All Topics Flashcards
What sections of 21 CFR pertain to blood products?
Sections 600, 606, 610, and 640 relate to blood/biologics
Sections 1270, 1271 relate to tissues and stem cells
What is the difference between QA and QC?
QC focuses on evaluation of processes IN PROGRESS.
QA is not directly tied to a process’s performance. Broad.
A
A
What REGULATORY AGENCIES oversee transfusion medicine?
FDA, CMS
(all others are professional orgs, eg AABB or JCo)
Sentinel events & reporting
Sentinel events include patient deaths and near misses.
They are not required to be reported to JCo, but it is a good idea, and if JCo becomes aware of one, a root cause analysis must be undertaken within 45d of the sentinel event.
Juran’s Quality Trilogy
Planning
Control
Improvement
3 forms of validation qualification
Installation qualification - Environmental needs
Operational qualification - Device function, alerts, etc
Performance qualifications - Verifying capabilities for intended use
What must be reported in the validation of an LDT?
Sensitivity, specificity
Accuracy, precision
Range, reference intervals
How can competency assessment be performed? How often must it be done?
Direct observation
Recording & reporting
QC/PT
Upon initial hire, at 6mo, then annually therafter.
What are the roles and reporting for an independent quality unit?
Must have the means to address and correct deviations
Must report directly to leadership
Change control
Preventing unplanned changes to processes
Who assumes all responsibility for contracted work?
The contracting facility (NOT the contractor, or manufacturer)
How are biologic product deviations reported, and when?
Report to FDA using form 3486.
Must report within 45d of the cGMP deviation occurring. Product must leave control of manufacturer.
How frequently must customer feedback be collected in contract agreements?
Not defined by regulation, but often is good.
How many crossmatch PTs can you fail before being shut down?
Shutdown after second unsuccessful PT (unsatisfactory).
How often should devices or reagents be QC’d?
Depends on how critical they are, but most things are QC’d daily.
Larger and more complex equipment may be QC’d less frequently.
When and how should transfusion (and donor) deaths be reported?
Initial report to CBER within 1 day.
Full written report within 7 days.
Pareto chart
Bar graph used as a cause analysis tool.
Ishikawa diagram
AKA fishbone diagram, used to identify causes of error or manufacturing defects.
Distinguish between market recalls and withdrawals.
Recalls: More severe–violation of FDA manufacture laws. Ranges from class I (most severe) to III (most common).
Withdrawals: Not actually subject to legislation. Usually post-donation, done at blood supplier discretion.
Who can evaluate competency assessment?
No special person is required, but one cannot audit their own work.
SQUIPP
Safety
Quality
Identity
Potency
Purity
Distinguish between remedial action and corrective action
Remedial action alleviates symptoms of nonconformance
Corrective action addresses the cause of nonconformance
In what settings is licensure required for a blood center?
When engaging in interstate commerce