Current state of Health Canada regulation for cellular and gene therapy products: potential cures on the horizon.

We provide an overview of the regulatory framework, pathways and underlying regulatory authority for cell, gene and tissue-engineered therapies in Canada. Canada's regulatory approach uses three sets of regulations, namely, the Cells, Tissues and Organs Regulations, the Food and Drug Regulations and the Medical Devices Regulations. We provide an overview of each these sets of regulations as they apply to clinical investigation to post-market product lifecycle stages. Information is provided on the current sources of relevant Health Canada guidance documents. We highlight several regional success stories including Prochymal, a cell therapy product that achieved Canadian regulatory approval using the conditional marketing approval system. We also examine the perceived gaps in the Canadian regulations and how those gaps are being addressed by interactions between the government, stakeholders and international bodies. We conclude that the risk-benefit approach used by Health Canada for regulatory approval processes is sufficiently flexible to enable to development of novel cell and gene therapy products in Canada, yet stringent enough to protect patient safety.

Allograft for knee ligament surgery: an American perspective.

PURPOSE: Allografts are frequently use for ligamentous reconstruction at the knee. In the United States, tissue donation and distribution are highly regulated processes with thorough oversight from private and government entities. Allograft is widely available in the United States and allograft procurement is a large industry with varying procurement, sterilization, processing, and distribution procedures. It is important to understand allograft regulation and processing which may affect graft mechanical properties and biological graft integration. METHODS: English-language literature, United States government and regulatory agency statues pertaining to allograft procurement, distribution, and usage were reviewed and the findings summarized. RESULTS: During the processing of allograft, multiple factors including sterilization procedures, irradiation, storage conditions, and graft type all affect the biomechanical properties of the allograft tissue. Biological incorporation and ligamentization of allograft does occur, but at a slower rate compared with autograft. For ligamentous reconstruction around the knee, allograft offers shorter operative time, no donor-site morbidity, but has shown an increased risk for graft failure compared to autograft. CONCLUSION: This article reviews the regulations on graft tissue within the United States, factors affecting the biomechanics of allograft tissue, differences in allograft tissue choices, and the use of allograft for anterior cruciate ligament reconstruction and multiligamentous knee injury reconstruction. LEVEL OF EVIDENCE: V.

Organization model for allotransplantations of cryopreserved vascular grafts in Czech Republic.

The transplantation of fresh or cryopreserved vascular allografts in patients with a prosthetic graft infection or critical limb ischemia is necessary for their limb salvage and, in many cases, represents a lifesaving procedure. While transplantation of fresh allografts has a long history in the Czech Republic, the standard use of cryopreserved vascular allografts was introduced into the clinical practice in 2011 as a result of the implementation of EU Directive 2004/23/EC into national legislation (Human Cell and Tissue Act No. 296/2008 Coll.). The authors present an organizational model based on cooperation between the majority of Czech Transplant Centers with a tissue establishment licensed by the national competent authority. In various points, we are addressing individual aspects of experimental and clinical studies which affect clinical practice. Based on experimental and clinical work, the first validation of cryopreserved arterial and venous grafts for clinical use was performed between 2011 and 2013. The growing number of centers participating in this programme led to a growing number of patients who underwent transplantation of vascular allografts. In 2015 the numbers of transplanted fresh versus cryopreserved allografts in the Czech Republic were almost equal. Cooperation of the participating centers in the Czech Republic with the licensed Tissue Establishment made it possible to achieve a full compliance with the European Union Directives, and harmonized national legal norms and assured a high quality of cryopreserved vascular allografts.

A Cell Graft or a Drug? Legal and Practical Aspects of Somatic Cells Application in Graft-Versus-Host Disease Experimental Treatment: The Polish Experience.

INTRODUCTION: Allogeneic hematopoietic stem and progenitor cell (HSPC) transplantation and organ transplantation are well-established treatments for different conditions. Graft versus host disease (GvHD) is a major complication in both methods. There has been a rapid increase in the application of nonhematopoietic somatic cells, such as mesenchymal stem cells and regulatory T cells in GvHD experimental therapy. According to current European Union (EU) law, human cells intended for human application can be considered either as cell grafts or as advanced therapy medicinal products (ATMPs). OBJECTIVE, MATERIALS AND METHODS: The aim of the paper is an attempt to answer, based on GvHD experimental treatment data as well as existing EU and Polish law, whether cells cease to be cells (cell grafts) and becomes drugs (ATMPs); if yes, when; and what are the consequences of such situation both for patients as well as for physicians engaged in the treatment process in Poland. RESULTS AND DISCUSSION: Data analysis confirmed the interest in the experimental GvHD cell therapy. In the vast majority of analyzed cases the in vitro culture step in the cell preparation protocols has been foreseen. Therefore, the answer to title question was unambiguous-expanded cells are recognized in EU as ATMPs. In borderline cases, a scientific recommendation by the Committee for Advanced Therapies (CAT) of the European Medicines Agency (EMA) can play an important auxiliary role; however, it is currently neither required by Polish law nor legally binding in Poland.

Islet Xeno/transplantation and the risk of contagion: local responses from Canada and Australia to an emerging global technoscience.

This paper situates the public debate over the use of living animal organs and tissue for human therapies within the history of experimental islet transplantation. Specifically, the paper compares and contrasts the Canadian and Australian responses on xenotransplantation to consider what lessons can be learnt about the regulation of a complex and controversial biotechnology. Sobbrio and Jorqui described public engagement on xenotransplantation in these countries as 'important forms of experimental democracy.' While Canada experimented with a novel nation-wide public consultation, Australia sought public input within the context of a national inquiry. In both instances, the outcome was a temporary moratorium on all forms of clinical xenotransplantation comparable to the policies adopted in some European countries. In addition, the Australian xenotransplantation ban coincided with a temporary global ban on experimental islet allotransplantation in 2007. Through historical and comparative research, this paper investigates how public controversies over organ and tissue transplantation can inform our understanding of the mediation of interspeciality and the regulation of a highly contested technoscience. It offers an alternative perspective on the xenotransplantation controversy by exploring the ways in which coinciding moratoriums on islet allograft and xenograft challenge, complicate and confound our assumptions regarding the relationships between human and animal, between routine surgery and clinical experimentation, between biomedical science and social science, and between disease risks and material contagion.

Rapid development of tissue bank achieved by International Atomic Energy Agency (IAEA) Tissue Banking Programme in China.

Before 1986, the development of tissue banking in China has been slow and relatively uncoordinated. Under the support of International Atomic Energy Agency (IAEA), Tissue Banking in China experienced rapid development. In this period, China Institute for Radiation Protection tissue bank mastered systematic and modern tissue banking technique by IAEA training course and gradually developed the first regional tissue bank (Shanxi Provincial Tissue Bank, SPTB) to provide tissue allograft. Benefit from training course, SPTB promoted the development of tissue transplantation by ways of training, brochure, advertisement and meeting. Tissue allograft transplantation acquired recognition from clinic and supervision and administration from government. Quality system gradually is developing and perfecting. Tissue allograft transplantation and tissue bank are developing rapidly and healthy.

Organ procurement and transplantation network. Final rule.

: HHS is issuing this final rule (herein referred to as ``this rule'') to add vascularized composite allografts (VCAs) as specified herein to the definition of organs covered by the rules governing the operation of the Organ Procurement and Transplantation Network (OPTN) (herein referred to as the OPTN final rule). When it enacted the National Organ Transplant Act in 1984, Congress included a definition of the term organ and authorized the Secretary to expand this definition by regulation. The Secretary has previously exercised this authority and expanded the statutory definition of organ. Prior to this rule, the OPTN final rule defined covered organs as ``a human kidney, liver, heart, lung, or pancreas, or intestine (including the esophagus, stomach, small and/or large intestine, or any portion of the gastrointestinal tract). Blood vessels recovered from an organ donor during the recovery of such organ(s) are considered part of an organ with which they are procured for purposes of this part if the vessels are intended for use in organ transplantation and labeled `For use in organ transplantation only.' '' This rule also includes a corresponding change to the definition of human organs covered by section 301 of the National Organ Transplant Act of 1984, as amended (NOTA).

Allocation of vascularized composite allografts: what is it?

To date, there are more than 80 reports of vascularized composite allografts (VCAs; a.k.a. composite tissue allotransplantation). However, the classification of this type of transplantation for oversight purposes has not been clarified. From a biological and regulatory perspective, we propose that VCA retrieval and transplantation is akin to organ transplantation and should be incorporated into the organ oversight structure. As VCA becomes more of a clinical reality, the need for a methodical approach to allocation and access to more donors will develop. Such an allocation system will likely incorporate parameters that deviate from those used for organ transplantation. To develop an effective and balanced system, the use of existing regulatory agencies that oversee solid organs should provide the maximum benefit to the patients and the society.

Reported infections after human tissue transplantation before and after new Food and Drug Administration (FDA) regulations, United States, 2001 through June, 2010.

Processors distributed about 1.5 million human tissue allografts in the U.S. in 2007. The potential for transmitting infections through allografts concerns clinicians and patients. In 2005, FDA implemented Current Good Tissue Practice (CGTP) rules requiring tissue establishments to report to FDA certain serious infections after allograft transplantations. We describe infection reports following tissue transplants received by FDA from 2005 through June, 2010, and compare reporting before and after implementation of CGTP rules. We identified reports received by FDA from January 2001 through June, 2010, for infections in human tissue recipients, examining the reports by tissue type, organism, time to onset, severity, and reporter characteristics. Among 562 reports, 83 (20.8/year) were received from 2001-2004, before the CGTP rules, 43 in the 2005 transition year, and 436 (96.9/year) from 2006 through June, 2010, after the rules. Tissue processors accounted for 84.2% of reports submitted after the rules, compared to 26.5% previously. Bacterial infections were the most commonly reported organisms before (64.6%) and after (62.2%) the new rules. Afterward, 2.5% (11) of reports described deaths, and 33.7% (147) involved hospitalizations. Before the rules, 13% (11) described deaths, and another 72% involved hospitalizations. Reports received by the FDA quadrupled since 2005, suggesting that CGTP regulations have contributed to increased reporting and improved tissue safety surveillance. However, these data do not confirm that the reported infections were caused by suspect tissues; most reports may represent routine post-surgical infections not actually due to allografts.

Custom, contract, and kidney exchange.

In this Essay, we examine a case in which the organizational and logistical demands of a novel form of organ exchange (the nonsimultaneous, extended, altruistic donor (NEAD) chain) do not map cleanly onto standard cultural schemas for either market or gift exchange, resulting in sociological ambiguity and legal uncertainty. In some ways, a NEAD chain resembles a form of generalized exchange, an ancient and widespread instance of the norm of reciprocity that can be thought of simply as the obligation to "pay it forward" rather than the obligation to reciprocate directly with the original giver. At the same time, a NEAD chain resembles a string of promises and commitments to deliver something in exchange for some valuable consideration--that is, a series of contracts. Neither of these salient "social imaginaries" of exchange--gift giving or formal contract--perfectly meets the practical demands of the NEAD system. As a result, neither contract nor generalized exchange drives the practice of NEAD chains. Rather, the majority of actual exchanges still resemble a simpler form of exchange: direct, simultaneous exchange between parties with no time delay or opportunity to back out. If NEAD chains are to reach their full promise for large-scale, nonsimultaneous organ transfer, legal uncertainties and sociological ambiguities must be finessed, both in the practices of the coordinating agencies and in the minds of NEAD-chain participants. This might happen either through the further elaboration of gift-like language and practices, or through a creative use of the cultural form and motivational vocabulary, but not necessarily the legal and institutional machinery, of contract.

Evolving practice of the Helsinki Skin Bank.

The purpose of this study is to review the management and running of the Helsinki Skin Bank between the years 2001 and 2008. Further aims were to assess the microbiological safety of the glycerol-preserved allograft skin and analyse its clinical use. The files of the Helsinki Skin Bank were reviewed for allograft skin harvested from organ donors between 2001 and 2008. Data on harvested skin area and microbiological culture results were collected. The patients receiving allograft were also identified and operation indications analysed. Allograft skin was collected from 115 donors, with a mean of 44,335 cm(2) per year. No skin batches were discarded. Microbiological cultures of the allograft skin batches were negative in 86 (75%) cases. Thirty-five donor skin batches were used in 69 operations. The most common indication was 'Biological dressing on partial-thickness burns', comprising 52% of cases. The cost per cm(2) was 0.81euro. The use of allograft skin in the Helsinki Skin Bank is microbiologically safe and continues to provide a versatile and useful treatment modality in many major burn cases with few observed complications. As compared with synthetically produced temporary dressings currently available, our allograft skin is also more economical.

Musculoskeletal allograft risks and recalls in the United States.

There have been several improvements to the US tissue banking industry over the past decade. Tissue banks had limited active government regulation until 1993, at which time the US Food and Drug Administration began regulatory oversight because of reports of disease transmission from allograft tissues. Reports in recent years of disease transmission associated with the use of allografts have further raised concerns about the safety of such implants. A retrospective review of allograft recall data was performed to analyze allograft recall by tissue type, reason, and year during the period from January 1994 to June 30, 2007. During the study period, more than 96.5% of all allograft tissues recalled were musculoskeletal. The reasons underlying recent musculoskeletal tissue recalls include insufficient or improper donor evaluation, contamination, recipient infection, and positive serologic tests. Infectious disease transmission following allograft implantation may occur if potential donors are not adequately evaluated or screened serologically during the prerecovery phase and if the implant is not sterilized before implantation.

[Logistics and European laws on allogeneic tissue transplantation]. / Logistik und europäische Gesetze für allogene Gewebetransplantate.

European rules stipulate quality and safety requirements on recruitment, testing, preserving, and distributing human tissues for application in patients in order to obtain a high level of health safety. In order to avoid transmissible diseases in tissue transplantation, specific requirements for all individual groups of tissues of human origin were defined. European Member States need to implement these directives in order to obtain a high level of health protection in human application. Precise instructions for tissue institutes regarding organization, management, documentation, and quality controls are required. Adverse effects have to be registered by these institutions. Costs need to be contained and therefore uniform administrative directives will engineer the modern techniques of communication. A uniform European code is needed for easy traceability of human tissues. The directive respects the basic human rights as laid down in the Charter of Fundamental Rights of the European Union.

Regulatory challenges in manufacturing of pancreatic islets.

At the present time, transplantation of pancreatic islet cells is considered an experimental therapy for a selected cohort of patients with type 1 diabetes, and is conducted under an Investigational New Drug (IND) application. Encouraging results of the Edmonton Protocol published in the year 2000 sparked a renewed interest in clinical transplantation of allogeneic islets, triggering a large number of IND applications for phase I clinical trials. Promising results reported by a number of centers since then prompted the Food and Drug Administration (FDA) to consider the possibility of licensing allogeneic islets as a therapeutic treatment for patients with type 1 diabetes. However, prior to licensure, issues such as safety, purity, efficacy, and potency of the islet product must be addressed. This is complicated by the intricate nature of pancreatic islets and limited characterization prior to transplantation. In this context, control of the manufacturing process plays a critical role in the definition of the final product. Despite significant progress made in standardization of the donor organ preservation methods, reagents used, and characterization assays performed to qualify an islet cell product, control of the isolation process remains a challenge. Within the scope of the FDA regulations, islet cells meet the definition of a biologic product, somatic cell therapy, and a drug. In addition, AABB standards that address cellular therapy products apply to manufacturing facilities accredited by this organization. Control of the source material, isolation process, and final product are critical issues that must be addressed in the context of FDA and other relevant regulations applicable to islet cell products.

[Philosophical and ethics aspects of the composite tissues allotransplantations (CTA)]. / Aspects éthicophilosophiques des allotransplantations de tissus composites (ATC).

The first successes of total hand and partial face transplants raise several philosophical and ethical questions. This paper examines the perspective of the recipient, the donor and the social aspect. The question of the identity remains unsolved. Philosophical point of view shows an historical continuity in the desire of the human being for improving his condition.

Decreasing latitude and increasing regulation in transplantable tissue programs.

ADVANCED TECHNOLOGY and improved surgical techniques have led to new therapeutic uses for allografts. DISEASE TRANSMISSION via allograft tissue transplants has prompted federal intervention in the tissue banking industry and resulted in federal regulations. NEW STANDARDS from the Joint Commission on Accreditation of Healthcare Organizations became effective July 1, 2005, and apply to all hospitals that store or implant allograft tissues. These standards include mandatory policies on all aspects of hospital transplantation programs, including tissue ordering, receipt, storage, issuance, and record keeping.