Comparability by design: a digital twin and sentinel panel for cell process changes
Improving how a cell therapy is made currently risks having to repeat clinical trials. A validated computer model plus a fixed set of product measurements would let changes be approved on data alone.
Because potency assays are imperfect, regulators often require clinical bridging when a cell-therapy process changes (new device, new site, shorter culture), freezing suboptimal processes. The proposal is a pre-agreed comparability framework: a mechanistic and statistical model of the process (a digital twin) validated against historical runs, a sentinel panel of product attributes (phenotype, transcriptomic signature, cytotoxicity, cytokine profile, vector copy number) with pre-specified equivalence margins, and a regulatory commitment to accept changes that fall within the margins without clinical data.
- Manufacturing cost and time for living and radioactive medicines · Cell therapies take weeks to make for one patient and cost hundreds of thousands of dollars. Isotopes run short.
- Regulatory divergence between regions · Regulatory divergence means a drug approved in one country can take years to reach another, or never arrive.
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