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FDA’s Criteria for Evaluation of Red Blood Cell Products
Ping He, M.D.Medical Officer
Blood Products Advisory Committee91st Meeting, May 1, 2008
Rockville Pike, Rockville, MD
2
ISSUE SUMMARY
FDA seeks the advice of the Committee on an industry proposal to change the current acceptance criteria for evaluation of red blood cell (RBC) studies based on in vivo radiolabeling recovery trials.
3
Key Issue – Should the RBC in vivo Recovery Threshold Value be Changed?
1. Threshold value ( ≥75%) for RBC recovery study serves as a cutoff line for determining the RBC viability of a unit during the evaluation of RBC in vivo recovery studies.
2. Industry believes, based on historical data, that the overall RBC recovery studies from 1990 to 2006 would not meet the FDA’s current acceptance criteria unless the threshold value is changed from ≥75% to ≥67%.
non-viable
viable
≥ 75%
Threshold value
3. In contrast, based on more recent data FDA believes that RBC products are improving. During the period 1998-2007, 17/19 RBC recovery studies met the current criteria. Therefore FDA maintains that the threshold value of ≥75% should not be changed.
viable
≥ 67%non-viable
Threshold value
4
RBC Products Play an Important Role in Transfusion Medicine
RBCs are life saving products that deliver oxygen to tissues
~14 million units of whole blood collected/year, > 38,000 units RBC product needed daily
There is no available substitute for RBC products.
5
RBC Product Manufacturing Causes a “Storage Lesion”
Red Blood Cells (RBCs)• Anticoagulants • Additive Solutions• Stored at 1-6oC• Shelf life of 42 days
Any preservation or manipulation can induce RBC membrane damage producing changes in the biochemical properties of RBCs and shortening their in vivo survival
6
↓ RBC viability(shortens time in circulation)
• reduce oxygen delivery to tissue• damaged RBCs may saturate macrophage clearance mechanisms & reduce bacterial clearance
↓ ATP • correlates with reduced RBC viability
• decrease of tissue perfusion -↓vasodilation
↓ 2,3-DPG • reduce oxygen delivery to tissue
Cell membrane loss
• makes RBCs rigid, increases spontaneous
lysis, decreases microvascular flow
↑ Hemolysis • harmful effects on organ function
(renal toxicity)
↑ Plasma K+ • potential hazard to neonates (arrhythmias)
Potentially Harmful Effects of the RBC Storage Lesion
Mollison, 2005; Hess et al. Transf, 2001; Nishiyama et al, Can J Anesth, 2000
7
42d
FDA Recommended Tests on Approval/Clearance of
Stored/Processed RBC Products
RBC in vitro tests are used as screening tests:
In vitro tests are not predictive of in vivo RBC performance
non-viable
New bag
~20 mL Radiolabeled RBC
viable
24-hr RBCin vivo recovery
8
• In vivo RBC recovery at 24 hours provides a surrogate endpoint for RBC product evaluation
• To demonstrate the safety and effectiveness of novel RBC collection and processing systems
FDA Recommended Tests on Approval/Clearance of Stored/Processed
RBC Products (contd.)
9
Comparison of RBC in vivo Recoveries with Different RBC Storage Periods (Mollison 1951)
The longer the storage, the poorer the RBC survival and recovery.
24-h
≥ 75% RBC recovery at 24 hours is the threshold value for an individual unit
viable
≥ 75%
Threshold value
non-viable
10
FDA Acceptance Criteria for Evaluation ofIn vivo RBC Studies – Historical Review
At least 20 volunteers, At least 2 sites
Year instituted
Criteria Rationale Forms of communication
1985 M ≥ 75% Historical data & expert opinion
FDA workshop on red cells stored in AS, Apr. 25, 1985
1998 M ≥ 75%SD ≤ 9%
Industry requested
Decision based on historical data
2004 (current criteria)
M ≥ 75%SD ≤ 9%Proportion of units with recovery ≥75% with a one sided 95% LCL >70%
Ensure the proportion successes
- Decision based on Historical data - BPAC, 2004- Pre-meetings with regulated industry - DIA meeting, 2005
...75%
11
RBC Product Approvals/Clearances Since 2004
Majority of the submissions to FDA in this time period passed the current criteria.
Those that did not meet the current criteria also failed the previous mean and SD criteria.
12
Maintenance of Quality for New RBC Products
Reduction in the approval/clearance criteria would allow RBCs with a more severe storage lesion on the market which may correlate with a poorer clinical outcome
13
The Association Between Duration of Storage of Transfused Red Blood Cells and Morbidity/Mortality
After Reoperative Cardiac Surgery Basran et al, Anesthesia & Analgesia. 2006
There is an association between prolonged RBC storage and adverse clinical outcomes such as mortality and organ failure (retrospective analysis)
In-h
osp
ital
mo
rtal
ity
Acu
te r
enal
dys
fun
ctio
n
14
Duration of Red-Cell Storage and Complications after Cardiac Surgery
Koch et al, N Engl J Med 2008
15
Reasons to Revise the in vivo RBC Recovery Acceptance Criteria
Study nMean
%SD %
# of units with recovery < 75%
One sided 95% LCL forproportion of units having
recovery ≥75%
Study A
24 78.3 9.0 8 47.9%
Study B
21 77.6 7.4 5 56.3%
Study C
21 81.3 6.5 2 72.9%
The high failure rate of individual units in studies A and B raised concerns about the quality of RBC products and led the FDA to consider revising the criteria.
Study A
40
50
60
70
80
90
100
22%
24
-hr
RB
C r
ec
ov
ery
24-hrs after transfusion
M SD75
Study C
40
50
60
70
80
90
100
22
% 2
4-h
r R
BC
re
co
ve
ry
24-hrs after transfusion
M SD75
40
50
60
70
80
90
100
22
Study B
M SD
% 2
4-h
r R
BC
re
co
ve
ry
24-hrs after transfusion
75
17
Population Proportion of Successes: “95-70 Rule”
To ensure that most (> 70%) products have >75% RBC recovery a new criterion was introduced:
With a one-sided 95% LCL, proportion of units with RBC recovery >75% is >70%.
To meet this “95-70 rule”, a specific number of maximum failures are allowed in a study:
Sample sizeNumber of units with
recovery < 75%
With a one-sided 95% LCL, proportion of units with
RBC recovery ≥ 75%
20 2 72%
24 3 71%
28 4 70.2%
33 5 70.8%
18
Key Issue
Should the RBC in vivo recoverythreshold value of >75%
be changed?
19
Threshold value of
RBC recovery
1990~1997 (n = 140)
1998~2003 (n = 376)
2004~2007 (n = 173)
SuccessRate
PowerN = 24
SuccessRate
PowerN = 24
SuccessRate
PowerN = 24
≥ 75% 0.836 0.43 0.883 0.69 0.931 0.92
≥ 74% 0.864 0.58 0.891 0.74 0.942 0.95
≥ 73% 0.886 0.71 0.926 0.90 0.948 0.97
# of studies meeting current criteria
4 of 8 9 of 11 8 of 8
FDA Analysis of Combined BEST & FDA Data Sets in Different Time Periods from 1990 to 2007
N = 689 (595 + 94)
Note: studies 40 and 41 were not included due to lack of information of study year
Power = probability of successful study
20
Observations of the Combined Data Analysis
Overall the quality of RBC products approved or cleared by FDA is improving with time.
Most recent (2004-2007) RBC studies submitted to FDA passed the higher standard (“95-70 rule”) with a power of 0.92 with the threshold of ≥75%.
It is known that most clinical studies performed to satisfy FDA criteria for drugs are powered at 0.80.
21
Observations of the Combined Data Analysis(continued)
Threshold value of ≥75% has provided a standard of RBC quality evaluation over the last 24 years. The current criteria assure that most of the RBC products (>70%) have a recovery ≥75%.
Based on these considerations, FDA proposes to continue applying the criteria adopted in 2004 (“95-70 rule”) to the quality evaluation of RBC products using in vivo radiolabeling studies.
22
Questions to the Committee
1. Does the Committee agree with FDA's proposal to maintain the current criteria?
{The current criteria are: Radiolabeling studies should be performed in at least two separate centers (laboratories) with a total of 20-24 healthy donors. The mean recovery at 24 hours for each unit should be >75% with SD <9%; and the one sided 95% lower confidence limit for the population proportion of successes >70% (successes = individual units recovery >75%)}.
2. Alternatively, does the Committee recommend that a change in the criteria is needed based on the data?
23
Questions to the Committee (contd.)
3. If the answer to question 2 is yes, what changes does the Committee recommend for the threshold value of individual subject RBC in vivo recovery, with a sample size of 24?
Examples to consider:
a) Based on combined data from 1998-2007, with >74% as the threshold value, power = 0.82
b) Based on combined data from 1998-2007, with >73% as the threshold value, power = 0.93
c) Based on BEST data from 1990-2006, BEST recommends 67% as the threshold value, power = 0.999
24
Acknowledgements
FDA:Jessica KimTie-Hua NgPeter LachenbruchGhanshyam GuptaHenry HsuBetsy PoindexterJaro VostalBasil Golding
BEST:Larry J. DumontJames P. AuBuchon