Responses to the Appendix M requirement of the NIH Guidelines should be provided by either written answers or references to specific sections of the protocol or its appendices. Investigators should indicate the points that are not applicable with a brief explanation. Investigators submitting proposals that employ the same vector systems may refer to additional documents submitted that relate to the vector sequence without having to rewrite such material.
M-II-A. Objectives and Rationale of the Proposed Research
State concisely the overall objectives and rationale of the proposed study. Provide information on the specific points that relate to whichever type of research is being proposed.
M-II-A-1. Use of Recombinant DNA for Therapeutic Purposes
For research in which recombinant DNA is transferred in order to treat a disease or disorder (e.g., genetic diseases, cancer, and metabolic diseases), the following questions should be addressed:
a. Why is the disease selected for experimental treatment by means of gene transfer a good candidate for such treatment?
b. Describe the natural history and range of expression of the disease selected for experimental treatment. What objective and/or quantitative measures of disease activity are available? In your view, are the usual effects of the disease predictable enough to allow for meaningful assessment of the results of gene transfer?
c. Is the protocol designed to prevent all manifestations of the disease, to halt the progression of the disease after symptoms have begun to appear, or to reverse manifestations of the disease in seriously ill victims?
d. What alternative therapies exist? In what groups of subjects are these therapies effective? What are their relative advantages and disadvantages as compared with the proposed gene transfer?
M-II-A-2. Transfer of DNA for Other Purposes
a. Into what cells will the recombinant DNA be transferred? Why is the transfer of recombinant DNA necessary for the proposed research? What questions can be answered by using recombinant DNA?
b. What alternative methodologies exist? What are their relative advantages and disadvantages as compared to the use of recombinant DNA?
M-II-B-1. Research Design, Anticipated Risks and Benefits:
Structure and Characteristics of the Biological System
Provide a full description of the methods and reagents to be employed for gene delivery and the rationale for their use. The following are specific points to be addressed:
a. What is the structure of the cloned DNA that will be used?
a-(1). Describe the gene (genomic or cDNA), the bacterial plasmid or phage vector, and the delivery vector (if any). Provide complete nucleotide sequence analysis or a detailed restriction enzyme map of the total construct.
a-(2). What regulatory elements does the construct contain (e.g., promoters, enhancers, polyadenylation sites, replication origins, etc.)? From what source are these elements derived? Summarize what is currently known about the regulatory character of each element.
a-(3). Describe the steps used to derive the DNA construct..
b. What is the structure of the material that will be administered to the research participant?
b-(1). Describe the preparation, structure, and composition of the materials that will be given to the human research subject or used to treat the subject’s cells:
i. If DNA, what is the purity (both in terms of being a single DNA species and in terms of other contaminants)? What tests have been used and what is the sensitivity of the tests?
ii. If a virus, how is it prepared from the DNA construct? In what cell is the virus grown (any special features)? What medium and serum are used? How is the virus purified? What is its structure and purity? What steps are being taken (and assays used with their sensitivity) to detect and eliminate any contaminating materials (for example, VL30 RNA, other nucleic acids, or proteins) or contaminating viruses (both replication-competent or replication-defective) or other organisms in the cells or serum used for preparation of the virus stock including any contaminants that may have biological effects?
iii. If co-cultivation is employed, what kinds of cells are being used for co-cultivation? What steps are being taken (and assays used with their sensitivity) to detect and eliminate any contaminating materials? Specifically, what tests are being conducted to assess the material to be returned to the subject for the presence of live or killed donor cells or other non-vector materials (for example, VL30 sequences) originating from those cells?
iv. If methods other than those covered by Appendices M-II-B-1 through M-II-B-3, Research Design, Anticipated Risks and Benefits, are used to introduce new genetic information into target cells, what steps are being taken to detect and eliminate any contaminating materials? What are possible sources of contamination? What is the sensitivity of tests used to monitor contamination?
b-(2). Describe any other material to be used in preparation of the material to be administered to the human research subject. For example, if a viral vector is proposed, what is the nature of the helper virus or cell line? If carrier particles are to be used, what is the nature of these?
M-II-B-2. Research Design, Anticipated Risks and Benefits:
Provide results that demonstrate the safety, efficacy, and feasibility of the proposed procedures using animal and/or cell culture model systems, and explain why the model(s) chosen is/are most appropriate.
a. Delivery System
a-(1). What cells are the intended target cells of recombinant DNA? What target cells are to be treated ex vivo and returned to the human subject, how will the cells be characterized before and after treatment? What is the theoretical and practical basis for assuming that only the target cells will incorporate the DNA?
a-(2). Is the delivery system efficient? What percentage of the target cells contain the added DNA?
a-(3). How is the structure of the added DNA sequences monitored and what is the sensitivity of the analysis? Is the added DNA extrachromosomal or integrated? Is the added DNA unrearranged?
a-(4). How many copies are present per cell? How stable is the added DNA both in terms of its continued presence and its structural stability?
b. Gene Transfer and Expression
b-(1). What animal and cultured cell models were used in laboratory studies to assess the in vivo and in vitro efficacy of the gene transfer system? In what ways are these models similar to and different from the proposed human treatment?
b-(2). What is the minimal level of gene transfer and/or expression that is estimated to be necessary for the gene transfer protocol to be successful in humans? How was this level determined?
b-(3). Explain in detail all results from animal and cultured cell model experiments which assess the effectiveness of the delivery system in achieving the minimally required level of gene transfer and expression.
b-(4). To what extent is expression only from the desired gene (and not from the surrounding DNA)? To what extent does the insertion modify the expression of other genes?
b-(5). In what percentage of cells does expression from the added DNA occur? Is the product biologically active? What percentage of normal activity results from the inserted gene?
b-(6). Is the gene expressed in cells other than the target cells? If so, to what extent?
c. Retrovirus Delivery Systems
If a retrovirus delivery system is not used, state “none used” and continue to next section.
c-(1). What cell types have been infected with the retroviral vector preparation? Which cells, if any, produce infectious particles?
c-(2). How stable are the retroviral vector and the resulting provirus against loss, rearrangement, recombination, or mutation? What information is available on how much rearrangement or recombination with endogenous or other viral sequences is likely to occur in the human subject’s cells? What steps have been taken in designing the vector to minimize instability or variation? What laboratory studies have been performed to check for stability, and what is the sensitivity of the analyses?
c-(3). What laboratory evidence is available concerning potential harmful effects of the transfer (e.g., development of neoplasia, harmful mutations, regeneration of infectious particles, or immune responses)? What steps will be taken in designing the vector to minimize pathogenicity? What laboratory studies have been performed to check for pathogenicity, and what is the sensitivity of the analyses?
c-(4). Is there evidence from animal studies that vector DNA has entered untreated cells, particularly germ-line cells? What is the sensitivity of these analyses?
c-(5). Has a protocol similar to the one proposed for a clinical trial been conducted in non-human primates and/or other animals? What were the results? Specifically, is there any evidence that the retroviral vector has recombined with any endogenous or other viral sequences in the animals?
d. Non-Retrovirus Delivery/Expression Systems
If a non-retrovirus delivery system is not used, state “none used” and continue to next section.
If a non-retroviral delivery system is used, what animal studies have been conducted to determine if there are pathological or other undesirable consequences of the protocol (including insertion of DNA into cells other than those treated, particularly germ-line cells)? How long have the animals been studied after treatment? What safety studies have been conducted? (Include data about the level of sensitivity of such assays.)
M-II-B-3. Research Design, Anticipated Risks and Benefits:
Clinical Procedures, Including Research Participant Monitoring
Describe the experimental treatment that will be administered to the human subjects and the diagnostic methods that will be used to monitor the success or failure of the experimental treatment. If previous clinical studies using similar methods have been performed by yourself or others, indicate their relevance to the proposed study. Specifically:
a. Will cells (e.g., bone marrow cells) be removed from human subjects and treated ex vivo? If so, describe the type, number, and intervals at which these cells will be removed.
b. Will human subjects be treated to eliminate or reduce the number of cells containing malfunctioning genes (e.g., through radiation or chemotherapy)?
c. What treated cells (or vector/DNA combination) will be given to human subjects? How will the treated cells be administered? What volume of cells will be used? Will there be single or multiple experimental treatments? If so, over what period of time?
d. How will it be determined that new gene sequences have been inserted into the subject’s cells and if these sequences are being expressed? Are these cells limited to the intended target cell populations? How sensitive are these analyses?
e. What studies will be conducted to assess the presence and effects of the contaminants?
f. What are the clinical endpoints of the study? Are there objectives and quantitative measurements to assess the natural history of the disease? Will such measurements be used in human subject follow-up? How will subjects be monitored to assess specific effects of the treatment on the disease? What is the sensitivity of the analyses? How frequently will follow-up studies be conducted? How long will follow-up continue?
g. What are the major beneficial and adverse effects of the experimental treatment that you anticipate? What measures will be taken in an attempt to control or reverse these adverse effects if they occur? Compare the probability and magnitude of deleterious consequences from the disease if recombinant DNA transfer is not used.
h. If a treated human subject dies, what special post-mortem studies will be performed? Note: Section III-B-2-c of Appendix M describes in the Informed Consent a request for autopsy.
M-II-B-4. Research Design, Anticipated Risks and Benefits:
Public Health Considerations
Describe any potential benefits and hazards of the proposed gene transfer to persons other than the human subjects receiving the experimental treatment. Specifically:
a. On what basis are potential public health benefits or hazards postulated?
b. Is there a significant possibility that the added DNA will spread from the human subject to other persons or to the environment?
c. What precautions will be taken against such spread (e.g., subjects sharing a room, health-care workers, or family members)?
d. What measures will be undertaken to mitigate the risks, if any, to public health?
e. In light of possible risks to offspring, including vertical transmission, will birth control measures be recommended to subjects? Are such concerns applicable to health care personnel?
M-II-B-5. Research Design, Anticipated Risks and Benefits:
Qualifications of Investigators and Adequacy of Laboratory and Clinical Facilities
Indicate the relevant training and experience of the personnel who will be involved in the preclinical studies and clinical administration of recombinant DNA. Describe the laboratory and clinical facilities where the proposed study will be performed. Specifically:
a. What professional personnel (medical and nonmedical) will be involved in the proposed study and what is their relevant expertise? Provide a two-page curriculum vitae for each key professional person in biographical sketch format (see Appendix M-I-A, Requirements for Protocol Submission).
b. At what hospital or clinic will the experimental treatment be given? Which facilities of the hospital or clinic will be especially important for the proposed study? Will subjects occupy regular hospital beds or clinical research center beds? Where will subjects reside during the follow-up period? What special arrangements will be made for the comfort and consideration of the research participants. Will the research institution designate an ombudsman, patient care representative, or other individual to help protect the rights and welfare of the research participant?
M-II-C. Research Design, Anticipated Risks and Benefits:
Selection of the Human Subjects
Estimate the number of human subjects to be involved in the proposed study. Describe recruitment procedures and eligibility requirements, paying particular attention to whether these procedures and requirements are fair and equitable. Specifically:
1. How many subjects do you plan to involve in the proposed study?
2. How many eligible subjects do you anticipate being able to identify each year?
3. What recruitment procedures do you plan to use?
4. What selection criteria do you plan to employ? What are the exclusion and inclusion criteria for the study?
5. How will subjects be selected if it is not possible to include all who desire to participate?
M-III. Informed Consent Process
In accordance with the Protection of Human Subjects (45 CFR Part 46), investigators should indicate how subjects will be informed about the proposed study and the manner in which their consent will be solicited. They should indicate how the Informed Consent document makes clear the special requirements of gene transfer research. If a proposal involves children, special attention should be paid to the Protection of Human Subjects (45 CFR Part 46), Subpart D, Additional Protections for Children Involved as Subjects in Research.
1. Which members of the research group and/or institution will be responsible for contacting potential participants and for describing the study to them? What procedures will be used to avoid possible conflicts of interest if the investigator is also providing medical care to potential subjects?
2. How will the major points covered in Appendix M-II, Description of Proposal, be disclosed to potential participants and/or their parents or guardians in language that is understandable to them?
3. What is the length of time that potential participants will have to make a decision about their participation in the study?
4. If the study involves pediatric or mentally handicapped subjects, how will the assent of each person be obtained?
M-III-B. Informed Consent Document Guidance for Gene Transfer Research
Submission of a human gene transfer experiment to either the Recombinant Advisory Committee (RAC) Board of the NIH or the University of Pittsburgh IBC must include a copy of the proposed informed consent document(s). Separate Informed Consent documents should be used for the gene transfer portion of a research project when gene transfer is used as an adjunct in the study of another technique, e.g., when a gene is used as a "marker" or to enhance the power of immunotherapy for cancer.
Section M-III-B of the Appendix M may be fulfilled by the submission of the proposed informed consent document. A synopsis of the Informed Consent requirements are below. For additional guidance on drafting an informed consent document, please contact the IRB Office.
M-III-B-1. General Requirements of Human Subjects Research Informed Consent Document
a. Description/Purpose of the Study
The subjects should be provided with a detailed explanation in non-technical language of the purpose of the study and the procedures associated with the conduct of the proposed study, including a description of the gene transfer component.
The Informed Consent document should indicate the availability of therapies and the possibility of other investigational interventions and approaches.
c. Voluntary Participation
The subjects should be informed that participation in the study is voluntary and that failure to participate in the study or withdrawal of consent will not result in any penalty or loss of benefits to which the subjects are otherwise entitled.
The subjects should be provided with an accurate description of the possible benefits, if any, of participating in the proposed study. For studies that are not reasonably expected to provide a therapeutic benefit to subjects, the Informed Consent document should clearly state that no direct clinical benefit to subjects is expected to occur as a result of participation in the study, although knowledge may be gained that may benefit others.
e. Possible Risks, Discomforts, and Side Effects
There should be clear itemization in the Informed Consent document of types of adverse experiences, their relative severity, and their expected frequencies.
The Informed Consent document should provide information regarding the approximate number of people who have previously received the genetic material under study. It is necessary to warn potential subjects that, for genetic materials previously used in relatively few or no humans, unforeseen risks are possible, including ones that could be severe.
The subjects should be provided with specific information about any financial costs associated with their participation in the protocol and in the long-term follow-up to the protocol that are not covered by the investigators or the institution involved.
M-III-B-2. Specific Requirements for Gene Transfer Research Informed Consent Document
a. Reproductive Considerations
To avoid the possibility that any of the reagents employed in the gene transfer research could cause harm to a fetus/child, subjects should be given information concerning possible risks and the need for contraception by males and females during the active phase of the study.
To permit evaluation of long-term safety and efficacy of gene transfer, the prospective subjects should be informed that they are expected to cooperate in long-term follow-up that extends beyond the active phase of the study.
c. Request for Autopsy
To obtain vital information about the safety and efficacy of gene transfer, subjects should be informed that at the time of death, no matter what the cause, permission for an autopsy will be requested of their families.
d. Interest of the Media and Others in the Research
To alert subjects that others may have an interest in the innovative character of the protocol and in the status of the treated subjects, the subjects should be informed of the following:
that the institution and investigators will make efforts to provide protection from the media in an effort to protect the participants' privacy
that representatives of applicable Federal agencies (e.g., the National Institutes of Health and the Food and Drug Administration), representatives of collaborating institutions, vector suppliers, etc., will have access to the subjects' medical records.
Privacy measures should help protect the confidentiality of information that could directly or indirectly identify study participants.
Indicate what measures will be taken to protect the privacy of subjects and their families as well as maintain the confidentiality of the research data.
A. What provisions will be made to honor the wishes of individual human subjects (and the parents or guardians of pediatric or mentally handicapped subjects) as to whether, when, or how the identity of a subject is publicly disclosed.
B. What provisions will be made to maintain the confidentiality of research data, at least in cases where data could be linked to individual subjects?
Although the following issues are beyond the normal purview of local review and oversight, investigators should respond to the following questions:
A. What steps will be taken, consistent with Appendix M-IV, Privacy, to ensure that accurate and appropriate information is made available to the public with respect to such public concerns as may arise from the proposed study?
B. Do you or your funding sources intend to protect under patent or trade secret laws either the products or the procedures developed in the proposed study? If so, what steps will be taken to permit as full communication as possible among investigators and clinicians concerning research methods and results?