FOOD AND DRUG ADMINISTRATION
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
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to its accuracy.
Meeting of:
TRANSMISSIBLE
SPONGIFORM ENCEPHALOPATHIES
ADVISORY COMMITTEE
September 18, 2006
Holiday Inn
Reported By:
CASET Associates
(703) 352-0091
TABLE
OF CONTENTS
Page
Administrative Remarks - Executive Secretary 1
Opening Remarks, Glenn Telling 8
Committee
Updates:
- US and Worldwide BSE 8
- vCJD epidemiology and transfusion transmission 26
- Draft Guidance for Industry: Amendment (donor 32
deferral for transfusion in
- Critical Factors Influencing Prion 39
Decontamination Using Sodium Hydroxide
- Human Prions: Clearance
and Plasma Lipoproteins 53
TOPIC
I: Experimental Clearance of
Transmissible
Spongiform Encephalopathy Infectivity
on
Plasma Derived FVIII Products 69
TSE Clearance studies for pdFVIII: Study Methods and 70
Clearance
Levels
Industry TSE Clearance Studies for pdFVIII 95
Open Public Hearing 116
- Statement by Dave Cavenaugh 118
Open Committee Discussion, Questions for the
Committee 122
Committee
Updates:
Status of FDA's Initiative on Communication of the 177
Potential
Exposure to vCJD Risk
Summary of WHO Consultation on Distribution of 184
Infectivity
in Tissues
Open Public Hearing 201
- Statement by Charles Sims 203
- Statement by Paul Brown 209
COMMITTEE
MEMBERS:
GLENN
C. TELLING, PhD, Chair.
VAL
D. BIAS, National
Hemophilia Foundation,
LYNN
H. CREEKMORE, DVM, USDA,
R.
NICK HOGAN, MD, PhD,
MO
D. SALMAN, DVM, PhD,
JAMES
J. SEJVAR, MD, CDC,
RONALD
S. BROOKMEYER, PhD,
BERNADINO
GHETTI, MD,
SUSAN
F. LEITMAN, MD, Department
of Transfusion Medicine, NIH,
JAMES
W. LILLARD, Jr., PhD,
MICHAEL
D. GESCHWIND, MD, PhD,
JAMES
MASTRIANNI, MD, PhD,
MARK
R. POWELL, PhD, USDA,
LAURA
K. MANUELIDIS, MD,
CONSUMER
REPRESENTATIVE:
NON-VOTING
INDUSTRY REPRESENTATIVE:
TARYN
ROGALSKI-SALTER, PhD, Merck & Company, Inc., PA
EXECUTIVE
SECRETARY:
WILLIAM
FREAS, PhD, CBER,
FDA,
COMMITTEE
MANAGEMENT SPECIALIST:
ROSANNA
L. HARVEY, CBER,
FDA,
P R
O C E E D I N G S (8:30 a.m.)
Agenda
Item: Administrative Remarks.
DR. FREAS: Good morning, and welcome to the 19th session
of the transmissible spongiform encephalopathy advisory committee. I am Bill Freas. I am the executive secretary
for today's meeting.
As announced in the Federal Register,
and amended in the Federal Register, today's meeting and tomorrow's meeting are
open to the public and the public is welcome to attend both days.
At this time, I would like to go
around the head table and introduce the committee members to the public. Would
the members please raise their hand when I call their name. I will be starting at the right side of the
room at the audience's right.
In the first chair is Dr. Sue Priola,
senior investigator, laboratory of persistent and viral diseases, Rocky
Mountain Laboratories.
The next chair is empty right now, but
it will soon be occupied by Dr. Michael Geschwind, assistant professor of
neurology,
The next chair is our consumer representative,
Ms. Florence Kranitz, president of the CJD Foundation,
The next chair is empty and that will
be soon occupied by a new committee member, Dr. Laura Manuelidis, professor and
head of neuropathology, Yale University School of Medicine.
Next we have David Gaylor, president
of Gaylor Associates,
Next we have our industry
representative, Dr. Taryn Rogalski-Salter. director of
Next we have Dr. Nick Hogan, associate
professor of ophthalmology, University of Texas Southwestern Medical School.
Next we have Dr. Mo Salman, professor
and director, animal population health institute,
Around at the head of he table is our
chair, Dr. Glenn Telling, associate professor, department of microbiology,
immunology and molecular genetics,
Next we have Ms. Jan Hamilton, advocacy
director, Hemophilia Foundation of America.
Next is another new member to this
committee, Dr. Mark Powell, risk scientist, office of risk assessment and cost
benefit analysis, U.S. Department of Agriculture.
Around he corner of the table we have
Dr. James Lillard, associate professor of microbiology, Morehouse School of
Medicine.
In the next chair we have Dr.
Next we have Dr. James Sejvar,
neuroepidemiologist, division of viral and rickettsial diseases, Centers for
Disease Control and Prevention.
Next we have Mr. Val Bias,
co-chairman, blood safety working group, National Hemophilia Foundation,
Next we have another new member, Dr.
Ronald Brookmeyer, professor, department of biostatistics, Bloomberg School of
Public Health,
Next, Dr. Susan Leitman, chief, blood
services section, department of transfusion medicine, National Institutes of
Health.
Next is another new member, Dr. James
Mastrianni, assistant professor of neurology,
Next we have Dr. Richard Colvin,
center for immunology and inflammatory diseases,
The empty chair will soon be filled by
Dr. Richard Johnson, professor of neurology,
Dr. Bernardino Ghetti could not be
with us at today's meeting. I would like to welcome everyone else and thank you
for coming.
Now I would like to read the conflict
of interest statement into the record. The Food and Drug Administration is
convening today's meeting of the transmissible spongiform encephalopathies
advisory committee under the Federal Advisory Committee Act of 1972.
All members of the committee are
special government employees or regular federal employees from other agencies,
and are subject to federal conflict of interest laws and regulations.
The following information on the
status of the committee's compliance with the federal conflict of interest
laws, including but not limited to, 18 US Code 208 and 21 US Code Section
355(n)(4) is being announced in today's meeting and will be part of a public
record.
FDA has determined that members of the
committee are in compliance with the federal ethics and conflict of interest
laws, including but not limited to 18 US Code section 208, and 21 US Code
section 355(n)(4).
Under 18 US Code 208, applicable to
all government agencies, and 21 US Code 355(n)(4), applicable to certain FDA
committees, congress has authorized FDA to grant waivers to special government
employees who have financial conflicts when determined by the agency's need for
that particular individual's services outweighs his or her potential conflict
of interest, section 208, and where participation is necessary to afford
essential expertise, section 355.
Members of the committee, including
consultants, appointed as temporary voting members, appointed as temporary
voting members, are special government employees or regular federal employees.
They have been screened for potential
conflicts of interest of their own as well as those imputed to them including
those of their employer, their spouse, minor child.
For the discussion topics, topic one,
which is experimental clearance of transmissible spongiform encephalopathy
infectivity in the plasma derived factor VIII products, and topic two, which is
possible criteria for approval of donor screening tests for vCJD, these
interests may include consulting, expert witness, testimony, contracts, grants,
CRADAs, teaching, speaking, writing, patents and royalties and primary
employment.
Today's agenda topics are considered
general matters discussions. In accordance with 18 US Code Section 208(b)(3),
general matters waivers have been granted to the following:
Drs. Ronald Brookmeyer, Michael
Geschwind, Bernardino Ghetti, James Lillard, Laura Manuelidis, and James
Mastrianni.
Previously approved waivers for Mr.
Val Bias, Dr. Lynn Creekmore, Dr. Nick Hogan, Ms.Florence Kranitz,
Dr. Glenn Telling, Dr. Mo Salman, are in effect for this meeting.
A copy of the written waiver statement
may be obtained by submitting a written request to the agency's freedom of
information office, Room 12-A-30, of the
Dr. Taryn Rogalski-Salter is serving
as the industry representative acting on behalf of all related industries and
is employed by Merck Laboratories.
Industry representatives are not special government employees and they
do not vote.
With regard to the FDA's guest
speakers, the agency has determined that information provided by these speakers
is essential.
The following information is made public
to allow the audience to objectively evaluate any presentations and comments
made by the speakers for topic one:
Dr. Lisa Ferguson is employed by USDA
in
In addition, there are regulated
industry and outside organization speakers at today's meeting making
presentations.
These speakers may have financial
conflicts of interest associated with their employer and with other regulated
firms.
These individuals who were invited
here to represent their companies, these individuals were not screened by FDA
for their conflicts of interest, since they are representing regulated
industry.
This conflict of interest statement
will be available for review at the registration table. We would like to remind
members that, if discussions involve any products or firms not already on the
agenda, for which they have a personal or imputed financial interest, they need
to exclude themselves from such involvement, and their exclusion will be noted
for the record.
FDA encourages all meeting
participants to advise the committee of any financial relationships that they
may have with firms that could be affected by the committee discussions.
So ends the reading of the conflict of
interest statement. Before I turn the microphone over to the chair, I would
like to ask, if you have a cell phone, please put it in the silent mode, so
that you won't disrupt those sitting next to you. Dr. Telling, I turn the
meeting over to you.
Agenda Item: Opening Remarks.
DR. TELLING: Thank you, Bill. I would
like to also welcome everybody here today. We have a full agenda so, without
further ado, I think we will get on to the committee updates. The first speaker
is going to be Dr. Ferguson, who will update us on
Agenda Item: Committee Updates. US and Worldwide BSE.
DR. FERGUSON: I am just going to go through. If you have my
handout, you see I have a whole bunch of slides, but I am going to rip through
things pretty fast.
They are pretty straightforward
slides, just to update what is happening in regard to BSE around the world, and
then finally, in the
Just a reminder for everybody, total
cases worldwide still is greater than 189,000 cases. Again, most of those, actually greater than
96 percent, have still occurred within the
So, when you still see all these
numbers of cases, the vast majority of that reflects what happened in the
If you are interested in current
totals, the OIE's web site actually has fairly good numbers, fairly updated
numbers, about all countries that report cases.
Let's start off and talk about what
has happened in the European Union. EU monitoring, since 2001, they have done
very intensive surveillance, mandated by legislation.
In 2005, they have recently released
their compiled report on all of the monitoring that went on in 2005, greater
than 10 million tests in all the 25 member countries, in cattle.
Of those, about 1.5 million are what
they call risk animals, which would be the same as our targeted population in
the United States, and 8.6 million approximately are animals either 24 or 30
months old at slaughter.
Of that, 561 positive cases, 448 of
those are in their risk or suspect animals, and 113 in the healthy slaughter
population.
Again, in 2005, same as in 2004, both
the number of cases and the overall prevalence in tested animals continues to
decrease. The number of cases decreased
by about 35 percent, overall prevalence by about 29 percent.
These reductions in the number of cases,
also the increasing age of positive cases -- if you read their report, there is
a lot of very good information about age of cases and how that progresses over
the years. I didn't include that there, because that would have made me go on
for far too long this morning.
Both of those do indicate success of
control measures in
The peak of exposure actually appears
pretty well defined in a few of the member states. This is the same as it was
last year, which is a good indication.
Either that is when the control
measures really started to kick in or, more important, it could also be an
indication of the increased surveillance that began in 2001. It is a little bit
early to tell.
They are also doing significant
monitoring in small ruminants, 614,000 tests in sheep and goats. Of that, 959
positives. Obviously, most of that is scrapie. They had no confirmed BSE cases
in small ruminants this year.
Just to show you what has happened
over the past five years within Europe, as you see, total number of positives
by year, and that is decreasing every year, the same thing here in the risk or
suspect animals versus healthy slaughter.
Those are very good indication that
the control measures that they have in place in Europe are working and are
doing the job that they are supposed to do.
Let's move to North America and a
brief update here on BSE in Canada. As a
reminder, Canada has been doing active surveillance, targeted surveillance, in
the population where they are most likely to find disease since 1991.
As everybody knows, in 2003, they
identified their first native case, in May of 2003. After that period, they
significantly increased their surveillance.
So, these are just their numbers, in
2003, about 5,700 samples, two positives. One was the one that we found here in
the United States in Washington State in December of 2003. So, increasing their surveillance again, with
no cases in 2004, two in 2005, and five to date in 2006.
They did provide a very detailed
epidemiological summary that was made public in January of this year. They are continuing that work and hopefully
will have some more updates out fairly soon.
What this summary shows, it really
talks about their geographic cluster theory, and the idea that the links
between rendering, feed production, livestock production, tend to occur in
clusters, in a fairly well defined geographic area. It is only logical, then, that that would be
where the disease could cycle, would be in that type of a cluster.
What this report shows, which went
through the first five cases, I believe, it does define links between most of
these cases and links in this cluster.
There are also linkages in the more
recent cases, again, to that same cluster and, as I mentioned earlier,
hopefully they will be putting out some more updates with as good epi work in
the near future.
To focus a bit on Japan, BSE was first
identified in Japan in late 2001. Actually, it was September 2001. They imposed
a feed ban, than, after that first diagnosis. So, the feed ban has only been in
place since 2001.
Here is the number of cases. It stays
about the same here until the past two years, where it has jumped up a bit.
One note about Japan. A lot of their
surveillance and the testing numbers that you see have been primarily in
clinically normal animals, or animals presented at slaughter.
It has only been since about 2004 that
they have really increased their focus on the targeted animals or the risk
population, as we would define it.
Now, let's move to the United States.
As everybody knows, we have been doing active surveillance in the United States
since 1990, and we are targeting the population where the disease is most
likely to be diagnosed. That is the most efficient way for us to conduct a
surveillance system.
The assumption is that if we can't
find disease in that population, then it is even more unlikely for us to find
it in the non-targeted population.
So, we can use the data that we get
from that targeted sampling to extrapolate information to the broader cattle
population.
Our targeted population has always
been, and continues to be, those animals that have some type of a clinical
abnormality that could even remotely be considered consistent with BSE.
So, these would be non-ambulatory
animals, dead stock, which are animals that die for some unexplained reason,
central nervous system cases, either called to our field people or on farms.
We work with veterinary diagnostic
labs, public health labs, for rabies negative animals, and then we also work
with our colleagues in FSIS, for those animals that are condemned on
ante-mortem inspections when presented to slaughter.
Everybody knows we ran an enhanced BSE
surveillance program that began in June 2004. Our initial intention was to run
that for 12 to 18 months, with the goal of getting as many samples from the
targeted population as we could.
We actually ran on a bit longer than
the 18 months and ran through August of 2006, greater than 785,000 tests during
that whole enhanced program. During that
time frame, there were two positives identified during that effort.
Just to show on a monthly basis what
we did in our enhanced program, as you can see, there is a little bit of a
cycle.
With the population that we are
sampling -- these are animals that are clinically abnormal in some way, and
with the facilities where we were collecting, these are animal disposal
facilities, rendering facilities, 3D, 4D, salvage slaughter plants.
Animals tend to get sicker, die, be
culled in the winter. So, we always had a little peak in the winter. I just
wanted to show folks, most folks don't quite understand exactly where we were
sampling and why that might occur.
Let me explain a bit about OIE
standards. These are the international animal health standards for BSE
surveillance.
This reflects changes to those
standards in May 2005. This is what we are using as our guidance for how we do
surveillance from here on out.
It is a weighted point system.
Previously it was a simple table that said if you had cattle population X, you
need to get Y number of samples.
Now it is an interesting system where
it recognizes that you are more likely to find the disease in certain
subpopulations.
So, you get more points for that
population where you are most likely to find the disease. We have four
surveillance streams.
They are clinical suspect, which would
be those animals with really pretty classic clinical signs of BSE, causality
slaughter -- these would be those animals -- these are European terms,
sometimes they fit with North American terms, sometimes they don't.
Casualty slaughter are those animals
that are clinically abnormal. They would be condemned on antemortem inspections.
So, these are those non-ambulatory
animals, could be the very weak, emaciated, thin, just some type of a subtle
abnormality.
Fallen stock are dead stock,
essentially, those animals that die for unknown reasons. Then, healthy
slaughter is pretty self explanatory.
I don't know if you can actually read
this. Hopefully you can. This shows the point system where it recognizes that
you are most likely to find disease here in a clinical suspect.
So, you get 750 points for a clinical
suspect between four and seven years old. That subpopulation is where you are
really most likely to find disease if it is present.
You get essentially limited points for
sampling in routine slaughter. So, what countries can do to use this table, you
can access whatever population you like to meet the standards, and then the
table says you need to get X number of points for a certain design prevalence,
300,000 points over a seven year period at a design prevalence of one in
100,000.
So, a country can then use this table
and figure out what type of samples in what population they want to sample to
reach those numbers of points.
So, you could sample a pretty small
number of clinical suspects and reach that point value, or design prevalence,
or you can sample a much higher number of routine slaughters. It recognizes that you can access both of
those populations. It is just how many samples you want to get.
We did a summary of not only our
enhanced surveillance program, but also what we have done for surveillance for
the past seven years. That was made public in April of this year.
Just to give you kind of a graphic
example of how to do this point system, these are the points that we obtained
in our surveillance for the past seven years.
So, close to three million OIE points
over the past seven years in the different surveillance streams. For those who
ask about this healthy slaughter one, knowing that we really are not sampling
healthy slaughter animals, this is a function of our data base.
Especially in some of these earlier
years, our data might be somewhat limited. If we could not pull out of the data
base a specific clinical sign, to assign this to one of the other surveillance
streams, by default it would go into the healthy slaughter for this calculation.
So, with that summary of data, not
only did we put out there just a raw data summary, we also did an estimate of
BSE prevalence in the United States.
We used two methods to do this. One is
the BsurvE model, which is a model developed by the Europeans with some input
from our colleagues down under in New Zealand.
It looks at what we know from the
epidemiology of the disease in Europe and factors in population data when
animals are most likely to leave the population.
It can be used to help a country set
up a surveillance system, can also be used to estimate prevalence.
We then also tweaked this model a bit
and came up with what we call the Baysian birth cohort model, which
incorporates what we would expect to see the effects of a feed ban, which the
Bsurv doesn't show, and it also sets up some linkages between birth cohorts.
We also did several sensitivity
analyses in this report, just to make sure that our assumptions weren't way off
base.
The overall conclusion was that the
BSE prevalence in the United States is very low, less than one infected animal
per one million adult cattle.
If you are interested in most likely
values, with the Bsurv model the most likely value was seven infected animals,
with the BBC model the most likely value was four.
With the sensitivity analyses, those
values ranged from one up to about 40, which all of those then led us to this
conclusion, pretty solid, that the prevalence is less than one infected animal
per one million cattle.
So, what are we doing now and where
are we going from there? We have used these same methods and have moved forward
into what we call ongoing surveillance.
We have been transitioning here since
the end of August. What we figure is about 40,000 samples per year, again,
still from this targeted population.
This will allow us to continue to
monitor the status of U.S. cattle and will allow us to detect prevalence if it
starts to increase.
We did this calculation, again, based
on our analysis of the enhanced surveillance data and using the Bsurv model.
We first of all looked at OIE
recommendations, which are at a design prevalence of one in 100,000. We wanted
to make that a bit more sensitive. We wanted to stick with one per one million.
So, we used the Bsurv model to estimate sample numbers and points.
Again, think of that basic premise
that I described for the OIE, with a different number of points for different
subpopulations.
With this, we need to get three
million analytical points over a seven year time frame. When we look at what we
did in enhanced, we averaged about 9.5 points per sample. So, we just divided
and that gets you to about 40,000 samples per year, assuming we will get the
same average points over a seven year time frame.
That is a very quick run through of
both an update of what is going on in the world, what the international
standards are, and where we are headed in the future. I think I have time for
questions.
DR. TELLING: Yes, you do. Thank you, Dr. Ferguson.
Are there any questions?
DR. GESCHWIND: Dr. Ferguson, when you were talking about the
Japanese cases, could you comment about the ages of the animals?
Before 2004, I believe they were
testing every cattle within a certain age range, and that they did find BSE
cattle among those that would not be identified with the current methods in the
United States. Can you comment on that?
DR. FERGUSON: I am not quite sure what you expect me to
comment on. I think as we all know Japan, in 2001, by their regulations,
required that every animal slaughtered, regardless of age, be tested for BSE.
They have recently changed that reg
slightly, and it is only animals 20 months of age and older be tested at
slaughter.
They did find two animals, a 21 month
old and a 23 month old -- unless my memory escapes me at this point in time --
young animals, apparently normal at slaughter.
They were positive on the screening
tests, negative on IHC, and then positive again with the way Japan has done the
western blot.
They have put those into mice to see
if there is transmission. To the best of my knowledge, those results aren't out
there yet, but there is no indication that they have gotten any signs of
disease in those mice.
Perhaps some of the researchers in
this group can clarify that, if I am mistaken on that point. That is the
situation in Japan.
DR. EPSTEIN: Lisa, my question is, does USDA have
information about food chain controls in non-U.S. countries? Are we in a
position to comment how adequate the food chain controls are from country to
country?
DR. FERGUSON: I can speak for AFIS per
se, since we are not the food safety group. That is really not part of the
information that we have.
Our colleagues in FSIS, through their
equivalency evaluations, work with certain countries, will have some
information on essentially the red meat inspection and control, similar to what
they would do in the United States. They would have that type of information. I
am not sure how much further in the food chain you need to go beyond that.
MS. KRANITZ: Dr. Ferguson, in the United Kingdom and Japan
they have found cases of BSE in animals that are not symptomatic. So, I would like to know why the USDA doesn't
consider random sampling of healthy stock.
DR. FERGUSON: I think it is shown in
that OIE table. We all recognize that you can pick up disease in animals before
they begin to show clinical signs.
It all comes down to what is the
purpose of your surveillance program and how do you best accomplish that
purpose.
In the United States, the purpose of
our surveillance program is animal health monitoring, to help us define either
the presence or the absence of disease in the U.S. cattle population.
The purpose is not to identify each
and every individual case of BSE that might be out there. In fact, that is an
impossibility to do with current test methods that are there.
So, we have chosen the most efficient
way by targeting that population where we are most likely to find disease if it
is present, to give us sufficient information to help us define the status of
the U.S. cattle population.
DR. MANUELIDIS: As a point of information, how many cows,
adult cows, are there in the United States, so that the 459,000 that were
tested is what percentage of the population versus Japan.
Then the second question is, the
Japanese found more cases. Would you sort of compare a little bit or say
something about the method of testing and the adequacy of the American testing
method in its generality as compared to the more extensive Japanese testing and
European testing.
DR. FERGUSON: Let me make sure I remember it. The first
question was about adult cattle populations. We estimate adult cattle
populations to be about 42 million currently.
I haven't done those numbers. I am not
going to stand up here and do math in my had and divide 759,000 over 42
million. I will let you guys do that, if you so choose.
As far as the adequacy of our
surveillance efforts in the United States compared to other countries, we feel
very comfortable and very solid with the information that we have obtained,
both over our enhanced efforts for the past two years, and all of the
surveillance that we have done prior to that.
The prevalence estimates that we have
done uses some very solid analytical methods, we believe, to come to the
conclusions that we have.
So, we feel like the surveillance that
we have done, targeted in the population that we have, is sufficient to help us
define what is going on in the United States.