Effective 2010-05-25
ISBN: 978-1-100-14645-4 (PDF Version)
Cat.: H164-118/2010E (PDF Version)
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Guidance documents are meant to provide assistance on how to comply with governing statutes and regulations. Guidance documents also provide assistance to staff on how Health Canada mandates and objectives should be implemented in a manner that is fair, consistent and effective.
Guidance documents are administrative instruments not having force of law and, as such, allow for flexibility in approach. Alternate approaches to the principles and practices described in this document may be acceptable provided they are supported by adequate justification. Alternate approaches should be discussed in advance with the relevant program area to avoid the possible finding that applicable statutory or regulatory requirements have not been met.
As a corollary to the above, it is equally important to note that Health Canada reserves the right to request information or material, or define conditions not specifically described in this document, in order to allow the Department to adequately assess the safety, efficacy or quality of a therapeutic product. Health Canada is committed to ensuring that such requests are justifiable and that decisions are clearly documented.
This document should be read in conjunction with relevant sections of other applicable guidance documents.
This guidance document provides source establishments with assistance on how to comply with adverse reaction reporting obligations under the Food and Drugs Act and the Safety of Human Cells, Tissues and Organs for Transplantation Regulations1 (these regulations are referred to hereafter as “the Regulations”). Error and accident reporting requirements for source establishments are also outlined in this guidance document in section 1.4.
The adverse reaction reporting requirements covered by this guidance document apply only to human organs and minimally manipulated cells and tissues intended for homologous use in transplantation in another individual.
This guidance document for the reporting of adverse reactions to human cells, tissues and organs (CTO) accompanies the Guidance Document for Cell, Tissue and Organ Establishments – Safety of Human Cells, Tissues and Organs for Transplantation2, which provides general guidance on all aspects of the Regulations1 to establishments that process, distribute, import or transplant CTO for homologous use in transplantation in another individual.
Other agencies, branches and/or directorates of Health Canada and certain Health Canada partners collect adverse reaction reports on other products. Appendix 4 provides further details on these other reporting programs.
Definitions for a number of terms used in this document are set out below. A complete glossary is included in Appendix 1.
“Adverse reaction” as defined in the Regulations1 means an undesirable response in the recipient to transplanted cells, tissues or organs, including the transmission of a disease or disease agent.
“Cell” as defined in the Regulations1 means the fundamental biological unit of a human organism that is for use in transplantation.
“Establishment” as defined in the Regulations1 means a person, a partnership or an unincorporated entity, or a part of any of them, that carries out any of the following activities in respect of cells, tissues or organs:
“Homologous” as defined in the Regulations1 in respect of a cell, tissue or organ, means that the cell, tissue or organ performs the same basic function after transplantation.
“Minimally manipulated” as defined in the Regulations1 means
“Organ” as defined in the Regulations1 means a perfusable human organ for use in transplantation, whether whole or in parts, and whose specific function is intended to return after revascularization and reperfusion. It includes any adjunct vessels that are retrieved with the organ for use in organ transplantation.
“Processing” as defined in the Regulations1 means, in respect of CTO, any of the following activities:
“Serious adverse reaction” as defined in the Regulations1 means an adverse reaction that results in any of the following consequences for the recipient:
“Source establishment” as defined in the Regulations1 means
“Tissue” as defined in the Regulations1, means a functional group of human cells for use in transplantation. It includes the cells and tissues listed in the definition “tissue” in section 3.1 of the general standard (see Appendix 1 for the definition of General Standard) except for paragraphs (g) and (l).
Pursuant to section 51(1)(b) of the Regulations1, unexpected serious adverse reactions that are thought to involve the transmission of an infectious disease or disease agent must be reported to the Marketed Health Products Directorate (MHPD) of Health Canada by source establishments.
For the definitions of “adverse reaction” and “serious adverse reaction”, refer to section 1.2 of this guidance document.
An unexpected adverse reaction following the transplantation of a CTO includes the unintended and unforeseen transmission of an infectious disease or disease agent, for example any bacterial, viral or fungal infection that is caused by a contaminated transplanted CTO. The laboratory identification of the implicated infectious disease agent does not need to have been confirmed in order to proceed with reporting if there is sufficient clinical evidence to suspect infectious disease transmission. It does not include the transmission of an infectious disease or disease agent where such transmission is expected.
For example, transmission of hepatitis C virus (HCV) from an HCV positive donor to an HCV negative recipient would not be an unexpected adverse reaction, as this would be an expected outcome resulting from the use of an HCV positive organ. In the case where the recipient develops HCV following transplantation of an organ that was not known to be HCV positive, such an outcome would be considered an unexpected adverse reaction.
In the case of organ transplantation where recipients are immunosuppressed, clinical presentation of infectious diseases may be atypical. In addition, transplantation as a mode of transmission of an infectious disease should not be ruled out, even if not documented in the literature, especially in the case of rare infectious diseases, as was demonstrated in the case of rabies in 20043,4.
All establishments are also required to notify other relevant establishments of unexpected adverse reactions in accordance with sections 47 to 49 of the Regulations1.
Pursuant to section 51(1)(a) of the Regulations1, suspected errors and accidents that are identified after the distribution of CTO and that could lead to a serious adverse reaction involving the transmission of an infectious disease or disease agent must be reported by source establishments to Health Canada’s Health Products and Food Inspectorate. Further information is available in the Guidance Document for Cell, Tissue and Organ Establishments – Safety of Human Cells, Tissues and Organs for Transplantation2.
An error, as defined in the Regulations1, means a deviation from the standard operating procedures or applicable laws that could adversely affect the safety of a transplant recipient or the safety, efficacy or quality of cells, tissues or organs. An accident, as defined in the Regulations1, means an unexpected event that is not attributable to a deviation from the standard operating procedures or applicable laws and that could adversely affect the safety of a transplant recipient or the safety, efficacy or quality of cells, tissues or organs.
All establishments are also required to notify other relevant establishments of errors or accidents in accordance with sections 43 to 46 of the Regulations1.
The sections of the applicable Regulations1 that set out the adverse reaction reporting requirements for CTO are listed below.
Scope of the Regulations1
2. These Regulations apply only to organs and minimally manipulated cells and tissues.
Non-application - various therapeutic products
3. (1) These Regulations do not apply to any of the following therapeutic products:
Required action
47. (1) Subject to subsection (2), an establishment that is not a source establishment and that has reasonable grounds to believe that an unexpected adverse reaction has occurred must immediately take all of the following steps:
Exception – importers
(2) If the establishment that receives a notice under subsection (1) is the establishment that imported the implicated cells, tissues or organs, it only has to notify the source establishment.
Contents of notice
(3) The notice must include all of the following information:
Written notice
(4) If the notice is given verbally, a confirmatory written notice must be sent as soon as possible afterwards.
Action by source establishment
48. (1) A source establishment that has reasonable grounds to believe that an unexpected adverse reaction has occurred that involves cells, tissues or organs for whose processing it is responsible must immediately take all of the following actions:
Contents of notice
(2) The notice must include all of the following information:
Action on receipt of notice
49. An establishment that is not a source establishment and that receives a notice under section 48 or a copy of such a notice under this section must immediately take both of the following actions:
Requirement to cooperate
50. An establishment must provide the source establishment that is conducting an investigation with any relevant information in its possession with respect to cells, tissues or organs that it distributed or transplanted.
Reports to Minister
51. (1) A source establishment that is conducting an investigation into either of the following subject-matters must provide the Minister with the reports described in subsection (2):
Contents and timing
(2) The reports must include the following information and be provided at the following times:
When investigation shows no contamination or compromise
52. (1) If the results of the investigation show that the implicated cells, tissues or organs are not contaminated or compromised, the source establishment must notify every establishment that was notified under section 44 or 48 to that effect in writing and that they may be released from quarantine.
Forwarding of copies of notice
(2) On receipt of a notice under subsection (1), an establishment that is not a source establishment must forward a copy of the notice to every establishment to whom it distributed implicated cells, tissues or organs.
When investigation inconclusive or shows contamination or compromise
53. (1) If the results of the investigation show that some or all of the implicated cells, tissues or organs are contaminated or compromised, or the results are inconclusive, the source establishment must notify every establishment that was notified under section 44 or 48 to that effect in writing and that they may not be released for distribution.
Forwarding of copies of notice
(2) On receipt of a notice under subsection (1), an establishment that is not a source establishment must forward a copy of the notice to every establishment to whom it distributed implicated cells, tissues or organs.
Final report to Minister
54. (1) On completion of an investigation, the source establishment must submit a detailed final report to the Minister that contains at least all of the following information:
the results of the investigation;
Summaries of final reports
(2) The source establishment must send a summary of the final report to every establishment that was notified under section 44 or 48.
Forwarding of summaries
(3) An establishment that receives a summary under subsection (2) must send a copy of it to every establishment to which it distributed implicated cells, tissues or organs.
Source establishment records
59. The source establishment must keep records with respect to cells, tissues and organs that it processes that contain at least all of the following information:
(h) documentation of any reported errors, accidents and adverse reactions and their investigation, if any, in connection with cells, tissues or organs retrieved from the donor that it banked or distributed and any corrective action taken.
Retention – 10 years after record creation
62. (2) An establishment must keep the following records for 10 years after the date of their creation:
In accordance with sections 51 and 54 of the Regulations1, source establishments conducting an investigation into an adverse reaction involving CTO for whose processing they are responsible, must submit to MHPD the following reports of unexpected serious adverse reactions that are thought to involve the transmission of an infectious disease or disease agent:
The preferred adverse reaction reporting format for source establishments is the:
Source establishments should assign a unique report number for each adverse reaction case reported to them.
Pursuant to section 51(2)(a) of the Regulations1, within 24 hours of the start of an investigation, the source establishment must report to MHPD all available information regarding the unexpected serious adverse reaction that is thought to involve the transmission of an infectious disease or disease agent. The information provided in this report could include, but is not limited to, the name of the suspected infectious disease and/or disease agent, the description of the CTO, the number of recipients potentially affected, and the identification code of the donor(s) (if known).
The source establishment should send to MHPD one reporting form for each recipient affected by the adverse reaction. Refer to section 3 of this guidance document for more information.
As required by section 51(2)(b) of the Regulations1, within 15 days after the start of the investigation and every 15 days after that until the final report is submitted, the source establishment must provide MHPD with an update on any new information about the unexpected serious adverse reaction, the progress made in the investigation during those 15 days, and the steps taken to mitigate further risks. This update should also include both clinical information (e.g., progress of patient, outcome of infection, if known, results of clinical investigation) as well as information regarding the identification of the root cause of the infection (e.g., source of contamination, how contamination was ruled out, actions taken).
On completion of the investigation, the source establishment must submit a final report to MHPD, as per section 54 of the Regulations1. The final report provided is to be detailed and is to indicate the results of the investigation; it should include conclusions, specify any infectious agent(s), results of any tests performed, follow-up and corrective actions taken, and details of the reconciliation of the CTO and their final disposition (number processed, distributed, transplanted, quarantined, destroyed).
The adverse reaction reporting requirements set out under section 51(1)(b) of the Regulations1 are connected to a series of risk mitigation steps that a source establishment is required to perform under section 48 of the Regulations1, when an adverse reaction is suspected to have occurred in relation to CTO for whose processing the source establishment is responsible. The Regulations1 require that the source establishment that discovers or suspects that an unexpected adverse reaction has occurred, must take steps as outlined in section 48 of the Regulations1 as follows:
In accordance with section 48(1)(a) of the Regulations1, all implicated CTO that a source establishment is responsible for processing must be quarantined. Quarantine will usually involve at least all CTO originating from the same donor. However, should the investigation uncover other potential causative factors, the quarantine may apply to other CTO as well.
In accordance with section 48(1)(b) of the Regulations1, the source establishment is also required to send a notice, as described in 48(2) of the Regulations1 (see also section 2.2.2.1 of this guidance document), to:
In accordance with section 48(2) of the Regulations1, the notice must include:
Pursuant to section 49 of the Regulations1, an establishment that is not a source establishment and that receives a notice or a copy of such a notice under section 48 of the Regulations1 must immediately:
In addition, in accordance with section 48(1)(c) of the Regulations1, the source establishment that discovers or suspects that an unexpected adverse reaction has been associated with a CTO must initiate an investigation into the adverse reaction. Section 51 of the Regulations1 further describes the investigation.
In accordance with sections 55 to 63 of the Regulations1, all source establishments must keep records with respect to CTO for whose processing they are responsible. A source establishment must maintain in these records documentation of any adverse reactions and their investigation and of any corrective action taken, for 10 years after the date of their creation (see sections 59(h) and 60(f)).
Source establishments should submit the completed Mandatory Adverse Reaction Reporting Form for Industry by facsimile to the Canada Vigilance national office at 613-957-0335 (see Appendix 3 of this guidance document). The Mandatory Adverse Reaction Reporting Form for Industry is available on the Health Canada Web site at: http://www.hc-sc.gc.ca/dhp-mps/medeff/report-declaration/ar-ei_indus_form-eng.php
The Mandatory Adverse Reaction Reporting Form for Industry contains specific instructions on how to complete the reporting form. Those instructions should be followed to avoid delays in the processing of the adverse reaction report.
In addition to the instructions provided on the reporting form itself, the following general guidance is also provided for source establishments when preparing an adverse reaction report for submission to MHPD.
Accident1
Accident means an unexpected event that is not attributable to a deviation from the standard operating procedures or applicable laws and that could adversely affect the safety of a transplant recipient or the safety, efficacy or quality of cells, tissues or organs.
Adverse Reaction1
Adverse reaction means an undesirable response in the recipient to transplanted cells, tissues or organs, including the transmission of a disease or disease agent.
Canada Vigilance Adverse Reaction Monitoring Program
Health Canada’s Canada Vigilance Adverse Reaction Monitoring Program is responsible for the collection and assessment of adverse reaction reports related to the following marketed health products: pharmaceuticals, biologics (including fractionated blood products, as well as therapeutic and diagnostic vaccines), natural health products, radiopharmaceuticals and cells, tissues and organs. Canada Vigilance is a program of MedEffect™ Canada and is operated by the Marketed Health Products Directorate.
Cell1
Cell means the fundamental biological unit of a human organism that is for use in transplantation.
Donor1
Donor means a living or deceased person from whom cells, tissues or organs are retrieved.
Donor Identification Code1
Donor identification code means the unique numeric or alphanumeric designation that is assigned by the source establishment to a donor under section 56 and that associates each cell, tissue and organ, or part of one, to that donor.
Donor Screening1
Donor screening means an evaluation based on the donor’s medical and social history and physical examination, the results of any diagnostic procedures performed, and, if applicable, the autopsy.
Error1
Error means a deviation from the standard operating procedures or applicable laws that could adversely affect the safety of a transplant recipient or the safety, efficacy or quality of cells, tissues or organs.
Establishment1
Establishment means a person, a partnership or an unincorporated entity, or a part of any of them, that carries out any of the following activities in respect of cells, tissues or organs:
General Standard1
General standard means National Standard of Canada CAN/CSA-Z900.1 entitled Cells, Tissues, and Organs for Transplantation and Assisted Reproduction: General Requirements, as amended from time to time.
Homologous1
Homologous, in respect of a cell, tissue or organ means that the cell, tissue or organ performs the same basic function after transplantation.
MedEffect™ Canada
MedEffect™ Canada has been developed by Health Canada's Marketed Health Products Directorate:
Minimally Manipulated1
Minimally manipulated means
Organ1
Organ means a perfusable human organ for use in transplantation, whether whole or in parts, and whose specific function is intended to return after revascularization and reperfusion. It includes any adjunct vessels that are retrieved with the organ for use in organ transplantation.
Package Insert1
Package insert means the document that is prepared by the source establishment to accompany a cell, tissue or organ.
Processing1
Processing, in respect of cells, tissues and organs, means any of the following activities:
Serious Adverse Reaction1
Serious adverse reaction means an adverse reaction that results in any of the following consequences for the recipient:
Source Establishment1
Source establishment means
Standard Operating Procedures1
Standard operating procedures mean the component of the quality assurance system that comprises instructions that set out the processes and procedures to follow in carrying out the activities of an establishment.
Tissue1
Tissue means a functional group of human cells for use in transplantation. It includes the cells and tissues listed in the definition “tissue” in section 3.1 of the general standard, except for paragraphs (g) and (l).
Transplant1
Transplant means to implant cells, tissues or organs into a recipient.
Safety of Human Cells, Tissues and Organs for Transplantation Regulations, SOR/2007-118.
Health Canada, Guidance Document for Cell, Tissue and Organ Establishments – Safety of Human Cells, Tissues and Organs for Transplantation, (2009). Available on the Health Canada Web site at: http://www.hc-sc.gc.ca/dhp-mps/brgtherap/reg-init/cell/cto_gd_ld-eng.php
CDC. Investigation of Rabies Infections in Organ Donor and Transplant Recipients — Alabama, Arkansas, Oklahoma, and Texas, 2004. MMWR. 2004;53:586–589.
Srinivasan A, Burton EC, Kuehnert MJ et al. Transmission of Rabies Virus from an Organ Donor to Four Transplant Recipients. N Engl J Med. 2005;352:1103-1111.
The preferred method of reporting adverse reactions related to CTO by source establishments is by fax. All adverse reaction reports should be sent to:
Canada Vigilance Program
Marketed Health Products Safety and Effectiveness Information Bureau
Marketed Health Products Directorate
Health Products and Food Branch
Health Canada
Tunney’s Pasture
Postal Locator: 0701E
Ottawa, Ontario
K1A 0K9
Telephone: 613-957-0337
Facsimile: 613-957-0335
E-mail: CanadaVigilance@hc-sc.gc.ca (do not send reports via e-mail)
Access to Information
For copies of adverse reaction reports, consult the
Access to Information Web site at http://www.tbs-sct.gc.ca/gos-sog/atip-aiprp/index_e.asp .
Health Canada and its partners collect adverse reaction reports in order to monitor health and safety risks related to the sale and use of a variety of products. In order to avoid delays in reporting, it is important to direct adverse reaction reports to the appropriate program area of expertise. Refer to the Web site and table below, which provide further information on adverse reaction reporting specific to other products that are not within the scope of this guidance document. All adverse reaction reports related to CTO should be sent to the Canada Vigilance national office (see Appendix 3 of this guidance document).
Adverse Reaction Reporting for Specific Products
Table 1: Adverse Reaction Reporting Programs