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CBER 1 Disease Associated Antibody Donor Program Rosia E. Nesbitt, BS, SBB(ASCP), CQA(ASQ) Consumer Safety Officer CBER, OBRR, DBA September 16, 2009
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CBER 2 Outline Definition of Disease-associated Antibodies Examples of Disease Agents or Antigens Immunoglobulin M (IgM) Antibody Collection Disease-associated Antibody Program Informed Consent Reporting Program Implementation Label Submission Other Naturally Occurring or Pre-Existing IgG Antibodies References/Resources
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CBER 3 Definition of Disease-associated Antibodies Antibodies that have occurred in response to exposure to disease agents or other antigens
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CBER 4 Examples of Disease Agents or Antigens Chlamydia Coccidioidomycosis C-Reactive Protein Cytomegalovirus (CMV) Mononucleosis (Epstein-Bar Virus) Hemophilus influenza Hepatitis A (Anti-HAV) Hepatitis B core (Anti-HBc) – Anti-HBc collections allowed in this category only when donor is known to also have Anti-HBs
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CBER 5 Examples of Disease Agents or Antigens (cont.) Hepatitis B (Anti-HBs) Herpes Type I and II Histoplasmosis Mumps Parvovirus B19 Pseudomonas Respiratory Syncytial Virus (RSV) Rubella Rubeola Toxoplasmosis Varicella Zoster (VZV)
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CBER 6 Immunoglobulin M (IgM) Antibody Collection Program Plasma containing IgM antibodies or from donors who do not meet all donor suitability requirements are not covered under a disease- associated antibody program – Considered disease state donors – Submit as a Prior Approval Supplement under 601.12(b)
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CBER 7 Disease-associated Antibody Program Manufacturers may implement a program to collect Source Plasma from donors who have detectable levels of disease-associated IgG antibodies Donors must meet all donor suitability requirements in 640.63 Donors should be in good health at time of donation
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CBER 8 Disease-associated Antibody Program (cont.) Donors: – Should have either recovered from the disease or been exposed to the disease agent but remained asymptomatic – Possess specific IgG antibodies to the disease agent Source Plasma may be used in the manufacture of injectable and noninjectable products – Examples: IVIG; controls for in vitro diagnostic assays
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CBER 9 Informed Consent In addition to the requirements in 640.61, donors: Should be informed that their plasma is being collected because it contains a specific antibody Should be informed that their antibody level will be monitored periodically to determine if they may continue participating in the program
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CBER 10 Reporting Program Implementation Report in your Annual Report under 601.12(d) Include Form FDA 356h Annual Report should include statements that: – Donors met all required suitability criteria for Source Plasma donors in 640.63 – The plasma was collected from donors who have been exposed to the disease agent but are in good health at the time of collection
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CBER 11 Reporting Program Implementation (cont.) Do not need to submit SOPs or the Informed Consent with the Annual Report Each program is facility specific – If implemented at more than one facility, submit a list of facilities and dates of implementation
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CBER 12 Label Submission Submit labels for each pre-existing antibody as a CBE under 601.12(f)(2) Immunizing antigen (or antibody) must be on Source Plasma label [640.70(a)(7)]
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CBER 13 Label Submission (cont.) Form FDA 2567 May submit a base label and include a list of different disease-associated antibodies with an explanation of placement on label Submit disease-associated antibody label for each facility if using address of each facility on label
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CBER 14 Other Naturally Occurring or Pre-Existing IgG Antibodies Establishments may implement or expand the program to collect other naturally occurring or pre-existing IgG antibodies Donors must meet all suitability requirements in 640.63
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CBER 15 Other Naturally Occurring or Pre-Existing IgG Antibodies (cont.) For donors with other naturally occurring or pre-existing red blood cell antibodies, submit a statement attesting that the donor: – Is not currently in an immunization program – Has not been immunized, either deliberately or by transfusion, within the previous 12 months Annual report should describe the procedures implemented to address these issues
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CBER 16 References/Resources Label Regulations 640.70 Guidance: Implementing a Collection Program for Source Plasma Containing Disease Associated and Other Immunoglobulin G (IgG) Antibodies (August 2006) http://www.fda.gov/downloads/BiologicsBloodVaccines/Guida nceComplianceRegulatoryInformation/Guidances/Blood/ucm0 79673.pdf http://www.fda.gov/downloads/BiologicsBloodVaccines/Guida nceComplianceRegulatoryInformation/Guidances/Blood/ucm0 79673.pdf Guidance: Informed Consent Recommendations for Source Plasma Donors Participating in Plasmapheresis and Immunization Programs (June 2007) http://www.fda.gov/downloads/BiologicsBloodVaccines/Guida nceComplianceRegulatoryInformation/Guidances/Blood/ucm0 62905.pdf http://www.fda.gov/downloads/BiologicsBloodVaccines/Guida nceComplianceRegulatoryInformation/Guidances/Blood/ucm0 62905.pdf
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