.

· The ability of the overall process to remove infectivity is expressed as the sum of the logarithm of the reductions at each step. The summation of the reduction factors of multiple steps, particularly of steps with little reduction (e.g., below 1 log10), may overestimate the true potential for virus elimination. Furthermore, reduction values achieved by repetition of identical or near identical procedures should not be included unless justified.

· The expression of reduction factors as logarithmic reductions in titer implies that, while residual virus infectivity may be greatly reduced, it will never be reduced to zero. For example, a reduction in the infectivity of a preparation containing 8 log10 infectious units per milliliter (mL) by a factor of 8 log10 leaves zero log10 per mL or one infectious unit per mL, taking into consideration the limit of detection of the assay.

· Pilot-plant scale processing may differ from commercial-scale processing despite care taken to design the scaled-down process.

· Addition of individual virus reduction factors resulting from similar inactivation mechanisms along the manufacturing process may overestimate overall viral clearance.

The viral clearance studies should include the use of statistical analysis of the data to evaluate the results. The study results should be statistically valid to support the conclusions reached (see Appendix 3).

Whenever significant changes in the production or purification process are made, the effect of that change, both direct and indirect, on viral clearance should be considered and the system re-evaluated as needed. For example, changes in production processes may cause significant changes in the amount of virus produced by the cell line; changes in process steps may change the extent of viral clearance.

This document suggests approaches for the evaluation of the risk of viral contamination and for the removal of virus from product, thus contributing to the production of safe biotechnology products  derived from animal or human cell lines, and emphasizes the value of many strategies, including:

1. · Thorough characterization/screening of cell substrate starting material in order to identify which, if any, viral contaminants are present

2. · Assessment of risk by determination of the human tropism of the contaminants

3. · Establishment of an appropriate program of testing for adventitious viruses in unprocessed bulk

4. · Careful design of viral clearance studies using different methods of virus inactivation or removal in the same production process in order to achieve maximum viral clearance

5. · Performance of studies which assess virus inactivation and removal

Adventitious Virus: See virus.

Cell Substrate: Cells used to manufacture product.

Endogenous Virus: See virus.

Inactivation: Reduction of virus infectivity caused by chemical or physical modification.

In Vitro Cell Age: A measure of the period between thawing of the MCB vial(s) and harvest of the production vessel measured by elapsed chronological time in culture, population doubling level of the cells, or passage level of the cells when subcultivated by a defined procedure for dilution of the culture.

Master Cell Bank (MCB): An aliquot of a single pool of cells which generally has been prepared from the selected cell clone under defined conditions, dispensed into multiple containers, and stored under defined conditions. The MCB is used to derive all working cell banks. The testing performed on a new MCB (from a previous initial cell clone, MCB, or WCB) should be the same as for the original MCB, unless justified.

Minimum Exposure Time: The shortest period for which a treatment step will be maintained.

Nonendogenous Virus: See virus.

Process Characterization of Viral Clearance: Viral clearance studies in which nonspecific model viruses are used to assess the robustness of the manufacturing process to remove and/or inactivate viruses.

Process Evaluation Studies of Viral Clearance: Viral clearance studies in which relevant and/or specific "model" viruses are used to determine the ability of the manufacturing process to remove and/or inactivate these viruses.

Production Cells: Cell substrate used to manufacture product.

Unprocessed Bulk: One or multiple pooled harvests of cells and culture media. When cells are not readily accessible, the unprocessed bulk would constitute fluid harvested from the fermenter.

Virus: Intracellularly replicating infectious agents that are potentially pathogenic, possess only a single type of nucleic acid (either ribonucleic acid (RNA) or DNA), are unable to grow and undergo binary fission, and multiply in the form of their genetic material.

Adventitious Virus: Unintentionally introduced contaminant virus.

Endogenous Virus: Viral entity whose genome is part of the germ line of the species of origin of the cell line and is covalently integrated into the genome of animal from which the parental cell line was derived. For the purposes of this document, intentionally introduced, nonintegrated viruses such as EBV used to immortalize cell substrates or Bovine Papilloma Virus fit in this category.

Nonendogenous Virus: Virus from external sources present in the MCB.

Nonspecific Model Virus: A virus used for characterization of viral clearance of the process when the purpose is to characterize the capacity of the manufacturing process to remove and/or inactivate viruses in general, i.e., to characterize the robustness of the purification process.

Relevant Virus: Virus used in process evaluation studies which is either the identified virus, or of the same species as the virus that is known, or likely to contaminate the cell substrate or any other reagents or materials used in the production process.

Specific Model Virus: Virus which is closely related to the known or suspected virus (same genus or family), having similar physical and chemical properties to those of the observed or suspected virus.

Viral Clearance: Elimination of target virus by removal of viral particles or inactivation of viral infectivity.

Virus-like Particles: Structures visible by electron microscopy which morphologically appear to be related to known viruses.

Virus Removal: Physical separation of virus particles from the intended product.

Working Cell Bank (WCB): The WCB is prepared from aliquots of a homogeneous suspension of cells obtained from culturing the MCB under defined culture conditions.

For products manufactured from fluids harvested from animals inoculated with cells from characterized banks, additional information regarding the animals should be provided. Whenever possible, animals used in the manufacture of biotechnological/biological products should be obtained from well defined, specific pathogen-free colonies. Adequate testing for appropriate viruses, such as those listed in Table 3, should be performed. Quarantine procedures for newly arrived as well as diseased animals should be described, and assurance provided that all containment, cleaning, and decontamination methodologies employed within the facility are adequate to contain the spread of adventitious agents. This may be accomplished through the use of a sentinel program. A listing of agents for which testing is performed should also be included. Veterinary support services should be available on-site or within easy access. The degree to which the vivarium is segregated from other areas of the manufacturing facility should be described. Personnel practices should be adequate to ensure safety. Procedures for the maintenance of the animals should be fully described. These would include diet, cleaning and feeding schedules, provisions for periodic veterinary care if applicable, and details of special handling that the animals may require once inoculated. A description of the priming regimen(s) for the animals, the preparation of the inoculum, and the site and route of inoculation should also be included.

The primary harvest material from animals may be considered an equivalent stage of manufacture to unprocessed bulk harvest from a bioreactor. Therefore, all testing considerations previously outlined in section IV. of this document should apply. In addition, the manufacturer should assess the bioburden of the unprocessed bulk, determine whether the material is free of mycoplasma, and perform species-specific assay(s) as well as in vivo testing in adult and suckling mice.

1. Nonspecific model viruses representing a range of physico-chemical structures:

· SV40 (Polyomavirus maccacae 1), human polio virus 1 (Sabin), animal parvovirus or some other small, nonenveloped viruses;

· a parainfluenza virus or influenza virus, Sindbis virus or some other medium-to-large, enveloped, RNA viruses;

· a herpes virus (e.g., HSV-1 or a pseudorabies virus), or some other medium-to-large, DNA viruses.

These viruses are examples only and their use is not mandatory.

2. For rodent cell substrates murine retroviruses are commonly used as specific model viruses.

Several viruses that have been used in viral clearance studies are listed in Table A-1. However, since these are merely examples, the use of any of the viruses in the table is not considered mandatory and manufacturers are invited to consider other viruses, especially those that may be more appropriate for their individual production processes. Generally, the process should be assessed for its ability to clear at least three different viruses with differing characteristics.

Virus titrations suffer the problems of variation common to all biological assay systems. Assessment of the accuracy of the virus titrations and reduction factors derived from them and the validity of the assays should be performed to define the reliability of a study. The objective of statistical evaluation is to establish that the study has been carried out to an acceptable level of virological competence.

1. Assay methods may be either quantal or quantitative. Quantal methods include infectivity assays in animals or in tissue-culture-infectious-dose (TCID) assays, in which the animal or cell culture is scored as either infected or not. Infectivity titers are then measured by the proportion of animals or culture infected. In quantitative methods, the infectivity measured varies continuously with the virus input. Quantitative methods include plaque assays where each plaque counted corresponds to a single infectious unit. Both quantal and quantitative assays are amenable to statistical evaluation.

2. Variation can arise within an assay as a result of dilution errors, statistical effects, and differences within the assay system which are either unknown or difficult to control. These effects are likely to be greater when different assay runs are compared (between-assay variation) than when results within a single assay run are compared (within-assay variation).

3. The 95 percent confidence limits for results of within assay variation normally should be on the order of +0.5 log10 of the mean. Within-assay variation can be assessed by standard textbook methods. Between-assay variation can be monitored by the inclusion of a reference preparation, the estimate of whose potency should be within approximately 0.5 log10 of the mean estimate established in the laboratory for the assay to be acceptable. Assays with lower precision may be acceptable with appropriate justification.

4. The 95 percent confidence limits for the reduction factor observed should be calculated wherever possible in studies of clearance of "relevant" and specific "model" viruses. If the 95 percent confidence limits for the viral assays of the starting material are +s, and for the viral assays of the material after the step are +a, the 95 percent confidence limits for the reduction factor are

Appendix 3 (continued)

At low virus concentrations (e.g., in the range of 10 to 1,000 infectious particles per liter) it is evident that a sample of a few milliliters may or may not contain infectious particles. The probability, p, that this sample does not contain infectious viruses is: p = ((V-v)/V)n where V (liter) is the overall volume of the material to be tested, v (liter) is the volume of the sample and n is the absolute number of infectious particles statistically distributed in V. If V >> v, this equation can be approximated by the Poisson distribution: p = e-cv where c is the concentration of infectious particles per liter. or, c = ln p /-v

As an example, if a sample volume of 1 mL is tested, the probabilities p at virus concentrations ranging from 10 to 1,000 infectious particles per liter are:

c 10 100 1,000

p 0.99 0.90 0.37

This indicates that for a concentration of 1,000 viruses per liter, in 37 percent of sampling, 1 mL will not contain a virus particle. If only a portion of a sample is tested for virus and the test is negative, the amount of virus which would have to be present in the total sample in order to achieve a positive result should be calculated and this value taken into account when calculating a reduction factor. Confidence limits at 95 percent are desirable. However, in some instances, this may not be practical due to material limitations.

Department of Health and Human Services
Public Health Service
Food and Drug Administration
1401 Rockville Pike
Rockville, MD 20852-1448

Division of Vaccines and
Related Products Applications
Telephone: (301) 827-3070

March 12, 2001

Dear:

The Center for Biologics Evaluation and Research (CBER) is issuing this letter to inform manufacturers of the following interim recommendations pertaining to viral vaccine products that are produced in Vero cells and investigated for human use. These recommendations are based on extensive internal discussions, consultation with outside experts, and comments received from the Vaccines and Related Biological Products Advisory Committee (VRBPAC) during the meeting held on May 12, 2000. In general, CBER currently views Vero cells as an acceptable cell substrate for viral vaccines, but has residual concerns sponsors should attempt to address.

CBER recommends that all products derived from Vero cells be free of residual intact Vero cells. If your manufacturing process does not include a validated filtration step or other validated procedure to clear residual intact Vero cells from the product, please incorporate such a procedure into your manufacturing process and submit the appropriate changes to your IND or MF.

Internal discussions and comments from the VRBPAC suggest the need for continued concern about the level of residual Vero cell DNA in products manufactured in these cells. Although the World Health Organization (WHO) currently accepts a limit of residual DNA from continuous cell lines of 10 ng per dose for these products when administered parenterally, CBER wishes to continue considering the level of risk posed by residual Vero cell DNA on a case-by-case basis for viral vaccines. Consideration will also be given to the method of vaccine administration, e.g., parenteral, mucosal, or other route. Based on this concern, CBER recommends that you:

1. Measure the amount and size distribution of residual cellular DNA in your final product if you have not done so already. Please submit these results to your IND or MF and describe them in terms of the amount of residual cellular DNA per human dose of final formulated vaccine.

    

2. Consider various methods (e.g., DNAse treatment) by which the amount and size of residual cellular DNA might be further reduced. Please comment on what you have done or intend to do to consider the introduction of additional DNA reducing methods into your process, as well as the potential impact of such changes on the performance (e.g., immunogenicity) of the product.

Internal discussions and preliminary comments of the VRBPAC also suggest the need for tumorigenicity testing of each manufacturer's Vero master cell bank and the end-of-production-passage-level-cells (EOPC) derived from this cell bank. The term "EOPC" is meant to include cells at the end of a production run, as well as cells cultured from the master or working cell bank to a population doubling level comparable to or beyond cells at the end of production. EOPC should preferably be described in terms of population doublings from your Vero master cell bank. The preferred model for this test is the immunosuppressed newborn Wistar rat, which should be followed for a period of at least five months. Alternative tumorigenicity models may also be appropriate in certain circumstances and their use should be discussed with CBER. If any evidence of tumorigenic potential is demonstrated in these tests, or if the results are inconclusive, the need for additional tumorigenicity testing with cell lysates and/or DNA will also need to be discussed with CBER.

Please submit your responses to your IND(s) or MF(s) within six months from the date of issuance of this letter. Please direct any questions in the interim to Dr. Rebecca Sheets at the telephone number above.

Sincerely yours,

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Karen Midthun, M.D.
Director
Office of Vaccines Research and Review
Center for Biologics Evaluation and Research