Submission and Review of Preparation Process Dossiers Overview When to submit a PPD Overview of Submission Procedure Overview of Review Procedure Questions PPD Submission When to submit a PPD New process New licence including processing Change in processing PPDs should be authorised before undertaking processing activity How to submit a PPD Basic Information FAQs Guide PPD http://www.hta.gov.uk/licensingandinspections/licensingunderthequalityandsafetyregulations/authorisingprocesses.cfm The Preparation Process Dossier A. B. C. D. E. F. G. H. Establishment Information General Information Reagents and Materials Quality Control Testing Process Validation Final Labelling/Accompanying Information Additional Information Declaration by DI Section B — preparation process — general information Descriptive Title A description of the tissues and cells 18-30 years of age Liver function tests QC requirements Neutrophils collected from healthy adult donors Any donor selection criteria & non-mandatory testing requirements The cryopreservation of neutrophils for human application Free from monocyte contamination 20 x106 cells/vial Negative fungal screen Details of the process SOP, flowcharts and representative processing worksheets Section C — Reagents and materials Reagent or material that comes into contact with the tissues/cells Specification e.g. CE marked, clinical grade, reagent grade etc. Manufacturer or supplier product code All reagents and materials that come into contact with tissues and cells e.g. PBS, DMSO, culture media, plasticware Should not present a risk to Q&S of processed cells CE marked: yes or no? Rationale/RA for choice of non CE marked reagents/kits Section D — Quality control testing Test (manufacturer name and product code if applicable) What is the assay e.g. cell viability testing kit CE marked or validated? Is assay CE marked Description of test article (analyte) What is being measured/output e.g. number of viable cells in the final product Criteria for release Criteria for release e.g. >80% viability Quality Control Testing-samples taken over the course of processing What critical quality attributes (CQAs) are measured – by validated or CE marked tests Section E — Process validation Section E — Process validation How have the processing methods applied been validated to demonstrate that they do not render the tissues clinically ineffective or harmful for the recipient? a) By studies conducted at your establishment? YES If yes, please append a copy of the validation report. NO b) By studies published by others? YES NO If yes, please append copies of the most relevant publications, and written verification that the process and the published process are equivalent. c) By retrospective analysis of clinical results? YES NO If yes, please attach a summary of the analysis methods and results. Section E — Process validation Identify the Critical Quality Attributes (CQAs) Demonstrate that processing has not rendered the tissue harmful or clinically ineffective Examples of CQAs include: Corneas- density of viable cells per surface area Femoral heads- free from microbiological contamination PBSC- viability upon recovery Heart valves- size Section E — Process validation Identify the Critical Processing Parameters (CPPs) Conditions that bring about or preserve the CQAs Examples of CPPs include: When freeze-drying acellular pericardium the CPPs of temperature and duration of the process have a critical impact on the CQAs of residual water and stability of the resulting collagen matrix For the controlled rate freezing of PBSC the CPP of cryoprotectant concentration has a critical impact on the CQA of viable cell recovery Section E — Process validation A process optimisation report specifying the CPPs, how they were optimised and, where necessary, how their tolerance levels have been set A description of the CQAs, how they are to be assessed, and the acceptable result thresholds A validation plan with documented methodology All results obtained, in a clear form with relevant interpretation showing how at least three independent runs have produced tissues or cells within predetermined criteria for CQAs Section E — Process validation Comparative phenotype data (4 runs repeated 3 times) OUTPUT Run Number A B C D A 0.02 0.099 0.03 B 0.019 0.01 0.028 C 0.039 0.061 0.05 D 0.022 0.013 0.009 RUN NUMBER At least 3 independent processing runs that meet predefined criteria, validation data Data presented as for publication Raw data may be requested at a later stage if required Section F — Final labelling and accompanying information Tissue Establishment Unique identifier Type of tissue/cells Storage Expiry Date Requirement for labelling for distribution to end users P.159-162 Guide to Quality and Safety Assurance for Human Tissues and Cells for Patient Treatment PPD Submission Checklist Document PPD SOP of the preparation process Process flowchart Reagent risk assessment and testing details Validation Report Your own validation Published studies by others Retrospective evaluation Sterilisation validation Viral inactivation validation Final labels Accompanying documents Required? Included Completed PPDs can be sent to: enquiries@hta.gov.uk HTA, 151 Buckingham Palace Road, London SW1W9SZ PPD Review What is the PPD review process? PPD assigned to WG member PPD reviewed by WG member PPD review presented at WG meeting PPD authorised by PPDWG Further information submitted by establishment More information needed? Further information requested from establishment Yes No Proposed Timeframe for Review The PPDWG will aim to reach a decision within 20 working days of receipt of the completed dossier or any additional information requested by the HTA. A ‘completed dossier’ is one in which all fields of the form have been completed appropriately and all relevant validation data to support the application has been supplied. PPD Initial Review Is it complete? Document PPD SOP of the preparation process Process flowchart Reagent risk assessment and testing details Validation Report Your own validation Published studies by others Retrospective evaluation Sterilisation validation Viral inactivation validation Final labels Accompanying documents Required? Included Section A —Establishment Information Inspection reports Existing Activities Other PPDs Annual activity data SAEARs DI/LH information CAPAs Conditions Relationship to the process Premises/Facilities Specific requirements: clean room, environmental monitoring Section B — preparation process — general information General Information SOP/description of process Specific Requirements Demonstrate Critical Quality Attributes Flowchart of preparation process Is the process clearly described? Are all the steps in the process necessary? Are samples taken for quality control testing? Section C — Reagents and materials Reagent or material that comes into contact with the tissues/cells Are all critical reagents and materials included? Specification e.g. CE marked, clinical grade, reagent grade etc. Manufacturer or supplier In house/lower grade reagents used? Justification for use Standard raised to acceptable limit by additional testing? + additional testing product code Is all the required information provided? Section D — Quality control testing Test (manufacturer name and product code if applicable) CE marked or validated? Description of test article (analyte) Criteria for release QC Testing - Samples taken over the course of processing What CQAs are measured – by validated or CE marked tests For example: Sterility testing-in process samples and end product Final cell count Sample viability Residual water in freeze dried tissue Purity e.g. phenotype of cells Section E — Process validation a) By studies conducted at your own establishment Optimisation report for each CPP Appropriate CQAs identified, including acceptable results thresholds? e.g. DMSO tolerance during cryopreservation - concentration of cryoprotectant and duration of exposure prior to freezing e.g. free from microbial contamination following open processing Validation plan with documented methodology Are assays CE marked or appropriately validated? Section E — Process validation a) By studies conducted at your own establishment Results in a clear format with relevant interpretation Figure 1. The effect of cryopreservation on cell viability. Cell viability was determined by trypan blue exclusion and was measured both pre and post cryopreservation for 10 independent batches of cells. How are results presented? At least 3 independent runs produce tissues and cells within predetermined CQAs Relevant interpretation Any non-conformances considered Section E — Process validation b) By studies published by others All referenced publications attached Publications are relevant to the process Operational validation Can you reproduce the process? How will staff be trained in the process? Are reagents of equal specification or appropriately validated? Have any changes been made to the process? Validation of changes? Section E — Process validation c) By retrospective analysis of clinical results Clinical results from tissues and cells supplied by your establishment using well established processing procedures Number of tissues and cells implanted following processing by your method Period over which these implantations occurred Procedures for reporting adverse reactions Context of the data if available National or worldwide success rates for the procedure Your PPD is now authorised You will receive written authorisation from a member of the PPD Working Group to undertake processing Licensing Standard GQ2d Processes affecting the quality and safety of tissues and/or cells are validated and undergo regular evaluation Making changes to an existing process Change to existing process identified Notify the HTA Managed by internal change control Change control recorded No Impact quality or safety of product? Yes Submit change of process PPD Summary Allow sufficient time for PPD review Check that appropriate information is provided Provide clear methodology and validation All CQAs and CPPs are clearly defined and supported by the validation report For further information Guidance Document: Preparation Process Dossiers – a guide for processors of tissues and cells for patient treatment The HTA website: http://www.hta.gov.uk/licensingandinspections/licensingunderthequalityandsafetyregulations/authorisingtissueorcellpreparation processesfaqs.cfm Enquiries helpline: 020 7269 1900 enquiries@hta.gov.uk www.hta.gov.uk http://twitter.com/HTA_UK http://www.Facebook.com/HumanTissueAuthority