Medical Device Animal Source Guidance Explained

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CDRH Office of Compliance materials engineer Scott McNamee says a final guidance on the use of animal tissues in the manufacture of medical devices succeeds a 1998 guidance that gave the FDA understanding of how to address the risk to the public health from bovine spongiform encephalopathy (BSE). “Since 1998, a great deal has changed in our understanding of transmissible diseases and the impact on the medical device market in particular from the use of materials derived from bovine animals,” he told a 4/23 Webinar.

He said that a 2014 draft guidance was revised to provide clarity on the intersection between recognized standards in the guidance, what information should be documented in a premarket submission versus what information should be maintained in manufacturing facility records, and how to apply the Quality System regulation.

Three key differences between the final guidance and the 1998 version, McNamee said, were (1) the guidance now provides recommendations on viral pathogens and all transmissible spongiform encephalopathies and not just BSE; (2) the guidance outlines information needed related to the sourcing of animal materials and how that information should be provided and documented; and (3) the guidance recommends how viral inactivation studies should show the sum of log reduction of viral load within the steps of the manufacturing process that will lead to a safe product for the market.

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