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released as a draft in 2013 and  guidance in 2017 and updated in  gene therapies. This framework

        finalized in 2015. It discussed  2020 to help industry apply these  contained several new guidance
        many     recommendations      for   new regulations that together  documents, including hemophilia
        manufacturing,  testing  and           are referred to as the FDA  CGT. This brought the total
        patient safety and follow-               regenerative       medicine   number of guidance documents
        up.                                      framework. Both human  in the framework to 27. In 2021,
                                                   gene editing and transfer,  we can see how the evolution
        In 2016, Congress passed                     as well as genetically  of hemophilia gene and cell
        the 21st Century Cures Act                   modified    cells   that  therapy has been affected by the
        or Cures Act, which includes                lead to a sustained factor  development of this framework.
        provisions designed to expedite     production in hemophilia, are
        and streamline development of       considered to be regenerative      EARLY 2020: FDA LAUNCHES
        innovative new medicines. This      medicine therapies by FDA.         CELL    AND    GENE    THERAPY
        law builds on FDA’s existing                                           GUIDANCE FRAMEWORK
                                                                               On Jan. 28, 2020, FDA launched
        responsibilities and established  Guidance        for     developing   its landmark guidance framework
        regenerative medicine therapies,  CGT products specifically for        for   CGT    products.   Updates
        including   gene   therapy,   cell  hemophilia was published by        included improvements to the
        therapy, products made from  FDA in 2018. Then in 2020, it was         guidance for hemophilia and
        tissues and combinations of  updated when FDA launched its
        these products. FDA published  expanded framework for cell and                 CONTINUED ON PAGE 17



        GUIDANCE, REGULATION AND LAWS THAT MAKE UP
        THE U.S. FDA FRAMEWORK FOR DEVELOPING NEW CELL
        AND GENE THERAPY (CGT) PRODUCTS FOR HEMOPHILIA

         Federal Food, Drug, & Cosmetic Act (FD&C)
          The key law giving FDA responsibility to oversee safety of drugs,                         A look at the
          medical devices, and other products like food and cosmetics.       U.S.        US FDA Framework
                                                                            Laws           for Developing New
         Public Health Service Act (PHS)                                  made by Congress  Cell & Gene Therapy
          Law that gives FDA more pathways and manufacturing information for
          biologic drugs, or drugs made from living organisms or their parts (e.g.               Products for
          genetic materials like DNA)
                                                                         Regulations               Hemophilia
         21st Century Cures Act (CURES) of 2016                         (CFR Title 21)
          Law that creates regenerative medicine advanced therapy (RMAT)   are made by FDA based on laws
          framework, to speed development of innovative cell, gene, and tissue
          products.
         Coronavirus Aid, Relief, & Economic                            FDA Guidance
         Security Act (CARES) of 2020                            are made by FDA with help from the public
          In response to COVID-19 outbreak, gives FDA greater responsibility   to help industry and the public interpret regulations
          for managing interruptions & disruptions in drug manufacturing.

             2015                   2017                    2018             2020 GCT Framework:
          Design of Early  Regenerative Medicine Framework:  CGT Therapy for  Updated CGT Therapy for
                                                                             Hemophilia Guidance
          Phase CGT Trials  Human Cell & Tissue Products                   CGT in Rare Disease Guidance  2021
          Guidance        Same Surgery Exception      Hemophilia Guidance  Long-term CGT Trial Follow-up  CGT
                         RMAT Expedited Programs                        CGT Manufacturing Guidance  Manufacture
                        Medical Device Use with Products                                           During COVID
                                                                       CGT “Sameness” for Orphan Drugs
        Image Source: Adapted for Sigilon Therapeutics, Inc. with permission of the author. © 2021 Angela N. Johnson. All rights reserved.
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