Medical countermeasures (MCMs) are developed to prepare and protect against both natural and man-made public health threats. TRLs are defined for MCM products, such as a drug or vaccine, and for Product Development Tools (PDTs), such as assays, models, and reagents.
- Product Development Tools
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Challenge Materials
Identify threat agent and make link between threat agent or physical exposure and disease or injury processes in humans and animals.
Animal Models Using the Animal Efficacy Rule
Review of human clinical disease or injury. Perform natural history studies to determine clinical course of disease or injury in animals and whether the animal species are potentially suitable models to mimic human disease.
Pathogenesis and pathophysiology studies designed and conducted to evaluate and compare the animal disease or injury process to the human.
- Product Development Tools
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Challenge Materials
Identify and characterize threat agent: natural variation, characteristics that affect the behavior in vitro and in vivo; physicochemical characteristics, dose rate, and exposure duration of physical agents.
Animal Models Using the Animal Efficacy Rule
Generate hypotheses for types of animal models to be developed for product assessment relevant to human disease or injury and the intended indication.
Perform exploratory studies to determine mechanisms of action for countermeasure intervention based on potential indications.
- Product Development Tools
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Assay/Reagents
Identify potential assays for measuring product quality and measuring important outcomes in relevant animal models.
Challenge Materials
Select type strain candidate(s) or physical/physicochemical forms of challenge material that represent threat agent for further study of production, master banks, identity, purity, potency, stability and assays to measure these characteristics including performance in animal model(s).
Lab-scale production.
Availability of physical agent sources.
Animal Models Using the Animal Efficacy Rule
Conduct initial proof-of-concept animal efficacy studies with an identified medical countermeasure.
Identify in vivo potency and efficacy animal models critical to the likely product development path. The mechanism of action of the product is reasonably well understood.
Identify critical parameters and outcomes in animal models (change in survival or major morbidity) for Animal Rule.
- Animal Models
- Initiate development of appropriate and relevant animal model(s) for the desired indications.
- Assays
- Initiate development of appropriate and relevant assays and associate reagents for the desired indications.
- Manufacturing
- Manufacture laboratory-scale (i.e., non-GMP (Good Manufacturing Practice)) quantities of bulk product and proposed formulated product.
- Product Development Tools
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Assay/Reagents
Develop assays that will be used to assess product quality and those that will be used to assess critical outcomes in both animals and humans. Identify critical reagents needed for assays, and assess source (availability, change control and master banks).
Challenge Materials
Develop pilot scale production of selected challenge material that preserves critical attributes and develop batch record.
Develop stability program for challenge material where required.
Identify facilities for physical agent exposure.
Animal Models Using the Animal Efficacy Rule
Animal model(s) development to assess the ability of the product to induce a certain response (potency).
Animal model(s) tentatively selected that are suitable for continued product development.
Identify endpoints that satisfy the Animal Rule: enhanced survival or reduction of major morbidity.
- Animal Models
- Continue development of animal models for efficacy and dose-ranging studies.
- Assays
- Initiate development of in-process assays and analytical methods for product characterization and release, including assessments of potency, purity, identity, strength, sterility, and quality as appropriate.
- Manufacturing
- Initiate process development for small-scale manufacturing amenable to GMP.
- Target Product Profile
- Draft preliminary Target Product Profile. Questions of self life, storage conditions, and packaging should be considered to ensure that anticipated use of the product is consistent with the intended use for which approval will be sought from FDA.
- Product Development Tools
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Assay/Reagents
Optimize assays to assess product quality and ensure that appropriate candidate reference and QC (quality control) reagents for those assays are produced.
Stability studies of these candidate reference reagents are initiated.
Optimize assays that will be used to assess critical outcomes in both animals and humans.
Candidate reference and QC reagents for these assays are produced and stability studies initiated.
Challenge Materials
Produce challenge material at pilot scale and establish specifications and acceptance criteria.
Ensure physical agent exposure facilities are GLP compliant.
Animal Models Using the Animal Efficacy Rule
Begin studies to demonstrate efficacy of candidate products using relevant animal model(s).
Generate database for identification of potential correlates/surrogates of efficacy.
- Animal Models
- Continue animal model development via toxicology, pharmacology, and immunogenicity studies.
- Assays
- Qualify assays for manufacturing quality control and immunogenicity, if applicable.
- Manufacturing
- Manufacture, release and conduct stability testing of GMP-compliant bulk and formulated product in support of the IND and clinical trial(s).
- Target Product Profile
- Update Target Product Profile as appropriate.
- Product Development Tools
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Assay/Reagents
Validate or qualify appropriate critical assays used to assess physicochemical, in vitro and in vivo animal efficacy, pharmacokinetics/pharmacodynamics (PK/PD) and/or immunogenic characteristics of the product.
Candidate reference reagents for these assays are qualified.
Challenge Materials
Produce challenge material at pilot scale within established specifications.
Animal Models Using the Animal Efficacy Rule
Continue studies to determine dose-response, optimal route of administration and timing/schedule of administration of product in relevant animal efficacy models.
Define reproducibility of relevant animal model(s) with respect to achieving endpoints.
Initiate planning for future GLP studies.
- Animal Models
- Refine animal model development in preparation for pivotal GLP animal efficacy studies.
- Assays
- Validate assays for manufacturing quality control and immunogenicity if applicable.
- Manufacturing
- Scale-up and validate GMP manufacturing process at a scale compatible with USG requirements. Begin stability studies of the GMP product in a formulation, dosage form, and container consistent with Target Product Profile. Initiate manufacturing process validation and consistency lot production.
- Target Product Profile
- Update Target Product Profile as appropriate.
- Product Development Tools
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Assay/Reagents
Assays used to assess product quality are validated; exception: potency assays may still be under development and not yet validated.
Assays used to assess critical outcomes in clinical trials and in animal efficacy studies are validated.
Evaluate human biologic outcomes in Phase 2 clinical studies using validated assays and properly qualified reference and QC reagents.
Challenge Materials
Produce consistency lots of challenge material at final scale (final scale is determined by requirements of medical countermeasure evaluation).
Consistency lots are defined by three consecutive lots where critical threat agent attributes are measured using validated assays where feasible.
Animal Models Using the Animal Efficacy Rule
Refine animal models to include appropriate range of product doses, optimal route of administration and timing/schedule using data from Phase 2 clinical studies.
Conduct animal efficacy studies to demonstrate that product positively impacts endpoints that reflect desired benefit in humans.
Initiate documentation (SOPs, forms, etc.) and procedures to support future GLP studies.
Transfer animal models to GLP facility if necessary and conduct studies sufficient to demonstrate successful transfer.
- Manufacturing
- Complete validation and manufacturing or consistency lots at a scale compatible with USG requirements Complete stability studies in support of label expiry dating.
- Target Product Profile
- Finalize Target Product Profile in preparation for FDA approval.
- Product Development Tools
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Assay/Reagents
Evaluate critical biologic outcomes in Phase 3 clinical trials or GLP pivotal animal efficacy studies using validated assays and properly qualified reference and QC reagents.
Challenge Materials
Validated challenge material as defined by final production specifications and acceptance criteria for pivotal animal efficacy studies/species.
Animal Models Using the Animal Efficacy Rule
Authenticate animal models.
Perform animal efficacy studies with final formulation and dose to produce responses predictive for humans.
Finalize all GLP procedures
Conduct pivotal animal GLP efficacy studies using final product formulation and incorporating prospective statistical plans for BLA/NDA submission.
- Product Development Tools
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Assay/Reagents
Transfer and cross-validate assays in additional facilities if necessary.
Challenge Materials
Cross-validated challenge material as defined by use of agent in multiple facilities, as appropriate.
Animal Models Using the Animal Efficacy Rule
Transfer animal model to additional facilities if necessary.
Sources
- MedicalCountermeasures.gov. Technology Readiness Levels (TRLs) for Medical Countermeasure Products (Drugs and Biologics) [online]. Available at: https://www.medicalcountermeasures.gov/federal-initiatives/guidance/integrated-trls.aspx.
- MedicalCountermeasures.gov. Technology Readiness Levels (TRLs) for Medical Countermeasure Product Development Tools (PDTs) [online]. Available at: https://www.medicalcountermeasures.gov/federal-initiatives/guidance/trls-for-product-development-tools.aspx.