When laboratories use the term "GLPs" they are not referencing 21 CFR 58, but instead Good Clinical Laboratory Practices (GCLP) which are the minimal requirements that clinical research laboratories should follow, as GCLP embraces both the research/pre-clinical and
clinical aspects of Good Laboratory Practices (GLP).
GCLP regulation and accreditation standards define laboratory practices, which support human sample analysis and result reporting to medical professionals (e.g., physicians) for the purpose of diagnosis and/or treatment of patients or clinical research subjects. Typically, testing methods employed in support of GCLP activity represent government approved in-vitro diagnostic devices (e.g., US FDA approved and/or CE marked medical devices).
GLP regulations and guidance define laboratory requirements, which support non-human laboratory analysis for samples that are derived, primarily, from animal host systems (i.e., analysis of animal samples, which support non-clinical research studies).
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Constance Bridges RAC, MBA
Head of Quality and Regulatory
Marana AZ
United States
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Original Message:
Sent: 17-Jun-2018 09:44
From: Yogesh Patel
Subject: Is GLP required for IVD 510(k)?
For criteria 1) to me you are using the human blood to demonstrate the ability of you assay to detect micro organisms. Since your using human sample You will fall in to clinical space not in " non clinical space". scenario 1 specifically capture non clinical studies conducted in animal plant or organism.
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Yogesh Patel MS, RAC
Bridgewater NJ
United States
Original Message:
Sent: 15-Jun-2018 11:01
From: Noemi Olivo
Subject: Is GLP required for IVD 510(k)?
I need help with interpreting the GLP requirements:
The following was copied from a previous post, not mine:
"For practical intents and purposes, remember that 21 CFR part 58 and the GLP requirements therein become mandatory only when three criteria are met:
- the studies are non-clinical laboratory studies performed on animals, plants, microorganisms or subparts thereof;
- the purpose of the studies is to characterize the safety of the product;
- the studies are submitted, or are conducted for submission to, the FDA in support of an investigational or marketing approval/clearance.
If the studies do not meet these three criteria, then they are outside the intended scope of the GLP regulations."
My question is:
I am preparing a 510(k) for an IVD that detects "microorganisms" in human blood. The performance studies for this submission include testing the IVD using human blood samples spiked with microorganisms as well as whole blood specimens from infected patients. Do we therefore meet the requirement listed above specifically #1, i.e., "... studies performed on ...microorganisms..."? Do we need to meet GLP?
Thank you!
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Noemi Olivo
CRO Services
Milford CT
United States
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