Institute for Human Gene Therapy Responds to FDA
(Announced February 14, 2000)
The Institute for Human Gene Therapy at the University of Pennsylvania
today (Feb. 14) filed its response to Inspectional Observations made by
the Food and Drug Administration on Jan. 18, 2000, as the result of its
investigation into the death of Jesse Gelsinger, an 18-year-old with a
rare metabolic disease who was participating in an experimental gene therapy
trial for the disease known as ornithine transcarbamylase (OTC) deficiency,
an inherited disorder that in its most common form causes death in affected
newborn males due to a genetic defect in the liver.
The IHGT immediately placed the OTCD clinical trial on hold following
Jesse Gelsinger's death on Sept. 17, 1999. The IHGT had informed the FDA
of Jesse Gelsinger's deteriorating condition prior to his death and, following
his death, promptly notified the FDA, the Recombinant DNA Advisory Committee
of the NIH and the Institutional Review Board.
The IHGT response to the FDA continues an extensive review of research
at the University of Pennsylvania, ordered by President Judith Rodin, including
a comprehensive review of all aspects of research using human subjects,
considering everything from the mechanics of the approval process to oversight
to accountability and research outcomes; and an independent review
of oversight and monitoring of clinical trials at the Institute for Human
Gene Therapy, which will be conducted by research scientists who are unaffiliated
with the University of Pennsylvania.
"We understand that nothing less than the highest possible standards
for the conduct of research are acceptable at the University of Pennsylvania,"
said Richard Tannen, M.D., professor of medicine and senior vice dean at
the School of Medicine. "The thoughtful process that has led to our
[FDA] response is an important step which, together with the other important
initiatives underway, will ensure that the conduct of research at Penn
does, in fact, meet those standards."
The FDA identified "important issues arising out the OTCD trial,"
said James M. Wilson, John Herr Musser Professor of Research Medicine and
director of the IHGT, and, he said "we have taken its questions and
concerns very seriously."
Dr. Wilson said, that the IHGT will continue to cooperate, fully and
completely, with the FDA, the National Institutes of Health and all other
interested agencies in their respective reviews.
He also said that IHGT "will continue to work closely with the
FDA to implement revised clinical procedures relating to monitoring and
related practices and to provide additional patient safeguards to the fullest
extent possible in clinical research settings."
The 28-page IHGT response to the FDA makes the following points:
- The record demonstrates that each and every patient who participated
in the OTCD trial gave informed consent to participate.
- The IHGT contemporaneously documented each patient's eligibility to
participate in the OTCD trial.
- The IHGT did submit data in January 1999 on the toxicity levels of
two participants in the OTCD trial, data that should have been submitted
in October 1998 and in November 1998, and data that should have been discussed
with the FDA before proceeding with the trial, but the FDA had these
comprehensive reports on these patients in its possession for more than
six months prior to August 1999, when it approved the continuation
of the trial into the sixth cohort of patients, which included Jesse Gelsinger.
- While the IHGT had numerous documented procedures governing clinical
trials, Standard Operating Procedures relating to clinical trials at the
IHGT would have helped to ensure that all necessary communications and
notifications to the FDA were made on a timely basis and that clear
and unambiguous acknowledgement of such communications was obtained before
proceeding to new stages of the trial.
- An animal study involving two primates was performed in connection
with a different, and unrelated, clinical trial involving the use
of a different genetic material for the treatment of a different
disease, colorectal cancer. A third primate in the study did
receive the same generation vector used in the OTCD trial, but at a higher
dose, and it exhibited mild illness, but not death. All three animals
in the study received a dosage approximately 17 times higher than the highest
dose in the OTCD trial. In sum, the study did not have significant implications
for the safety of the OTCD trial.
- The available scientific evidence does not establish any causal
link between Jesse Gelsinger's plasma ammonia level prior to the infusion
of genes and his death. Note: Neither the FDA's observations nor
its public comments have asserted any such causal link.
- There is absolutely nothing in his medical chart to suggest
a causal link between Jesse Gelsinger's gender and his death.
The University of Pennsylvania has made a commitment to cooperate, fully
and completely, with the appropriate regulatory agencies and public officials
in the examination of Jesse Gelsinger's death.