Abstract

Clinical islet allotransplantation has been successfully regulated as tissue/organ for transplantation in number of countries and is recognized as a safe and efficacious therapy for selected patients with type 1 diabetes mellitus. However, in the United States, the FDA considers pancreatic islets as a biologic drug, and islet transplantation has not yet shifted from the experimental to the clinical arena for last 20 years. In order to transplant islets, the FDA requires a valid Biological License Application (BLA) in place. The BLA process is costly and lengthy. However, despite the application of drug manufacturing technology and regulations, the final islet product sterility and potency cannot be confirmed, even when islets meet all the predetermined release criteria. Therefore, further regulation of islets as drugs is obsolete and will continue to hinder clinical application of islet transplantation in the US. The Organ Procurement and Transplantation Network together with the United Network for Organ Sharing have developed separately from the FDA and BLA regulatory framework for human organs under the Human Resources & Services Administration to assure safety and efficacy of transplantation. Based on similar biologic characteristics of islets and human organs, we propose inclusion of islets into the existing regulatory framework for organs for transplantation, along with continued FDA oversight for islet processing, as it is for other cell/tissue products exempt from BLA. This approach would reassure islet quality, efficacy and access for Americans with diabetes to this effective procedure.

Highlights

  • Islets used for clinical allotransplantation have been successfully regulated as tissue/organs for transplantation in several countries and are recognized worldwide as a safe and efficacious therapy for selected patients with type 1 diabetes mellitus (T1DM) (1, 2)

  • Health and Human Services’ (HHS) decision in 2013 to include vascularized composite allografts (VCAs) under OPTN/UNOS jurisdiction provides a strong precedent for including human islets under the OPTN final rule (2)

  • We do believe that proposed adjustments would not compromise islet processing regulatory oversight, which could remain subject to Food and Drug Administration (FDA) Good Tissue Practice (GTP) requirements, since it has been successfully in place for over 30 years for the same human islets that are prepared for autologous use

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Summary

Introduction

Islets used for clinical allotransplantation have been successfully regulated as tissue/organs for transplantation in several countries and are recognized worldwide as a safe and efficacious therapy for selected patients with type 1 diabetes mellitus (T1DM) (1, 2). The Secretary of HHS has the authority to designate allogeneic islets for transplantation as human organs under the OPTN Final Rule. It would conform to the statutory definition of the human organ under the National Organ Transplantation Act (NOTA 1988).

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