Draft Risk Assessment:
Potential Exposure to the vCJD agent in United States recipients of Factor XI coagulation product manufactured in the United Kingdom
Center for Biologics
Evaluation and Research
U.S. Food and Drug
Administration
January 31, 2005
EXECUTIVE SUMMARY
In December 2003 the U.K. government announced that vCJD had likelylikely been
transmitted via blood transfusion to a 69 year-old patient that had died. of the disease. This was followed by the announcement in July
2004 of a second
presumptive case of transfusion-transmitted vCJD that had occurred in a patient
that had displayed no symptoms of the disease and had died of other
causes. Cases of variant
Creutzfeldt-Jakob disease (vCJD) were first reported in humans in the U.nited K.ingdom in 1996 – and as of January 2005November 2004
overapproximately
1760 cases have been reported occurred worldwide. Variant CJD is
a fatal neurodegenerative disease attributed to human infection with the agent
of Bovine Spongiform Encephalopathy (BSE), most often transmitted by the
consumption of beef products from infected cattle.The disease is a fatal
neurodegenerative disease whose cause has been attributed to the consumption of
beef from bovine spongiform encephalopathy (BSE)-infected cattle.
The probablepossibility that transmission of vCJD via whole blood or
blood components raised a similar possibility that plasma derivatives might
also pose a risk of vCJD transmission.
Accordingly, U.K.nited
Kingdom authorities recently notified some recipients of plasma
derivatives that they might be at increased risk of vCJD. These products
included coagulation factors VIII, IX, and XI, as well as antithrombin III, and
intravenous immunoglobulins. The derivatives of concern were manufactured from
plasma of U.K. donors between
1980 and late in 1999, when--consistent with a decision announced in 1998--—U.K. manufacturers
stopped using U.K. plasma. The last
expiry date for any of the U.K. products was in 2001.
Problem: Some
Factor XI made from U.K. plasma was used
between 1989 and 1997 to treat relatively small number of patients
participating in several Investigational New Drug (IND) studies in the United
States.S. No Factor XI product used in the U.S. was manufactured
from a pool containing plasma from any donor known to have become ill donor diagnosed with
variant CJD (that is,
there were no known "implicated" lots). However, U.K. plasma donors are
at a significantly higher risk for vCJD.
Question addressed by risk assessment: Given the probable recent
transmission of vCJD via transfusion of whole blood and component products,
what is the risk to US recipients that received human plasma derived Factor XI
product manufactured in the UKU.K.?
The average prevalence of vCJD in the U.K. population is estimated assumed
asto be
1 in 4,225 based on a surveillance study by Hilton, et al (2004). Therefore, the model assumes that there is
nearly 100% likelihood that a plasma pool containing 20,000 donations will
contain at least one donation from a vCJD-infected individual. Additional
rResults
from the model are presented below in Table I. The intravenous (i.v.) ID50 per
single unit and per vial of Factor XI was estimated by the model. A single ID50 is defined as
exposure to an amount of infective material, in this case plasma
derivative, that causes infection in 50% of the population. Three Additionally,
results that predict exposure for 3 scenarios were modeled to depict depicting
various
plausible levels of utilization that approximate clinical
treatment withof FXI were generated. Scenario 1 involves the treatment of
a 60 kg individual prior to surgery with 50 units/kg, or a total of 3,000 units
given to restore FXI levels to normal. FXI doses in the
literature typically range from 20 – 50 iu/kg,
but doses as high as 15,000 units/patient
have been administered
in the postoperative setting, over a period of days reported. Scenario
2 and Scenario 3 assume a treatment regimen consisting of 9,000
units, and 15,000 units of FXI, respectively.
Clinical treatment under the three scenarios suggests patients may be exposed to vCJD i.v. ID50
during the course of treatment that may pose a risk of causing infection. It is not possible to estimate the precise
magnitude of risk faced by patients that received U.K.-manufactured FXI product.
Table
I – Potential eExposure to vCJD
agent i.v. ID50 via Factor
XI. Results are expressed as per unit or vial of
FXI. Hypothetical scenarios provide an
estimate of the magnitude of exposure to vCJD agent i.v. ID50 that might occur per surgery
incident. A surgical incident includes
prophylactic treatment prior to surgery and possibly several post-operative
treatments with FXI.
|
|
Scenario |
Quantity*
Factor XI Utilized |
Mean vCJD(1) i.v. ID50 |
5th (1) percentile |
95th (1) percentile |
|
|
|
|
|
|
|
|
|
A
single unit FXI |
1 u |
2 x 10-5 |
6.8 x 10-7 |
7.0 x 10-5 |
|
|
One
vial FXI |
1,000 u |
2 x 10-2 |
6.8 x 10-4 |
7.0 x 10-2 |
|
|
Scenario 1: Treatment 3,000 u |
3,000 u |
6 x 10-2 |
2.1 x 10-3 |
0.21 |
|
|
Scenario 2: Treatment 9,000 u |
9,000 u |
0.17 |
6.2 x 10-3 |
0.6 |
|
|
Scenario 3: Treatment 15,000 u |
15,000 u |
0.28 |
1.0 x 10-2 |
1.0 |
(1) Estimates may have been rounded
No U.K.-manufactured FXI product distributed in the
US from 1989 to 1997
is known to have been
manufactured from “implicated” plasma poolsbatches that
were known to have may
have ccontained
plasma from a donor
later diagnosed withdonations from an individual(s) later diagnosed
with vCJD. If the prevalence of vCJD
in the U.K. is assumed to be 1/4,225, iIt is likely
that most plasma
pools used to manufacture FXI until 1998 could have contained a product
manufactured in the UK in the 1990s may have been manufactured from plasma
pools that contained a plasma donation(s) from an plasma donation from a
person individual that may have been iinfected with vCJD.
Potential exposure to vCJD agent present in Factor
XI manufactured in the UK in the 1990s was estimated in this risk
assessment.
The likelihood of exposure to the vCJD agent via UK
manufactured Factor XI was assumed to be nearly 100%. Although results of the model suggest that exposure maycould have occurreddid occur, it is not
possible to provide a precise
estimate of the vCJD risk to patients that may have used Factor XI manufactured
in the U.K. in the
1990s.
Factor XI is a clotting factor present in blood plasma that
plays a role in the very early stages of the blood coagulation pathway. It is a precursor to plasma thromboplastin,
which is one of the proteins that alters the shape of blood platelets and
facilitates clotting. Factor XI is normally present at very low concentrations
of 50-u/dl to
70 u/dl
in human plasma.
Factor XI (FXI) deficiency
is a rare bleeding disorder that occurs in the general population at a rate of
1 per 100,000 people and that was
first described in the 1950s. Unlike
other hemophilias, it is an autosomal bleeding disorder that affects both
genders equally. Generally, bleeding with
FXI deficiency is less severe than with hemophilias A and B and does not
usually involve joints or muscles or spontaneous bleeding in those areas. ([http://www.hemophilia.org/bdi/bdi_types9.htm
(accessed Oct 26, 2004)]. Factor XI deficiency
is usually categorized as (1) severe or (2) partial. Those with severe deficiency have FXI levels below 15 mgu/dl and are at high risk of excessive
bleeding if injured, or after surgery or dental extractions. Medical intervention that brings FXI levels
to the 50 u/dl to 70 u/dl range is recommended
prior to surgical procedures on severely deficient patients. Therapy can include infusion with fresh
plasma, antifibrinolytic agents, or investigational therapy,
such as was done under several IND studies from 1989 to 1997 using purified FXI preparations.
Generally, bleeding with FXI deficiency is less
severe than with hemophilias A and B and does not usually involve joints or
muscles or spontaneous bleeding in those areas. Bleeding is much more variable and can be
associated with injury and certain types of surgical procedures such as dental extractions,
tonsillectomies, surgery in the urinary and genital
tracts and nasal surgery [http://www.hemophilia.org/bdi/bdi_types9.htm
(accessed Oct 26, 2004)].
Factor XI
manufactured in the U.K.nited
Kingdom b
between 1989 and 1997 was used by a small group of patients in several investigational new
drug (IIND)
studies in the U.S. and this risk
assessment estimates the potential exposure to vCJD agent via thatis product. Currently, there is no Factor XI product
commercially licensed in the United States.
I. Hazard Identification
The hazard identification portion of the risk assessment
provides an in-depth overview and analysis of information from laboratory
studies, epidemiological studies, the scientific literature, government reports
and other credible or peer-reviewed sources of data that establish a causal
relationship between the hazard and adverse effects on humans. To date, there is no
epidemiological evidence suggestsing that vCJD has been transmitted by use of plasma
derivative products.
A new human variant Creutzfeldt-Jakob disease (vCJD) was
first described reported in
the U.K.nited
Kingdom in 1996. As of January 2005, 171November 2004 167 cases have been reported including 1537 in the U.K., 9 8(not U.K.-acquired) in
France, and single non-U.K.
acquired cases in 3 in Ireland and Italy. In
addition, single cases of vCJD in former long-time residents of the U.K. have
occurred in Ireland, Canada, and the U.S.1 each in Hong Kong, Canada, and
the US (the single cases were likely not domestic in origin but rather,
occurred in former U.K.
residents). The disease is a fatal
neurodegenerative disease whose cause has been attributed to the consumption of
beef from bovine spongiform encephalopathy (BSE)-infected cattle.
Both vCJD and BSE belong to a class of diseases known as
transmissible spongiform encephalopathies (TSEs). The leading theory is that
the transmissible infectious agent is a proteinaceous infectious agent, or “prion,” that originates in the misfolding of a ubiquitous prior
protein (Prp) normally expressed in many cells. or proteinaceous infectious
agent, that is an altered but pathogenic form of the PrP protein that is
normally present in cells. The
altered PrP, known as PrPres, is highly stable and resistant to
degradation by high heat and many
chemical treatments commonly used to denature proteins. The incubation period for TSEs is long. For example, the mean incubation period for BSE in cattle
(interval between first exposure to contaminated feed and onset of illness) has
been estimated at about 5 years, and that for blood-borne vCJD to exceed 10
years. –BSE incubates approximately 4.5 years, vCJD incubates
approximately 10 –12 years or longer – and Iindividuals become symptomatic with most forms of CJD only in
the last few months of life, only in the last few months of the disease
making early detection very difficult.
Diagnostic tools can usually detect BSE in the later stages, usually in cattleanimals more than older than 24 months oldof age. Confirmation of vCJD requires postmortem
examination of brain tissue to confirm diagnosis, but abnormal prion protein has been detected in
antemortem tonsil biopsies early in clinical illness and archived appendices of two asymptomatic individuals one and two years
prior to the onset of symptoms. prion protein
has been detected in tonsil and appendix of asymptomatic individuals as long as
two years prior to the onset of symptoms. There are currently no rapid tests available
to detect the vCJDdisease
in its early stages or to detect the
presence of TSE agents in blood.
Transmission of TSEs through the transfusion of blood or
blood products has been demonstrated in animal models on multiple
occasions. At least four studies reported transmission vial
blood transfusion in the same animal species: Four studies have reported
transmission via blood transfusion in the same animal species. The studies include use of a sheep experimentally infected with BSE model to
demonstrate transmission of BSE (Houston et al 2000) and naturally infected with and scrapie
(Hunter et al 2002), and
experimentally infected rodents (hamsters with scrapie and mice with a human
TSE (hamsters with BSE and mice with a
strain of human Gerstmann-Straussler-Scheinker (Rohwer et
al 2004, Brown et al 1999).
Other groups have demonstrated interspecies
transmission of TSE agent via transfusion of blood products. Two research groups were able to estimate
the quantity of infectivity that might be present in the whole blood of mice
and hamsters. Using a murine model and human CJD Brown et al (1998, 1999)
conducted further experiments to determine the infectivity of buffy coat
material and plasma but not red blood cells. Assuming that red blood cells
retain approximately 25% of the infectivity of whole blood, then the
infectivity present in whole blood could be estimated to be in the range of
approximately 10 i.c. ID50 and 20 i.c. ID50 per ml. Transfusion
of blood products using the hamster scrapie model by Rohwer suggests that
addition of infectivity levels derived for individual blood components would
generate a titer for whole blood of approximately 2 to 20 i.c. ID50/ml.
Studies have shown that greater than 50% of
transmissible spongiform encephalopathy agent present in whole blood is
associated with plasma. Two sets of
experiments (Gregori et al 2004). using a hamster
– sheep scrapie model showed that approximately 58% of infectivity in whole
blood is associated with plasma. Thise model uses the
more conservative of the two outcomes and assumes that 58% of infectivity is
associated with plasma.
Brown, Rohwer, Taylor and others
have attempted to estimate the amounts of infectivity present in blood, which
generally fell between two and 20 icLD50/ml. A recent study of scrapie-infected
hamsters concluded that more than 40% of the infectivity present in whole blood
was associated with plasma (approximately 58% [Gregori L, et al. 2004].)
The model uses the more conservative of the two outcomes and assumes that 58%
of infectivity is associated with plasma.
I. B. Transfusion
transmission of vCJD in the U.nited K.ingdom
In December 2003 the U.K. government announced an alarming finding –
that vCJD had likely been transmitted via blood transfusion to a 69 year-old
patient
that had died of the disease.
The patient had received a transfusion of non-leucoreduced red blood cells in 1996 from
a donor
in 1996 that died three years later of vCJD. This first case was followed by the
announcement in July 2004 of yet another probablelikely case of
transfusion-transmitted vCJD that occurred in a patient that had displayed no
symptoms of the disease, had died of ruptured aortic aneurysm without signs of vCJD, a cause
unrelated to vCJD, but postmortem testing detected PrPsc prion agent
in spleen tissue and cervical and lymph node tissue.
It
is possible that dietary exposure may have been responsible for the cases,
however the probabilities for either or both of these two events are
small. As Llewelyn et al (2004)
pointed out in their publication discussing the first presumed transfusion-transmitted case “the
age of the patient was well beyond that of most vCJD cases, and the chance of
observing a case of vCJD in a recipient in the absence of transfusion
transmitted infection is about 1 in 15,000 to 1 in 30,000.” The combined probability that two elderly patients
in a small cohort of transfusion recipients—in an age group underrepresented
among vCJD cases—both acquired infection from food, is remote.
The
presumptive transmission of Transmission of vCJD via by labile whole blood
or blood components
raises the possibility that plasma derivatives may pose a risk. The U.nited K.ingdom authorities recently notified some
recipients of plasma derivatives that they might be at increased risk of vCJD.
These products included coagulation factors VIII, IX, and XI,
as well as antithrombin III, and intravenous immunoglobulins. The derivatives
of concern were manufactured from plasma of U.K. donors between 1980 and late in 1999,
when--consistent with a decision announced in 1998--—U.K. manufacturers
stopped using U.K. plasma. The last
expiry date for any of the U.K. products was in 2001. To date, no cases of vCJD have been detected
in patients that have received human plasma-derived coagulation products from
implicated lots made in the U.K.
The focus of this risk assessment is on the risk of vCJD for patients in the U.S. that received Factor XI manufactured in the U.K. in the 1990s.
II. Hazard Characterization
The hazard characterization component (also known as
dose-response) relates the information in the exposure assessment, which
determines the dose, to the adverse consequence(s) such as infection, illness,
etc., at the individual, subpopulation, or population level. Determining dose-response relationships are
extremely complex and often difficult to accomplish because data are limited,
especially exposure and outcome data for humans. Other factors such as characteristics of the hazard (e.g. strain,
chemical make-up, etc.), route of introduction, genetics of exposed
individuals, influence the dose-response relationship but are often difficult
to characterize. Often in lieu of human
data, animal data are used and appropriately extrapolated to estimate the
dose-response relationship for humans. Determining the
dose-response relationship for the vCJD agent is challenging because animal
data are limited and human data are lacking.
Another challenge is estimating the probability of infection
when the exposure to TSEs is small and/or occurs repeatedly over a period of time. It is unknown whether there is a minimal
amount of the agent, or threshold, that is needed to initiate infection in an
individual. Furthermore, it is not
known whether the effects of small multiple exposures over a period of time are
cumulative and may result in infection and disease. Some risk assessments have made assumptions concerning the exposure
and dose for TSE agent that leads to infection. For instance, the Det Norske Veritas (Feb 2004) blood products
risk assessment assumes that exposure to infectivity, quantified in ID50
units, is cumulative over the period of one year. The ID50 is the
common metric used to quantify the infectivity of transmissible spongiform
encephalopathies (TSEs). One ID50 is defined as the amount of
infectious material or tissue that is necessary to initiate infection in 50% of
the population. The route of exposure
to TSE infectious material influences the efficiency of transmission of the
disease and it has been shown that the intraercerebral (i.c.) route (injection
directly into the brain) is the most efficient mode, the intravenous (i.v.)
route is approximately 5 to 10 times less efficient than the i.c. route.
In estimating the dose-response relationship for TSEs one
could use a strict interpretation of the ID50 and assume a linear
relationship between exposure and infection.
In such a case exposure to 1 ID50 would suggest a 50%
probability of infection, exposure to 0.1 ID50 would suggest a 5%
probability of infection, and so on. Assuming
the dose-response is a linear function it is possible for products
produced in large batches such as plasma
derivatives and used by thousands of individuals on a repeated basis that there
may be a possibility of infection occurring among the population. However, given the lack of
information and high degree of uncertainty on the dose-response relationship
for TSE agents it is plausible that low level exposures, even on a chronic
basis, may not attain the threshold necessary to initiate infection in
humans. The conservative assumption is that The
Food & Drug Administration makes the conservative assumption that low levellow-level exposure to a TSE
agent could potentially lead to infection and appropriate risk
management interventions should, whenever possible, be implemented to reduce
such risk..
Exposure assessment evaluates the routes of exposure to a
hazard, the probability that exposure occurs and the amount of a hazardous
agent to which a person or population may be exposed. This exposure assessment specifically addresses exposure to the
vCJD agent that may have been present in Factor XI manufactured in the 1990s in
the U.K. and administered
to U.S. patients during a
clinical study under an investigational new drug (IND)
application. The administration of
Factor XI, and thus the route of exposure, is intravenous and used in the
clinical treatment of individuals prophylactically prior to surgery and after
surgery to control bleeding.
Pools consisting of 20,000 or more plasma donations
collected from U.K. plasma donors
were used as the starting material from which FXI was purified. Because of the relatively large number of
donations per plasma pool and the prevalence incidence of vCJD in
the U.K. population it is possiblelikely
that at least one or more plasma donations per pool may have been collected
from asymptomatic individuals unknowingly infected with vCJD. The worst-case assumption is also that TSE
infectivity is presentcontained in the blood of an incubating donor at any stage
of incubation.
Assumption used in the model: The probability of at least one donation from a vCJD-infected individual being present in a plasma pool used to manufacture Factor XI in the U.K. in the 1990s is nearly 100%.
Module A (vCJD ID50 per plasma pool) uses estimates of vCJD incidence prevalence in the U.K. population of 1
in 4,225 (Hilton et al 2004) to estimate the number of vCJD donations
that could be present in a plasma pool of 20,000 donations. The output of this module is an estimate of
the vCJD ivID50 per plasma pool.
Module B (ID50 reduction during processing /
production) approximates the processing process and the reduction
of vCJD agent during manufacturing. The
model estimates a reduction of between 0 and 4 log10 reduction
(10,000 fold) in the amount of agent with a most likely level of reduction of 2
log10 reduction (100 fold).
The output of this module is an estimate of the ID50 per vial
of Factor XI. Module C (Dose for
Pre- / Post- surgical treatment) estimates utilization of FXI by patients. The outcomes are expressed in i.v. ID50 per single unit FXI, per
vial (1,000 units) and for three possible clinical treatment scenarios.
Model of
Exposure Assessment
III.
A.1. PvCJD - Probability
of vCJD-infected individual in U.K. population
In
the scientific literature estimates of the rate of incubating vCJD cases in the
U.nited K.ingdom have been derived from two potential
sources – (1) mathematical modeling and (2) surveillance testing of tissues
such as tonsil and appendix. For this
risk assessment we used the estimates derived from the tonsil and appendix
studies since they are surveillance studies and would be expected to provide a
more representative estimate of the potential rate of vCJD in the population. In vCJD patients the distribution of
infectivity in tissues throughout the body is different than for other forms of CJD. Infectivity has been observed in the tonsil
and spleen (Bruce et al 2001) as well as in the lymph nodes (Wadsworth et
al 2001) of vCJD patients
at the time of death. Prion protein
has been observed in two asymptomatic vCJD individuals two years prior to the
onset of symptoms (Hilton et al 2002). However, it is unclear at which point during
the incubation period of the disease that the prion agent becomes detectable in
tonsil, appendix and other tissues. PrPsc has also been observed in
appendices of two asymptomatic vCJD individuals one and two years (but not 10
years) prior to the onset of symptoms (Hilton et al 1998).
The most recent surveillance results for the U.K. by Hilton et
al (2004) indicated three appendicectomy samples from different
patients showed accumulation of prion protein in tonsil and/or appendix samples
examined from a total of 12,674 individuals.
For the risk assessment model we converted this 3 in 12,674 individuals
sampled to an average rate of vCJD in the U.K. population of 1 in 4,225 ( 1 / 20,300 to 1 / 1,450 at 95% CI ). The data from tissue studies were then used
to generate variables and parameters representing the potential number of vCJD
donations that may be present in a batch of 20,000 recovered plasma donations
used to manufacture Factor XI product in the U.nited K. ingdom in
the 1990s. Assuming an average
prevalence of 1 in 4,225 ( 1 / 20,300
to 1 / 1,450 at 95% CI ) there would be an estimated 4.7 (95% CI
0.98 - 13.8) potential vCJD donations per plasma pool of 20,000
donations (20,000 donations x 1/
4,225 = 4.7).
Although the potential rate of vCJD is derived from
surveillance studies there may be some limitations on the data because the
number of samples tested is
still relatively small (about 12,000) and even in the U.K. population, vCJD is
a rare illness., a total of 12, 674, is still relatively low given
that vCJD is such a rare event.
Therefore, many caveats are given with these estimates. For instance, they survey may underestimate the number of cases in the population if PrPsc
is not detected in the tissues of in the population because
infectivity may not be detected in the tissues of vCJD-infected individuals
until later in the disease process. It
is also possible that the estimates derived from the tissue testing
surveillance programs may in some way overestimate the risk. For example, the population surveyed for the
tonsil and appendix studies may not be identical, e.g. in terms of age, to the
plasma donor population. H – however, this estimate is selected as the most
conservative estimatebeing used .
to err
on the side of caution and in the interest of
protecting public health.
Assumption used in the model: An average incidence prevalence of vCJD in the U.K. population was assumed to be 1 in 4,225 ( 1
/ 20,300 to 1 / 1,450 - 95% CI ).
Table II.
Summary of surveillance testing of tissues including tonsil and appendix in the
UK.
|
Reference |
Ages of population examined |
Type tissue examined |
Years tissue taken |
Number of positives |
Total samples examined |
Rate per million (95% CI) |
|
Ironside
JW, et al. 2000 |
10–50
yr |
Tonsils and appendices |
1995-1999
(?2000) |
0 |
>3,000 |
0 |
|
Hilton
DA, et al. 2002 |
10–50
yr |
Tonsils and appendices |
1995-1999 |
1 appendix |
8,318 |
|
|
Hilton
DA, et al. 2004 |
20 – 29
yrs |
Tonsils and appendices |
1995 - 1999 |
3 appendices |
12,674 appendices |
237/million (49–692 per million) |
III. A.2. DTpool - Total number of donations per pool
Assumption used in the model: Factor XI was manufactured from a pool of approximately 20,000 recovered plasma donations.
III. A.3. DvCJD - Total number of vCJD donations per pool
The estimate in the model of the total number of donations
from individuals incubating vCJD that may be present in a pool of 20,000 plasma
donations used to manufacture Factor XI was estimated from surveillance studies
that tested lymphoreticular tissue from patients in the U.K. for the presence
of vCJD agent. Surveillance studies
testing for the presence of prion protein in tonsil and appendectomy samples
from U.K. health clinics
identified a total of 3 prion protein positive appendix samples from a total of
12,674 individuals tested (Hilton et al 2004). These testing results for appendices and tonsils suggest a
potential incidenceprevalence of 1 positive
vCJD case per 4,225 individuals in the U.K.
Hilton et al (2004) suggest that an average of 237 vCJD
infections per million individuals with a 95% CI of 49 to 692 vCJD cases per
million.
Given the potential vCJD prevalenceincidence of
1 case per 4,225 individuals in the U.K. from Hilton et al. (2004) it is
likely that there is nearly a 100% probability that one or more donations from
vCJD infected individuals will be present in each pool. The model represents the uncertainty of the
estimated number of vCJD donations per plasma pool using a statistical
distribution.
Assuming an average prevalence of 1 in 4,225 ( 1 /
20,300 to 1 / 1,450 at 95% CI ) there
would be an estimated 4.7 (95% CI 0.98
- 13.9) potential vCJD donations per plasma pool of 20,000 donations (20,000
donations x 1/ 4,225 =
4.7). The model assumed all
donations were comparable in volume and there were no partial donations; all
partial donations were rounded to the nearest whole number.
Assumption used in the model: The number of vCJD donations per pool is represented by a triangular distribution that assumes a minimum of 0 donations from vCJD individual will be present, it is most likely that as many as 2 donations (or an average of approximately 5 donations) from vCJD cases could be present, and a there is a small probability that a maximum of 14 donations from vCJD individuals may be present in a plasma pool consisting of 20,000 donations.
III. A.4.
ID - Estimated Total Infectivity (or i.c.ID50) per vCJD donation
The model estimates the total
infectivity or i.c. ID50 per vCJD donation as a function of the
volume of plasma per donation multiplied by the infectivity associated with
plasma. The i.c. ID50 in
plasma are calculated from the percentage of infectivity that is estimated to
be present in plasma. The model
expresses intracerebral (i.c.) vCJD infectivity in terms of the i.c. ID50
as the amount of tissue material, in this case blood or plasma, that when
injected into the brain causes infection in 50% of the population. More details on the variables and parameters
for this portion of the model are described below.
III. A.4.a. DV - Amount
of recovered plasma per donation
DV - The amount of plasma recovered from a unit
of whole blood is represented in the model by a single value point estimate of
200 milliliters
A unit of whole blood has a volume of approximately 450 milliliters. Recovered plasma is the plasma portion separated from the cellular portion of a unit of whole blood within hours of its collection.
Assumption used in the model: The model assumes that approximately 200 milliliters (mls) of plasma can be separated away from the blood cells.
III.
A.4.b. Ibl - Infectivity
of vCJD (or i.c.ID50)
present in infected blood per ml
Ibl - The potential amount of vCJD agent present
in whole blood collected from a vCJD infected individual is represented in the
model by a triangular statistical distribution of (0.1, 10,1000)
i.c. ID50/ml (minimum, most likely, and maximum).
Conclusions from two research groups arrive at somewhat
similar estimates for the quantity of infectivity that might be present in the
whole blood of mice and hamsters. Using a murine model and human CJD Brown et al (1999) found that infectivity
in the blood of mice rose to as high as 100 infectious units (iu) per ml of
buffy coat. Furthermore, Brown et al
(1998, 1999) conducted experiments to determine the infectivity of buffy coat
material and plasma but not red blood cells. Assuming that red blood cells
retain approximately 25% of the infectivity of whole blood, then the
infectivity present in whole blood could be estimated to be in the range of
approximately 10 i.c. ID50 and 20 i.c. ID50 per ml.
Cervenakova et al (2003) found levels of 20 – 30 infectious doses per ml
( 10-15 i.c. ID50 per ml) associated with buffy coat and plasma during
incubating and symptomatic stages of the disease. Red blood cells were not
found to be infectious. Transfusion of
blood products using the hamster scrapie model by Rohwer suggests that addition
of infectivity levels derived for individual blood components would generate a
titer for whole blood of approximately 2 to 20 i.c. ID50/ml.
Assumption
used in the model: Whole blood
collected from a vCJD-infected individual potentially carries a minimum of 0.1
i.c. ID50 per ml, a most likely of amount of 10 i.c. ID50
per ml, and a maximum of 1,000 i.c. ID50 per ml. Attempts to identify vCJD
infectivity titers in
human in blood experimentally have
not been successful, but the assay sensitivity for vCJD in vitro and in animal models is limited (Bruce, et al 2001 and Wadsworth et al, 2001).
Wadsworth et al estimated a
limit of sensitivity of about 1,000 ID50/ml by their assay (Wadsworth, 2001).
III. A.4.c. IPl-perc - Percentage
infectivity associated with plasma (i.c.ID50/ml)
IPl-perc - The percentage of vCJD agent associated with the plasma portion of whole blood is represented in the model by a single value point estimate of 58%.
Studies have shown that greater than 50% of transmissible spongiform encephalopathy agent present in whole blood is associated with plasma. Two sets of experiments
(Gregori et al. 2004) using a hamster – sheep scrapie model showed that approximately 58% of infectivity in whole blood is associated with plasma.
Assumption used in the model: The model uses the more conservative of the two outcomes and assumes that 58% of infectivity is associated with plasma.
III. A.4.d. ID - Total
infectivity (or i.c.ID50) per vCJD recovered plasma donation
Total i.c.ID50 per vCJD donation is represented by the equation:
ID
= DV x Ibl x IPl-perc
In this case ID or total infectivity or i.c. ID50 per vCJD donation equal to the volume of plasma per donation (DV) multiplied by the infectivity associated with plasma which is derived from the ID50s present in blood (Ibl) times the percentage of infectivity present in plasma (IPl-perc). Total vCJD infectivity is expressed in terms of the ID50 or the infectious dose needed to cause infection in 50% of the population.
Assumption used in the model: One ID50 is the amount of material containing infectious agent that has a 50% probability of causing infection in an individual or population.
III. A.4.e. Aic-iv - Adjustment
for intravenous route of infection
Aic-iv - is represented in the model by a uniform distribution between 5 and 10. This variable provides an adjustment for the difference in efficiency between the intravenous and intracerebral routes of introduction in initiating infection.
Animal data with mouse-adapted scrapie suggest that
the intravenous route of administration is approximately 10 times less
efficient in causing infection than the intercerebral route (Kimberlin,
1996). Animal data collected by Brown et al (1999) in a
mouse model using plasma suggest that the i.v. route may be 7 times less
efficient while similar experiments using buffy coat suggested the i.v. route
might be approximately 5 times less efficient.
The blood products in Brown et al (1999) had
been obtained from mice previously infected with a mouse-adapted strain of
human CJD.
Studies
with mouse-adapted scrapie agent suggest that the i.v. route of administration is approximately 10 times less
efficient in causing infection than the intracerebral route (Kimberlin et al 1996). Brown
et al (1999) used a mouse-adapted human
TSE agent to show that i.v. injection of plasma was about seven times less
efficient and i.v. injection of buffy coat approximately 5 times less
efficient than were i.c. inoculations of the same materials in transmitting
infection.
Assumption used in the model: Exposure to infectivity by the i.v. route is between 5 and 10 times less efficient at causing infection than introduction via the intracerebral route.
III.
A.5. Iiv-pool - Total intravenous infectivity or i.v.ID50 per plasma pool of 20,000 donors
The output of this component of the model, total i.v. ID50 per plasma pool, is represented by the equation:
Iiv-pool = DvCJD x ID
Aic-iv
Total intravenous vCJD infectivity per plasma pool (Iiv-pool)
was calculated in the model by multiplying the total vCJD donations per pool, DvCJD,
by the total quantity of infectivity, ID, (ID50) per donation
and dividing the product by the adjustment for intravenous route of
introduction, Aic-iv.
This component of the model estimates the total i.v. ID50
of vCJD infectivity that may be present in a vial of Factor XI that was
manufactured in the U.K. and used in the U.S. under IND. Production of Factor XI in the U.K. involved the
pooling of recovered plasma from a pool of approximately 20,000 donations. Some steps during production may be expected
to remove vCJD infectivity, thereby reducing the amount in the finished
product. There were two steps that
reduced the amount of infectivity.
First, the UK manufacturer of Factor XI indicated that the
original starting plasma material was approximately 5,000 kg of plasma from
which approximately 800 kg was removed and used to produce the Factor XI
product. This means that only
approximately 16% (800/5,000) of infectivity from the large pool of 20,000
donations remained. Finally, because of
the processing steps used in the manufacture of Factor XI we assumed a most
likely reduction in infectivity of 2 log10 (or 99%). These two steps
would result in a significant reduction in the amount of vCJD present in the
Factor XI product from the U.K. Hhowever, the
model assumes that infectivity would only be reduced and not eliminated. Therefore, some vCJD infectivity is
predicted by the risk assessment model to have been present in vials of Factor
XI produced in the U.K. and may have
posed a risk of transmitting vCJD to patients that received the product.
III.B.1. RW% - Percentage of
pool used to manufacture Factor XI
The initial starting amount of material from 20,000
recovered plasma donations in the UK U.K. was estimated
to weigh 5,000 kg of which 800 kg (or 16%) of the material was removed and used
to produce Factor XI. As stated earlier
this step represents an 84% reduction in infectivity from the pool of 20,000
plasma donations.
Assumption used in the model: Approximately 16% of starting plasma
material from 20,000 donations was used in the manufacture of FXI.
III.B.1.a. Wst - Weight
of starting product
Information provided by
the manufacturer indicated that approximately 20,000 donations of recovered
plasma assembled into a larger pool of source material equal to approximately
5,000 kg.
Assumption used in the model: Weight of starting product is represented in the model by a single value point estimate of 5,000 kg.
III.B.1.b. Wm - 800kg
portion removed and used to extract Factor XI
Wm - Portion of total product used in manufacturing is represented in the model by a single value point estimate of 800 kg.
Assumption used in the model: 800 kg of material was removed and used to produce Factor XI.
Portion used is represented by
the equation and calculations:
RW =
Wm / Wst
RW =
800 / 5,000
RW% =
0.16
The removal of 800 kg or 16% of the pooled product from the original starting material of 5,000 kg represents an 84% reduction in the amount of i.v. ID50s present in the original pool of 20,000 donations.
III.B.2. RLog
- Log reduction in ID50 during
processing
Represented in the model by a
triangular statistical distribution representing a reduction in ID50
during processing of (0, 2,4) Log10 i.v. ID50/ml (minimum, most likely, and
maximum).
TSE agents The vCJD agent
isare
highly resistant to conventional inactivation methods such as alcohol, other solvents, chemical,
and heat denaturation. At least one There
are no ssteps
during the production of Factor XI that wilhas potential tol
reduce the amount of agent present byut some steps during
processing can physically remove part of the
agent along with other proteins separation (partitioning). CBER has estimated by internal expert
opinion that the level of removal of agent during processing corresponds to a
reduction of a minimum of 0, a most likely reduction of 2 Log10 ID50, and a maximum
possible reduction of 4 Log10 ID50 per ml. Empirical verification of these estimated
levels of reduction has not been done to our knowledge.
Assumption used
in the model: Processing reduction is represented by a
triangular statistical distribution representing a reduction in ID50
during processing of (0, 2, 4 ) Log10
i.v. ID50/ml (minimum, most likely, and maximum).
Assumption used
in the model: The model assumes that infectivity is
reduced but not entirely eliminated from plasma and the product during
processing. Therefore, although the
amount of ID50 vCJD
agent may be reduced the percentage of pools and vials containing the agent
still remains the same.
III.B.3.
Ipp - Total i.v. ID50 present per pool of Factor XI post-processing
Ipp
= Iiv-pool x RW x
1/RLog
The total i.v. infectivity (i.v. ID50s) present in processed
product (Ipp)
is a function of the total infectivity present in the pool (Iiv-pool) prior to processing steps that might reduce
the amount of infectivity present in the final Factor XI product. The infectivity in the pool (Iiv-pool) is multiplied by RW
because only 800kg out of the original 5,000 kg (or 16%) of starting plasma
pool is used and multiplied by processing reduction steps (RLog), which are expected to reduce the
infectivity in the final Factor XI product by a most likely of Log10
2 (or 99%), or by a maximum level of Log10 4 (or 99.99%).
III.B.4.
YfT - Total
yield of Factor XI from plasma pool
Factor XI is present
in trace amounts in human plasma.
Assumption used in the model: The
estimated the yield of FXI per kg plasma was approximately 150 to 180 units,
subsequently the model estimates the total yield of Factor XI as 120,000 to
144,000 units per batch of 800 kg starting material. FXI was distributed in vials containing 1,000 units each. The term unit (u) is equivalent to the term
international unit (i.u.).
The yield of Factor
XI from the starting material was represented in the model by the equation:
YfT = WM x Yf-kg
III.B.4.a. Yf-kg
- Yield of Factor XI per kg of plasma
Yield in the model was estimated to be between 150
to 180 units of FXI per kg plasma This variable was represented in the model
using a uniform distribution with a minimum yield of 150 units and a maximum
yield of 180 units per kg of starting plasma material.
III.B.5.
Viu - Vial size or number of units per vial
It was assumed that each vial contained 1,000 units of factor XI.
III.B.6.
VT - Total number vials produced
The Factor XI
product was aliquoted into vials with approximately 1,000 units each, and the
total number of vials produced was estimated in the model by the simple
equation:
VT = YfT / Viu
III.B.7. Ivial - Total i.v. ID50 per vial
The total i.v. ID50
present in each vial of Factor XI
was estimated by dividing the total estimated i.v. ID50 per pool (Ipp) of starting material by the total number of vials produced. Calculations used in the model are
represented by the equation:
Ivial = Ipp / VT
or including all component variables by the equation:
![]()
![]()
DvCJD x DV x Ibl x Ipl-perc
Ivial = x RW% x 1/RLog (Wm x Yf-kg / Viu)
Aic-iv
Summary of variable names used above are:
DvCJD -
Total
number of vCJD donations per pool
DV - Amount of recovered plasma per donation
Ibl
- Infectivity of vCJD (or
i.c.ID50) present in infected blood
per ml
IPl-perc - Percentage
infectivity associated with plasma (i.c.ID50/ml)
Aic-iv - Adjustment for
intravenous route of infection
RW%
- Percentage of pool used to
manufacture Factor XI
RLog
- Log reduction in ID50s
during processing
Wm
- Portion of total product used
in manufacturing(800 kg).
Yf-kg
- Yield of Factor XI per kg of
plasma
Viu - number FXI units per vial
Factor XI normally circulates in the human bloodstream at a
concentration of approximately 50 u/dl and has been observed by some
researchers to be present at concentrations as high as 70 u/dl. Those with very severe Factor XI deficiency can have
< 15 unit per
deciliter (u/dl) of blood. The commonly
used treatment dose is 50 units per kg body weight. Individuals at risk for excessive bleed prior to surgery can
receive prophylactic treatment at the recommended dose in anticipation of
surgery. Because the half-life of FXI is approximately 52 hrs (Mannucci et
al 1994), patients may need additional post-surgical maintenance treatments
every 2 to 3 days to maintain therapeutic levels.
III.C.1. Total Dose for Pre- and Post-surgical treatment with Factor XI
Published data are available on the per surgical event
utilization of Factor XI (Mannucci et al 1994, Aldedort et al 1997) manufactured
in the U.K. so that potential
exposure to the vCJD agent can be estimated more accurately. It is difficult to determine the exact dose
given to each patient without the patient medical record because only the dose
per body weight of 50 u/kg is provided.
The scenarios described below approximate the amount of factor XI given
per patient to provide insight into the possible magnitude of risk. In this portion of the model we lay out
three possible scenarios:
Scenario 1 – Treatment of a 60kg individual with
Factor XI (50 u/kg) once during or
after surgery for a total patient dose
of approximately 3,000 units.
.
This is the most likely scenario, based on published usage information.
Scenario 2 - Treatment of a 60kg individual both pre- and post-surgery with a total of approximately 9,000 units of Factor XI.
Scenario 3
- Treatment of a 60kg individual
both pre- and post-surgery with a total of approximately 15,000 units of Factor
XI. .
While doses of this magnitude have been given, this dose would represent
a very uncommon scenario.
III.C.1.a. DPre
- Prior to major Surgery - doses of 50 u/kg
given
Assumption used in the model: The
dosage prior to surgery is approximately 50 u/kg body weight. This dosage scheme is represented in the
model with a point estimate.
DPre
= Dose (50 iu/kg) x Patient
weight (kg) x Number treatments
III.C.1.b. DPost -
Post-surgical
maintenance of 50 u/kg every 2 - 3 days
Assumption used in the model: The
post-surgery maintenance dosage is assumed to be 50 u/kg given every two to
three days. This dosing scheme is
represented in the model with a point estimate.
DPost = Dose
(50 u /kg) x Patient weight (kg) x
Number treatments
III.C.1.c. DT
- Total Factor XI doses given per patient per surgical procedure
The output
is a sum of all doses of Factor XI given pre- and post-surgery to prevent or
minimize bleeding by Factor XI deficient patients. The sum of doses is represented by the equation:
DTu = DPre + DPost
III.C.2. Scenario 1: Treatment 60 Kg individual
A 60 Kg person
receives one dose factor XI to minimize potential bleeding episodes at a
concentration of 50u/kg would receive a total of approximately 3,000 units.
Output is the estimated total units Factor XI received and estimated vCJD ID50
received. This dosing regimen for one IND using U.K. manufactured factor XI in the United States
is described in Aldedort et al (1997). It should
be noted that 12 of the patients in the study received 50 u /kg but one patient
in the study received only 20 u / kg.
III.C.3. Scenario 2: Treatment with 9,000 units Factor XI
Assumption used in the model: During
preparation and recovery from surgery the model assumes that a patient receives
a total dose of 9,000 units Factor XI to minimize potential bleeding episodes.
Output is the estimated total units Factor XI received and estimated vCJD ID50
received.
Scenario 2 is
similar to amounts of Factor XI given in three dosing regimens given at 50
units per kg body weight -one treatment given prior to surgery and two
treatments given during post-operative recovery (Mannucci et al 1994).
III.C.4. Scenario 3:
Treatment with 15,000 units Factor XI
Assumption used in the model: During
preparation and recovery from surgery the model assumes that a patient receives
a total dose of 15,000 units Factor XI to minimize potential bleeding
episodes. This scenario may involve a
60 kg individual that receives approximately five treatments both prior to and
following surgery at a dose of 50 u/kg.
Output Scenario 3:
Estimated Total units Factor XI received and estimated vCJD ID50
received.
IV.
Risk Characterization
The risk characterization section of the risk assessment integrates the hazard identification, hazard characterization and the exposure assessment components to arrive at estimates of the risks posed by a hazard.
In this risk assessment data for hazard characterization are
lacking, so we could not the development of
a human vCJD dose-response was not possible. The dose-response relationship provides
information needed to use the exposure (dose) assessment results to estimate
the probability of adverse responses including infection, illness or mortality – based on assessment of exposure
(dose) to the hazard. Many TSE
models and risk assessments, including our model, use the ID50, or amount of material infectious dose
that leads to infection in 50% of the population, as a semi-quantitative
estimate of the amount of TSE agent.
It is possible to interpret the ID50 as representing a linear
dose-response relationship or linear relationship between exposure and the
probability of infection. In such a
case exposure to 1 ID50 would suggest a 50% probability of
infection, exposure to 0.1 ID50 would suggest a 5% probability of
infection, and so on. Given the limited
data available, FDA believes that any
extrapolation or interpretation has limited utility in actually estimating clinical outcomes
such as infection and illness. Therefore, any estimate of the risk based on
estimates of exposure to the vCJD agent through use of Factor XI will be
imprecise and extremely uncertain.
This risk assessment and model link the available scientific and epidemiological data together to mathematically approximate the processes (predicted presence of vCJD in U.K. population, manufacturing, reduction of vCJD agent, and patient utilization) leading to exposure of US patients to vCJD agent present in U.K.-manufactured Factor XI. A summary of the variables, parameters and equations used in the model were described in Section III. Exposure Assessment and a summary of the variables and equations are provided in Appendix A. Where data were not available, simplifying assumptions were used in the model and are detailed in the preceding documentation. Assumptions used in the model are presented in tabular form in Appendix B.
The model was run using @Risk software package (Palisades Corp, NY) to conduct the Monte Carlo analysis. Simulations of 10,000 iterations were run.
The model provided predictions of estimated exposure to the vCJD agent in the form of intravenous (i.v.) ID50 in patients treated with U.K.-manufactured Factor XI. Because an accurate dose-response relationship (or hazard characterization) for vCJD exposure and the probability of human illness has not been developed it is not possible to predict with any accuracy the probability of vCJD infection and illness in an individual exposed to the agent.
Results from the model are presented below in Table
4.1. The intravenous (i.v.) ID50
per single unit and per vial (of 1,000 units) of Factor XI was estimated by the
model. Additionally, results that
predict exposure for 3 scenarios depicting various levels of utilization that
approximate clinical treatment with FXI are presentedwere generated. Scenario 1
involves the treatment of a 60 kg individual prior to surgery with 50 units/kg
given to restore FXI levels to normal (Aldedort et al 1997). The patients in this scenario would likely
receive a total of approximately 3,000
units of factor XI. Scenario
2, and Scenario
3 assume a treatment regimen consisting of 9,000
units, and 15,000 units of FXI, respectively.
Clinical treatment under the three scenarios suggests patients may
receive significant levels of vCJD iv ID50 during
the course of treatment that may pose a risk of causing infection. It is not possible to estimate the precise
magnitude of risk faced by patients that received UK-manufactured FXI product.
Table
I – Potential eExposure
to vCJD agent i.v. ID50 via
Factor XI. Results are expressed as per
unit or vial of FXI. Hypothetical
scenarios provide an estimate of the magnitude of exposure to vCJD agent i.v.
ID50 that might occur
per surgery incident. A surgical
incident includes prophylactic treatment prior to surgery and possibly several
post-operative treatments with FXI.
|
|
Scenario |
Quantity*
Factor XI Utilized |
Mean vCJD(1) i.v. ID50 |
5th (1) percentile |
95th (1) percentile |
|
|
|
|
|
|
|
|
|
A
single unit FXI |
1 u |
2 x 10-5 |
6.8 x 10-7 |
7.0 x 10-5 |
|
|
One
vial FXI |
1,000 u |
2 x 10-2 |
6.8 x 10-4 |
7.0 x 10-2 |
|
|
Scenario 1: Treatment 3,000 u |
3,000 u |
6 x 10-2 |
2.1 x 10-3 |
0.21 |
|
|
Scenario 2: Treatment 9,000 u |
9,000 u |
0.17 |
6.2 x 10-3 |
0.6 |
|
|
Scenario 3: Treatment 15,000 u |
15,000 u |
0.28 |
1.0 x 10-2 |
1.0 |
Sensitivity (or importance) analysis is a process of varying
the value of variables in the model to identify those with the greatest
influence on the estimated risk outcome(s).
A simple sensitivity analysis of the Factor XI model suggests that the
estimated number of vCJD donations per plasma pool (DvCJD ) had the
greatest influence on the final risk estimate.
In the model DvCJD
was bounded by a 5th percentileminimum value of of 01 vCJD
donation per pool, a most likely estimate of 2 5(average of approximately 5) vCJD donations
per pool and a maximum value
of 95th percentile of
14 vCJD donations per pool. The second most influential factor in the model was the log
reduction of vCJD agent (RLog) during processing and manufacture of Factor
XI product. For RLog
it was assumed that the minimum level of reduction was 01,
the most likely level of reduction was 2 log10 and the maximum level
of reduction in agent that could occur was 4 log10.
Uncertainty arises from the absence of information or
availability of limited information. In
our probabilistic model statistical distributions are used to represent the
uncertainty of the information used in the model. We express the uncertainty of the final risk estimates generated
from the model using a mathematical mean (average) of exposure in ID50
units and the 5% and 95% confidence intervals for each estimate. The uncertainty for the risk estimates
generated from by
this the FDA FacFXItor XI risk
assessment model is significant and decision makers should use the results with
caution.
Many of the variables and parameters used in the
model have significant uncertainty associated with them – in some cases expert
opinion and assumptions were used to estimate the values and ranges of certain
parameters used in the model which will add to the uncertainty surrounding the
final risk estimates. In the future, additional research and
information may be substituted for assumptions or used to improve estimates for
the individual parameters and ultimately improve the precision of the final
risk estimates generated by the model.
Even considering the associated uncertainty of estimated
risks, risk assessment provides a best estimate of risk based on the current
and known information. It is still a
useful tool that informs the science-based decision making process. It can identify data gaps and research
priorities where additional research and information would have the greatest
impact on enhancing the final risk estimates.
Results from the sensitivity analysis in Section IV.C. indicated that the risk assessment
results are highly dependent upon
·
Eestimation
of the incidence
prevalence of
vCJD in the U.nited K.ingdom,, and in turn, the
parameter for vCJD donations per plasma pool (DvCJD ), and
·
Log reduction of vCJD agent (RLog) during the
manufacturing process
had the greatest influence on the final risk
estimate. Improved data
and surveillance studies on the estimated vCJD prevalence incidence in the U.K. would enhance the
precision of the
estimated number of incubating donors that would contribute to a plasma
pool. e estimates for this
variable and the resulting risk estimates from the model. Data from laboratory studies could improve the
estimate of the reduction
of vCJD during manufacturing. The
modeled estimates were based upon levels of reduction seen for a manufacturing
step that was similar in some but not all respects to that used for FXI. Likewise, direct
data were not available on the level of log reduction of vCJD agent (RLog)
during processing and manufacture of Factor XI product and
it was assumed that the level of reduction was similar to that of similar steps
used in the manufacture of other coagulant products. Again, more precise information would improve estimates from the
model.
No data are available on the level of infectious units or ID50 units present in the bloodstream of vCJD infected individuals at the time of blood donation. The model extrapolates an estimate of the level of vCJD agent that might be present in human blood based on data from several animal models. However, the presence and level of agent present in an infected individual at the time of blood donation could differ from our assumption and this adds to the uncertainty of the risk assessment outcomes.
The model estimates exposure to the vCJD agent in the form of intravenous ID50 units. Data are not available to estimate the probability of various clinical outcomes, such as infection or illness that might be predicted to arise from exposure to a particular level of agent. Therefore, we did not estimate a probability of infection or illness in our model. However, a meaningful dose-response model will need to be generated for vCJD exposure in humans to estimate the probability of adverse clinical outcomes for humans. Until then, estimates of the probability of vCJD infection or illness arising from exposure to the agent are extremely uncertain and should be viewed with caution.
Potential exposure to vCJD agent present in Factor XI manufactured in the U.K. and used during investigational studies in the U.S. from 1989 to 1997 was estimated in this probabilistic risk assessment.
Although
nNo U.K.-manufactured FXI product distributed in the
U.S. during the 1990s is known
to have been manufactured from “implicated” batches that may have contained
donations from an individual(s) later diagnosed with vCJD, .
i It
is possiblelikely
that most FXI product manufactured from U.K. plasma in the
UK in the 1990s may have been manufactured from plasma pools that
contained a plasma donation(s) from an individual that was incubating may
have been infected with vCJD. To date,
no recipients of plasma derivatives in the U.K. or elsewhere have been
diagnosed with vCJD. However, given the
potentially prolonged incubation times for human TSEs, it is still
theoretically possible that such transmissions occurred are
are yet to be identified.
The likelihood of exposure to the vCJD agent via UK
manufactured Factor XI was assumed to be nearly 100%. Although exposure did occur it is not possible to provide a
precise estimate of the vCJD risk to patients that may have used Factor XI
manufactured in the UK in the 1990s.
Appendix
A
Summary
of Model Components
|
Variable
name |
Input |
Numerical
input / output |
|
|
A. Total intravenous vCJD infectivity ( i.v. ID50 ) per plasma pool |
|
|
|
Inputs
|
|
|
|
|
A.1. |
Probability
individual has vCJD in U.K. population |
PvCJD |
1
/ 4,225 (5%
CI = 1 / 1,452) (95%
CI = 1 / 20,280) |
|
A.2. |
Total
number of donations per pool |
DT |
20,000
donations |
|
A.3. |
Total
number of vCJD donations per pool |
DvCJD |
Triangular distribution Minimum =
0 donations Most
likely = 2 donations Maximum = 14 donations |
|
A.4.a. |
Amount
of recovered plasma per donation |
DV |
200
mls |
|
A.4.b. |
Infectivity
of vCJD in infected blood per ml |
Ibl |
Triangular distribution Minimum =
0.1 ID50 Most
likely = 10 ID50 Maximum = 1,000 ID50 |
|
A.4.c. |
Percentage
infectivity in plasma (ID50/ml) |
Ipl-perc |
58% |
|
A.4.e. |
Adjustment
for intravenous route of infection |
Aic-iv
|
Uniform distribution Minimum = 5 Maximum = 10 |
|
Outputs |
|
|
|
|
A.4.d. |
Total
infectivity (or i.c.ID50) per vCJD donation |
ID = DV x Ibl x Ipl-perc |
|
|
A.5. |
Total
i.v. ID50
per plasma pool of 20,000 donors |
Tiv-pool
= DvCJD
x ID
|
|
|
Summary
of output at this point in the model: Tiv-pool
= DvCJD
x DV x Ibl x Ipl-perc
Aic-iv |
|||
|
|
|
|
|
B. Total i.v. ID50 per vial after processing / production of Factor XI |
|
|
|
Inputs
|
|||
|
B.1.a. |
Weight
of starting product |
Wst |
5,000
kg |
|
B.1.b. |
Portion
removed and used to extract Factor XI |
Wm |
800kg |
|
B.1. |
Percentage
of pool in manufacture Factor XI |
RW% = Wm / Wst |
0.16 |
|
B.2. |
Log
reduction in ID50s during processing |
RLog |
Triangular distribution Minimum = 0 log10 Most
likely = 2 log10 Maximum = 4 log10 |
|
B.4.a. |
Yield of Factor XI per kg of plasma |
Yf-kg |
Uniform distribution Minimum = 150 iu/kg Maximum = 180 iu/kg |
|
B.5. |
Vial
size or # iu per vial |
Viu |
1,000
iu |
Outputs
|
|||
|
B.3. |
Total
ID50
in Factor XI post-processing |
Ipp= Iiv-pool x RW x 1/RLog |
|
|
B.4. |
Total
yield of Factor XI from plasma pool |
YfT = Wm x
Yf-kg |
|
|
B.6. |
Total
number vials and vial size produced |
VT
= YfT /
Viu |
|
|
B.7. |
Total
ID50 per vial |
Ivial = Ipp / VT |
|
|
Summary
of output at this point in the model:
Aic-iv |
|||
|
|
|
|
|
B.
Total Utilization of
Factor XI
|
|
|
|
|
Inputs |
|||
|
C.1.a. |
Prior to major Surgery -
dose 50 iu/kg given |
DPre |
50
u/kg |
|
C.1.b. |
Post-surgical
maintenance of dose 50 iu/kg given every 2 - 3 days |
DPost |
50
u/kg |
Output |
|||
|
C.1.c. |
Total
Utilization of Factor XI
|
DTu = DPre + DPost |
|
Appendix
B
|
Section |
Variable and description |
Assumptions used in the model |
|
III. |
Not applicable |
The probability of at least one donation from a vCJD-infected individual being present in a plasma pool used to manufacture Factor XI in the U.K. is nearly 100%. |
|
III. A.1. |
PvCJD - Probability individual has vCJD in U.K. population |
An average |
|
III. A.2. |
DTpool - Total number of vCJD donations per pool |
Production of Factor XI included the pooling of plasma donations recovered from whole blood from approximately 20,000 donations |
|
III. A.3.a. |
DV - Amount of recovered plasma per donation |
The model assumes that approximately 200 milliliters (mls) of plasma can be separated away from the blood cells. |
|
III. A.3.b. |
Ibl - Infectivity of vCJD (or i.c.ID50s) present in infected blood per ml |
Whole
blood collected from a |
|
III. A.3.c. |
IPl-perc - Percentage infectivity associated with plasma (i.c.ID50/ml) |
The model uses the more conservative of the two outcomes and assumes that 58% of infectivity is associated with plasma. |
|
III. A.3.d. |
ID - Total infectivity (or i.c.ID50) per vCJD recovered plasma donation |
One
ID50 is the amount of material containing infectious agent that
has a 50% probability of causing infection in an individual or
population. |
|
III. A.3.e. |
Aic-iv - Adjustment for intravenous route of infection |
Exposure
to infectivity by the i.v. route is between 5 and 10 times less efficient at
causing infection than introduction via the intracerebral route. |
|
III.B.1. |
RW% - Percentage of pool used to manufacture Factor XI |
Approximately
16% of starting plasma material from 20,000 donations was used in the
manufacture of FXI. |
|
III.B.1.a. |
Wst - Weight of starting product |
Weight
of starting product is represented in the model by a single value point
estimate of 5,000 kg. |
|
III.B.1.b. |
Wm - 800kg portion removed and used to extract Factor XI |
800 kg of material was removed and used to produce Factor XI. |
|
III.B.2. |
RLog - Log reduction in ID50s during processing |
Processing
reduction is represented by a triangular statistical distribution
representing a reduction in ID50s during processing of (0, 2,4)
Log10 i.v. ID50/ml
(minimum, most likely, and maximum). |
|
The
model assumes that infectivity is reduced but not entirely eliminated from
plasma and the product during processing.
Therefore, although the amount of ID50 vCJD agent may be reduced
the percentage of pools and vials containing the agent still remains the
same. |
||
|
III.B.4. |
YfT - Total
yield of Factor XI from plasma pool |
The
yield of FXI per kg plasma was approximately 150 to 180 units, subsequently
the model estimates the total yield of Factor XI as 120,000 to 144,000 units
per batch of 800 kg starting material.
FXI was distributed in vials of 1,000 units each. |
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