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Someone recently tried to tell me there were only 4 laboratories approved by the FDA for screening and testing ovum donors for infectious diseases.  I say this is just good marketing on those 4 lab’s part.  From my reading of 21 CFR 1271 it looks to me as though the FDA only specifies that the kits used by the testing facility must be FDA cleared for that test and that the testing be done in a CLIA-certified lab.  So, in other words, if the tests are being done in a CAP-inspected lab and the tests are FDA-cleared, any lab should be able to screen the blood.  Is this correct?
 
Draft Guidance for Industry: Use of Nucleic Acid Tests to Reduce the Risk of Transmission of West Nile Virus from Donors of Whole Blood and Blood Components Intended for Transfusion and Donors of Human Cells, Tissues, and Cellular and Tissue-Based Products (HCT/Ps)
Posted: 4/25/2008

Answer

A Section 1271.80 (c) requires only two items 1) that FDA-approved or cleared donor screening tests are used and 2) that the tests are performed "by a laboratory that either is certified to perform such testing on human specimens under the Clinical Laboratory Improvement Amendments of 1988" or has met equivalent requirements as determined by CMMS. Section 1271.1 of the regulations states that if you "manufacture" donor tissue you must be registered. The definition of "manufacturer" in Section 1271.3 (e) includes if you do ANY of the following: recovery, processing, storage, labeling, packaging, distribution, screening or testing. One portion of Good Tissue Practices (GTP; Subpart D (1271.150(c))) that applies to reproductive tissue states that we must ensure that any group we contract with to perform any steps (like testing) also complies with the GTP requirements. This means that in addition to the two required items above, we must also make sure the laboratory is FDA registered and we should also regularly audit these companies and make sure that we have contracts with them stating that they will only use the proper FDA approved tests in the approved manner.

 

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