12 th Annual FDA & the Changing Paradigm for Blood Regulation – 01/16/2009 – Las Vegas, NV – Gilliam B. Conley 1 FDA perspective on “Where are we? Where can we go?” 12 th Annual FDA & the Changing Paradigm for Blood Regulation 16 January 2009 -- Las Vegas, NV Gilliam B. Conley Director, Division of Inspections & Surveillance FDA, Center for Biologics Evaluation & Research Office of Compliance & Biologics Quality
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12 th Annual FDA & the Changing Paradigm for Blood Regulation – 01/16/2009 – Las Vegas, NV – Gilliam B. Conley 1 FDA perspective on “Where are we? Where.
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12th Annual FDA & the Changing Paradigm for Blood Regulation – 01/16/2009 – Las Vegas, NV – Gilliam B. Conley 1
FDA perspective on “Where are we?
Where can we go?”
12th Annual FDA & the Changing Paradigm for Blood Regulation16 January 2009 -- Las Vegas, NV
Gilliam B. Conley Director, Division of Inspections & SurveillanceFDA, Center for Biologics Evaluation & Research Office of Compliance & Biologics Quality
12th Annual FDA & the Changing Paradigm for Blood Regulation – 01/16/2009 – Las Vegas, NV – Gilliam B. Conley 5
Top 10 Blood & Blood Component ObservationsFY-2008 (Oct. ’07 through Sept. ’08)
Cite ID Count 21 CFR… Text
#1 76 116 606.100(b) Written standard operating procedures including all steps to be followed in the [collection] [processing] [compatibility testing] [storage] [distribution] of blood and blood components for [homologous transfusion] [autologous transfusion] [further manufacturing purposes] are not always [maintained] [followed] [maintained on the premises]. Specifically, ***
#2 98 31 606.100(c) Failure to [perform a thorough investigation] [make a record of the conclusions and follow-up] of [an unexplained discrepancy] [a failure of a lot or unit to meet any of its specifications]. Specifically,***
#3 9225 29 606.171 Failure to submit a biological product deviation report [within 45 days from the date you acquired information suggesting that a reportable event occurred]. Specifically, ***
12th Annual FDA & the Changing Paradigm for Blood Regulation – 01/16/2009 – Las Vegas, NV – Gilliam B. Conley 6
Top 10 Blood & Blood Component Observations FY-2008 (Oct. ’07 through Sept. ’08) - continued
Cite ID Count 21 CFR… Text (abbreviated)
#4 31 26 606.20(b) Personnel…to assure competent performance of their assigned functions, and to ensure that the final product has the safety, purity, potency, identity and effectiveness it purports or is represented to possess.
#5 4425 23 606.60(a) Equipment…to assure that it performs in the manner for which it was designed.
#6 160 19 606.160(a)(1) Records…so as to provide a complete history of work performed.
12th Annual FDA & the Changing Paradigm for Blood Regulation – 01/16/2009 – Las Vegas, NV – Gilliam B. Conley 8
Inspection Classification – FY-2008
Blood Banks Source Plasma
NAI 743 107
VAI 243 50
OAI 13 1
Note: These numbers represent a snapshot in time from our inspections database. Because of the further routine review following an investigator’s initial recommendation for an OAI inspection decision, the year-end actual numbers are fewer than the 14 reported here.
12th Annual FDA & the Changing Paradigm for Blood Regulation – 01/16/2009 – Las Vegas, NV – Gilliam B. Conley 24
Donors who subsequently test positive for viral marker
FY-’05 FY-’06 FY-’07
Lookback; Subsequent
unit confirmed pos (MI-02) – total:
495 608 1,367
HIV (MI-02-02) 92 99 210
HBV (MI-02-03) 50 90 344
HCV (MI-02-04) 333 372 708From FY-2007 annual BPDR summary reportBlood Safety Team (BST) reviewed rising numbers of reportsBST requested additional information from several manufacturersRise appears to be the result of
>Altered reporting patterns after the October, 2006 final Guidance published Biological Product Deviation Reporting for Blood and Plasma Establishments >Rising numbers of collections – especially in Source Plasma centers
BST will continue to monitor these seroconversion rates