CBER Presentation

FDA and Tissue Regulation

PDF version

Celia Witten, Ph.D., M.D.
Office Director, OCTGT, CBER, FDA

World Health Organization
June 7-9, 2006
Geneva, Switzerland


PATIENT SAFETY: EVERYONE'S GOAL

schematic of interactions between FDA, CDC, HRSA, healthcare facilities and providers, WHO, States, Tissue organizations


Outline

  • Development of FDA Regulations and Guidance
  • Working with Professional Organizations

LEGAL FRAMEWORK

  • Constitution
  • Statutes
  • Regulations
  • Guidance

STATUTES

  • Public Health Service Act
    • licensing provisions
    • prevent communicable disease
  • Federal Food, Drug and Cosmetic Act
  • Other Statutes
    • e.g. Administrative Procedure Act
    • Federal Advisory Committee Act

RULEMAKING AND POLICY: BASIS FOR REGULATORY DECISIONS

  • Rule-" an agency statement of general or particular applicability and future effect designed to implement, interpret, or prescribe law or policy"
  • Has binding effect
  • We create rules under statutory authorities (PHS Act and FDC Act)

GOOD GUIDANCE PRACTICES
(Title 21 Code of Federal Regulations (CFR) 10.115(a))

  • GGP's are FDA's policies and procedures for developing, issuing, and using guidance documents
  • Purpose-to make our procedures clear to public
  • Regulated persons may chose an alternative approach that complies with laws and regulations

GOOD GUIDANCE PRACTICES
What is a Guidance Document? (21 CFR 10.115(b))

  • A document prepared for FDA Staff, applicants/sponsors, and public that:
    • Describes FDA's interpretation of or policy on a regulatory issue; or
    • Relates to
      • The design, production, labeling, promotion, manufacturing, and testing of regulated products;
      • The processing, content, and evaluation or approval of submissions; and
      • Inspection and enforcement policies

Tissue Rules

  • 21 CFR Part 1270 - Human Tissue Intended for Transplantation
  • 21 CFR Part 1271- Human Cells, Tissues, and Cellular and Tissue-Based Products

TISSUE GUIDANCE

  • Guidance for Industry: MedWatch Form FDA 3500A: Mandatory Reporting of Adverse Reactions Related to Human Cells, Tissues, and Cellular and Tissue-Based Products (HCT/P's) - 11/30/2005

  •  
  • Guidance for Industry: Recommendations for Obtaining a Labeling Claim for Communicable Disease Donor Screening Tests Using Cadaveric Blood Specimens from Donors of Human Cells, Tissues, and Cellular and Tissue-Based Products (HCT/P's) 11/12/2004

  •  
  • Guidance for Industry: Validation of Procedures for Processing of Human Tissues Intended for Transplantation 3/8/2002

  •  
  • Draft Guidance for Industry: Eligibility Determination for Donors of Human Cells, Tissues, and Cellular and Tissue-Based Products (HCT/Ps) 5/20/2004

  •  
  • Draft Guidance for Industry: Preventive Measures to Reduce the Possible Risk of Transmission of Creutzfeldt-Jakob Disease (CJD) and Variant Creutzfeldt-Jakob Disease (vCJD) by Human Cells, Tissues, and Cellular and Tissue-Based Products (HCT/Ps) 6/14/2002

FDA is only one piece of the puzzle...


FDA / PROFESSIONAL ORGANIZATIONS

  • Public input and dialogue on FDA regulations and guidance
  • Professional standards
    • Can be referred in a guidance
    • How to comply with regulations
    • Areas not addressed by regulations or guidance

FDA/Professional Organizations: Communication

  • Liaison Meetings
  • Dissemination of FDA Policy
  • Communication by industry of issues of concern
  • Educational Programs
  • Public workshops
  • Participation at Public Advisory Committee Meetings

EXAMPLES

  • EBAA/AATB - Q's and A's on GTP's
  • FDA liaison membership on committees (AATB Standards Committee, Medical Advisory Committee, Reproductive Council, EBAA Medical Advisory Committee)
  • Participation in District Office Inspectors Training
  • ISCT/FDA workshop on Somatic Cell Therapy
  • Workshop participation (examples)
    • Human Bone Allograft: Manipulation and Homologous Use in Spine and Other Orthopedic Reconstruction and Repair (8/2000)
    • Unrelated Allogeneic Cord Blood Banking and Transplantation Forum (8/2000)
  • FDA Liaison to Unified Donor History Questionnaire Task Group

CONTACT INFORMATION

Celia Witten, PH.D., M.D.
Office Director, OCTGT
CBER/FDA
1401 Rockville Pike (HFM 700)
Suite 200N
Rockville, MD 20852-1448

Celia.witten@fda.hhs.gov

301-827-5102

 
Updated: June 14, 2006