Main
Main
Contemporary Review
A R T I C L E I N F O A B S T R A C T
Keywords: In order to develop new and effective medicines, pharmaceutical companies must be modality agnostic. As
Occupational exposure limit science reveals an enhanced understanding of biological processes, new therapeutic modalities are becoming
Worker safety important in developing breakthrough therapies to treat both rare and common diseases. As these new modalities
Occupational health
progress, concern and uncertainty arise regarding their safe handling by the researchers developing them, em
Exposure control band
ployees manufacturing them and nurses administering them. This manuscript reviews the available literature for
Pharmaceutical modalities
Vaccine safety emerging modalities (including oligonucleotides, monoclonal antibodies, fusion proteins and bispecific anti
Protein therapeutic bodies, antibody-drug conjugates, peptides, vaccines, genetically modified organisms, and several others) and
PET Tracer provides considerations for occupational health and safety-oriented hazard identification and risk assessments to
Oncolytic virus enable timely, consistent and well-informed hazard identification, hazard communication and risk-management
Engineered bacteria decisions. This manuscript also points out instances where historical exposure control banding systems may not
be applicable (e.g. oncolytic viruses, biologics) and where other occupational exposure limit systems are more
applicable (e.g. Biosafety Levels, Biologic Control Categories).
* Corresponding author.
E-mail address: [email protected] (J.C. Graham).
https://doi.org/10.1016/j.yrtph.2020.104813
Received 7 May 2020; Received in revised form 13 August 2020; Accepted 26 October 2020
Available online 2 November 2020
0273-2300/© 2020 Elsevier Inc. All rights reserved.
J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
toxicology and pharmacology information on each of the modalities deeply embedded in occupational health and safety practices, particu
with a focus on occupationally relevant data including occupational larly in the pharmaceutical industry (Naumann et al., 1996; Zalk and
exposure case studies and inhalation studies for the modalities described Nelson, 2008; NIOSH, 2019). Additionally, such systems are elements of
(See Supplementary Table 1). Information discussed for each modality well-developed, current hazard communication programs (e.g., United
includes: Nations 2019 Globally Harmonized System of Classification and Label
ling of Chemicals) (Nations U, 2019). Occupational health categoriza
(1) Background: a brief background on the modality; tion and compound handling practice systems are considered standard
(2) How they work: an introduction to how the drugs within this practice throughout the pharmaceutical industry in both research and
modality work; manufacturing operations.
(3) Marketed drugs: examples of marketed drugs; The occupational categorization system was designed to give guid
(4) ADME: the documented absorption, distribution and elimination ance, based on historical experience, on safe handling practices for
(ADME) properties; compounds with limited data as a stopgap until additional relevant data
(5) Health hazards associated with therapeutic use: health hazards could be generated. For pharmaceuticals with robust data sets,
observed or expected after therapeutic administration as well as compound-specific occupational exposure limits (OELs) are established
those observed in relevant nonclinical studies; to protect employees. However, when there is limited data for a com
(6) Occupational hazard and exposure considerations: a summary of pound, occupational exposure banding is often employed to establish
the occupational exposure risk considerations and occupationally occupational exposure constraints. While an OEL is a specific airborne
relevant hazards; and concentration limit usually presented in units of μg/m3 or parts per
(7) Occupational exposure banding guidance: a recommendation for million (ppm), an occupational ECB is a range of airborne concentra
an occupational exposure control band based on the occupational tions to which exposure to a compound should be controlled to ensure
health hazards and risks. worker safety (See Table 1).
Table 1
Example of an exposure control band (ECB) system.
ECB Range Relevant Compounds Rationale Examples
(μg/m3)a
2 100 - < Compounds of low Permitted exposure of >1000 μg/day (>1 mg/day) for compounds Antibiotics of tetracycline, aminoglycoside and
1000 toxicity/potency of low toxicity which are not potent. Compounds that may cause fluoroquinolones class; some cardiovascular, antiviral,
mild, reversible acute affects (e.g. skin/eye irritation). and central nervous system (CNS) drugs
3 10 - < Compounds of A TTC of 1000 μg/day is recommended for relatively unstudied Some cardiovascular drugs, statins
100 intermediate toxicity/ compounds that may be intermediately potent or toxic.
potency
4 1 - < 10 Potent/Toxic A TTC of 100 μg/day is recommended for relatively unstudied Some potent cardiovascular, metabolic, antiviral and
compounds compounds that are not likely to be highly potent, highly toxic, or CNS drugs, early discovery APIs, some chemically
carcinogenic, have no a priori evidence of unusual potency or synthesized peptides
toxicity and are not considered mutagenic (Dolan et al., 2005;
Kroes et al., 2004; Cramer et al., 1978; Bercu and Dolan, 2013).
5 0.1 - <1 Highly toxic/potent A TTC of 10 μg/dayb is recommended for relatively unstudied Toxic oncology drugs, potent compounds, chemically
compounds compounds that may be highly potent or highly toxic with limited synthesized peptides, antibody drug conjugates, steroids
data to indicate they may produce pharmacologic or toxic effects at
very low doses (Dolan et al., 2005; Kroes et al., 2004; Cramer et al.,
1978).
5 special <0.1 Especially potent/toxic A TTC of 1 μg/dayb is recommended in the absence of sufficient Especially potent/toxic compounds, protein nucleic
case compounds data for anti-cancer drugs, which are developmental toxicants, acids
mutagenic, or may be carcinogenic (Dolan et al., 2005; Bercu and
Dolan, 2013; Stanard et al., 2015).
a
The banding recommendations presented reflect the assumption that an employee will inhale 10 m3 of air daily during his/her 8-h shift (Derelanko, 2017).
b
A threshold of 1.5 μg/day is recommended for relatively unstudied compounds which may be mutagenic or carcinogenic (Guideline, 2018).
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
and the spectrum and severity of clinically observed adverse effects of a BMS and is presented in Table 2. Essentially, active biologic materials
specific drug substance, all provide the basis for the hazard assessment. that are made through biological processing (i.e. cell culture), can be
Preclinical data such as QSAR (in silico predictive systems) and animal categorized into one of two Biologic Control Categories (BCC) (BCC A or
data is also considered in the hazard assessment, and one or more BCC B). BCC A or BCC B is assigned based on the hazards and potency of
compound characteristic may be responsible for placing a compound in the biologic of concern (See Fig. 1). For potent or toxic therapeutic
a specific ECB. It is generally prudent to assign compounds to more proteins or other biologic compounds, BCC B exposure controls (and
protective bands earlier in their development, and as new data emerges, corresponding handling practices) should be utilized. Note that while
subsequently adjust their occupational exposure limits/bands to less Table 2 illustrates the banding system that BMS implements for bi
restrictive bands and corresponding handling practices (with the goal ologics, alternative schemes are also utilized in the pharmaceutical in
being to ensure workers in the early development space are adequately dustry which are equally effective in controlling exposures.
protected). Additionally, for compounds expected to pose special hazards, a
The banding system is integrated into the organization’s engineering compound-specific risk assessment can be completed to confirm
controls and thus may be different across organizations. For illustrative whether additional exposure controls are needed (e.g. BCC B controls
purposes, Table 1 presents a typical pharmaceutical compound banding with additional personal protective equipment). Also, note that once a
system and is the one employed by Bristol Myers Squibb (BMS). The sufficient data package is available to establish an OEL (also referred to
cutoffs for the bands/categories presented are based on several factors, as a health-based exposure limit [HBEL] or an exposure guideline [EG]),
including approaches based on the threshold of toxicological concern the BCC is of limited applicability.
(TTC) (NIOSH, 2019; Dolan et al., 2005; Kroes et al., 2004; Cramer et al.,
1978; Gould et al., 2016; Guideline, 2018). While the TTC may not be 2.4. Banding decision tree
originally derived for occupational purposes, the principles have been
applied successfully in the field of occupational health and safety for the In order to assist in the selection of the appropriate ECB or BCC for
establishment of safe occupational exposure limits (Chebekoue and pharmaceutical modalities discussed in subsequent sections, a decision
Krishnan, 2017, 2019; Carthew et al., 2009; Hoersch et al., 2018). TTC tree was generated as shown in Fig. 1. The primary consideration for
limits can be applied using an assumed breathing volume of 10 m3 and band selection is pharmacological potency in vivo, and details regarding
100% inhalation bioavailability. The banding recommendations derivation of the pharmacological potency levels which can differentiate
included in this manuscript for compounds including small molecules, between bands, bioavailability considerations, and additional toxicities
antibody drug conjugates, oligonucleotides and biologic material made which may warrant an additional safety factor are described in more
through chemical synthesis, are based on those presented in Table 1. For detail within this article (see Sections 3.1.7 and 3.4.7). This decision tree
more information on occupational exposure banding systems and ap focuses specifically on ECB 4, 5, and 5 special case (for small molecules)
plications including suggested exposure controls and handling practices since early in drug development when the banding approach is most
see the following references (Naumann et al., 1996; Zalk and Nelson, applicable, limited data are available such that less restrictive bands
2008; NIOSH, 2019; Ader et al., 2005; Garrod and would not be considered, and active pharmaceutical ingredients (APIs)
Rajan-Sithamparanadarajah, 2003). would generally default to one of these three bands. It should be noted
that this decision tree, and the doses included therein, should be
considered as a rough guide for initial band selection. Ultimate selection
2.3. Banding considerations for biologics
of the band should come from a qualified occupational toxicologist, and
rely on the consideration of a number of additional criteria as described
Due to the general instability of biologic therapeutics, differences in
in this article, including the innate hazards of the therapeutic as well as
their manufacturing (generally closed processes to protect sterility) and
its pharmacokinetic and pharmacodynamic profiles among others.
their potential limited bioavailability (BA) via the inhalation, oral and
dermal routes (Gould et al., 2018; Pfister et al., 2014a; Bos and Mei
3. Occupational exposure control banding considerations for
nardi, 2000; Krause and Sahin, 2019), it can be argued that a different
pharmaceutical modalities
set of exposure controls can be utilized to protect employees when
working with biologics as compared to small molecules. Based on this
3.1. Small molecules
information as well as extensive industrial hygiene monitoring con
ducted by BMS showing that airborne concentrations of biologics are
3.1.1. Background
most often <1 μg/m3 (data not shown), a simplified two-band system
Small molecule drugs (<900 Da [Da]) are generally designed to
was developed for biologics for use when there is insufficient informa
freely enter cells (Dougherty and Pucci, 2011). Once inside a cell, small
tion available to calculate an OEL. Therefore, a two-category system for
molecule drugs can interact with proteins, receptors and deoxy
banding mid-to high-molecular weight (MW) biologics made through
ribonucleic acid (DNA). This is different from drugs that have a large
biological processes (i.e., mammalian cell culture) is implemented at
MW, such as monoclonal antibodies, which are not able to penetrate
cells very easily even once they are systemically bioavailable. While
Table 2 there are exceptions, generally oral bioavailability significantly de
Example of a biologic-specific banding system.
creases when the molecular size exceeds 900 Da.
Biologic Range Relevant Examples
Control (μg/m3) Compounds
3.1.2. How they work
Category
(BCC)
Small molecules exert pharmacologic effects through various
mechanisms of action, including but not limited to: 1) agonism/antag
A Biologics with low Mid- to high- MW biological
onism of specific receptors (e.g. tamoxifen), 2) enzyme inhibition (e.g.
≥1
to moderate compounds, therapeutic
toxicity/potency proteins, PEGylated proteins, apixaban), 3) hormonal interaction (e.g. levonorgestrel), 4) alkylation
antibodies, adnectins (e.g. lomustine), and 5) inhibition of transporters (e.g. dapagliflozin).
B <1 Especially toxic/ Potent proteins, bispecific Their small size allows for the possibility of rapid diffusion across cell
potent biologics antibodies or other large membranes so that they can reach intracellular sites of action (Dough
molecule biologics as erty and Pucci, 2011; Veber et al., 2002).
determined by a case-by-case Approximately 20% of all small molecule drugs approved during the
assessment
period of 2000–2008 were prodrugs (Huttunen et al., 2011) and they
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
Fig. 1. Occupational Exposure Control Banding Decision Tree for Therapeutic Modalities. Use of this decision tree, and the potencies included herein, should be
considered as a rough guide for initial band selection. Ultimate selection of the band should come from a qualified occupational toxicologist, and rely on the
consideration of a number of additional criteria such as the innate hazard of the therapeutic, its pharmacokinetics, and pharmacodynamics, among others. For
example, an additional safety factor may need to be applied for compounds which are mutagenic or teratogenic, resulting in a more restrictive band.
Footnotes: a ADC banding is generally driven by the warhead potency; b Follow guidance for radiolabeled compounds, banding is based on the API; c Biologic
materials made through biological processes (i.e. cell culture); d This biologically significant effect should also be clinically relevant; e Note that for live viruses,
enhanced control measures may be required. Abbreviations: aa = amino acids; sc = special case.
remain a significant portion of drugs being developed (Rautio et al., derivatives that are only one or two chemical or enzymatic steps away
2017). Prodrugs are inactive derivatives of active drug molecules that from the active parent drug. Prodrugs are typically designed to improve
must undergo an enzymatic and/or chemical transformation in vivo to the pharmacokinetic (PK) profile of the active drug and can also facili
release/become the active drug, which can then elicit its desired phar tate the intracellular localization of drugs. The liver is generally assumed
macological effect in the body (Huttunen et al., 2011). to be the major site of first-pass metabolism of a small molecule drug
administered orally.
3.1.3. Marketed drugs There are many different routes of excretion including via the urine,
Small molecules make up the majority of marketed pharmaceuticals. bile, sweat, saliva, tears, milk, and stool. The majority of drugs are
Examples of small molecule pharmaceutical drugs include many car eliminated via pathways that involve the kidneys and/or the liver. A
diovascular drugs (e.g. Eliquis® or Apixaban), antivirals (e.g. Dacla major characteristic of compounds excreted in urine is that they are
tasvir or Daklinza®), and diabetes therapeutics (e.g. Farxiga® or polarized (i.e., charged) and water-soluble. Drugs that are lipid soluble
Dapagliflozin), to name a few. One example of a prodrug is Vyvanse® (a are not readily removed by the kidneys and require hepatic metabolism
form of amphetamine used to treat attention-deficit/hyperactivity dis (e.g. phase I and phase II biotransformation reactions) to increase their
order) which is designed to have less abuse potential than other am water solubility for possible urinary excretion (Kapusta et al., 2007).
phetamines due to the slower release of the active drug following Drugs with a MW exceeding 300 Da and with polar and lipophilic groups
bioconversion in the intestine/liver. Another example of a prodrug is are more likely to be excreted in bile (Lu et al., 2019).
omeprazole (a proton pump inhibitor used to treat acid reflux and ul
cers) which is bioactivated site-selectively in the acidic conditions of the 3.1.5. Health hazards associated with therapeutic use
stomach. Due to their small size, the oral and inhalation BA of small molecules
is often quite high (>50%). In general, the hazards associated with small
3.1.4. ADME molecule drugs are due to their pharmacological effects or exaggerated
The absorption of a small molecule drug is highly variable and pharmacology. Hazards can also be due to off-target effects.
dependent on multiple factors including its hydrophobicity/hydrophi In general, the hazards of prodrugs are the same as for small mole
licity, size, molecular charge/ionization state, and plasma/protein cules. Prodrugs can be metabolized into more active or less active forms,
binding potential. Small molecule drugs are generally administered which can contribute to their pharmacology and/or toxicity.
orally and are designed to have high oral BA, which can give them an
ease of use advantage over high MW drugs that require parenteral 3.1.6. Occupational hazard and exposure considerations
administration. Small molecule pharmaceuticals are designed to be Small molecules can elicit effects via the oral, dermal, inhalation and
stable alone and/or in formulation enabling a long shelf-life and the systemic routes (in addition to others) therefore exposure via each of
ability to reach cellular targets intact with consistent pharmacological these occupational exposure routes is of concern. Regarding inhalation
potency (Chen et al., 2018). In most cases, prodrugs are simple chemical exposure, it is important to consider the molecule’s potential to exert
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
direct effects on the lung (e.g. target receptor present in the lung, pul ‘unlocked’ (UNA – unlocked nucleic acid) with LNAs generally having
monary vasodilator) as well as the compound’s systemic BA via the higher stability resulting in a longer half-life and stronger base-pairing
inhalation route. In the absence of inhalation BA data, it is acceptable to potential than their unlocked counterparts. A typical ON is a short
conservatively assume 100% of the inhaled dose reaches the systemic chain DNA or RNA molecule, with a MW > 7000 Da, manufactured by
circulation. There is also the potential for dermal absorption for this an isolated/enclosed process such as solid phase synthesis followed by
class of compounds and therefore the potential for dermal toxicity due to preparative chromatographic purification and downstream processing.
dermal absorption and subsequent systemic exposure. This biosynthetic process is closer to a chemical process than a biological
process.
3.1.7. Occupational exposure banding guidance recommendation
When assigning a small molecule to an ECB (Fig. 1), the goal is to 3.2.2. How they work
ensure that employees are adequately protected throughout their tenure ONs are currently being investigated for the treatment of a variety of
working with the compound of concern. Since the data to support the diseases, and are primarily being administered by parenteral injection.
calculation of the OEL is not available in the early development space, ON drugs target mRNA and are generally synthesized to match a specific
assumptions need to be made to enable the determination of the nucleotide sequence of interest. Pharmacology is dependent on Watson-
appropriate ECB. These assumptions include information and confi Crick base pairing between the drug and an mRNA target molecule, a
dence in the dose where biologically significant (and clinically relevant) scenario that provides for both high affinity and exquisite specificity.
pharmacology is expected. Adhering to the suggested doses where bio ONs such as RNAi compounds are important tools for therapeutic use
logically significant pharmacology is observed in Fig. 1 provides a 100- because of the roles they play in controlling gene expression. ONs can
fold safety factor from the midpoint of the band for a 50 kg individual alter gene expression through a variety of mechanisms by targeting
(bodyweight recommended when establishing permissible daily expo mRNA for degradation by cellular RNase H activation or blocking
sure limits) (Agency, 2014). It is important to note that cytotoxic com ribosome initiation of protein translation (Templin et al., 2000).
pounds, mutagens, teratogens and hormones may require a greater
safety factor due to their potential for severely toxic effects. It is BMS’s 3.2.3. Marketed drugs
practice that the default band for pharmacologically-active, small Though there are many clinical trials ongoing (>100 ONs are in
molecule APIs can be considered to be ECB 4, however this default band clinical trials), there are only a few ON-based drugs approved to date,
should be reconsidered if a molecule is expected to be extremely which include Vitravene® (no longer marketed) and Macugen® (Stein
potent/toxic or based on professional judgment. and Castanotto, 2017).
Another helpful piece of information when establishing the ECB is
the projected (or actual) lowest human therapeutic dose. Compounds 3.2.4. ADME
which may have a therapeutic dose of <1 mg/day may need to be placed Once in the systemic circulation, ONs are generally taken up endo
into ECB 5 or 5 special case in order to allow for an acceptable margin of cytically and distributed to the lysosomes or target mRNA. ONs cleared
safety, in this instance defined as the exposure margin between the from the circulation are taken up by the liver, kidneys, spleen, and bone
therapeutic dose and the midpoint of the occupational exposure band. marrow. In a study in which rats received an ON dosed as a single
Information on the PK of the compound such as half-life and oral BA, intratracheal (i.t.) instillation, ONs rapidly left the lung via absorption
along with pharmacodynamics (PD), should also be considered if into the systemic circulation and were renally excreted within minutes
available. For example, a compound with a long half-life (on the order of (Moschos et al., 2011).
days) may bioaccumulate, resulting in a lower acceptable occupational
exposure than for a compound with a half-life of hours. For compounds 3.2.5. Health hazards as a class/modality associated with therapeutic use
that are prodrugs, the ECB should be consistent with that of the more Adverse effects associated with an ON are generally related to the
active form, taking into account the rate of formation of the active and sequence’s ability to interfere with normal cellular function. Health
the route of exposure. hazards associated with ONs include target-mediated effects, effects
resulting from the binding of the ON to off-target DNA/RNA, and effects
3.1.8. Establishing default bands due to tissue accumulation (liver, kidney and lung [inhalation
In the situation where very limited data is available, the API can be exposure]).
assigned to a default band, based on the in vitro/in vivo potency, Oligonucleotides are generally not associated with genetic toxicity,
knowledge and/or experience with the therapeutic target and the pro developmental or fertility effects and have been well tolerated in the
jected human efficacious dose (if available). As mentioned previously, clinic. The primary effect of ON administration in rodents appears to be
the default band employed by BMS for pharmacologically-active APIs is a result of pro-inflammatory effects. Additionally, preclinical studies
ECB 4, however this default band should be reconsidered if a molecule is with ONs have demonstrated histopathologic alterations in the liver and
exquisitely potent or toxic or based on professional judgment resulting kidneys, which were dependent upon dose level, dosing frequency, and
from knowledge or experience with the therapeutic target and modality. duration of treatment (Alton et al., 2012). Effects on tissues are generally
For example, some modalities are known to have potent toxicity (e.g. related to deposition and accumulation. The most common effect in the
ADCs) and therefore can be assigned to a default ECB based on prior clinic is transient, blood-level-dependent effects stemming from inter
experience or information on pharmacologically, toxicologically or action with plasma proteins. Theoretical causes for concern with ONs
structurally similar compounds. documented in the literature include the potential incorporation of
degradation products of phosphorothioate nucleotides into newly syn
3.2. Oligonucleotides thesized DNA, as well as the binding of ONs to DNA resulting in triplex
formation that could ultimately induce site-specific mutations (Vasquez
3.2.1. Background et al., 2000). While a genotoxicity hazard due to DNA incorporation is
Oligonucleotides (ONs) are a novel class of therapeutic agents unlikely based on available data, it has been recommended that the
comprised of the nucleotides adenine, guanine, cytosine, thymine, and potential for triplex formation should be assessed if appropriate (Berman
uracil. ONs are usually made up of 13–25 nucleotides and are designed et al., 2016).
to hybridize specifically to DNA or RNA sequences. ONs include anti
sense oligonucleotides (ASO), DNA duplexes, Aptamers, Spiegelmers, 3.2.6. Occupational hazard and exposure considerations
and RNA interference compounds (RNAi) such as small interfering RNA In the workplace, potential routes of exposure to ONs include inha
(siRNAs) and microRNAs (miRNAs). ONs can be ‘locked’ (LNA) or lation, ingestion (via mucocilliary transport from the lung, hand to
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
mouth contact, etc.) and dermal contact. Overall, the inhalation BA is 3.3.3. Marketed drugs
expected to be low (Guimond et al., 2008), oral BA is generally unknown Approximately 140 peptide drugs were in clinical trials in 2015 with
and dermal BA will depend on such properties as the MW of the ON. >500 in preclinical development (Fosgerau and Hoffmann, 2015). Ex
Regarding occupational exposures to ONs, the primary concern is amples of peptide-based medicines include Lupron™ for the treatment
immunogenicity due to their foreign nucleic acid structure. Based on a of prostate cancer and Byetta™ (exenatide) for Type 2 Diabetes. With
favorable PK profile, inhalation delivery is a therapeutic option for ONs regards to route of administration, most peptide therapeutics are in
and pharmacologically relevant doses for the treatment of localized lung jectables (e.g. administered subcutaneously or intravenously) (Fosgerau
diseases will likely be in the range of 1 mg/kg or less (Templin et al., and Hoffmann, 2015).
2000). Regarding inhalation exposure, adverse effects associated with
inhaled ONs such as lung inflammation are: 1) typically dose related, 2) 3.3.4. ADME
primarily occur at high toxicological doses and 3) have been observed to Peptides are cleared by the same catabolic pathways used to elimi
be reversible upon termination of exposure, suggesting regression of nate endogenous and dietary proteins, and are generally regarded as
lung inflammation in humans after exposure is terminated (Alton et al., having a predictable metabolism (Taft et al., 2009). They tend to be
2012). After inhalation exposure to ONs, reversible lung inflammation chemically and physically unstable in the general environment, are
has been observed in preclinical studies; however, no toxicity or prone to hydrolysis and oxidation, have a tendency for aggregation,
increased lung inflammation has been reported in patients or healthy exhibit a relatively short circulating plasma half-life and fast elimina
individuals (Alton et al., 2012). A pro-inflammatory response observed tion, and have low membrane permeability (Fosgerau and Hoffmann,
in studies in higher species such as primates is expected to be of minimal 2015). Several drug delivery strategies employ binding the peptide of
consequence since the mixed monocellular infiltrate characteristic of the interest to the circulating protein albumin as a means of obtaining an
response in rodents is absent even after long-term exposure in monkeys. extended half-life, leading to less frequent dosing, in some cases only
However, the effect of prolonged inhalation exposure to ONs remains once weekly (Fosgerau and Hoffmann, 2015).
unknown as inhaled concentrations have been low and clinical trials
have been short in duration. 3.3.5. Health hazards as a class/modality associated with therapeutic use
It is important to note that each ON may have different intrinsic Inhalation of therapeutic peptides has been examined in the clinic
toxicological and PK properties following typical occupational routes of and in preclinical studies; however, in these studies the therapeutic
exposure. Therefore, as with small molecules, the specific chemistries of target(s) was present in the lung (Hartmann et al., 2015; Fellner et al.,
ONs warrant individual risk assessments. LNAs are expected to be more 2016; Kuehl et al., 2016; Onoue et al., 2011; Walker et al., 2017).
of a concern than naturally occurring DNA/RNA in the workplace. Inhalation studies with peptides have shown that they have the potential
to produce local immunogenicity and irritation upon chronic exposure
3.2.7. Occupational exposure banding guidance (Fellner et al., 2016). Given that therapeutic doses generally need to be
Despite their complexity in formulations and large molecular sizes, administered with a delivery device to ensure sufficient lung exposure,
ONs are considered more similar to small molecules than biologics in occupationally relevant airborne exposures to therapeutic peptides are
that they are manufactured by chemical synthesis processes and as such, expected to be lower than the levels which would cause adverse effects
are generally expected to follow the small molecule quality guidelines in the lung. The potential for direct lung effects (resulting from the
issued by regulatory agencies and the ICH. ONs can be evaluated in a therapeutic target being present in the lung), however, would need to be
similar manner to small molecules, and assigned to an ECB according to considered. For peptides where there is no target in the lung, the inha
the system outlined in Fig. 1. The recommended default ECB for ONs lation route would be less of a concern, although inhalation BA would
with insufficient data is similar to that recommended for small mole still need to be considered. An evaluation of inhalation studies with
cules: ECB 4 (1 - <10 μg/m3; <100 μg/day). ONs which are not expected peptides conducted by Pfister et al. (2014) reported BAs of up to 100%,
to be highly toxic or carcinogenic can be assigned to ECB 4 (1 - <10 μg/ with most being <50% (Pfister et al., 2014a).
m3; <100 μg/day). ONs which may be highly toxic, mutagenic or
carcinogenic can be assigned to ECB 5 (0.1 - <1 μg/m3; <10 μg/day). 3.3.6. Occupational hazard and exposure considerations
Peptides are generally unstable in the environment (e.g. degrade
3.3. Peptides upon prolonged exposure to light, temperature-sensitive), therefore any
pharmacological activity may be lost over time should the material be
3.3.1. Background present on a work surface (Krause and Sahin, 2019). Although there are
Peptides are short chains of amino acid monomers linked by amide a few marketed oral peptides, in general peptides are not orally
bonds, the covalent chemical bonds formed when the carboxyl group of bioavailable due to their instability in the GI tract (Fosgerau and Hoff
one amino acid reacts with the amino group of another. Peptide thera mann, 2015). Dermal exposure would also be of limited concern due to
peutics are distinguished from proteins on the basis of size. Generally, a the size of these compounds, the fact that they are naturally occurring
peptide is comprised of approximately 50 amino acids or less (Baldo, proteins and their relative instability under environmental conditions.
2015). Exposure via inhalation is a concern, especially when there are potential
targets present in the lung (e.g. compounds that target glucocorticoid
3.3.2. How they work receptors). Additionally, enzyme proteins have been reported to cause
Naturally occurring peptides function in crucial physiological roles occupational allergies such as asthma (Basketter et al., 2015). Needle
such as hormones, neurotransmitters, growth factors, ion channel li sticks and sharps exposures are also a concern as there is a potential for
gands, or anti-infectives (Fosgerau and Hoffmann, 2015). Peptides as immunogenicity upon systemic exposure (Fosgerau and Hoffmann,
therapeutics are recognized for being highly selective and efficacious as 2015).
well as relatively safe and well tolerated. They also are generally asso
ciated with lower production complexity compared with protein ther 3.3.7. Occupational exposure banding guidance recommendation
apeutics and small molecules. Current development efforts involve Based on the chemical synthesis used, small size and higher BA of
peptide targets with emerging peptide technologies inclusive of multi these compounds compared with large MW biologics, peptides can be
functional and cell penetrating peptides, as well as peptide drug banded according to the small-molecule ECB system (See Fig. 1). Even if
conjugates. made via a biologic process, their small size precludes them from the
BCC system. Similar to small molecules, peptides can be placed in ECB 4
as a default band. A more conservative ECB can be selected if the
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
compound is an extremely potent peptide (i.e. Calcitonin), if it can cause Based on the types of biological targets and modes of action, bispe
direct lung effects or exhibit pharmacology at occupationally relevant cific immunotherapies can be divided into three main categories:
exposures and/or if the compound is a respiratory sensitizer. In the case
of enzyme proteins, suggested industry exposure and handling guide (1) T-cell redirectors: Cytotoxic effector cell redirector bsAbs target a
lines are presented in Basketter et al., 2015 (Basketter et al., 2015). tumor-associated antigen (e.g. CD19, CD20, epithelial cell
adhesion molecule [EpCAM], B-cell maturation antigen [BCMA])
3.4. Biologics and the T-cell receptor/CD3 complex, which activates cytotoxic T
lymphocytes, thereby redirecting T-cell cytotoxicity to malignant
3.4.1. Background cells.
Biologics are considered therapeutic proteins, antibodies, enzymes, (2) Tumor-targeted immunomodulators: These bispecific immuno
adnectins or other active biologic materials that are made through therapies bind to a tumor-associated antigen and an immuno
biological processing (i.e. cell culture). modulating receptor, such as CD40. Such compounds are usually
Monoclonal antibodies: Monoclonal antibodies are typically large designed to be inactive until binding the tumor antigen, thereby
molecules which have a MW > 140 kDa and are designed to target localizing immune stimulation to the tumor environment, while
specific proteins. minimizing immune activation elsewhere. This is expected to
Bispecific antibodies: Bispecific antibodies (bsAbs) are emerging as induce powerful activation of tumor-specific T cells with reduced
the next generation of antibodies. Bispecific antibodies generally have a risk of immune-related adverse events.
MW ranging from 50 to 60 kDa, and have the potential to improve (3) Tumor-targeted dual immunomodulators: Bispecific compounds
clinical efficacy as well as safety by targeting two distinct immunoreg that bind two distinct immunomodulating targets, often
ulatory pathways (Dahlen et al., 2018; Brinkmann and Kontermann, combining targeting of PD-1 or PD-L1 with that of lymphocyte-
2017). activation gene 3 (LAG-3) or T-cell immunoglobulin and mucin-
Probodies: Probodies are similar to prodrugs but are antibodies domain containing-3 (TIM-3). The rationale is to induce supe
engineered to remain inert until activated proteolytically in diseased rior tumor immunity compared to monospecific antibodies to the
tissue. In principle, any therapeutic antibody can be converted into same targets (Dahlen et al., 2018).
probody form. There are two types of probodies, conventional IgG-based
probodies and probody-drug conjugates (Polu and Lowman, 2014). Probodies: Probodies leverage the upregulation of protease activity
Fusion proteins: Fusion proteins generally consist of a peptide (or in diseased tissue (e.g. cancer, inflammatory diseases) to achieve
other short-lived effector domain) coupled to a ‘carrier’, which is usually disease-tissue-specific therapeutic activity. The probody remains intact
a protein or peptide that contributes to the functional properties of the and is blocked from binding to the antigen target, however, once the
resultant fusion protein. As peptides have a short half-life owing to linker peptide is cleaved by proteases that are selectively activated in the
proteolytic degradation and are usually rapidly cleared (within minutes) diseased-tissue, the masking peptide is released, allowing the active
via the kidneys, the peptide can be linked to a protein/fusion partner to antibody to bind to its target, resulting in tissue-specific activity (Polu
enable a more stable molecule with an extended half-life. The crystal and Lowman, 2014). Preclinical studies have demonstrated that a
lizable Fc region of human IgG1 antibody is commonly utilized as a therapeutic antibody with known on-target toxicity can be reengineered
fusion partner for the effector molecule(s) because it extends the fusion as a probody retaining potent in vivo efficacy, but with greatly reduced
protein half-life by recycling via the salvage neonatal Fc receptor (FcRn) side effects (Desnoyers et al., 2013).
receptor, and protects the molecule from lysosomal degradation. The Fusion proteins: Fusion proteins have been used in the biophar
linked effector peptide may have widely varying properties contributing maceutical industry for over 25 years to improve the PK properties of
to recognition, binding, and toxicity, while its fused partner may aid in otherwise short half-life biologics (Strohl, 2015). Fusion proteins offer
stability and targeting of the chimeric polypeptide (Baldo, 2015). the potential to target a therapy to the location of disease by combining a
targeting component such as a mAb with a therapeutic peptide or pro
3.4.2. How they work tein such as a cytokine. This avoids short half-lives, dose-limiting tox
Monoclonal antibodies: Antibodies, or immunoglobulins (Igs), are icities, and sub-optimal localization of the therapy, which may be
large Y-shaped molecules with Fab (fragment, antigen binding) regions encountered if the unbound therapeutic peptide or protein was sys
and an Fc (fragment crystallizable) region. Fab regions consist of two temically administered. Many approved fusion proteins work as agonists
variable domains that are designed to recognize and bind to specific (e.g. alefacept) or antagonists (e.g. belatacept, etanercept) of receptor
antigens. Binding triggers the endocytotic internalization of the mAb function, or by a direct targeted cytotoxic killing effect (e.g.
and subsequent lysosomal degradation (Ryman and Meibohm, 2017). denileukin-diftitox). Antibody-cytokine fusion proteins, often referred
The Fc region interacts with cell surface receptors, and allows the mAb to as immunocytokines, are being utilized to employ the tumor-targeting
to activate the immune system (Kennedy et al., 2018). Antibody thera ability of mAbs to guide the cytokines specifically to tumor sites where
peutics can have activity via antibody dependent cellular cytotoxicity they can stimulate anti-tumor immune responses while avoiding
(ADCC) or complement dependent cytotoxicity (CDC). In ADCC medi dose-limiting systemic toxicity (Young et al., 2014; Hutmacher and Neri,
ated effector activity, the Fc portion of the mAb binds to an FccR on an 2019).
effector cell, such as a monocyte, macrophage, or natural killer cell, and
the Fab domains bind to cell surface receptors on the target cell. This 3.4.3. Marketed drugs
leads to the destruction of the target cell via phagocytosis by the immune Monoclonal antibodies: Currently, most mAbs developed are hu
cell or release of cytokines leading to cell death (Ryman and Meibohm, manized or fully human. The use of mAbs has expanded exponentially
2017). Monoclonal antibodies are potent and highly selective and they during the last decade and currently covers several therapeutic areas,
can be agonists, antagonists or neutralizing. such as oncology, respiratory diseases, hematology, immunology, car
Bispecific antibodies: Bispecific antibodies can target two antigens diovascular diseases, and inflammatory diseases (Singh et al., 2018). In
at once. Companies are developing bispecific antibodies with the 1992, the FDA approved the first therapeutic mAb Muromonab-CD3
objective of creating drugs which encompass the function of two (trade name Orthoclone OKT3) to reduce acute rejection in patients
monospecific drugs or which have properties that cannot be achieved with organ transplants (Cai, 2018). As of May 10, 2018, the FDA had
with a mixture of monospecific compounds. However, the development approved 80 therapeutic mAbs with indications includinging
of bsAbs is considerably more challenging than development of con immune-mediated disorders (e.g. brodalumab, dupilumab) and cancer
ventional mAbs. indications (e.g. avelumab, ocrelizumab) (Cai, 2018; Kaplon and
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
immune system, so increased risk of infection, reduced immune system target is present in the lung since adverse effects would not be dependent
function and autoimmune responses are a concern. For example, the on systemic BA in this case.
most common adverse effects of etanercept are relatively mild and Due to the high potency and generally low clinical doses associated
consist of fever, headache, injection-site reactions, mild allergic re with bsAbs, the default BCC for bsAbs is considered to be BCC B (<1 μg/
actions, and pruritus (Baldo, 2015). Importantly, some fusion m3), even after taking into account the low inhalation BA and high MW.
protein-induced skin responses may represent direct targeting events
that are not genuine hypersensitivities and are similar to, for example, 3.5. Antibody-drug conjugates
agents that bind EGFR causing non-immune-mediated adverse cuta
neous events (Baldo, 2015). Proteins conjugated with a polyethylene 3.5.1. Background
glycol (PEG) carry additional safety concerns around the lack of Antibody drug conjugates (ADCs) are a novel class of therapeutic
biodegradability of the PEG component. agents typically developed as treatments for cancer that are character
It has been shown that FcRn is expressed in both the upper and ized by an antibody scaffold covalently modified with a variable number
central airways in non-human primates as well as in humans. After of small-molecule payloads. The payloads are generally highly potent
deposition of the aerosolized protein in the lung, transport of the Fc- cytotoxic chemicals (known as warheads) and are bound to the antibody
fusion proteins occurs through binding to FcRn in the epithelial cells scaffold via synthetic linkers. Such immuno-conjugates combine the
followed by transport to the underlying tissue and ultimately into the anti-tumor potency of highly cytotoxic small-molecule drugs (300–1000
systemic circulation. The bioavailabilities for Fc-fusion molecules in Da, with subnanomolar IC50 values) with the high selectivity, stability,
non-human primates have been in the range of 20–50% when given by and favorable pharmacokinetic profile of monoclonal antibodies (Drake
inhalation (Dumont et al., 2005). Monomeric fusion proteins are ex and Rabuka, 2017). These drugs are hybrid entities combining both
pected to have higher bioavailabilities than dimeric due to their biologic and small-molecule characteristics, where the antibody serves
decreased size among other factors (Dumont et al., 2005). For example, to target the small molecule specifically to the intended cell type.
the BA of the therapeutic protein erythropoietin-Fc fusion molecule
(~112 kDa) in monkeys was ~6% with the dimer and ~35% with the 3.5.2. How they work
monomer (Dumont et al., 2005). Additionally, many biologics are ADCs are currently being investigated for the treatment of a variety
designed to have long half-lives and may bioaccumulate upon repeated of cancers. The mechanistic basis for the ADC activity includes its spe
dosing. cific binding to the cellular target, triggering ADC cellular internaliza
tion by pinocytosis, followed by the intracellular release of the payload
3.4.6. Occupational hazard and exposure considerations (Roberts et al., 2013). Therefore, after administration into the systemic
As biologics are generally specific for their target(s) and can be quite circulation, the antibody fragment guides the complex to the targeted
potent, they should be evaluated on a case-by-case basis. The potential tumor antigen where it becomes internalized into the cancer cell (Hasan
for accumulation due to long half-lives, the pharmacodynamic profile et al., 2018). The intracellular release of the payload in its active form
and the potential for developmental toxicity should be considered in the results in cell death. The three components of ADCs, namely the anti
hazard assessment for biologics. body, the linker and the cytotoxic drug, have their own inherent char
Regarding exposure risks, exposures via the dermal, oral and inha acteristics and limitations which influence each other, thus finding the
lation routes are generally expected to be low. Compounds >500 Da are best combination of these components to design an ideal ADC is a
not expected to be bioavailable via dermal exposure (Bos and Meinardi, complicated task (Hasan et al., 2018). Although this targeted approach
2000). Low systemic exposure potential is generally expected via the appears straightforward, its translation to clinical practice has been
inhalation route of exposure (e.g. BA<1%) in the occupational setting problematic with initial attempts failing due to inappropriate linker
for biologics with a MW > 10 kDa (Gould et al., 2018; Pfister et al., systems or insufficiently potent cytotoxins, resulting in unfavorable
2014b). Limited studies conducted on the inhalation BA of Fc-fusion therapeutic indices. Modern ADCs tend to use highly potent cytotoxic
proteins, have shown BAs of 20–50%, which is substantially higher molecules, such as derivatives of calicheamicin, maytansine and auri
than the BA observed with mAbs, emphasizing the importance of statins (Senter, 2009; Ducry and Stump, 2010). A number of these
considering the binding component when estimating the inhalation BA molecules have demonstrated substantial in vivo antitumor activity. To
of fusion proteins (Gould et al., 2018; Dumont et al., 2005; Pfister et al., translate the fundamental advantage of ADCs in targeting
2014b). Low BA may not be the case when there are drug targets present tumor-selective or tumor-specific antigens in clinical practice, it is
in the lung/skin. essential that linkers be of sufficient stability to minimize systemic
Regarding sensitization potential, there are currently no validated in exposure to the cytotoxin and the resulting toxicities, while still
vitro or in vivo models for respiratory sensitization potential. Available providing sufficient targeted intracellular release of the cytotoxic agent
screening tools are generally based on historical data for known respi (Roberts et al., 2013).
ratory sensitizers; therefore, the structure of the biologic should be
examined for potential similarities to known respiratory sensitizers. 3.5.3. Marketed drugs
Occupational exposures to therapeutic proteins (like other drugs) There are currently four ADCs marketed in the US, although there are
should be kept to a minimum (de Lemos et al., 2018). While exposure over 60 ADCs in clinical trials (Garcia-Alonso et al., 2018). Gemtuzumab
can never be truly proven to be zero, occupational exposure limits, en ozogamicin (Mylotarg™) was the first marketed ADC, originally
gineering controls, administrative controls, and PPE are necessary to approved in 2000 for treatment of CD33-positive acute myeloid leuke
protect employees. Dermal exposure to drugs is never recommended and mia (AML). However, it was withdrawn from the market in 2010 due to
this remains the recommendation for biologics. treatment-related toxicity concerns. Mylotarg™ was reapproved in 2017
with a lower recommended dose and altered dosing schedule for the
3.4.7. Occupational exposure banding guidance recommendation treatment of adults with newly diagnosed CD33-positive acute myeloid
The default BCC for mAbs, probodies and fusion proteins which are leukemia (AML) and for patients ages 2 years and older with relapsed or
expected to exhibit pharmacology at doses of ≥1 μg/kg is considered to refractory CD33-positive AML. In 2011, brentuximab vedotin (Adcet
be BCC A (≥1 μg/m3), after accounting for the low systemic BA ris©), an anti-CD30 monomethyl auristatin E (MMAE) conjugate gained
following inhalation (e.g. less than 1%) for compounds with a MW > 10 market approval for the treatment of relapsed/refractory Hodgkin
kDa. For biologics where a pharmacological effect is expected at <1 μg/ lymphoma and systemic anaplastic large cell lymphoma. In 2013, tras
kg, BCC B is generally appropriate. It is also important to take into tuzumab emtansine (Kadcyla©), an anti- HER2 directed ADC conjugated
consideration the potential for direct lung effects and when the drug to DM1 (also called mertansine, a potent antimicrotubule agent) was
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approved for the treatment of HER2+ metastatic breast cancer. Addi payload. The toxicity of other types of linkers would need to be evalu
tionally, in 2017, another ADC was approved by the FDA, which ated on a case-by-case basis. Potential issues include the possibility of
included a cytotoxic agent from the class of calicheamicins. Inotuzumab linking to endogenous proteins or other cellular macromolecules, or
ozogamicin (Besponsa©), which targets CD22 was approved for relapsed altered immune responses.
or refractory B-cell precursor acute lymphoblastic leukemia (Garcia-A For the ADC as a whole, it is important to note that even though the
lonso et al., 2018). payload is connected to an antibody, it does not mean that the toxicity to
the payload will be reduced. There is a strong possibility that the
3.5.4. ADME payload could be released despite not having a (tumor) binding site.
ADCs are large molecules (~150 kDa) typically administered sys Therefore, it is critical to account for the hazards associated with the
temically by intravenous (IV) infusion (Malik et al., 2017). After sys payload and not to assume the linker to the antibody is systemically
temic administration, the distribution of the intact ADC is generally stable.
confined to the plasma, interstitial fluid, and lymph (Han and Zhao,
2014). They often possess long plasma residence times because of their 3.5.6. Occupational hazard and exposure considerations
dynamic interactions with the FcRn (Garg and Balthasar, 2007) and are In the workplace, potential routes of exposure to the intact ADC or its
therefore administered intermittently, typically once every 1–4 weeks respective components include inhalation, ingestion (via mucocilliary
(Malik et al., 2017). In most, but not all cases, ADCs exhibit nonlinear PK transport from the lung, hand to mouth contact, etc.) and dermal contact
and dose-dependent clearance due to saturable target binding and (depending on MW, etc.). The overlying concern with occupational
elimination (Levy, 1994). Plasma stability and the extent of deconju exposure to these types of molecules is the highly potent and toxic na
gation in circulation can be estimated with direct measurements of the ture of the payload component. A critical attribute of any ADC is the
conjugated fraction (Kraynov et al., 2016). The free payload concen amount of drug loading, or the average ratio of conjugated payload to
trations can be used to evaluate payload dependent toxicity, although antibody. This is referred to as the drug-to-antibody ratio (DAR). Since
this toxicity is difficult to distinguish from toxicity that occurs when the the DAR dictates the amount of payload delivered per internalized
conjugated antibody is taken up into normal tissues (Poon et al., 2013). antibody, it strongly influences both efficacy and toxicity. In addition,
ADCs are designed to bind membrane-bound target proteins that can depending on the conjugation and linker technologies used, high-DAR
facilitate internalization into tumor cells by receptor-mediated endo ADCs can have poor biophysical characteristics (e.g., hydrophobicity,
cytosis (Ritchie et al., 2013). Because of the high affinity of the initial aggregation) that reduce efficacy and increase toxicity (Drake and
binding interaction, ADCs undergo target-mediated drug disposition Rabuka, 2017). Another important factor to consider when assessing the
(TMDD), meaning that the properties of the target influence the PK of toxicity of the ADC and individual components is the relative size of the
the drug (Mager and Jusko, 2001). Target expression, internalization, component molecules. While the payload and linker may have molar
turnover, accessibility and binding affinity all impact the PK of ADCs. masses in the several hundreds of Da, the antibody will typically have a
After administration, ADCs distribute to occupy target sites that are molar mass of around 150,000 Da, though antibody fragments may be
present in both normal and diseased tissue. significantly smaller. As such, the payload element of the ADC may only
constitute less than 0.5% by weight of the total MW; a potentially
3.5.5. Health hazards as a class/modality associated with therapeutic use important fact when safe exposure levels are typically quoted in mass
The health hazards of ADCs may be dissected into the relative parts terms. Of course, with smaller antibody fragment utilization, this effect
or building blocks of these hybrid molecules and can also be evaluated will be reduced and the toxic payload will constitute a greater propor
for the ADC as a whole. There are the obvious hazards associated with tion of the compound mass.
the highly potent cytotoxic payload, hazards associated with the During each step to the manufacturing process, the hazards may
monoclonal antibody scaffold, and hazards associated with the linker change based on the nature of the components being utilized in that step
molecules, which can then vary depending if the linker is bound with the of the manufacturing process. The relatively low toxicity of antibody
payload or antibody. proteins, and the common processing of such macromolecular materials
The potent cytotoxic payloads typically utilized in ADCs include in enclosed solution or suspension forms, results in a relatively low risk
DNA double strand breakers such as Calicheamicin (Mylotarg©) or of intolerable exposure by main traditional routes (inhalation, ingestion
esperamycin; DNA alkylating agents such as duocarmycin, cyclo and skin absorption). In addition, the BA of such large biologically
propabenzidole (CBI), or pyrrolobenzodiazepines (PBD); and inhibitors derived macromolecules by traditional exposure routes (ingestion and
of tubulin polymerization such as maytansine (T-DM1), auristatin (SGN- airborne inhalation) is low due to instability of proteins in the GI tract as
35), or tubulysin (Beck et al., 2017). These agents typically induce cell well as low inhalation BA of such large molecules from the respiratory
death in rapidly dividing tissues and induce hematologic and GI toxicity. tract. The processes used for the manufacture of payload and subsequent
Genotoxicity, and reproductive and developmental toxicities are also conjugation to the antibody scaffold are typical “wet chemistry”
associated with exposure to these highly potent cytotoxic drugs, and covering all normal synthetic chemistry and pharmaceutical processing
neurotoxicity is a known adverse effect of the tubulin disruptors steps for small molecules, which includes the synthesis of the payload
(Remesh, 2012). Radio-nucleotides were also historically used as ADC and linker and associated purification and isolation steps including
payloads, but have been replaced in modern ADCs by the use of these chemical reaction, chromatography distillation, filtration, crystalliza
highly potent cytotoxic drugs (Hasan et al., 2018). tion, drying and lyophilization, with solvent recovery and emission
The antibody scaffolds may have potential toxicity resulting from the control. Given the known toxicities of payload materials, activities such
intended and unintended pharmacological action as well as immuno as payload manufacture and handling of pure payload material prior to
genic effects associated with exposure to proteins. Proteins are thought conjugation, and especially any processes involving open handling of
to have lower potential to cause harm, and most of these are humanized such materials, especially in a dry powder form, are considered a high
antibodies with a lower potential for off target immunological events. risk of unacceptable exposure. Similarly, ancillary activities such as
They are designed to preferentially target cancer cells rather than Quality Control (QC) testing and cleaning, where exposure to the
normal tissues, which can lower the hazard of off target pharmacology. payload as either a trace residue or component of a sample may occur,
The linkers are typically small molecules with hazards that may vary should also be considered.
and need to be assessed on a case-by-case basis. Linking strategies that Major concerns during synthesis and conjugation will include all
take advantage of the properties of endogenous amino acids (such as activities where manual intervention is required, transfer of materials
engineered antibodies or peptides) are unlikely to be toxic on their own, between processes except in sealed transit routes, and in recovery and
or to significantly contribute to the toxicity of either the antibody or the storage of the high toxicity material in a form which may present
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enhanced emission risks by certain routes; for example as a dry friable transported rapidly into cells by amino acid transporters (uptake time
solid for airborne transfer, or as a solution in an organic solvent for 3–5 min) (Clarke, 2018).
transdermal transfer. The high toxicity of the payload and of the ADC NETs have receptors for somatostatin, a hormone that regulates the
requires a more rigorous consideration of the routes of exposure than endocrine system. 68Ga-Dotatate (AAA’s NETSPOT®) is a positron-
might be typical for small molecule applications where typically only emitting analogue of somatostatin, which works by binding to somato
airborne and (occasionally) surface transfer routes are considered. It is statin receptors enabling imaging of NETs. 68Ga-DOTATATE is
important to note that a payload could be released from an ADC despite comprised of DOTA-TATE, an amino acid peptide, with a covalently
not having a binding site. Therefore, it is critical to protect directly for bonded DOTA bifunctional chelator, bound to radionuclide gallium-68
the contribution of the payload and not to assume the linker to the (Clarke, 2018).
antibody is systemically stable. The extreme toxicity of the payload
warrants consideration of all routes, with control of hand contamination 3.6.4. ADME
in particular being a concern as this is a major transfer route into ocular Distribution of a PET agent is going to depend on its receptor spec
and ingestion routes of exposure. The high toxicity and uncertainty of ificity and intended area(s) of localization. Based on clinical studies, the
exposure uptake efficiencies means that other activities that may lead to organs with the highest radiation from 18F radiotracers are the urinary
exposure to trace levels of residues, such as might occur during manual bladder and gallbladder followed by the kidney, liver, pancreas and
cleaning of contaminated equipment, may be significant, and the po lungs (Zanotti-Fregonara et al., 2013). The elimination half-lives are
tential and mechanisms for equipment and containers to become generally in the order of hours, for example with those of Axumin® and
contaminated on exposed external surfaces should also be assessed. 68Ga-DOTATATE being 110 min and 68 min, respectively (Clarke,
2018).
3.5.7. Occupational exposure banding guidance recommendation
Occupational exposure banding recommendations are based on the 3.6.5. Health hazards as a class/modality associated with therapeutic use
inherent hazards associated with exposures to each component of the The pairing of a radioactive element with a targeted drug/compound
ADC manufacturing process. Therefore, those components containing results in a dual hazard, one from the toxicity of the compound or drug
the intact or generally active payload, which would include the payload substance and one from the radioactive effects. Non-ionizing radiation is
itself and the payload plus the linker, which are all small molecules essential to life, but excessive exposures will cause tissue damage. All
components, are assigned to ECB 5 special case (<0.1 μg/m3) due to forms of ionizing radiation have sufficient energy to ionize atoms that
their highly potent cytotoxic hazards. The intact ADC, while retaining may destabilize molecules within cells and lead to tissue damage
the cytotoxic hazards, is assigned to ECB 5 (0.1 - < 1 μg/m3) due to its (Occupational Safety, 2020). The hazards attributable to the small
mixed biological/small molecule dilution effect. The intact antibody molecule or target-oriented compound are aligned with those described
components are assigned to Biologic Control Category A (≥1 μg/m3). herein under the appropriate modality.
The linker molecules are typically evaluated on a case-by-case basis, but
generally fall within ECB 3 (10 - <100 μg/m3; <1000 μg/day) or ECB 4 3.6.6. Occupational hazard and exposure considerations
(1 - <10 μg/m3; <100 μg/day). With regards to the occupational hazard of radiation exposure, the
guiding principle of radiation safety is that exposure be controlled to “as
3.6. Positron-emission tomography (PET) tracers low as reasonably achievable” (“ALARA”) (Control CfRadiatio, 2015).
Radioactive hazards are addressed using the techniques detailed by
3.6.1. Background several organizations (Occupational Safety, 2020; EPA, 2020); and are
Positron-emission tomography (PET) is a nuclear medicine func focused on limiting the time spent near a radiation source, maximizing
tional imaging technique that is used to observe biochemical processes the distance from the radiation source and shielding from a radiation
in the body and for the detection of many diseases. PET imaging tracers source (Directive C, 2013).
enable molecular imaging that relies on derangement of physiological
and biochemical processes for the detection of many diseases (Hicks 3.6.7. Occupational exposure banding guidance recommendation
et al., 2006). The compounds and/or drug substances which are “attached” to the
tracer should be addressed as if there were no radioactive tracers present
3.6.2. How they work and would maintain their ECB or BCC that existed prior to the
The PET imaging system detects pairs of gamma rays emitted indi radiolabeling.
rectly by a positron-emitting radionuclide tracer, which is introduced
into the body on a biologically active molecule. This tracer can be a 3.7. Chimeric antigen receptor (CAR) T cell therapies
small or large molecule that has been labeled with a radioactive element
(commonly fluorodeoxyglucose, 11C, 18F, 64Cu, 89Zr) (Hicks et al., 3.7.1. Background
2006). Adoptive T-cell therapy (ATC) refers to the use of ex vivo culture and
cellular engineering to modify a patient’s own lymphocytes in order to
3.6.3. Marketed drugs elicit anti-viral, anti-inflammatory, or anti-tumor effects. There are
While the first radiopharmaceutical approved by the FDA was so currently three forms of ACT being developed for cancer therapy spe
dium Fluoride F-18 in 1972, the majority of PET imaging agents have cifically, including tumor-infiltrating lymphocytes (TILs), T cell receptor
been approved in the past 10 years (Clarke, 2018). Examples of (TCR) T cells, and chimeric antigen receptor (CAR) T cells (June et al.,
approved PET agents include Axumin® and 68Ga-DOTATATE, indicated 2018). CAR T-cell therapy involves the isolation of a patient’s autolo
for imaging prostate tumors and neuroendocrine tumors (NETs), gous T cells via leukapheresis, genetic modification of said cells ex vivo
respectively. using viral and non-viral transfection methods (e.g. viral transduction,
The PET Tracer Axumin® is indicated for Positron Emission DNA-based transposons, CRISPR/Cas9), modified cell expansion in
Tomography—Computed Tomography (PET/CT) imaging in men with culture, and finally, re-infusion of the CAR T-cells back into the patient.
suspected prostate cancer for men with elevated blood prostate specific This genetic modification involves transgenic expression of a CAR for a
antigen (PSA) levels following prior treatment. Axumin® contains flu cell surface receptor(s) or antibodies (e.g. CD19, CD22, BCMA) specific
ciclovine, a fluorine 18 (F 18) labeled synthetic amino acid. Since amino to cancer targets, essentially re-directing a patient’s T cells to specif
acids are key nutrients for tumor growth, fluciclovine is readily incor ically target and destroy tumor cells (Miliotou and Papadopoulou,
porated into dividing tumor cells. It is administered as an injection, is 2018).
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3.7.3. Marketed drugs cardiac dysfunction, renal impairment, hepatic failure, and dissemi
CAR T cells are the first form of gene transfer therapy to gain com nated intravascular coagulation appearing 1–2 h after the first infusion
mercial approval by the U.S. FDA, and there now more than 250 clinical (Lee et al., 2014). The incidence rate of CRS in patients receiving CD19
trials evaluating the effectiveness of this therapy (June et al., 2018). The CAR T-cell therapy ranged from 54 to 91%, including severe CRS in
majority are directed against hematological malignancies, although 8.3–43% (Hay et al., 2017).
there are ongoing efforts to apply this therapeutic approach more Neurotoxicity is often observed concurrently with CRS, and is the
broadly to solid tumors such as glioblastoma (Brown et al., 2015) and result of increased circulating levels of cytokines crossing the blood
head and neck cancer (van Schalkwyk et al., 2013). To date, there are brain barrier into to the cerebrospinal fluid (Prudent and Breitbart,
two FDA-approved CD19-directed autologous CAR T-cell therapies: (1) 2017). This neurotoxicity presents as seizures, delirium, aphasia, and
tisagenlecleucel (Kymriah™), approved for adults with relapsed or re hallucinations, and is largely reversible (June et al., 2018). In rare in
fractory diffuse large B-cell lymphoma, and you adult patients up to age stances, CRS can evolve into CAR T-cell related encephalopathy syn
25 with relapsed or refractory acute lymphoblastic leukemia, and (2) drome (CRES) or fulminant hemophagocytic lymphohistiocytosis (HLH;
axicabtagene ciloleucel (Yescarta™), approved for various types of also known as macrophage activation syndrome) (Miliotou and Papa
B-cell lymphoma that have either not responded to, or have relapsed dopoulou, 2018). Patients receiving tisangenlecleucel and axicabtagene
following two or more lines of systemic therapy. Given the high cost of ciloleucel during clinical trials reported neurotoxicity in percentages of
autologous CAR T-cell therapy, there are efforts to develop allogenic 15% and 28%, respectively (Buechner et al., 2017; Neelapu et al., 2017).
CAR-T-cells sourced from healthy donors and cryopreserved for future Less common hazard considerations include “on-target off-tumor”
use as an “off-the-shelf” product. Cellectis, for example, is developing toxicity resulting from target engagement of target antigen on non-
allogenic CAR T-cell therapies targeting a number of protein markers pathogenic tissues (Morgan et al., 2010), anaphylaxis resulting from
including CD19, CD22, CD38 and CS1 (Yip and Webster, 2018). host recognition of infused foreign components (Maus et al., 2013), and
the risk of insertional oncogenesis as observed in gene therapy of he
3.7.4. ADME matopoietic stem cells for X-linked severe combined immunodeficiency
The conventional ADME criteria that apply to modalities such as and chronic granulomatous disease (Hacein-Bey-Abina et al., 2008).
small molecules and biologics, are not necessarily applicable to CAR T- From an occupational perspective, common hazards include acci
cells. Because a CAR transgene is permanently integrated in the T-cell dental punctures with needles or contaminated sharps, spills and
genome, the equivalence to ADME for this modality is cell infusion, splashes on the skin and mucus membranes, and inhalation exposure to
trafficking, proliferation, persistence, and apoptosis (Mueller et al., infectious aerosols. Since workers tasked with manufacturing CAR T
2017; Wang, 2017). In consideration of approved CAR T-cell therapies cells will be handling cells isolated from individual patients, the nature
specifically, both Kymriah™ and Yescarta™ exhibited an initial rapid of the hazard will be dependent on the patients themselves (e.g.,
expansion immediately following infusion (peak levels occurred within potentially infected with viruses pathogenic for humans such as HIV,
the first 7–14 days for Yescarta™), followed by a decline to near baseline adenovirus, etc.).
levels (by 3 months for Yescarta™). For Kymriah™, the transgene was
present in the blood and bone marrow and was measurable beyond 2 3.7.6. Occupational hazard and exposure considerations
years, with high distribution to bone marrow (44%, 67%, and 69% of Occupational hazards associated with manufacturing of CAR T cells
that present in the blood at Day 28, Month 3, and Month 6, respectively) are going to be similar to those encountered in any cell culture labora
(Novartis, 2017; Food and Administration D, 2018). tory or medical laboratory where the handling of blood and body fluids
occurs (Vormittag et al., 2018). Strict adherence to sterile technique and
3.7.5. Health hazards as a class/modality associated with therapeutic use standard microbiological practices will ensure that occupational expo
Toxicities associated with CAR T-cell therapy are summarized in sures are limited.
Table 3. The most common adverse effect following CAR T-cell infusion
is immune activation known as CRS, similar to what has been observed 3.7.7. Occupational exposure banding guidance recommendation
following infusion of therapeutic mAbs, bispecific antibodies, and sys A BSL is a biocontainment designation system with requirements
temically administered IL-2 (Bonifant et al., 2016). CRS is the result of intended to protect personnel from potentially harmful pathogenic
elevated inflammatory cytokines (interferon gamma, granulocyte exposure in a research or manufacturing environment (Table 4) (Control
macrophage colony-stimulating factor, IL-10, IL-6) being released once CfD and Prevention., 2009). Assigning an exposure control band is not
the CAR T-cell engages surrogate antigens. Other innate immune system appropriate for this modality. Rather, CAR T cell should only be handled
cells also become activated and subsequently release additional soluble by individuals trained in proper BSL procedures as recommended by the
mediators. CRS presents clinically as high fever, malaise, fatigue, CDC for any human or other animal sourced material.
myalgia, nausea, anorexia, tachycardia/hypotension, capillary leak,
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
Table 4 including entry of the virus into the host cell and entry of the virus
Biosafety levels and examples. genome into the nucleus. The proteins encoded by E1A specifically, are
Biosafety Applicable to Example: Microbes Example: produced immediately after infection to modulate the cell cycle, recruit
Levela Occupational Exposure Cells cellular proteins, and regulate the expression of cellular and viral genes
Scenarios (Wechman et al., 2016). The E1A protein binds the retinoblastoma
1 Low-risk microbes that Nonpathogenic protein (pRb) resulting in the release of E2F (E2 factor) and cell cycle
pose little to no threat of Escherichia coli arrest. The release of E2F subsequently triggers activation of viral genes
infection in healthy that eventually lead to the generation of new virions, lysis of the infected
adults
cell, and spread of the viral progeny to adjacent cells (Garcia-Moure
2 Moderate-risk microbes Staphylococcus aureus; Human and et al., 2017). Cancer cell lysis also releases tumor antigens, and path
that pose moderate Shiga toxin producing primate cells
ogen- and damage-associated molecular pattern molecules (DAMPs)
hazards to laboratory E. Coli; Adenoviruses (CAR T cells)
personnel and the capable of stimulating tumor-infiltrating antigen presenting cells that
environment activate innate and adaptive immune responses (Keller and Bell, 2016).
3 Microbes (indigenous or Mycobacterium
exotic) that can cause tuberculosis 3.8.3. Marketed drugs
serious or potentially There exists and extensive number of completed or ongoing clinical
lethal disease(s) through trials utilizing adenoviruses. A 2018 search of clinicaltrials.gov found
respiratory transmission
more than 180 clinical trials utilizing some form of adenovirus as cancer
4 High-risk microbes Ebola virus therapeutics (Baker et al., 2018). These trials have focused on a plethora
which pose a high risk of
of tumor types ranging from prostate carcinoma to glioblastoma multi
aerosol-transmitted
infections and infections
forme, and have been examined as monotherapies or in combination
caused by these with previously approved chemotherapeutics (Rosewell Shaw and
microbes are frequently Suzuki, 2016). While none have been approved to date by any Western
fatal and without country health authority, there is one oncolytic adenovirus that was
treatment or vaccines
approved in 2005 by the Chinese State Food and Drug Administration
a
Note that enhanced control measures may be required depending on the for the treatment of squamous cell cancer of the head and neck (HNC),
strain and pathogenicity of the micro-organism being handled. and is marketed under the brand name Oncorine (Garcia-Moure et al.,
2017; Garber, 2006). Oncorine (H101) is an E1B-55K/E3B-deleted
3.8. Oncolytic adenoviruses oncolytic adenovirus that demonstrated efficacy and safety in HNC in
a phase III trial, obtaining an overall response rate of nearly 80% in
3.8.1. Background combination with cisplatin, with only mild flu-like symptoms as side
Oncolytic virotherapy is an emerging approach in the treatment of effects (Xia et al., 2004).
human cancer. Recently, the oncolytic virus Talimogene laherparepvec
(T-VEC; Imlygic™) was approved for the treatment of advanced mela 3.8.4. ADME
noma. T-VEC, an attenuated herpes simplex type 1 (HSV-1) encoding Clinical studies on oncolytic adenoviruses have demonstrated varied
Granulocyte-Macrophage Colony-Stimulating Factor (GM-CSF), pro PK depending on the route of administration, adenovirus serotype and
vided evidence of the potential of locally delivered genetically modified associated genetic modifications, such that generalizations regarding
replicating viruses as oncology agents, and opened the door for the pharmacokinetic (PK) parameters cannot be made. For example, in a
development of viruses capable of tumor oncolysis via systemic Phase 1 study of enadenotucirev (a group B Ad11p/Ad3 chimeric
administration (Rehman et al., 2016). Within this arena, development oncolytic adenovirus) administered intravenously to patients with
has focused primarily on the oncolytic adenoviruses given the fact that epithelial solid tumors, the half-life was short (16.7 min) and indepen
these non-enveloped, double-stranded DNA viruses possess genomes dent of dose and administration frequency (Machiels et al., 2019).
that are easily engineered, and because they exhibit low levels of Post-infusion viral shedding (i.e., release of adenovirus from injection
pathogenicity following administration (Baker et al., 2018). While sites and patient secretions) manifested as buccal shedding and rectal
dozens of different adenoviruses have been described, they all share a shedding (both of which were related to dose level), and to a lesser
common architecture consisting of an icosahedral capsid composed of extent, urine shedding. In a second example, a Phase 1 dose escalation
up to seven different structural proteins. One of these, the fiber, is a study examined the safety and host immune response of telomelysin
trimeric protein located on each of the twelve vertices of the virion, (OBP-301) following a single intratumoral injection in patients with
which protrudes from the capsid like an antennae and directly influences advanced solid tumors (Phadke, 2008). Telomelysin is a
adenovirus tropism (Russell, 2009). telomerase-specific replication-selective adenovirus in which the human
telomerase reverse transcriptase promotor element drives expression of
3.8.2. How they work E1A/E1B genes linked with an internal ribosome entry site. This study
Oncolytic adenoviruses function by selectively infecting and repli indicated that despite intratumoral dosing, viral DNA was detected in 5
cating in cancer cells while sparing non-cancerous cells. This selectively of 9 patient plasma samples, as early as 30 min and as late as 14 days
is accomplished via a number of subtle modifications in early adenoviral post-treatment. Viral DNA was also detected in the sputum of one pa
genes, and is summarized in the review by Baker et al., 2018 (Baker tient, indicating systemic dissemination following intratumoral injec
et al., 2018). The general viral cycle involves adenoviral recognition of tion (Phadke, 2008). Systemic dissemination of oncolytic adenoviral
its specific receptor on the cell surface thus triggering its internalization. DNA via vascular transduction has also been demonstrated in a study
Following this internalization, the adenovirus migrates through the examining post-mortem tissues of cancer patients treated with this
microtubules and subsequently introduces the viral genome inside the modality either intratumorally or intravenously, and whose deaths were
nucleus. The adenovirus genome is composed of linear, double-stranded caused by disease progression rather than the treatment vector (Koski
DNA of approximately 36 kilobases, which can be divided into early (E) et al., 2015). Oncolytic adenoviral DNA was recovered in a wide array of
and late (L) genes based upon their expression across the infection cycle tissues, including both injected and non-injected tumors and various
(Seth and Higginbotham, 2000). While the L genes encode structural normal tissues, including the brain.
proteins, which package the viral DNA into the adenovirus virion during
the final stages of replication, the E genes regulate viral replication itself,
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
3.8.5. Health hazards as a class/modality associated with therapeutic use 3.8.7. Occupational exposure banding guidance recommendation
Generally, the use of oncolytic adenoviruses appears to be reason Adenoviruses should be handled as dictated by the applicable Bio
ably safe following local administration (i.e., intratumoral) and lower logical Safety Level (BSL) (See Table 4) (Control CfD and Prevention.,
systemic doses, although the development of newer generations of ad 2009). For other virus types, the appropriate BSL as outlined in the
enoviruses expressing transgenes and possessing altered capsids or Biosafety in Microbiological and Biomedical Laboratories guidance
different promoters could alter the safety profile (Buijs et al., 2015). prepared by the Centers for Disease Control and the National Institutes
Viral shedding of engineered adenovirus vectors could theoretically of Health should be followed (Control CfD and Prevention., 2009).
result in homologous recombination between wildtype adenoviruses of
the same subgroup, leading to new wildtype adenoviruses that possess 3.9. Engineered bacteria
transgenes or have expanded tissue tropism due to retargeting strategies
(Buijs et al., 2015; Singh et al., 2013). To date, no such recombination 3.9.1. Background
events have been observed in clinical trials. Bacteria can be genetically modified (GM) to produce a continuous
Given the mechanism of action of oncolytic adenoviruses, one might and inexpensive supply of proteins/molecules such as human hormones,
consider CRS an outcome of concern. However, in the thousands of interleukins and antibodies within specific organs or tissues (Pine
patients that have received adenoviruses therapeutically, only one pa ro-Lambea et al., 2015). An enhanced understanding of the role of the
tient (who consequently, had an underlying metabolic disorder) has human gut microbiome in health and diseases has increased interest in
died as a result of CRS (Sibbald, 2001). Based on this prior extensive the use of live bio-therapeutic products (LBPs), such as GM bacteria, for
clinical experience, the risk of severe CRS and toxicity is generally the treatment or prevention of disease. Also important, especially in the
deemed to be minimal, especially considering the neoantigens expressed context of developing countries, is that GM bacteria can be administered
by the virus are not typically present in normal tissue and therefore, orally, which makes the requirement for hygienic syringes and needles
cross-reactive T-cell responses are unlikely to occur (Larson et al., 2018). unnecessary. The use of this technology for vaccines is in the spotlight
since, in addition to the ease of oral administration, GM bacteria are
3.8.6. Occupational hazard and exposure considerations relatively inexpensive to propagate/manufacture and transport (resis
Occupational exposure to an adenovirus is generally through the tant to poor refrigeration), and thus the ongoing revolution in GM
upper respiratory tract via aerosol exposure, although other potential bacteria for vaccination fits well with the World Health Organization
routes of exposure include via mucus membranes (splash of virus to eye, (WHO) agenda and recommendations.
nose, mouth), parenteral (needle stick or sharp object injury) and con
tact with non-intact skin (Larson et al., 2018). In general, adenovirus 3.9.2. How they work
infection most commonly causes respiratory illness, although, depend GM bacteria serve as drug delivery systems, which, upon oral
ing on the infecting serotype, they may cause other illnesses such as administration, can carry the drug and deliver it to a local environment
gastroenteritis, conjunctivitis, cystitis, and rash (Stanford. Stanford En such as the gut or mucosa, without the need for systemic exposure. GM
viro, 2020). Adenovirus infection of the respiratory systems typically bacteria are being regarded as a technologically viable, economically-
can present as a spectrum of ailments ranging from the common cold feasible, safe delivery modality for drugs/proteins to localized areas in
syndrome to pneumonia, croup, and bronchitis. In terms of exposure the body (Ferreira et al., 2017). The insertion of plasmid vectors, which
scenarios specifically, special consideration must be given to the po encode proteins such as enzymes, antibodies, antigens and cytokines
tential for viral shedding and human-to-human transmission. In the into living bacteria, enables these GM bacteria to produce or deliver the
clinical setting, viral shedding can occur from injection sites and patient therapeutic proteins/molecules to the target site. GM bacteria have also
excretions, and prevalence has been demonstrated to increase with been designed to convert pro-drugs to their active form at the localized
higher doses and systemic administration (Kimball et al., 2010; Keedy disease site (Pinero-Lambea et al., 2015). GM bacteria can bypass
et al., 2008; Tian et al., 2009). Preclinically, viral shedding could result problems associated with conventional cancer chemotherapies, such as
in exposure via contact with animal secreta, excreta and bedding. poor selectivity and limited tumor penetrability, and can be finely
Pregnant individuals and those who are severely immunocompro engineered to sense and respond to the tumor microenvironment (For
mised are particularly susceptible to adenovirus exposure and should bes, 2010). Local delivery of recombinant proteins via GM bacteria in
exercise extreme caution when handling adenoviruses, as infection affected organs also has many advantages as systemic side effects are
could lead to systemic disease (e.g. hepatitis). There is a paucity of data generally avoided.
in terms of occupational exposures to oncolytic adenoviruses. However,
a study in which health-care workers involved in the aerosolized 3.9.3. Marketed drugs
administration of adeno-associated virus (AAV) during a Phase II cystic Currently, there are no approved GM bacterial therapeutics. Many
fibrosis study determined that individuals were exposed to an estimated have been studied in clinical trials and been shown to be promising
0.0006% of the administered doses based on airborne vector particle components of therapies for numerous cancer types and immune-related
concentration. At this level of exposure, the prevalence of symptoms diseases, while exhibiting a low incidence of adverse events (Pine
(typically associated with adenovirus exposure) was very low, the ro-Lambea et al., 2015; Ferreira et al., 2017). Many of the GM bacteria
spectrum of symptoms was similar in both active and control health care utilized in clinical trials are similar to those sold over the counter as
workers, and there were no reported negative health effects (Croteau probiotics (Dreher-Lesnick et al., 2017) and natural isolates obtained
et al., 2004). It is assumed that oncolytic adenoviruses and AAVs would from the microbiota of healthy individuals. They are most often lactic
behave similarly in this exposure scenario. Therefore, if proper handling acid bacteria (LAB) and to a lesser extent Escherichia coli strains (Pine
precautions and engineering controls are implemented as described in ro-Lambea et al., 2015).
the proceeding section, occupational exposure is expected to be limited.
While the focus here has been placed on adenoviruses specifically, 3.9.4. ADME
there are a number of other oncolytic virus platforms in development for Microbes are commonly ingested via a variety of fermented foods
the treatment of cancer including herpes simplex virus 1, measles virus, and drinks. They then go on to live in the intestinal milieu. Once a new
coxsackievirus, and poliovirus, among others (Buijs et al., 2015). host has ingested the bacteria, the bacteria must colonize otherwise they
Occupational exposure considerations as outlined for adenoviruses will rapidly transit through the gastrointestinal system and be elimi
previously would be applicable to these other virus types as well. nated in fecal matter. Additionally, bacteria which have successfully
colonized the intestinal environment by establishing a niche and
reaching replication levels that ensure stability and survival can shed
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
from the host into fecal matter (Browne et al., 2017). Once it has entered 3.10.3. Marketed drugs
the external environment, there is a potential that the GM bacteria can A few examples of marketed vaccines include Flumist® Quadriva
enter a new susceptible host. lent, Gardasil® and BioThrax®. Flumist® Quadrivalent, a vaccine
against influenza, contains a live attenuated influenza virus that con
3.9.5. Health hazards as a class/modality associated with therapeutic use tains four vaccine virus strains for administration via an intranasal spray
The main health hazards associated with GM bacteria are the risk of (MedImmune. FluMist Quadri, 2013). Gardasil®, a vaccine targeted
infection and the risk of transient or stable transfer of identified genes of against human papillomavirus (HPV), is a recombinant quadrivalent
concern (e.g. antibiotic resistance genes) in the LBP to another species vaccine prepared from the purified virus-like particles (VLPs) of the
present in host sites exposed to product colonization. major capsid (L1) protein of HPV Types 6, 11, 16, and 18 and is
administered with Alum adjuvant (Siddiqui and Perry, 2006). Bio
3.9.6. Occupational hazard and exposure considerations Thrax®, a subunit vaccine for Anthrax (Bacillus anthraxis), consists of
Bacteria are key elements for human health as evinced by the gut an avirulent, nonencapsulated strain of Bacillus anthracis and proteins
microbiota and the numerous health disorders in axenic animals and is administered with Alum adjuvant (BioSolutions, 2013).
(Pinero-Lambea et al., 2015). The occupational safety assessment of a Several vaccine platforms along with the relevant occupational
novel bacterial species should take into account information on the hazards and control guidance as well as examples of currently marketed
bacterial strain(s) and source(s) of the strain (e.g. original donor), the vaccines are presented in Table 5. Coronavirus disease or COVID-19
proposed subject population, mechanism of action, the intended route of vaccine candidates exist for each of the vaccine platforms and several
administration and the delivery method. If there are genetic modifica of these are noted (Le et al., 2020). The WHO’s authoritative and
tions to the strain, the stability of those genetic modifications should be continually updated list of COVID-19 vaccine candidates is located at:
taken into account and assessed. As it is important to ensure https://www.who.int/publications/m/item/draft-landscape-of-covi
product-related infections can be treated should they arise, strain d-19-candidate-vaccines.
characterization information including details about the presence of
virulence factors or toxins and the strain’s antibiotic resistance profile 3.10.4. ADME
(inclusive of knowledge of any antibiotic resistance genes present in the PK studies are generally not required or conducted for vaccines
GM bacteria) should be assessed/considered. because the kinetic properties of antigens do not provide useful infor
mation for determining dose recommendations. Differences in distri
3.9.7. Occupational exposure banding guidance recommendation bution, persistence and elimination of the components of a vaccine can
Given that GM bacteria are microbes, they should be handled as be attributed to several factors such as the route of administration, the
dictated by the applicable BSL (Control CfD and Prevention., 2009). number of injections, the quantity of antigen and the species under study
(Faurez et al., 2010). Whatever the route of administration, the site of
injection is the area where the vaccine components tend to remain the
3.10. Vaccines most concentrated and persist the longest, however vaccine components
have been observed in organs throughout the body including immune
3.10.1. Background cells and the blood (Faurez et al., 2010). Vaccinated persons have been
Vaccines provide the main method of prophylaxis against pandemic shown to shed vaccine viruses, however the shed live attenuated viruses
viruses and other infectious diseases. The introduction of human vac are generally stable and do not revert to virulent strains (Fiore et al.,
cines has had a tremendous impact on global health by dramatically 2009).
reducing the mortality and morbidity caused by infectious diseases.
Vaccination is considered one of the most cost effective and successful 3.10.5. Health hazards as a class/modality associated with therapeutic use
medical interventions ever introduced. Vaccines have inevitably pre There are safety concerns associated with various vaccine platforms.
vented diseases, complications, and the death of millions of people by Although attenuated vaccines elicit long-lasting immunity, safety issues
protecting against many deadly and debilitating infectious diseases including the administration of live viral or bacterial components and
including smallpox and polio (Kallerup and Foged, 2015). The World their capacity to replicate, infect immunocompromised individuals, and
Health Organization (WHO) currently recommends routine immuniza revert to pathogenic forms are of concern. For example, whole virus
tion against 22 different diseases (WHO, 2019). vaccines are considered too reactive, particularly in young children
(Wood and Robertson, 2004). In the case of plasmid DNA, there is a
3.10.2. How they work concern that the DNA vaccine could possibly integrate into host ge
The ideal vaccine elicits the exact immune response that occurs nomes, increasing the risk of malignancy (via insertional mutagenesis)
during natural infection, safely inducing a strong humoral and cellular (Kim and Jacob, 2009). Adjuvanated vaccines have only recently been
immune response. Vaccines work by mimicking disease agents and licensed so there remains some uncertainty regarding the safety of some
stimulating the immune system to build up defenses against them. adjuvants in humans (Keitel and Atmar, 2009). Additionally, adjuvanted
Vaccines are generally created to express one or more antigens present formulations typically elicit a higher frequency of injection site, and
on a pathogen to prime an individual’s immune system, so that if the occasionally systemic, reactions when compared with non-adjuvanted
individual is exposed to the pathogen in the future, the immune system formulations (Keitel and Atmar, 2009). The possibility of adverse re
will respond swiftly with a specific defense. Briefly, antigen-presenting actions increase when multiple doses are required to provide immunity.
cells (APCs; e.g., dendritic cells, macrophages) take up and process the Both aerosol-administered and intradermally administered vaccines
pathogen-specific antigen(s) and present them to CD4+ T cells via the have been well tolerated and immunogenic. Respiratory adverse events
MHC class II pathway and then to B cells, ultimately resulting in the are rare and mild. Intradermal vaccines have been associated with ex
production of antibodies. For most infectious diseases, primary protec pected mild local injection-site reactions (Satti et al., 2014). Common
tion is mediated by existing antibodies, whereas for intracellular path adverse effects in vaccine recipients include fatigue and headache. In
ogens (e.g. mycobacterium tuberculosis), protection is mediated by studies with FluMist®, adverse effects included runny nose or nasal
MHC class I-restricted CD8 T cell responses. The goal of vaccination is to congestion, headache, sore throat, tiredness/weakness, muscle aches,
produce a memory of the vaccine antigen, so that if an individual is cough or chills and rarely wheezing that required bronchodilator ther
exposed to the pathogen in the future, the memory cells will recognize it apy or that was associated with significant respiratory symptoms (Fiore
and the immune system will be able to respond more effectively than if it et al., 2009).
had never encountered the pathogen.
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
Table 5
Vaccine platforms, associated occupational hazard and exposure control guidance, and banding paradigmsa.
Vaccine Platform Potential Vaccine Example(s)b Occupational Hazards and Exposure Control Banding Paradigmc
Components Guidance
Live Attenuated Deoptimized live Marketed: Flumist® Quadrivalent (Influenza) COVID- See Section 3.8 (Oncolytic adenoviruses), 3.9 BSLs (Table 4)
Virus or attenuated virus or 19 Candidates in Development: Attenuated Influenza (Engineered Bacteria) and Section 3.10
Bacteria bacteria expressing an antigenic portion of the Spike protein (Vaccines)
Inactivated Virus Adenovirus, measles, Marketed: IPOL® (Polio) COVID-19 Candidates in See Section 3.8 (Oncolytic adenoviruses) and BSLs (Table 4)
influenza or other viral Development: Whole-Virion Inactivated Section 3.10 (Vaccines)
vector
Protein Subunit Peptide, S protein, Marketed: BioThrax® (Anthrax) See Sections 3.1 (Small molecules), 3.3 Small molecule banding
peptide antigens COVID-19 Candidates in Development: Recombinant (Peptides), 3.4 (Biologics), 3.9 (Engineered paradigm (Table 1) or
protein (RBD-Dimer) + Adjuvant Bacteria) and Section 3.10 (Vaccines) BCCs (Table 2)
DNA DNA, Plasmid DNA Marketed: None currently approved for use in See Section 3.2 (Oligonucleotides) and Small molecule banding
humans; West Nile-Innovator DNA vaccine for equines Section 3.10 (Vaccines) paradigm (Table 1)
(West Nile Virus)
COVID-19 Candidates in Development Include: Spike
DNA vaccine + Adjuvant
RNA mRNA, small activating Marketed: None currently approved COVID-19 See Section 3.2 (Oligonucleotides) and Small molecule banding
RNA, encapsulated Candidates in Development: LNP-encapsulated mRNA Section 3.10 (Vaccines) paradigm (Table 1)
mRNA
Virus-like Proteins Marketed: Gardasil® (human papillomavirus) COVID- See Section 3.1 (Small Molecules) and Section Small molecule banding
particle (VLP) 19 Candidates in Development: Plant-derived VLP + 3.10 (Vaccines) paradigm (Table 1) or
Adjuvant BCCs (Table 2)
a
Not an exhaustive list.
b
COVID-19 Candidate information obtained from the WHO’s authoritative and continually updated list of COVID-19 vaccine candidates located at: https://www.
who.int/publications/m/item/draft-landscape-of-covid-19-candidate-vaccines (accessed 07August 2020).
c
Note that BCCs are utilized at BMS, however alternative banding paradigms for biologics are also used in the pharmaceutical industry which are equally effective in
controlling exposures.
3.10.6. Occupational hazard and exposure considerations national regulatory bodies). Stringent vaccine biosafety control mea
Many vaccines are expected to be avirulent in humans. Inactivated sures with specific enhancements, defined as BSL2 enhanced (BSL2-e;
pandemic influenza vaccines present no biosafety risks provided that the pandemic influenza vaccine) and BSL3 enhanced (BSL3-e; pandemic
results of the inactivation steps show complete virus inactivation, as the influenza vaccine) are designed to manage the risk from vaccine pro
viral vaccine is rendered incapable of replication (Organization WH, duction and quality control using such viruses during the pre-pandemic
2005). Concerns arise where workers are immunologically naive to a or inter-pandemic period (Organization WH, 2005). In the United
virus and potentially susceptible to infection. In the instances where Kingdom, it is necessary to use BSL4 facilities, but in other parts of the
viruses are utilized, there are concerns around human infection with the world (e.g. United States) working with highly pathogenic avian influ
vaccine virus during manufacturing and of a subsequent outbreak enza (HPAI) viruses is acceptable under BSL3-e (Wood and Robertson,
originating from the manufacturing plant (Organization WH, 2005). 2004). Note that while this guidance exists, a risk assessment should be
Inhalation exposure to live viruses or bacteria are of concern. Upon performed that will depend on the nature of the strain and the pandemic
inhalation, live attenuated viruses have the potential to replicate in the period declared by WHO (Organization WH, 2005).
mucosa of the respiratory tract (Chen and Subbarao, 2009).
Human-to-human transmission is expected to be unlikely since replica 4. Conclusion
tion is attenuated and the virus titers would be below those considered
necessary for human infection (Organization WH, 2005). Potential Novel therapeutic drugs and technologies of increasing complexity
adverse effects may be at worst, similar to those observed upon intra and potency are being developed and handled throughout pharmaceu
nasal administration of live attenuated influenza, which consist of some tical research, development and manufacturing organizations and
effects of local viral replication (e.g., nasal congestion). With the clinics. As biological processes become elucidated and novel drug plat
exception of surrogate viruses, the use of wild type pandemic-like vi forms continue to be discovered, classical small-molecule approaches
ruses to develop pandemic vaccine strains presents considerable are not always appropriate or adequate and so other types of modalities
biosafety risks to personnel in vaccine development and manufacturing are required to address these targets (e.g. protein–protein and pro
facilities (Organization WH, 2005). Additionally, viruses may be ex tein–nucleic acid interactions). From an occupational safety perspective,
pected to survive for at least a short time (hours) on surfaces and thus this means staying current with the emerging literature on the hazards
provide a potential means of infection for workers (Organization WH, observed and expected with therapeutics spanning multiple modalities.
2005). Therefore, the wild-type pandemic-like viruses present the Occupational safety professionals must be proactive and aware of the
greatest occupational health concern. pharmacological, toxicological and physicochemical characteristics of
the new modalities residing within their respective drug development
3.10.7. Occupational exposure banding guidance recommendation pipelines to ensure occupational exposures are appropriately controlled
Vaccine production facilities are designed to maintain the sterility of and the risk of adverse effects, both pharmacological and toxicological,
the product. Therefore, although there is opportunity to be exposed to in the workplace is minimized. Occupational exposure control banding
the virus and/or antigens, occupational exposures are expected to be systems represent an acceptable approach to ensuring the safe handling
limited. The WHO biosafety risk assessment and guidelines for the of many new modalities, however it is important to be aware that certain
production and quality control of human influenza pandemic vaccines modalities do not fit historical banding paradigms and require other
presents guidance to vaccine manufacturers on the safe production of means of classification, such as BSLs or BCCs.
influenza vaccines (Organization WH, 2005). According to the WHO
guideline, all laboratory procedures involving live highly pathogenic Funding sources
influenza viruses should take place at a high level of biological
containment (e.g., BSL3 and above, as recommended by WHO and This research was funded by Bristol Myers Squibb.
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J.C. Graham et al. Regulatory Toxicology and Pharmacology 118 (2020) 104813
Declaration of competing interest Browne, H.P., Neville, B.A., Forster, S.C., Lawley, T.D., 2017. Transmission of the gut
microbiota: spreading of health. Nat. Rev. Microbiol. 15 (9), 531–543. https://doi.
org/10.1038/nrmicro.2017.50. Epub 2017/06/12, PubMed PMID: 28603278.
The authors declare that they have no known competing financial Buechner, J., Grupp, S., Maude, S., Boyer, M., Bittencourt, H., Laetsch, T., et al., 2017.
interests or personal relationships that could have appeared to influence Global registration trial of efficacy and safety of CTL019 in pediatric and young adult
the work reported in this paper. patients with relapsed/refractory (R/R) acute lymphoblastic leukemia (ALL): update
to the interim analysis. Clin. Lymphoma, Myeloma & Leukemia 17, S263–S264.
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