The timing of the draft guidelines would suggest they were initiated much earlier. Remember, before the guidelines were published as drafts at least one company used an external control arm to obtain approval. Data in this the DCVax-l trial was locked 13 months ago, don’t you think that it’s much more likely they got the tentative endpoint change “buy-in” (which is not announced “acceptance”) and then the FDA went about drafting guidelines to formalize its thinking whilst NWBO/UCLA/et al went about developing the journal article format in line with the guidance being drafted, and prior to either coming out, a test case went through the approval process on such basis? Do you really think the FDA fought to fight itself by drafting those guidelines?
No, there was likely buy-in way back by early October, 2020. This does not mean they made anything like a peremptory marketing approval decision, it simply means they bought into the different approach (Aka: adding external/synthetic arm) that must be considered with delayed response trials exhibiting potential crossover confoundment; and, in addition to that psPD confoundment in information arms and other real world data.
Third, regarding manufacturing, manual would probably handle any brief time window between MHRA (potential) approval in the UK, and the NICE price evaluation, then, as if you forgot, there has been a five year development, and another six months of batch runs on the automated closed system patented manufacturing device. It could probably start producing months after approval but concurrent with a NICE decision. (NICE/Orbis/MHRA just conveniently provided such a temporary exception for companies meeting certain requirements) Next, CRL’s Cognate has already been given GMP certification associated with DCVax-l production.
Finally, Dr. Pazdur thinks most manufacturing expansion readiness needs to be in place or imminently ready for expansion if some new SOC is to be ready for increasing global demand. Project Orbis.