CBER Whole Blood and Blood Components Diane K. Hall Consumer Safety Officer CBER, OBRR, DBA September 16, 2009
CBER 2 Presentation Outline Submission contents General Standard Operating Procedures (SOPs) Whole Blood and blood components – Whole Blood and Red Blood Cells (RBCs) – RBC Modifications – Autologous Donations – Plasma – Platelets – Cryoprecipitated AHF
CBER 3 General Submission Contents 21 CFR * Cover Letter Form FDA 356h Form FDA 2567 with Labels Chemistry, Manufacturing and Control Section (CMC) – Appropriate SOPs – Validations and failure investigations – Quality Control (QC) – Records – Contractors names, addresses, registration numbers/CLIA approved
CBER 4 General SOPs 21 CFR : Maintain SOPs for all steps followed in collection, processing, storage and distribution of blood and blood components 640.4(h): Whole Blood storage temperatures during transport from collection site to processing site: – Cooling continuously towards 1-10C, or – Held in an environment maintained at a temperature range specified for that component in the directions for use for the blood collecting, processing, and storage system
CBER 5 General SOPs (b)(5)(iv): Validate shipping containers (e): Supplies shall be used in a manner consistent with manufacturers instructions If applicable, submit SOP for Sterile Connecting Device procedure **
CBER Whole Blood
CBER 7 Whole Blood 21 CFR : General requirements – Manufacturing responsibility – Blood container – Reissue of blood 640.3: Suitability of donor 640.4: Collection of the blood 640.5: Testing the blood
CBER Red Blood Cells
CBER 9 RBCs 21 CFR : General requirements – Storage – Inspection : Suitability of donor : Collection of the blood : Testing the blood : Segments for testing : Processing
CBER RBC Modifications Red Blood Cells Washed Red Blood Cells Rejuvenated Red Blood Cells Frozen Red Blood Cells Deglycerolized
CBER 11 Considerations for RBC Modifications: Storage and Dating Period Approved submissions have typically contained Red Blood Cells Washed – Storage: 1-6C – Dating period: 24 hours from start of washing process Red Blood Cells Rejuvenated – Storage: 1-6C – Dating period: 24 hours from start of washing process Red Blood Cells Frozen Rejuvenated – Storage: <-65C – Dating period: 10 years for RBCs collected and stored in CPD or CPDA-1 or 3 years for RBCs stored in CPD/ AS-1
CBER 12 RBC Modifications: Storage and Dating period , (c) Red Blood Cells Frozen (FRBC) – Storage: <-65C – Dating period: 10 years, or as specified in the manufacturers instructions Red Blood Cells Deglycerolized – Storage: 1-6C – Dating period: 24 hours after removal from <65C storage or as specified in the directions for use for the blood collection, processing, and storage system approved by FDA
CBER 13 RBC Modifications: Product QC Considerations for Red Blood Cells Washed Approved submissions typically have contained – Two months of product QC – 4 units/month – RBC Percent Recovery *** – Residual Total Protein *** – Sterility testing (10 units) ***
CBER 14 RBC Modifications: Product QC Red Blood Cells Deglycerolized and Red Blood Cells Rejuvenated – RBC Percent Recovery *** – Determination of free hemoglobin *** – Monitor glycerol removal *** – Sterility testing (10 units) ***
CBER Autologous Donations
CBER 16 Autologous Donations 640.3(b): Donor qualifications (d): Infectious disease testing (b)(20): Donor deferral
CBER 17 Autologous Donations Labels 21 CFR (i) and (j) Information identifying the patient, e.g. – Name, – Blood Group, – Hospital, – Identification Number Date of donation If applicable, FOR AUTOLOGOUS USE ONLY May use a tie tag attached to the container
CBER 18 Autologous Donations Labels (cont.) (i)(4) If donor fails to meet any Whole Blood donor suitability requirements, FOR AUTOLOGOUS USE ONLY label replaces the Blood Group label (h)(2)(ii)(B): Components that have reactive infectious disease screening tests must be labeled with the BIOHAZARD legend
CBER 19 Autologous Donations Labels (cont.) (d) If there is no cross over allowed and the units are not shipped anywhere else, then no infectious disease testing is required and the unit can be labeled, DONOR UNTESTED If facilities cross over autologous units or ship to facilities that allow cross over, then all units must be tested for infectious diseases and labeled according to (i)
CBER 20 Autologous Donations Labels (cont.) (d) If products are shipped to another facility that does not allow cross over, you must assure that the first donation in each 30-day period is tested. – Tested units: Label according to – Untested units: Label as DONOR TESTED WITHIN THE LAST 30 DAYS
CBER Plasma Components Fresh Frozen Plasma (FFP) Plasma Cryoprecipitate Reduced Plasma Frozen Within 24 Hours After Phlebotomy
CBER 22 Plasma 21 CFR – : Suitability of donors : Collection of source material : Testing the blood : Processing
CBER 23 Plasma Components (b), (a)(2): Separate plasma from RBCs and place in freezer within 8 hours of phlebotomy or within the timeframe specified in the directions for use for the blood collecting, processing and storage system (c) – Storage: <-18C – Dating period: 1 year from the collection date of Whole Blood
CBER Platelet Components Platelets Pooled Platelets-5d, Leukocytes Reduced
CBER 25 Platelets 21 CFR : Suitability of donors : Collection of source material : Testing the blood : Processing : General requirements – Storage – Quality control testing – Manufacturing responsibility
CBER 26 Platelets (d) : Phlebotomy shall be performed by: – A single uninterrupted venipuncture – With minimal damage to and manipulation of donors tissue
CBER 27 Platelets : Processing Whole Blood temperatures during transport from collection site to processing site shall be maintained as close as possible to a range between 20-24C Separate within 4 hours or within the timeframe specified in the direction for use for the blood collecting, processing, and storage system
CBER 28 Platelets : Storage 20-24C with continuous gentle agitation, or 1-6C with no agitation (c): Dating period 72 hours from the time of collection, or 5 days, with approved containers
CBER 29 Platelets (c) and (d) The time and speed of the centrifuge should demonstrate that the manufactured product: – Is an unclumped product – Is without visible hemolysis – Yields a count of >5.5x10 10 platelets per unit (75% of tested units) The volume of original plasma used to resuspend the platelets shall maintain a pH of >6.2
CBER 30 Considerations for Platelets: Product QC Approved submissions have typically contained two consecutive months of product QC 21 CFR – 4 units/month – pH – Platelet count – Plasma volume
CBER 31 Platelets: Product QC (c), : Acceptance Criteria for Platelets pH: >6.2 Platelet yield: 5.5x10 10 platelets/unit in >75% of tested units
CBER 32 Considerations for Pooled Platelets-5d, Leukocytes Reduced Approved submissions have typically contained Manufacturing: Use a process based on the manufacturers package insert that is capable of demonstrating the specified acceptance criteria
CBER 33 Considerations for Pooled Platelets-5d, Leukocytes Reduced Approved submissions have typically contained Product QC – Two consecutive months of product QC – Statistically sound plan – Ensure products meet specifications stated in the manufacturers instructions Acceptance Criteria – Acceptance criteria: manufacturers recommendations for product specifications
CBER Cryoprecipitate Components Cryoprecipitated AHF Pooled Cyroprecipitated AHF
CBER 35 Cryoprecipitated AHF: 21 CFR – : Suitability of donors : Collection of source material : Testing the blood : Processing : Quality control test for potency
CBER 36 Cryoprecipitated AHF (a): Processing Plasma (cryo rich) Separate plasma by centrifugation Place plasma in freezer within 8 hours after collection or within the timeframe specified in the directions for use for the blood collecting, processing, and storage system Store plasma at <-18C until further processed
CBER 37 Cryoprecipitated AHF (b): Processing Final Product Separate the Cryoprecipitated AHF from the plasma by a procedure that has been shown to produce an average of >80 IU of AHF/final container Do not add diluent prior to freezing final product
CBER 38 Cryoprecipitated AHF (c): for Cryoprecipitated AHF Storage: <-18C Dating period: 1 year from the date of Whole Blood collection
CBER 39 Considerations for Cryoprecipitated AHF Approved submissions typically have contained two consecutive months of product QC 21 CFR (n), – 4 units/month – Fibrinogen – AHF potency – Acceptance Criteria Fibrinogen: >150 mg Mean AHF potency: >80 IU of AHF/final container
CBER 40 Considerations for Pooled Cryoprecipitated AHF Approved submissions have typically contained Manufacturing – Use of Sterile Connecting Device ** – Storage: <-18C – Dating period: 1 year from the oldest units date of collection Product QC and Acceptance Criteria – Same as Cryoprecipitated AHF
CBER 41 References *Guidance for Industry: Changes to an Approved Application: Biological Products: Human Blood and Blood Components Intended for Transfusion or for Further Manufacture **Guidance for Industry: Use of Sterile Connecting Devices in Blood Bank Practices ***Guidance for Industry For the Submission of Chemistry, Manufacturing and Controls and Establishment Description Information for Human Blood and Blood Components Intended for Transfusion or for Further Manufacture and For the Completion of the Form FDA 356h Application to Market a New Drug, Biologic or an Antibiotic Drug for Human Use mation/Guidances/Blood/default.htm Eight-Hour Hold mation/OtherRecommendationsforManufacturers/MemorandumtoBlood Establishments/default.htm
CBER 42 Questions - Contact us! Mailing address: Director, Division of Blood Applications, OBRR, CBER, FDA HFM-370 c/o Document Control Center, HFM Rockville Pike, Suite 200N Rockville, MD Telephone: FAX: