Contact: Director General's Office
Health Canada
Health Products and Food Branch (HPFB)
Biologic & Genetic Therapies Directorate (BGTD)
Joint meeting of Expert Advisory Committee on Blood Regulations & Expert Advisory Committee - Cells, Tissues and Organs
Thursday, November 18, 2010
8:00 a.m. - 3:00 p.m. EST
The Hilton Lac-Leamy Hotel, 3 boulevard du casino
Gatineau, Québec
Members: Dr. Lindsay Nicolle, Chair EAC-BR (Winnipeg, MB); Dr. Joanne Embree (Winnipeg, MB); Dr. Marina Klein (Montreal, QC) (via teleconference); Dr. Bryce Larke (Edmonton, AB); Dr. Gail Rock(Ottawa, ON); Dr. Jacob Pendergrast (Toronto, ON); Dr. Mel Krajden (Vancouver, BC); Dr. Mohammad Qadura (Hamilton, ON); Dr. Sue Robinson (Halifax, NS); Dr. Alan Tinmouth (Ottawa, ON); Ms. Corinne Weernink, Chair, EAC-CTO, (London, ON); Dr. Martin Champagne (Verdun, QC); Dr. Bruce Light (Winnipeg, MB); Dr. Jolanta Karpinski (Ottawa, ON); Ms. Linda Wright (Toronto, ON); Ms. Penny Marrett (Toronto, ON); Mr. Sean Marguerrat (Halifax, NS) (via teleconference); Mr. Tumelo Mokoena (Edmonton, AB); Pastor Ian Robb (Milford, ON); Ms. Sandra White (St. John's, NL)
Health Canada and Public Health Agency Representatives:
Dr. Elwyn Griffiths, Director General, BGTD; Ms.Angela Briginshaw, Senior Executive Director, BGTD; Dr. Peter Ganz, Director, CBTE, BGTD; Dr. Francisca Agbanyo, Chief, BGTD; Ms. Liz Anne Gillham-Eisen, Manager, OPIC, BGTD; Ms. Karen Farrell, OPIC, BGTD; Ms. Lindsay Blaney, Director, OBIRM, BGTD; Ms. Alicia Li, BGTD; Ms. Geeta Daté, BGTD; Mr. Kyle Norrie, A/Manager, BGTD; Ms. Dorothy Corbett, BGTD; Dr Carole Légaré, Manager, MHPD; Dr. Marie Goulet, MHPD; Ms. Gita Nayeri, Manager, HPFBI; Ms. Jessica Halverson, Manager, PHAC
Presenters:
Dr. Margaret Fearon, Canadian Blood Services (CBS); Ms. Jennifer Biemans, CBS; Dr. Marc Germain, Héma-Québec; Mme Suzanne Rémy, Héma-Québec
Regrets:
Dr. Jun Wu, Associate Director, PHAC, Ms. Georgette Roy, BGTD.
Joint Morning Session
Presenter: Dr. Elwyn Griffiths, Director General, BGTD
Context: Information Update
Major Points: Dr. Elwyn Griffiths welcomed everyone to the first joint face to face meeting of the Expert Advisory Committee on Blood Regulations (EAC-BR) and Expert Advisory Committee on Cells, Tissues & Organs (EAC-CTO).
Presenter: Dr. Lindsay Nicolle, Chair
Context: Administrative
Major Points: Dr. Nicolle welcomed all participants to the first joint meeting of the EAC-BR and EAC-CTO. The agenda was approved.
Presenter: Dr. Lindsay Nicolle, Chair
Context: Administrative
Major Points: Dr. Larke, Dr. Krajden, and Dr. Champagne declared their affiliations with the Canadian Blood Services (CBS) and Héma-Québec (HQ). Dr. Rock declared her affiliation with the Canadian Apheresis Group. Dr. Pendergrast declared his affiliation with the Thalassemia Foundation of Canada. Ms. Weennink and Mr. Mokoena declared their possible conflict for the agenda item on composite tissue transplant. Dr. Larke declared his position as the chair of the Safety Advisory Committee for Héma-Québec as a conflict of interest for the agenda item on HIV-1 Group O. All members submitted their affiliations and interests in writing.
Presenter: Ms. Jessica Halverson, PHAC
Context: Information & Discussion
Major Points: Ms. Halverson presented key findings from the "HIV and AIDS in Canada: Surveillance Report to December 31st 2009".
In 2009, 2,417 HIV cases were reported in Canada, a decrease of 8.3% since 2008. When looking at the different risk exposures for HIV, men who have sex with men (MSM) was the leading risk exposure in Canada. This group accounted for 41.8% of all positive HIV cases reported in 2009 with known exposure category. The second most reported exposure category was heterosexual contact (30.7%). Injection drug use (IDU) was the third most frequently reported exposure category, representing 21.6% of HIV reports among adults in 2009.
From 1998-2009, HIV cases reported to PHAC revealed differences in HIV exposure categories among different ethnic groups. Aboriginal people had the highest proportion of HIV reports attributed to injection drug use (60.3%). There were some questions on the geographical distribution of HIV infections in Aboriginal people. PHAC responded that it is very difficult to draw conclusions from the surveillance data because Ontario and Québec do not submit ethnic status information with HIV test reports. From the ethnic information available from other provinces, the Eastern provinces have relatively low levels of HIV in Aboriginal people. In the Western provinces, the highest levels of HIV incidence occurred in Aboriginal people in Saskatchewan.
Some questions were raised on the immigration trends from countries that are highly endemic for HIV infections. PHAC responded that there is publicly available data on different patterns of immigration trends; however, PHAC does not have access to information on the HIV status of immigrants. The surveillance data does not provide any information on whether an individual with HIV acquired the disease in the country of origin or after arrival in Canada. PHAC has implemented several enhanced surveillance systems to help monitor HIV prevalence and risk behaviors among some key populations; it hopes to expand these systems to additional populations, including people from HIV-endemic countries.
In response to a question on the undiagnosed HIV cases, PHAC commented that the surveillance data indicated that the highest proportion of undiagnosed cases occurred in the heterosexual contact category. The lowest proportion of undiagnosed cases occurred in the injection drug use and MSM categories.
Presenter: Dr. Peter Ganz, BGTD, Health Canada
Context: Information
Major Points: Dr. Ganz provided a comprehensive presentation on Health Canada's regulatory role and current policies for managing infectious agent transmission via blood transfusion and CTO transplantation.
The donor screening questions, including the MSM question, seek to identify prospective donors who have taken part in activities that have been identified as placing participants at higher risk of infections that are transmissible via blood, cells, tissues, and organs. In blood donations, a man who has had sex with another man even once since 1977 is indefinitely deferred. In the case of CTO donations, the MSM exclusionary criterion in Annex E of the CTO Regulations includes men who have had sex with another man in the preceding five years. Section 40 of the Regulations, Exceptional Distribution, allows for the use of CTOs (in the absence of any suitable CTO available) from donors with risk factors based on the judgment of the transplanting physician and with the informed consent of the recipient.
The major issues with changing the deferral period for the MSM indefinite deferral were discussed. Peer reviewed modelling studies published in the scientific literature indicated that if the deferral for MSM were relaxed from indefinite to 1, 5, or 10 years, the risk of transmission of HIV through blood transfusion would increase above the very low levels observed today. Epidemiological studies have shown that the MSM group has a higher prevalence than the general population for other infectious diseases that can be transmitted through blood for which screening tests are currently not available. In addition, although current nucleic acid based testing is highly sensitive and specific, it is not completely error free and there remains the possibility of false negative results.
The current policies on MSM deferral in other countries, including the United States and European Union, were presented. A comparison of Health Canada's current and future strategies for addressing infectious agent risks to blood safety was also provided.
A presentation on the "Freeman Case" was provided. The Freeman litigation, the Ontario Superior Court Decision by Justice Aitken, and some observations from the court case were discussed.
There were questions on the peer reviewed modelling studies that indicated an increased risk of transmission of HIV through blood transfusion if the MSM deferral were relaxed from indefinite to 1, 5, or 10 years. Health Canada stated that although the increase in risk demonstrated in these modelling studies is very small, blood recipients expect the regulatory authority to increase blood safety, not decrease it. In response to a question on any data to demonstrate that there is no threat to Canada's blood supply, Health Canada responded that CBS and HQ have not reported any shortages of labile blood components in Canada.
Presenter: Dr. Peter Ganz, CBTE, BGTD, Health Canada
Context: Information
Major Points: On June 10 -11, 2010, the Human and Health Services Advisory Committee on Blood Safety and Availability (HHS ACBSA) met to discuss the current Food and Drug Administration (FDA) policy on men who have sex with other men. Dr. Ganz presented on Health Canada's policy on MSM at this meeting.
An overview of the ACBSA's recommendations on the current donor deferral policies was presented. In summary, the ACBSA committee recommended that the current MSM deferral policy not be changed at this time.
Moderator: Dr. Lindsay Nicolle, Chair, EAC-BR
Context: Discussion and Recommendation
Major Points: The EAC-BR and EAC-CTO engaged in deliberations and discussed the following: does the recently published Canadian epidemiological data warrant a change to the donor screening criteria, particularly the current deferrals for MSM in blood and CTO donations?
The committees concluded that the latest available surveillance data are inadequate to support a change to the current MSM deferrals in blood and CTO donations. Therefore, both the EAC-BR and EAC-CTO recommended that the current MSM donor screening criteria in blood and CTO donations not be changed at the present time. The committees, however, acknowledged that there are limitations to the current screening questions in accurately and effectively identifying all potential high risk donations and limitations in available data with which to make an informed decision.
The EAC-BR and EAC-CTO made the following recommendations in order to better address this issue in the future and inform future discussions about potential changes:
Presenter: Dr. Peter Ganz, CBTE, BGTD, Health Canada
Context: Information, Discussion and Recommendation
Major Points: Dr. Ganz provided a detailed presentation on the risk management of the potential emerging infectious agent, Xenotrophic Murine Leukemia Virus Related Virus (XMRV).
In 2009, Lombardi et al, reported in Science the detection of XMRV DNA in 67% of persons suffering from chronic fatigue syndrome (CFS) compared with a 3.7% infection rate in healthy controls. However, subsequent reports from four independent groups of investigators have failed to find evidence of any association between XMRV and CFS. More recently, a study published in the journal Proceedings of the National Academy of Sciences, confirmed a linkage of Murine Leukemia Virus (MLV)-related virus gene sequences in patients with CFS showing positivity of 86.5% of CFS patients compared with 6.8% of healthy blood donors.
Currently, there is no direct evidence to support XMRV transmission through blood or CTOs. The potential risks of XMRV to blood recipients were extensively discussed. The various regulatory and operational measures that have been evaluated internally by Health Canada for managing potential XMRV risks were presented.
The results of preliminary studies on XMRV conducted by the Public Health Agency of Canada to determine evidence of infectivity of the virus in certain study cohorts were presented. The evidence to date does not prove a link between XMRV infection and CFS. But as a precautionary measure, CBS has chosen a passive deferral for individuals with CFS.
In conclusion, Health Canada raised the following questions to the EAC-BR and EAC-CTO for discussion:
On the CTO side, the EAC-CTO recommended the status quo at this time on this issue; no additional screening question needs to be added to the donor assessment questionnaire in relation to chronic fatigue syndrome.
A member expressed the concern that if future studies show that there is no link between XMRV and CFS, how much evidence is necessary to discontinue the passive deferral and allow these individuals to donate blood. Due to the controversial evidence surrounding the potential link between XMRV and CFS, a member mentioned the possibility of virus detection from laboratory contamination that resulted in false positives.
A member commented that international regulatory authorities should establish a consistent framework for the risk mitigation of emerging threats to the blood system.
In conclusion, the EAC-BR did not recommend any additional measures to be evaluated in Health Canada's current risk mitigation efforts in managing XMRV. However, the committee expressed interest in getting updates on this issue from Health Canada in the next meeting / teleconference.
Presenter: Dr. Lindsay Nicole, Chair EAC-BR
Context: Information
Major Points:
The joint morning session was adjourned at 12:15 pm.
EAC-CTO Break-out Session
Presenter: Ms. Corinne Weernink, Chair EAC-CTO
Context: Information and Approval
Major Points: The minutes of the EAC-CTO meeting of June 10, 2010 were approved. A member inquired if CBS had reached an agreement with the provinces regarding sharing personal identifier information contained within adverse reaction reports between provinces.
Action: Health Canada to inquire if Canadian Blood Services have reached an agreement with provinces regarding sharing of personal identifier information between provinces.
Ms. Weernink and Mr. Mokoena reiterated their possible conflict regarding the agenda item on composite tissue transplant.
Presenter: Ms. Gita Nayeri, HPFBI
Context: Information & Discussion
Major Points: Ms. Nayeri made a presentation on the CTO inspection process. The inspections of registered domestic establishments were initiated in August 2009 and it is anticipated that the first round of inspections will be completed by the end of 2011. The objective of Health Canada's inspections is to assess the compliance of CTO establishments with the CTO Regulations. All CTO establishments must be registered with Health Canada, with the exception of establishments that only retrieve, transplant or import directly for transplant (i.e. not for further distribution). To date, 112 domestic establishments, and 47 foreign establishments have registered with Health Canada. A list of registered establishments is available on Health Canada's website. The presentation also included Health Canada's compliance promotion activities which included: compliance education, regular communications with stakeholders, pre-inspection package, information sheets, etc.
Once all the Canadian registered establishments have been inspected, a final inspection program will be established that is the most appropriate for the product and the variability that exists within the types of establishments and their activities.
Committee Discussions: In response to a member's question on internal audits, Health Canada commented that establishments are required to conduct an internal audit every two years, document the results, maintain the documentation, and provide the documentation to an inspector upon request during an inspection.
Health Canada re-iterated that it is the joint responsibility of the establishments and Health Canada to keep the CTO Regulations current by providing pertinent proposals for change to the CSA Technical Committee, specifically on the sections of the CSA standard that are referenced in the CTO Regulations.
Presenter: Ms. Liz Anne Gillham-Eisen, BGTD
Context: Information
Major Points: Ms. Gillham-Eisen provided an update on the comments provided on the pertinent sections of the draft second edition of the CSA Standards by the EAC-CTO members at the June 10th 2010 meeting. Health Canada reviewed all the comments provided by the EAC-CTO and internal stakeholders, and submitted a final list of over fifty comments that were within Health Canada's mandate to the CSA. The CSA Technical Subcommittee will review the pertinent comments received during the public consultation period, and any accepted suggestions will be incorporated into the draft CSA Standards. Health Canada will inform the establishments as soon as the second edition of the CSA Standards is publicly available. The pertinent sections of the second edition of the CSA Standards that are referenced in the CTO Regulations will become part of the law.
Committee Discussions: In response to a question on providing comments to the CSA, Health Canada clarified that comments regarding the CSA Standards could be provided to the CSA at any time before and after the publication of the second edition. Health Canada strongly suggested that all establishments register their copy of the second edition of the CSA Standards. Every establishment who has registered its copy of the Standard would receive replacement pages to update the Standards, as further amendments are made. In this way the standards are kept current, and consequently the standards based CTO Regulations are kept current.
Presenter: Ms. Liz Anne Gillham-Eisen, BGTD
Context: Information & discussion
Major Points: Ms. Gillham-Eisen provided background information on composite tissue transplants, and sought the support of the EAC-CTO on Health Canada's proposal to regulate composite tissues for transplantation under the CTO Regulations as an organ for transplantation.
Composite tissue transplants are transplants that involve multiple tissues, for example, a hand would be constituted of skin, muscles, tendons, bones, cartilage, blood vessels, and nerves, in a single transplant. The similarities between composite tissue transplants and organ transplants were discussed. Similar to organs, the screening process must be completed and a specific recipient is identified while the donor is still in the intensive care unit (ICU). The source of composite tissue is deceased donors who have been declared neurologically dead, because the blood circulation must be intact into the retrieval surgery, at which time the tissue is perfused with perfusion solution. In order for the tissue to remain viable, there is only a matter of hours before the transplant procedure must take place. Composite tissue recipients must be on life-long anti-rejection therapy.
Currently under the CTO Regulations, composite tissue would meet the definition of tissue. Therefore, composite tissue would have to meet the regulatory requirements for tissues under the CTO Regulations. However, based on the process for composite tissue retrieval, it would be impossible to meet these requirements, specifically the donor testing requirements and bacteriological testing. Furthermore, it may be inappropriate for Health Canada to regulate retrieval and preparation for use stages of the transplant process as they fall under the practice of medicine.
Based on the source and level of processing, the more comprehensive provisions applying to tissues would effectively prevent transplantation of composite tissues, except under exception distribution. Therefore, Health Canada recommended that composite tissues be regulated under the provisions of the CTO Regulations specific to organs. However, this would apply to fresh allograft only. If in the future, the processing of composite tissue changes, allowing for the tissue to be cryopreserved and banked, more of the provisions specific to tissue may be applied.
Committee Discussions: In response to a question on the demand for composite tissue transplants in Canada, Health Canada commented that these transplants have not yet been done in Canada. This kind of transplant is done to mitigate serious trauma, however, a program has to be developed and ready to perform such transplants when the need arises. Currently, there are very few such programs in the United States and European Union. Even after a Composite Tissue Transplant Program is established, there will be only a few (1-2) transplants performed every year.
In response to a question on the use of diagnostic tests, Health Canada commented that as composite tissue transplant would follow the same requirements as organs, diagnostic tests will be appropriate to be used in serological testing.
Health Canada commented that unlike amendments to the CSA Standards, which can be completed within 6-8 months, regulatory amendments would require a couple of years to accomplish. Taking in consideration the small number of these transplants per year, as a reasonable solution, composite tissues will have to be released for transplant under exceptional distribution, until the appropriate regulatory amendment comes into force. A member recommended that in the interim, a definition of composite tissue should be added under the Organs Subset of the CSA Standards.
Action: Health Canada will submit a proposal for amendment to add the definition of composite tissues to the Organs Subset of the CSA Standards to the CSA.
The Committee supported Health Canada's proposal to regulate composite tissues for transplant under the provisions of the CTO Regulations specific to organs.
Presenter: Dr. Peter Ganz, CBTE, BGTD, Health Canada
Context: Information & Discussion
Major Points: Dr. Ganz provided an update on the challenges and opportunities of cell therapies (stem and somatic cells).
Cell therapies are clinical interventions designed to modify biological processes in human subjects. While there is tremendous potential for alleviating a wide spectrum of diseases, these therapies carry a high risk potential. Currently, there are no CSA Standards for cell therapies that could be used as guidance for recommended practices for establishing quality or safety standards. Health Canada and BGTD's efforts are directed to providing a suitable regulatory oversight for cell therapies that protects the public and fosters innovative research and clinical work in this area for Canadian patients who may derive benefits from these therapies.
The existing regulatory framework for cell therapies in Canada is complex, involving the National Stem Cell Oversight Committee of the Canadian Institute for Health Research (CIHR) to cover "research" and our existing federal legislation including Food and Drugs Act & Regulations, the CTO Regulations and the Guidance documents as well as the Canadian Human Assisted Reproduction Act, covering some of the research and many aspects of commercialization of the technology.
The concerns and challenges regarding stem cell technologies recognized by the scientific community and regulators were discussed. Health Canada has consulted with stakeholders in various meetings in 2010 to address some of the issues in regulating cell therapies. These issues included: 1) need for further guidance for activities governed under the CTO Regulations and the Food and Drugs Act; 2) development of standards or regulatory guidance documents; 3) addressing the transition between research or proof of concept work and clinical trials; 4) Health Canada's regulatory role and international collaborations.
There has been some feedback from the Stem Cell Network that consideration should be given to the development of the Good Manufacturing Practices (GMP) Guidance for Stem Cells. The CIHR Stem Cell Oversight Committee would like to work closer with BGTD to assist with a major revision to their 2003 Guidance Document to clarify regulatory requirements for researchers and clinicians.
BGTD's activities on cell therapies were presented. This included the establishment of an internal steering committee and working group on cell therapies, as well as a Cell Therapies Workshop in Ottawa which will be held December 2010.
Action: Health Canada will provide updates from the Cell Therapies Workshop to the EAC-CTO in future meetings.
The EAC-CTO concurred that the issues with cell therapies raised in the presentation need to be addressed. The Committee agreed that the Cell Therapies Workshop would be a good venue to discuss these issues.
Presenter: Ms. Corinne Weernink, Chair, EAC-CTO
Context: Information
Major Points:
The joint morning session was adjourned at 2:45 pm.