The official blog of the Lung Institute.
Cellular therapy is classified as a treatment and not a drug. So what’s the difference?
A common question we receive at the Lung Institute is whether cellular therapy is approved by the FDA? As we’ve mentioned before, our cellular therapy procedures comply with FDA regulation; however, there are a variety of procedures involving Human Cells, Tissues and Cellular and Tissue-based products (HCT/Ps) that do fall under FDA regulation. The understandable follow-up is often why? The answer is that the need for regulation directly depends on several factors: are the HCT/P’s withdrawn and returned to the patient? Are they delivered to the patient within a same-day procedure? And are the cells that are being used manipulated, and to what degree? This simple distinction could mean the difference between being classified as a drug or a treatment.
With your health in mind, the Lung Institute is here to focus on HCT/P manipulation and treatment classification, providing a breakdown on the complexities of FDA regulation and giving you a concrete and simple answer to the question of Drugs vs Treatment: Where Cellular Therapy Stands with the FDA.
Minimally Manipulated (Treatment)
When it comes to FDA regulation of HCT/Ps, the primary distinction between treatments and drugs are whether they have been minimally manipulated or significantly manipulated. In the case of minimal manipulation, more often than not, a procedure will be exempt from further FDA regulation under the clauses provided in regulations 1271.10 and 1271.15.
Specifically, these three criteria must be met:
- The treatment must remove and implant the HCT/Ps into the same individual from whom they were removed
- The treatment must implant the HCT/Ps within the same surgical procedure (same day procedure); and
- The treatment must allow the HCT/Ps [to] remain in their original form (minimal manipulation)
If the treatment is able to meet these required regulations, particularly the “same procedure” clause, then it falls under the practice of medicine as a surgical procedure.
On the other hand, in regard to HCT/Ps that are determined to be more than minimally manipulated—or significantly manipulated—they immediately fall under the category of drugs and must, therefore, follow further FDA regulation. During this process, an HCT/P classified as a drug must follow the appropriate steps of a typical Investigational New Drug (IND). It must first apply, then devote about 10-15 years to conducting clinical trials.
A notable example of changes to genetic material that can alter an HCT/P from minimally manipulated to significantly manipulated would be the use of amniotic membrane. If you were to decellularize the membrane and leave it as a whole sheet, this would be considered minimal manipulation. However, if you were to use this genetic material and turn it into a powder after decellularization, this would be considered more than minimal manipulation because the processing alters the membrane’s ability to serve as a membranous barrier, and ultimately drug manufacturing. The deciding factor rests in the integrity of the tissue.
Here’s the Short Version
- Our cellular therapies meet exemption status by the FDA due to the fact that they are not considered a drug.
- For a treatment to be considered a drug, it must be more than minimally manipulated before being introduced to a patient.
- For a cellular therapy to be considered minimally manipulated, the processing of cell or non-structural tissue must not alter any relevant biological characteristics of the cells or nonstructural tissues.
- Cells must be administered within same surgical procedure to meet FDA exclusion requirements.
Drugs vs Treatment: Where Cellular Therapy Stands with the FDA? And What This Means for You…
If you’re looking to take a more proactive approach to treatment, it’s time to consider cellular therapy. Rather than only addressing the symptoms of lung disease, cellular therapy may directly affect disease progression, may improve quality of life and pulmonary function within patients. For those who suffer from lung disease, a change in quality of life could mean the difference between struggling to walk to the mailbox and riding a bike.
If you or a loved one suffers from a chronic disease like COPD, pulmonary fibrosis, emphysema or other symptoms of lung disease, the Lung Institute may be able to help with a variety of adult cellular therapy options. Contact us today at (800) 729-3065 to see if you qualify for cellular therapy, and find out what cellular therapy could mean for you.
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