1. Regulatory Implications of Neoplastic Cell Substrate Tumorigenicity
Andrew M. Lewis Jr. M.D.
DVP, OVRR, CBER, FDA

2. Outline Define tumorigenicity and oncogenicity
Review regulatory concerns associated with tumorigenic cell substrates, especially cell substrates that are highly tumorigenic
Review tumorigenicity testing:
1. How tumorigenicity is evaluated
2. How highly tumorigenic cells can be identified
3. Uses of expanded models of tumorigenicity testing and
their contributions to cell substrate evaluation
Review mechanisms of neoplastic development and their implications for neoplastic cell-substrate evaluation

3. Definitions, Explanations, Implications
Tumorigenicity
The process by which neoplastic cells growing in tissue culture form tumors when inoculated into animal
Tumorigenicity vs. Oncogenicity
During tumorigenicity, the inoculated cells grow into tumors
During oncogenicity, oncogenic agents transform the cells of the injected species into neoplastic cells that grow into tumors

4. Regulatory Concerns Associated with the Tumorigenicity of Cell Substrates
Induction of tumor allografts
Example: Reports of humans being engrafted with cells from human tumors
Transfer of known or unknown viruses
Examples: Unrecognized agent (LCMV) in cells from a human breast carcinoma; Variety of agents (herpesviruses, retroviruses, polyomaviruses, papillomaviruses) in human tumors.
Transfer of oncogenic agents
Example: Virus-free, SV40-transformed, human meningioma cells inoculated into nude mice induced mouse host-cell fibrosarcomas and lymphomas that contained SV40 DNA
Transfer of cell components that might initiate neoplastic processes
Example: Cellular oncogene H-ras, present in the DNA of neoplastic cells, induces tumors in Swiss mice

5. Highly Tumorigenic Cell Substrates: Regulatory Concerns
General perception that the more tumorigenic (aggressive) the neoplastic cell substrate, the greater the risk of its components inducing neoplastic processes
Factors that contribute to the highly tumorigenic phenotype require further explanation
No attempts to correlate the oncogenic activity of cell substrate DNA with the aggressiveness of their tumorigenic phenotype.
Fewer the cells required to produce a tumor, the smaller the safety factor that can be attributed to the transfer of factors that might induce neoplastic activity

6. Estimated Risk Factor Levels Cell substrate components
Perceptions of the Risks Posed by Tumorigenic Neoplastic Cell Substrates
Cell Substrate
Type
(Example)
Estimated Risk Factor Levels
Perceived Risk Level
Advent Agents from:
Cell substrate components
Host
Laboratory exposure
DNA oncogen.
DNA infect
Other
Adventitious
agents
Oncogenic
Primary
++++ + ++
Diploid -
Immortal
non-tumorig
(VERO)
Immortal.
weakly tumorig 1
(293)
highly tumorig 2
(HeLa)
+++
1.Cell lines are usually laboratory generated. High cell doses (10e6 to 10e7 cells/mouse) needed for tumor
formation in immunosuppressed host. No reports of recovery of dominant cellular oncogenes. With defective
adenovirus vectors, replication competent viruses can be recovered.
2. Capacity to form tumors at 10e1 to 10e4 cells/animal. Oncogenic viruses and dominant activated cellular
oncogenes can be recovered from tumor cells. Reports of adventitious agent contamination.

7. How is the tumorigenic phenotype expressed by neoplastic cell substrates evaluated?

8. Evaluating the Tumorigenicity of Neoplastic Cells: In Vivo Models
Currently Used
Inoculation of athymic (nude) mice or nude rats
Inoculation of newborn mice or newborn rats treated with either irradiation or anti-thymocyte globulin (ATG

9. Cell-Substrate History and Its Implications for Tumorigenicity Testing
Concerns about using neoplastic cells as vaccine substrates were voiced in 1954 by the Armed Forces Epidemiology Board with a recommendation that only “normal” cells be used
Prior to 2000, excepting 2 experimental, highly-purified, protein vaccines, only cells that were shown to be non-tumorigenic were used in the manufacture of virus vaccines

10. Tumorigenicity Testing of Cell Substrates Prior to 2000
Single-Dose Assay:
CBER assay: (Points To Consider in the Characterization of Cell Lines Used to Produce Biologicals 1993)
Inoculum cell/animal
Possible Host nude mice; 10 NB rats, NB mice, or NB hamsters immunosuppressed with antithymocyte globulin (ATG); 10 mice thymectomized, irradiated and reconstituted with bone marrow from healthy mice
Observation period - 3 weeks for half and 12 weeks for half, unless tumor growth intervenes, with necropsy/histopathology of injection site, tumors, lymph nodes-organs for metastases
Endpoint - Tumor incidence (i.e.. No. with tumors/No. surviving)

11. Limitations of Single-Dose Assays
Single dose assays are appropriate for documenting the lack of tumor forming capacity but provide only 1 data point
Single dose assays become less useful when cells possess a capacity to form tumors
Single-dose, short term assays can give data that are unreliable on the ability of some neoplastic cells to form tumors

12. Problems with the Validity of Tumor Incidence and Tumor Latency Endpoints in Single-Dose, Short- Term Tumorigenicity Assays1
Cell Lines2
No. Expts.
Tumor incidence after indicated No. of weeks
(Inoculum/host cells/ adult nude mouse) 5 10 15 20 25
SV40ME1 2
0/8
8/8
SV40ME2
4/8
6/7
Data from Lewis et al. Cancer Lett 93:179, 1995.
Independent lines of BALB/c mouse embryo cells transformed in tissue culture by SV inoculated into 6-8 week old nude mice 106 cells/mouse.

13. Rationale for Expanded Tumorigenicity Testing of Neoplastic Cell Substrates
Introduction of highly tumorigenic cell substrates in the manufacture of viral vaccines sets new precedents
Presence of unknown agents/factors in highly tumorigenic cell substrates represents their greatest risk
Detection of unknown agents/factors that could transfer oncogenic activity can be enhanced by expanding tumorigenicity testing methods and evaluating the data available from such assays
Every practical technique needs to be used to minimize the risk of transferring infectious/oncogenic agents/factors by vaccines

14. Expanded Tumorigenicity Testing Enhance the Regulatory Management of Neoplastic Cell Substrates
The tumorigenic phenotype of the cell substrate can be defined by evaluating the kinetics of tumor formation at doses of 107, 105, 103, and 101 cells/adult nude mouse
Determining the tumor forming capacity establishes the level of tumorigenicity (aggressiveness) expressed by the tumorigenic phenotype
Unrecognized oncogenic agents can be detected by identifying the species of the cells that grow into tumors across the range of tumor-forming doses and evaluating any spontaneous tumors that appear for evidence of DNA from the cell substrate
Unrecognized oncogenic agents can also be detected by looking for aberrations in the kinetics by which tumors are formed by the cell substrate

15. Identifying Neoplastic Cell Substrates that Exhibit Highly Tumorigenic Phenotypes
Determining the dose-response dynamics of tumor formation, expressed as TPD50 values (tumor-producing doses at the 50% endpoint), provides useful data on:
No. of cells required for tumor development - the fewer the
cells required, the more aggressive the phenotype
Time of tumor appearance (tumor latency) - the more rapidly
the tumors appear, the more aggressive the phenotype
Capacity of the tumors that form to metastasize also
contributes to assessing the aggressiveness of the phenotype

16. TPD50 Endpoint Explained
TPD50 = Tumor producing dose at the 50% endpoint
(i.e., No. of cells required for tumor formation)
TPD50 values change (evolve) as the tumor incidence changes during the observation period until they reach the limit of the capacity of the cells to form tumors
TPD50 values are best determined by the Spearman-Karber estimator of 50% endpoints

17. Tumor Formation by HeLa Cells in Nude Mice
Time
(weeks)
Tumor incidence at dose of cells inoculated (log10)
Mean TPD50
(log10) 7 6 5 4 3 2 1
8/8
0/13
6.50
13/13
4/13
5.19
7/13
4.96
1/13
4.88
10/13
4.75 8
9-12

18. Graph of the TPD50 Data at Weekly Intervals in Nude Mice Injected with HeLa Cells (TPD50 Evolution Curve)
TPD50 (log10)
Time (weeks)

19. TPD50 Evolution Curves
Represent survival curves of average tumor latency
Can be converted to survival curves
Conversion to survival functions simplifies statistical analyses

20. Tumor Formation Dynamics of Weakly Tumorigenic and Highly Tumorigenic Cell Substrates

21. Comparison of TPD50 Values for Cell Lines
of Human, Mouse, and Hamster Origin
Human
Mouse
Hamster
TPD50
Cell Line

22. Ability of the Adult Nude Mouse Model to Detect Tumorigenic Phenotypes
Data from 4 different studies found that 119/134 cell lines tested, at cells/mouse, had the capacity to form tumors in adult nude mice
Cell lines established from carcinomas of the pancreas, breast, and gliomas as well a lymphomas and leukemias from humans have failed to form tumors in adult nude mice
Newborn nude mice have been shown to detect many of those human tumors that are not tumorigenic in adults

23. Factors Known to Modify the Tumor-Forming Capacity of Neoplastic Cells Growing in Tissue Culture
1. Contamination of cell substrate with viruses or bacteria
2. Infection of rodent hosts used in tumorigenicity testing
3. Level of immunocompetence of rodent host (adults > newborns ≥ adult nude mice > newborn nude mice)

24. Impact of Viral Contamination (Cells) and Viral Infection (Host) on Neoplastic Cell Tumorigenicity in Nude Mice
Cell Line
106 to 107
Cells/mouse
Incidence of Progressively Growing Tumors in Nude Mice
Cells/Mice Infected with:1
Mice infected with mouse hepatitis virus2
Uninfected
VSV
Mumps
Flu/NWS
Measles
BHK-21
14/14
0/22
0/3
0/19 NT
HeLa
5/5
0/12
0/4
SH-Me
(human melanoma)
21/21
5/8
1. Reid et al. J Gen Virol 42:609, 1979
2. Akimaru et al. J Surg Oncology 17: 309, 1981

25. 3-Stage Model of Neoplastic Development
Mechanisms Involved in Neoplastic Development and Tumor Formation in Experimental Animals
3-Stage Model of Neoplastic Development
1. Initiation - first and apparently irreversible, stage of neoplastic development; initiating event can represent a single genetic change
2. Promotion - apparently reversible, stage of neoplastic development; promotional events can represent 1 or more additional genetic changes (oncogene activation/ tumor suppressor gene deactivation)
3. Progression - final genetic events (further genetic changes) resulting in tumor formation, invasion, and metastases

26. Multi-Step Models of Carcinogenesis
Mechanisms Involved in Neoplastic Development and Tumor Formation in Humans
Multi-Step Models of Carcinogenesis
4 - 6 somatic mutation model for progression of
colon carcinoma (Vogelstein et al. NEJM, 319:525, 1988)
3 - gene model of the neoplastic transformation of
human cells in culture to cells that can form tumors in nude mice (Hahn et al. Nature 400: 464, 1999)

27. Mechanisms of Neoplastic Development and the Regulatory Management of Tumorigenic Cell Substrates
Tumor development is a multi-step process requiring independent genetic alterations involving different genetic loci
Every “neoplastic mutation” above one decreases the possibility of transferring neoplastic activity by the power of the mutation number
Tumor development represents the end stage of neoplastic development that begins with an initiating event
Transfer of viral oncogene or dominant activated oncogene activity that is capable of inducing neoplastic activity resulting in tumor formation can be detected in animals models
The sensitivity of animal models to detect oncogenic activity is low
Initiating events can represent single genetic processes, do not appear to be reversible, and may or may not evolve along the path of neoplastic development during the life of an individual
Currently there is no way to test cell-substrate components for neoplastic initiation

28. OVRR Recommendations for Expanded Tumorigenicity Testing of Tumorigenic Neoplastic Cell Substrates
Evaluate and analyze for aberrations the dynamics of tumor formation by determining the tumor incidence at doses of 107, 105, 103, and 101 cells in adult nude mice
Record incidence of visible/palpable tumors at weekly intervals over 4-5 month interval.
Determine species of origin of cells in tumors across the range of tumor-forming doses, with particular attention to tumors at limiting cell doses
Necropsy all mice at end of the study and obtain histopathology on tumors/injection sites/organs,
Evaluate any spontaneous tumors that develop for evidence of DNA from the cell substrate

29. Data of Regulatory Significance Provided by Expanded Tumorigenicity Testing of Neoplastic Cell Substrates
Data on tumor formation kinetics reveals weakly/highly tumorigenic phenotypes, which influences the level of concern over adventitious agent contamination and oncogenic/infectivity activity of cell-substrate DNA
Data on aberrations in tumor formation, especially at high cell doses, may be indicative of cell-substrate contamination with known/unknown agents
Data on the species of origin of the cells that form tumors at the injection site or at distant sites (possibly spontaneous tumors) determine whether oncogenic activity can be transferred from the neoplastic cell substrate to the host
Histopathology on injection sites, tumors, and organs establishes/confirms the identity and possible aggressiveness of the neoplastic cell substrate

30. Summary Cell substrate tumorigenicity testing can provide data on:
1. Tumorigenic phenotype - whether the substrate cells are
weakly or highly tumorigenic
2. Transfer of oncogenic viruses
3. Presence of adventitious agents
Tumorigenicity testing in adult nude mice can detect tumor-forming capacity in 9/10 cell lines tested (newborn nude mice may provide a more sensitive alternative)
Tumor formation represents the end-stage of the multi-step process (initiation, promotion, progression) of neoplastic development
With exception of neoplastic initiation events, which can not be evaluated, the multi-step process of neoplastic development makes it unlikely that neoplastic activity can be transferred by cell components other than oncogenic viruses