European Blood Directive

1. European Blood Directive

2. Disclaimer • I have no official status as a spokesperson for the EU, EC, or Member States • I present a personal view of the EU Directives • Selected requirements of the directives are presented. Those not included should not be regarded as any less important than those covered • Some wording may have been amended for purposes of clarity and the directives themselves should be referenced for definitive text

3. Outline • Why is a directive required? • Directives – ‘mother’ and ‘daughter’ • Directives and Legislation • Definitions • Member States and Blood Establishment Responsibilities • Guidance Document

4. Why is a directive required? • “Community provisions should ensure that blood and its components are of comparable quality and safety throughout the blood transfusion chain in all Member States, bearing in mind the freedom of movement of citizens within Community territory”

5. Why is a directive required? • In order to ensure that there is an equivalent level of safety and quality of blood components, whatever their intended purpose, technical requirements for the collection and testing of all blood and blood components including starting materials for medicinal products should be established by this Directive

6. Directives

7. National Responsibility • Responsibility for the organisation of health services and the provision of medical care should remain the responsibility of each Member State

8. Transposition • A Directive of the EU places obligations upon Member States • Member States are required to bring into force laws, regulations and administrative provisions necessary to comply with a Directive • This process of transposition is carried out independently by each MS

9. UK Transposition • Statutory Instrument • The Blood Safety and Quality Regulations 2005 • The Blood Safety and Quality (Amendment)(No2) Regulations 2005 • Designation of the ‘Competent Authority’ • Licensing • Regulations • Criminal offences and penalties

10. Articles • Objectives • Scope • Definitions • Implementation • Licensing (etc) of blood establishments • Hospital blood banks • Provision for existing establishments • Inspection and control measures

11. Articles • Responsible person • Personnel • Quality systems for blood establishments • Documentation • Record Keeping • Traceability • Notification of SAE and SAR

12. Articles • Provision of information to prospective donors • Information required from donors • Eligibility of donors • Examination of donors • Voluntary and unpaid blood donation • Testing of donations • Storage, transport and distribution conditions

13. Articles • Quality and safety requirements • Data protection and confidentiality • Information exchange • Reports • Penalties • Regulatory procedure • Technical requirements • Consultation of scientific committees • (Final provisions – 4 articles)

14. Objectives • This Directive lays down standards of quality and safety of human blood and of blood components, in order to ensure a high level of human health protection.

15. Definitions • ‘blood establishment’ shall mean any structure or body that is responsible for any aspect of the collection and testing of human blood or blood components, whatever their intended purpose, and their processing, storage, and distribution when intended for transfusion. This does not include hospital blood banks • ‘hospital blood bank’ shall mean a hospital unit which stores and distributes and may perform compatibility tests on blood and blood components exclusively for use within hospital facilities, including hospital based transfusion activities

16. Impact on hospital blood banks • Hospital blood banks are hospital units which perform a limited number of activities, storage, distribution, and compatibility tests • Only provisions relevant to these activities should apply to hospital blood banks.

17. Implementation • Member States shall designate the competent authority or authorities responsible for implementing the requirements of this Directive. • UK BSQR: The Secretary of State is designated the competent authority for the purpose of the Directive • MHRA is the designated government agency

18. Implementation • This Directive shall not prevent a Member State from maintaining or introducing in its territory more stringent protective measures which comply with the provisions of the Treaty.

19. Licensing of Blood Establishments • Member States shall ensure that activities relating to the collection and testing of human blood and blood components, whatever their intended purpose, and to their preparation, storage, and distribution when intended for transfusion, are undertaken only by the blood establishments which have been designated, authorised, accredited or licensed by the competent authority for that purpose.

20. Verified activity • The competent authority, having verified whether the blood establishment complies with the requirements set out in this Directive, shall indicate to the blood establishment which activities it may undertake and which conditions apply • The competent authority may suspend or revoke the designation, authorisation, accreditation or licence of a blood establishment if inspection or control measures demonstrate that the blood establishment does not comply with the requirements of this Directive.

21. Inspection • Member States shall ensure that the competent authority organise inspections and appropriate control measures in blood establishments to ensure that the requirements of this Directive are complied with. • Inspection and control measures shall be organised by the competent authority on a regular basis. The interval between two inspections and control measures shall not exceed two years.

22. Inspection • Such inspection and control measures shall be carried out by officials representing the competent authority who must be empowered to: • inspect blood establishments as well as facilities of any third parties on its own territory entrusted by the holder of the (...) licence referred to in Article 5 with the task of carrying out evaluation and testing procedures pursuant to Article 18; • take samples for examination and analysis; • examine any documents relating to the object of the inspection...

23. Responsible Person • Blood establishments shall designate a person (responsible person), responsible for: • ensuring that every unit of blood or blood components has been collected and tested, whatever its intended purpose, and processed, stored, and distributed, when intended for transfusion, in compliance with the laws in force in the Member State, • providing information to the competent authority in the designation, authorisation, accreditation or licensing procedures as required in Article 5, • the implementation of the requirements of (relevant articles) in the blood establishment.

24. Responsible Person • Qualification criteria • Experience criteria • Notified to CA

25. Quality System • Member States shall take all necessary measures to ensure that each blood establishment establishes and maintains a quality system for blood establishments based on the principles of good practice.

26. Traceability • Member States shall take all necessary measures in order to ensure that blood and blood components collected, tested, processed, stored, released and/or distributed on their territory can be traced from donor to recipient and vice versa. • With regard to blood and blood components imported from third countries, Member States shall ensure that the donor identification system to be implemented by blood establishments permits an equivalent level of traceability • Data needed for full traceability in accordance with this Article shall be kept for at least 30 years

27. Voluntary and unpaid blood donation • Member States shall take the necessary measures to encourage voluntary and unpaid blood donations with a view to ensuring that blood and blood components are in so far as possible provided from such donations.

28. Technical Requirements • Requirements that are further specified and adapted to technical and scientific progress • Traceability • Information to be provided to donors • Information to be obtained from donors • Requirements concerning suitability of donors and the screening of blood • Storage, transport and distribution requirements • Quality and safety requirements • Requirements applicable to autologous transfusions • Quality system requirements • Procedures for SAR and SAE notification

29. Guidance • 2005/62/EC: In order to ensure the highest quality and safety for blood and blood components, guidance on good practice should be developed to support the quality system requirements for blood establishments • No current EU guidance document • Council of Europe “Guide to the Preparation, use and Quality Assurance of Blood Components” has been in existence for many years • This is a non binding legal instrument as such but possibility to use it as a reference in national binding legal instruments • Council of Europe has a wider scope than the EU

30. Guidance • 16th Edition 2010 • 17th Edition in preparation • Discussions between CoE and EC • Likely to be increasing harmonisation over future editions