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Exploring the Risks of Contaminated Medical Products

Exploring the Risks of Contaminated Medical Products. MODERATOR : Susan R. Chmieleski, APRN, CPHRM, FASHRM, JD, Senior Vice President, Healthcare Product Manager & Risk Management Lead, Darwin Allied World PANELISTS: Clay Anselmo, President & Chief Executive Officer, Reglera

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Exploring the Risks of Contaminated Medical Products

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  1. Exploring the Risks of Contaminated Medical Products MODERATOR: Susan R. Chmieleski, APRN, CPHRM, FASHRM, JD, Senior Vice President, Healthcare Product Manager & Risk Management Lead, Darwin Allied World PANELISTS: Clay Anselmo, President & Chief Executive Officer, Reglera Scott Brubaker, CTBS, Chief Policy Officer, American Association of Tissue Banks Robert E. Jurgel, Jr., MBA, RPLU, Senior Vice President & Head of Healthcare Underwriting, ROCKHILL Underwriting Management Anthony Vale, Esq., Partner, Pepper Hamilton, LLP

  2. Industry Overview / Case Study Rob Jurgel, RPLUSenior Vice President - HealthcareROCKHILL Underwriting Management Chicago, Illinois ~ March 24 & 25, 2009

  3. What is an allograft? A graft of tissue or an organ taken from one individual (donor) and given to another individual (recipient).

  4. Organ Bank Industry 58 federally chartered banks (non profit) Matching Network – UNOS via Unet (1999) 25,628 Transplants, 12,934 Donors 6 Products – Kidney, Heart, Lung, Liver, Pancreas, Intestines Procurement - Transplant Centers – 253 Regulation – HRSA, AOPO - voluntary Morphing into Tissue

  5. Tissue Bank Industry 200+ Banks, 100 AATB Accredited 1.5 million grafts annually Hundreds of products Procurement– Hospitals, Universities, Funeral Homes, Morgues Regulation – FDA, AATB – accreditation is VOLUNTARY New Regulations- May 2005

  6. Tissue Processing & Distribution Identify & Screen Donors Obtain Informed Consent Recover Tissue Test, Process, Sterilize & Store Tissue Distribute Record Keeping

  7. Case Study - Video You’ll never look at Healthcare the same!

  8. Claims Fallout 1077 bodies harvested illegally 13,000 people have received tissue harvested illegally Recipient Cases: “Disease” “Disease Phobia” Donor Cases - Estate Multiple parties

  9. Laws, Regulations, and Litigation Anthony Vale, Esq. Partner, Pepper Hamilton, LLP Chicago, Illinois ~ March 24 & 25, 2009

  10. Allograft Basics Human bone, ligaments, valves, skin Each donor may provide 50-100 allografts Over 1 million musculoskeletal per year Obtained by “recovery agency” “Tissue bank” processes bone/tissue Distributor supplies to hospital/surgeon

  11. Three statutes: NOTA, “Blood Shield” and UAGA National Organ Transplant Act: human tissue may not be sold Tissue banks may charge “reasonable fees” for services Blood shield laws Anatomical Gift Act: who may give consent? May rely on facially valid documents

  12. Federal, some state regulations and AATB Federal regulations Require testing of donor for infectious disease and medical history No equivalent of FDA 510k State regulations May require inspection of facility AATB standards

  13. Tissue Processors Few major players Role: increase donations; use donations to maximize value; ensure safety Redundant safety measures: screening by recovery agency; blood test; sterilization or other processing

  14. Litigation Risks Widespread use of allograft High demand for donations Supply chain extended Processing practically eliminates risks of disease transmission Fear of disease? Potential claims by donors’ families

  15. Are Practices Safe? Scott Brubaker, CTBS Chief Policy Officer Chicago, Illinois ~ March 24 & 25, 2009

  16. How many Tissue Banks are there? Depends on what your definition is- FDA’s eHCTERs database for registered “Tissue Establishments” Query capabilities are flawed in some ways but it can be useful….depends what you need Expectations probably include Tissue Banks involved in the chain (consent/recovery, processing, distribution) leading to the most commonly distributed tissues

  17. Examples of Who Must Register - by Function Recover HCT/Ps, Screen HCT/P Donors Test Donors Process Package, Label, Store Distribute

  18. FDA’s HCT/P List* Bone (including demineralized bone), cartilage Ligaments, tendons, fascia, pericardium, dura mater Skin, amniotic membrane (when used alone, not for ocular repair) Arteries and veins (except umbilical cord veins, etc.) Heart valve allografts Semen, oocytes, embryos Ocular tissue (corneas and sclera) Hematopoietic stem/progenitor cells derived from cord blood *grouped by me

  19. Recover(active registrations, query 4-17-08)

  20. Process(active registrations, query 4-17-08)

  21. Process(active registrations, query 4-17-08)

  22. Distribute(active registrations, query 4-17-08)

  23. 2007 AATB Survey of Accredited Tissue Banks- Distribution

  24. State Requirements for Tissue Banks(Data circa 2007) • New York State Department of Health • 811 TBs licensed;191 located outside of NY • Florida Agency for Health Care Administration • 76 TBs licensed; 56 located outside of FL • California Health and Safety Code • 496 TBs licensed; 118 hold outside of licenses • Other permit, licensing, certification, programs • DE, DC, GA, IL, LA, MD, MI, OK, OR

  25. AATB Bulletin No. 08-5513 States listed & requirements differ http://www.aatb.org/files/staterequirementsforlicensure.pdf

  26. AATB & State Laws • AATB accreditation or certification of personnel is referenced in statutes/laws in >20 states

  27. Recommendations & AATB Accreditation • American Academy of Orthopaedic Surgeons • Policy: use tissue only from banks accredited by AATB. • American Burn Association • Require compliance with all federal, state, and JCAHO requirements, and recommend standards of the AATB. • Philadelphia Grand Jury Report (BTS investigation) • Recommendation requires all tissue agencies to be licensed by the state and accredited by the AATB should be required for a license • FDA’s Inspection Program • Tiered approach; use professional accreditation as a factor when stratifying TEs to inspect

  28. AATB’s Standards • 1st published in 1984 • AATB’s Standards have served as a model for: • FDA’s CGTP regulations • Health Canada’s Safety of Cells, Tissues and Organs Regulations & draft Guidance • New York DOH’s Tissue & Cell Standards • European Union Commission Directives • European Association of Tissue Banks Standards • British Association for Tissue Banking Standards • Spanish Association of Tissue Banks’ Standards • (ALaBaT) Latin American Association for Tissue Banks Standards (in development)

  29. AATB’s Standards are More Detailed than FDA Regulations • Standards require: • Medical Director makes all donor suitability (eligibility) determinations • Detailed consent requirements • Donor screening for risk/quality • Specific “quality” screening requirements • Detailed tissue recovery requirements • time limitations for recovery • technical recovery methods

  30. AATB’s Standards-More Detailed than FDA Regulations • Standards: • Donor reconstruction requirements • Archiving of a serum or plasma sample from every donor if any remains after testing • Process control endpoints related to quality • Specific tissue release criteria • More labeling & package insert controls, content • More personnel-related safety concerns • Must establish recipient follow-up data collection protocols

  31. 3rd Party Inspections AATB EBAA In general, state licensing & voluntary accreditation offers an enhanced level of satisfaction and safety since there exists 3rd-party scrutiny of the tissue and/or eye bank’s operations. New York California Florida

  32. Standards for End Users “Tissue Services” • The Joint Commission • Transplant Safety Chapter - Transplanting Tissues • Hospitals, Critical Access Hospitals, Ambulatory Care, Office-based Surgery, Laboratory • AABB • Standards for Blood Banks & Transfusion Services • College of American Pathologists • Transfusion Medicine Checklist • American Association of Tissue Banks • Section L - Tissue Dispensing Services Tissue handling oversight unknown if not under these umbrellas

  33. Disease Transmission by Tissue Since 2000 CDC in 2005: Estimated incidence = 0.0004% per 900,000 implants/yr

  34. Largest Recalls • 2005-2006 • BTS-related • ≈ 28,000 allografts from 6 tissue banks made available • TBs verified where all grafts were sent • ≈ 700 tissue grafts unaccounted for by end users • 500 US + 200 International • ≈ 1,300 tissue devices unaccounted for by distributors & end users • ≈ 8,000 returned or destroyed by end users • ≈ 15,800 implanted • The rest were not distributed and quarantined at TBs • No disease transmission proven 7.1%

  35. Largest Recalls • 2006 • Chryseobacterium meningosepticum • 2 infections reported; resolved, grafts remain in place and functional • ≈ 4,800 frozen tendons/ligaments recalled • TB verified where all grafts were sent • Disposition of 99% of the grafts known within 30 days • Will some help from FDA, 100% reached • ≈ 750 hospitals in Canada, Mexico, and the US • ≈ 1,000 grafts returned by end users • ≈ 3,800 grafts implanted

  36. A Sentinel Event • Recovery agency and tissue processor were not accredited by AATB • AATB Standards were violated (body not cooled within 12 hrs of death for recovery up to 24 hrs after death; not until 19 hrs) • Death event should not have occurred • Processor has since attained AATB accreditation but recovery agency has not ?

  37. Aldous Huxley 1894-1963 “That men do not learn very much from the lessons of history is the most important of all the lessons of history.” A., Matthew. "Photo Cited" somaweb.org. 1995-2008; photographer unknown Thank you!

  38. ENSURING PATIENT SAFETY THROUGH APPLICATION OF QUALITY ASSURANCE SYSTEMS IN TISSUE BANKING Presented by Clay Anselmo, RAC President and CEO Reglera LLC Denver, CO Chicago, Illinois ~ March 24 & 25, 2009

  39. Key Risk Elements Donors Tissue Handling Processing Storage and Distribution Regulatory

  40. Quality Management Systems (QMS) • PURPOSE • FDA/Regulatory – Prevent Disease Transmission • General – Ensure Safety of Tissue Products • GENERAL CONCEPT- Procedure-Based Controls to Detect, Correct, Prevent Sources of Product Problems • Systematic • Self-Correcting • Continuously Improving • Addressing Each Risk Area • Provide Structure for Regulatory / Standards Compliance • Operational Stability

  41. Quality Management Systems (QMS) Diagram

  42. Tissue Regulations, Standards and Guidance • Important Regulations • 21 CFR 1271 • State Specific Regulations • Important Standards • AATB Standards For Tissue Banking • EBAA Medical Standards • What Are These and Why Are They Important? • Establish SPECIFIC Requirements for Tissue Banking • Provide QMS Implementation Framework • Establish Inspectional / Certification Criteria

  43. Important Risk Reduction Activities • Donor Eligibility Determination • Processing, Storage & Handling Controls • Audits • Post Market Monitoring Activities • Overall QMS Adoption

  44. Measuring Performance • Accreditation • Regulatory History • Assessment • Post-Market Monitoring

  45. Thank You

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