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International Journal of Toxicolgy, 24:153–155, 2005

Copyright c American College of Toxicology


ISSN: 1091-5818 print / 1092-874X online
DOI: 10.1080/10915810590948352

Application of Emerging Technologies in Toxicology


and Safety Assessment: Regulatory Perspectives

John K. Leighton
Division of Oncology Drug Products, Food and Drug Administration, Center for Drug Evaluation
and Research, Rockville, Maryland, USA

Critical Path Initiative (U.S. FDA 2004). Specific areas identi-


Emerging technologies applied in the regulatory field encom- fied in the Critical Path Initiative included immune toxicity and
pass a group of technologies that are used in addition to or in re- liver and cardiovascular safety evaluation. This discussion will
placement of the standard toxicology studies conducted to support focus on the scientific review of new technologies and briefly
an Investigational New Drug Application (IND) or New Drug Ap-
plication (NDA). The standard package includes general toxicol-
describe how data derived from some new technologies used in
ogy studies of various duration, safety pharmacology studies, ge- toxicology and safety assessment have affected review conclu-
netic toxicology studies, and reproductive toxicology studies. New sions. Finally, a brief description, from a regulatory perspective,
and emerging technologies applied to the regulation of new drugs of emerging “global” technologies will be presented.
include the use of novel biomarkers, transfected cells and trans- Within the Center for Drug Evaluation and Research (CDER),
genic animals, and the “omics” technologies (toxicogenomics, pro-
teomics, and metabonomics). These technologies are at various
the principal decision-making body on scientific evaluations and
stages of regulatory development and acceptance. For example, decisions involving pharmacology and toxicology issues affect-
the use of transgenic animals have gained acceptance by regulatory ing multiple divisions is the Pharmacology Toxicology Coordi-
authorities to replace a 2-year carcinogenicity assay. Alternatively, nating Committee (PTCC). This committee is comprised of the
the “omics” technologies are not sufficiently advanced to achieve team leaders of the operating divisions within CDER. A num-
regulatory acceptance as replacements, although these assays have
a role early in drug development and they may prove useful as
ber of subcommittees and working groups have been formed
supplements to standard studies. Data from these assays have been by the PTCC in order to assist with technical matters. To be
used to address specific mechanistic questions in combination with accepted into pharmacology or toxicology practice in different
standard toxicology assays. divisions within CDER, any new and emerging technology will
at some time be evaluated by one of the PTCC’s working groups
Keywords Biomarkers, Carcinogenicity Assessment, Critical Path, or subcommittees and/or the PTCC.
Toxicogenomics, Transgenic Animals Perhaps the best example of new technologies affecting reg-
ulatory practice is the use of alternative animal models for
The incorporation of new technologies into regulatory sci- carcinogenicity assessment. In the past, the standard assay for
ence is a stepwise process, involving ongoing discussion carcinogen assessment was the 2-year bioassay in rodents (rat
between industry, academic, and Food and Drug Administra- and mouse). More recently, an alternative model, usually in-
tion (FDA) scientists. The need to adopt new scientific advances volving testing of 6 months’ duration, has in some cases been
is driven by the desire to improve the safety assessment of new substituted for one of the 2-year assays. The most common al-
pharmaceuticals and to increase sensitivity and predictiveness of ternative models are the p53 (genotoxic compounds), RasH2
models. The need to improve the safety assessment, and tools to (topical products), and TgAC (genotoxic and nongenotoxic com-
accomplish this task, was described in some detail in the FDA’s pounds) transgenic mouse models. The determination of the ap-
propriateness of the proposed alternative model rests with either
the executive Carcinogenicity Assessment Committee (eCAC)
Received 21 October 2004; accepted 2 February 2005. or the full CAC depending upon the identified problems. Guid-
This work was presented as part of a Symposium entitled “Applica- ance documents available on the CDER Internet site guidance
tions of Emerging Technologies in Toxicology and Safety Assessment” document page (http://www.fda.gov/cder/guidance/index.htm)
held during the 23rd Annual Meeting of the American College of Tox- are available to assist with the selection of appropriate alter-
icology, Hershey, PA, November 10–13, 2002. native models, and a general discussion of the models can be
Address correspondence to John K. Leighton, PhD, DABT, Su-
pervisory Pharmacologist, Division of Oncology Drug Products, found in Pritchard et al. (2002). The PTCC continues to evalu-
FDA/CDER, 1451 Rockville Pike, Rockville, MD 20852, USA. E-mail: ate the appropriateness of the models and study designs for these
LEIGHTONJ@cder.fda.gov alternative models.

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154 J. K. LEIGHTON

The PTCC also is developing a working relationship with the cytochrome P450 promoter (e.g., the P450 3A promoter) linked
Advisory Committee for Pharmaceutical Sciences (ACPS) to to a reporter molecule, e.g., luceriferase. Findings from in vitro
assess new technologies. The ACPS, like other FDA advisory metabolism studies have been confirmed with nonclinical and
committees, is designed as a mechanism through which the clinical studies.
Agency can obtain advice from experts outside the Agency. In some cases, exploratory studies using new technologies
Working with the National Center for Toxicological Research’s have been designed to further investigate a finding observed in a
(NCTR) Nonclinical Studies Subcommittee (NCSS), expert standard toxicology study. β-Microglobulin, alanine aminopep-
working groups were formed to examine relevance of biomark- tidase, and N-acyl-β-D-glucosamidase have been used to assess
ers and the state of the science for vasculitis and cardiotoxicity. renal toxicity, troponins to assess cardiotoxicity, and acute phase
The reports and recommendations of the expert working groups proteins to assess an inflammatory response.
will be presented to the ACPS and the PTCC for evaluation. Inbred animal strains with identified mutations and trans-
Another mechanism through which the Agency adopts new genic animals have been used to assess risk. For example,
technology is through participation in workshops and the review arsenic trioxide was approved by the FDA for the treatment
of test methods under consideration of the Interagency Coor- of acute promyelocytic leukemia, and the drug developer relied
dinating Committee for the Validation of Alternative Methods upon literature information for developmental toxicity assess-
(ICCVAM). ICCVAM was established by the National Insti- ment. Most of the information on reproductive toxicity of arsenic
tute of Environmental Health Sciences (NIEHS) at the direc- is based on studies with oral administration, as the greatest con-
tion of Congress in 1997 and now has 15 Federal research and cern is from environmental exposure (e.g., drinking water). In
regulatory agencies that participate in the review process. For a study in which Sploch heterozygote mice were administered
example, two products that have completed the peer review panel 10 mg/kg sodium arsenite, the authors concluded that the intro-
process are Corrositex and the murine local lymph node assay duction of the sploch allelle increased the incidence of neural
(LLNA). Corrositex is an in vitro test method to examine the der- tube and other malformations (Machado et al. 1999). This and
mal corrosivity potential of chemicals. The LLNA is a method other studies led the FDA to conclude that arsenic trioxide may
for assessing allergic contact dermitis of chemicals, including cause fetal harm if administered to a pregnant woman. In another
drugs, is discussed in more detail in CDER’s recently published example, a standard segment II study was conducted to assess
immunotoxicology guidance document (Guidance for Industry: developmental toxicity of a small-molecular-weight compound,
Immunotoxicology Evaluation of Investigational New Drugs). and the findings were compared to transgenic animals in which
These panel reports are available from the IICVAM website the protein target was missing. Similar findings from both stud-
(http://iccvam.niehs.nih.gov/). ies led to the conclusion that the developmental toxicity findings
Drug developers are encouraged to incorporate new technolo- were due to the pharmacological activities of the drug product.
gies into the scientific evaluation of their product, in order to In general, transgenic and imbred animals used in safety assess-
gain a better understanding of a mechanism of action (i.e., phar- ments are not developed specifically for the drug under study
macology) or as an addition to the standard safety assessment but the assessment relies upon studies available in the scientific
(toxicology) at any time in product development. In general, un- literature.
less the data are derived from test methods that are sufficiently Additional nonstandard studies for genetic toxicity (i.e., stud-
robust, data derived from application of a new technology would ies not part of the International Conference on Harmonization
most likely be considered supportive rather than as crucial to the (ICH) core genetic toxicity battery) are often conducted to aid in
safety assessment. The distinction between a pharmacology and the assessment of carcinogenic potential of a drug. An example
toxicology study is at times arbitrary. In general the conduct of this is the Muta Mouse assay, which examined lac Z mutation
of the study (GLP [good laboratory practice] versus non-GLP) frequency in mouse kidney. However, the CAC questioned the
and the amount of supporting information that needs to be sub- relevance of these data as the tumors are found in rat, not mouse,
mitted for a pharmacology study is much less than what is gen- kidney, thus limiting the usefulness of this alternative assay.
erally expected in a study report intended to provide critical Perhaps the most important emerging technologies are the
safety information (Guidance for Industry: Content and Format “global” assays, including pharmacogenomics/ pharmacogenet-
of Investigational New Drug Applications [INDs] for Phase 1 ics, proteomics, and metabonomics. These technologies may
Studies of Drugs, Including Well-Characterized, Therapeutic, be able to cut development time by aiding in the selection of
Biotechnology-derived Products). compounds, improve comparability testing for product charac-
There are several specific examples of new technologies that terization (http://www.emea.eu.int/pdfs/human/ewp/309702en.
have been incorporated into the regulatory review of drugs. In pdf), and ultimately provide for “personalized medicine,” pro-
general, these technologies have a fairly extensive research his- viding the right drug tailored for a patient with specific disease
tory in multiple laboratories, and were used to provide supportive characteristics. A workshop was held in May, 2002, between
rather than pivotal data. For example, drug metabolism is usually representatives of FDA and the pharmaceutical industry to dis-
initially studied in vitro in cell culture systems using cytochrome cuss pharmacogenetics and pharmacogenomics. The workshop
P450 cDNA expression systems. As an adjunct to these studies, agenda and workbook are available from the FDA internet
enzyme induction has recently been investigated by using the site (www.fda.gov/cder/calendar/meeting/phrma52002/default.

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EMERGING TECHNOLOGIES: REGULATORY PERSPECTIVES 155

htm), and the full report of the workshop has been published Lesko, L. J., R. A. Salerno, B. B. Spear, D. C. Anderson, T. Anderson, C.
(Lesko et al. 2003). Additional FDA comments on this topic Brazell, J. Collins, A. Dorner, D. Essayan, B. Gomez-Mancilla, J. Hackett,
have been published (Lesko and Woodcock 2002; Petricoin et al. S. M. Huang, S. Ide, J. Killinger, J. Leighton, E. Mansfield, R. Meyer, S. G.
Ryan, V. Schmith, P. Shaw, F. Sistare, M. Watson, A. Worobec. 2003. Phar-
2002). Pharmacogenetics and pharmacogenomics are perhaps macogenetics and pharmacogenomics in drug development and regulatory
the furthest advanced of these technologies at the present time. decision-making: report of the first FDA-Phrma-DruSafe-PGW Workshop.
Blood and tumor samples are often collected in clinical trials for J. Clinical Pharmacol. 43:342–358.
genetic or genomic analysis. These technologies have the Machado, A. F., D. N. Hovland, S. Pilafas, and M. D. Collins. 1999. Teratogenic
promise to radically alter the way drugs are investigated and ap- response to arsenite during neurulation: Relative sensitivities of C57BL/6J
and SWV/Fnn and impact of the sploch allele. Toxicol. Sci. 51:98–107.
proved. At this time, the Agency has some research and review Petricoin, E. F., J. L. Hackett, L. J. Lesko, S. I. Gutman, K. Chumakov, J.
experience with these emerging technologies, but they are still Woodcock, D. W. Feigal, K. C. Zoon, and F. D. Sistare. 2002. Medical ap-
considered as promising technologies with their full potential plications of microarray technologies: a regulatory science perspective. Nat.
yet to be explored. Genet. Suppl. 32:474–479.
Pritchard, J. B., J. E. French, B. J. Davis, and J. K. Haseman. 2002. Trans-
genic mouse models: Their role in carcinogen identification. Environ. Health
Perspect. 111:444–454.
REFERENCES U.S. Food and Drug Administration. 2004. Challenge and opportuni-
Lesko, L. J., and J. Woodcock. 2002. Pharmacogenomic-guided drug ties on the critical path to new medical products. http://www.fda.gov/
development: Regulatory perspective. Pharmacogenomics J. 2:20–24. oc/initiatives/criticalpath/whitepaper.html

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