Review Memo - Categorical Exclusion - RiaSTAP

TO
STN: 125317/0 

FROM
Rebecca Olin , CSO, CBER/OCBQ/DMPQ/MRB2 

THROUGH
John A. Eltermann, Jr. , R.Ph., M.S.,
Director, DMPQ, HFM-670 

 Applicant:
CSL Behring GmbH, License# 1765 

PRODUCT
Human Fibrinogen Concentrate, Pasteurized 

SUBJECT
 Review Memo – Categorical Exclusion under 21 CFR 25.31(a) for Human Fibrinogen Concentrate, Pasteurized 

This is a request for a categorical exclusion from an Environmental Assessment under 21 CFR § 25.31(a).

This categorical exclusion request was submitted by CSL Behring as part of Biologics License Application 125317/0. The request for categorical exclusion has been reviewed and we conclude the request is justified because this submission involves a biological product that does not increase the use of the active moiety. Human Fibrinogen Concentrate (HFC) is fibrinogen (blood coagulation factor 1) that is isolated and purified from human plasma. Both fibrinogen and human plasma are substances that occur naturally in the environment. The final product container also contains human albumin, L-arginine hydrochloride, sodium chloride and sodium citrate; all naturally occurring substances. Other plasma products manufactured at the Marburg, Germany site include:
•Humate-P ®, Antihemophilic Factor/von Willebrand Factor Complex (Human), Dried, Pasteurized, and
•Vivaglobin ®, Immune Globulin Subcutaneous (Human).

HFC has been manufactured at the Marburg site since 1956 and with the same process since 1986 for the European market. The main difference is that U.S. plasma is now being used instead of European plasma.

___________________________________________
Rebecca Olin, CSO
CBER/OCBQ/DMPQ/MRB2

____________________________________________
John A. Eltermann, Jr., R.Ph., M.S.
Director, CBER, OCBQ, DMPQ
