Regulatory Open Forum

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  • 1.  Is GLP required for IVD 510(k)?

    Posted 15-Jun-2018 11:01

    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:

    1. the studies are non-clinical laboratory studies performed on animals, plants, microorganisms or subparts thereof;
    2. the purpose of the studies is to characterize the safety of the product;
    3. 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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  • 2.  RE: Is GLP required for IVD 510(k)?

    Posted 16-Jun-2018 08:32

    Yes.

     

    Christopher Smith, CQE, RAC

    President, Coastal Pharmaceutical Consultants, Inc. ®

    7950 Old River Road, Burgaw, NC 28425 USA

    910-789-1232 (mobile)

    chrissmith@coastalpharmaconsultants.com

     






  • 3.  RE: Is GLP required for IVD 510(k)?

    Posted 17-Jun-2018 09:44
    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
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  • 4.  RE: Is GLP required for IVD 510(k)?

    Posted 18-Jun-2018 17:59
    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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  • 5.  RE: Is GLP required for IVD 510(k)?

    Posted 19-Jun-2018 05:23
    Hi Constance,

    I do not believe that there are any GCLP Regulations worldwide, nor do I know about any official accreditation organizations. Please share any link to these, as this information would be most helpful.

    Thank you!

    Best regards,

    Robin
     
    Robin Guy, MS, DABT, RQAP-GLP
    Robin Guy Consulting, LLC
    Toxicology and GLP Consulting
    Lake Forest, IL USA



  • 6.  RE: Is GLP required for IVD 510(k)?

    Posted 18-Jun-2018 11:43
    Regardless of the response to item 1, your studies appear to meet the criteria for items 2 and 3 requiring that you comply with GLP for these.

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    Christie Hughes
    Founder and Principal Consultant
    Integrys Consulting
    Austin, TX
    United States
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  • 7.  RE: Is GLP required for IVD 510(k)?

    Posted 21-Jun-2018 17:48

    The following answer can be found in the 2013 FDA Draft Guidance Document: The Applicability of Good Laboratory Practice in Premarket Device Submissions: Questions and Answers:

    "Q12: Do the GLP regulations (21 CFR Part 58) apply to in vitro diagnostic (IVD) devices?

    A12: The GLP regulations only apply to nonclinical laboratory studies, which are defined as: "in vivo or in vitro experiments in which test articles are studied prospectively in test systems under laboratory conditions to determine their safety." (21 CFR 58.3(d)) Studies intended to evaluate the performance of IVD devices to determine their safety typically utilize human subjects or specimens derived from human subjects and are therefore not subject to the GLP regulation.)"



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    Kristen Kanack PhD
    SVP, Regulatory and Clinical Affairs
    Salt Lake City UT
    United States
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  • 8.  RE: Is GLP required for IVD 510(k)?

    Posted 22-Jun-2018 07:44
    Well said.

    All the best,

    Bob

    Robert Schiff, PhD, RAC, CQA, FRAPS
    President and CEO
    Schiff & Company, Inc.
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