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Followup

DATE: February 7, 2000

TO: Interested Parties

FROM: Stephen D. Nightingale, M. D., Executive Secretary
Advisory Committee on Blood Safety and Availability

SUBJECT: Recommendations of Advisory Committee on January 27, 2000 - Followup 8/3/00

    1. The Committee directs its staff to create on the Committee's web site a list of key recommendations that the Committee has made, in a format that would permit the public to see what progress has been made in implementing each of these recommendations.

Done.

    2. The experience of aviation and other industries supports the use in all blood establishments (i. e., both blood and plasma collection centers and facilities that provide transfusion services) of a confidential, non-punitive system for the management of errors and accidents not subject to regulatory requirements.

FDA is reexamining its current guidances to determine if additional recommendations are needed to address investigation and reporting of errors and accidents associated with blood and plasma treatments, as suggested in the Quality Interagency Coordination Task Force Report.

    3. All blood establishments should have a quality assurance program.

FDA will publish a Final Rule on this matter in the near future.

    4. Quality assurance programs in all blood establishments should capture, analyze, and respond to data on all deviations from established procedures, as well as errors and accidents, independent of whether affected blood units were distributed or caused adverse medical events.

Such reporting is understood to be a component of Good Manufacturing Practice. FDA is considering recommending the MERS-TM system developed by Dr. Harold Kaplan and colleagues, with grant support from the National Heart, Lung, and Blood Institute, for management of transfusion medicine error and accident investigation and reports.

    5. FDA should extend its current error and accident reporting requirements to apply to all blood establishments, including hospital transfusion services, rather than only to licensed blood establishments.

This will be a component of the Final Rule described in 3. above.

    6. In order to facilitate improved transfusion safety, for errors and accidents not subject to regulatory requirements, there should be established outside the regulatory framework an effective, confidential, non-punitive system for the accumulation, analysis, and dissemination of data from all blood establishments' quality assurance programs.

Referred back to the Advisory Committee for further consideration.

    7. Industry and government should be encouraged to facilitate the evaluation and implementation of devices that promise to prevent misidentification of blood products and/or patients.

FDA is evaluating its application review procedures for product and recipient identification devices to ensure efficient handling of these applications.

SDN August 3, 2000

Last Revised: October 27, 2003

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