Biological evaluation of medical devices — Part 4: Selection of tests for interactions with blood — AMENDMENT 1
5.2.2 External communicating devices indirectly contacting blood
Delete the bullet points “cannulae”, “cell savers”, “intravascular catheters” and “blood collection devices”.
Replace “blood and blood product” with “saline and/or therapeutics” as follows:
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devices for the storage and administration of either saline or therapeutics, or both (e.g. tubing and bags); |
Add the bullet point “blood monitors with indirect blood contact” as the second bullet point.
5.2.3
Add “blood collection devices” as a second bullet point, “cannulae” as a fourth bullet point, “cell savers” as a sixth bullet point and “devices for the storage and administration of blood and blood products (e.g. tubing and bags)” as an eighth bullet point.
Delete “or indirect” in the third bullet point as follows:
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— |
blood monitoring devices with direct blood contact; |
6.1.2
Add the following text to the second paragraph after the sentence “Only direct or indirect blood-contacting parts should be tested.”:
For direct contact haemocompatibility testing (e.g. direct haemolysis, complement activation, coagulation, platelet activation, haematology, in vitro or ex vivo thrombosis), testing should be conducted using only the direct blood contacting components of the device to minimize interference of non-direct blood contacting components on the results. For extract-based haemocompatibility testing (e.g. indirect haemolysis), testing should be conducted using only the direct and indirect blood-contacting components of the device. The test article shall be described and a justification shall be provided if the test article includes device components that include different tissue contact than described above.
Replace the fourth paragraph with:
As many tests for haemocompatibility are recognized to be generally surface-contact dependent (e.g. direct contact haemolysis, complement activation, coagulation, platelet activation, haematology, and in vitro or ex vivo thrombosis), such tests do not apply to indirect contact applications. For externally communicating medical devices or components that have indirect blood contact, only an indirect contact haemolysis test is generally recommended.
6.1.4
Replace NOTE 1 with:
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NOTE 1 Changes in the manufacturing process (e.g. change in manufacturer), the use of different manufacturing aids that can affect the surface properties or the chemistry of the complete sterilized device can also impact haemocompatibility. |
6.1.6
Replace Table 1 with:
Table 1 Devices or device components and categories of appropriate testing for consideration
| Device examples |
Test category |
| Haemolysis |
Thrombosisc |
| In vitro |
In vivo or ex vivoa |
| Material-induced |
Mechanically-induced |
Coagulation |
Platelet activation |
Complementd |
Haematology |
| External communicating devices indirectly contacting bloode |
| Blood monitors with indirect blood contact |
X |
|
|
|
|
|
|
| Devices for storage and administration of saline and/or therapeutics (e.g. tubing and bags), extension sets |
X |
|
|
|
|
|
|
| External communicating devices directly contacting circulating bloodb |
| Blood collection devices |
X |
|
X |
X |
|
X |
|
| Blood administration sets and extension sets |
X |
Xf |
X |
X |
|
X |
|
Catheters in place for less than 24 h (e.g. atherectomy devices, intravascular ultrasound catheters, antegrade or retrograde coronary perfusion catheters, guide wires); cannulae |
X |
|
X |
X |
|
X |
X |
Catheters in place for more than 24 h (e.g. parenteral nutrition catheters, central venous catheters); cannulae |
X |
|
X |
X |
|
X |
X |
| Cell savers |
X |
X |
X |
X |
|
|
|
| Devices for adsorption of specific substances from blood |
X |
X |
X |
X |
X |
|
|
| Donor and therapeutic aphaeresis equipment and cell separation systems |
X |
X |
X |
X |
X |
|
|
| Cardiopulmonary bypass system and components |
X |
X |
X |
X |
X |
X |
X |
| Haemodialysis or haemofiltration equipment |
X |
X |
X |
X |
X |
X |
X |
| Leukocyte removal filter |
X |
|
X |
X |
X |
X |
X |
| Percutaneous circulatory support devices |
X |
X |
X |
X |
X |
X |
X |
| Implant devices |
| Annuloplasty rings, mechanical heart valves |
X |
X |
|
|
|
|
X |
| Embolization devices |
X |
|
|
|
|
|
X |
| Endovascular grafts |
X |
|
|
|
|
|
X |
| Implantable defibrillator and cardioverter leads |
X |
|
|
|
|
|
X |
| Intra-aortic balloon pumps |
X |
X |
|
|
|
|
X |
| Pacemaker leads |
X |
|
|
|
|
|
X |
Prosthetic (synthetic) vascular grafts and patches, including arteriovenous shunts |
X |
|
|
|
|
|
X |
| Stents (vascular) |
X |
|
|
|
|
|
X |
| Tissue heart valves, vascular grafts and patches and AV shunts |
X |
|
|
|
|
|
X |
| Total artificial hearts |
X |
X |
|
|
|
|
X |
| Vena cava filters |
X |
|
|
|
|
|
X |
| Ventricular-assist devices |
X |
X |
|
|
|
|
X |
6.1.11
Delete “(see also ISO 10993-2)” at the end of the second paragraph.
6.1.12
Replace the paragraph with:
The use of antithrombotics in in vivo and ex vivo tests should be avoided unless the device is designed to perform in their presence. Even if the device is designed to perform in their presence, the completion of studies without antithrombotics can also be required in order to properly assess the thrombosis risk to patients that cannot receive antithrombotics. The type and concentration of antithrombotic(s) used influence(s) blood/device interactions and their selection shall be justified. Devices that are used with antithrombotics should be assessed using them in the range of concentrations specified clinically and/or described in the product IFU or other appropriate literature. Species differences should also be considered when determining the appropriate level of antithrombotic(s).
Add the following NOTE at the end of this paragraph:
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NOTE Antithrombotics can consist of any combination of either antiplatelet drugs (e.g. acetylsalicylic acid, clopidogrel and glycoprotein IIb/IIIa receptor antagonists) or anticoagulants (e.g. unfractionated or low molecular weight heparin, warfarin and direct thrombin inhibitors), or both. |
6.1.14
Delete "see ISO 10993-2" and add the following NOTE after the paragraph:
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NOTE For more information on animal welfare, see ISO 10993-2. |
6.3.1
Replace “Alternatives to the latter may be feasible if validated.” with:
The use of blood older than 4 h may be feasible for certain tests, if validated alongside freshly obtained blood or by other scientifically sound methods.
A.1.1
Delete “of non-contact-, externally communicating and implant devices” from the sentence as follows: “and a list of tests for evaluating blood/device interactions.”
A.1.4
Replace the first sentence of the third paragraph with:
The classical Chandler loop in vitro test model[43] or modifications thereof[193][194][195][199][200][203] are examples of models used to test for general material or device haemocompatibility under physiological and/or quasi-physiological flow conditions.
Add the following sentence at the end of the third paragraph:
Recent publications that describe and apply alternative in vitro methods are References [243] to [249].
Clause A.3
Add “(or an alternative surface treatment intended to have anti-thrombotic properties)” in the second sentence of the second paragraph as follows:
For example, following simple dose-response kinetics, the thromboresistance of a medical device heparin coating (or an alternative surface treatment intended to have anti-thrombotic properties) can be completely masked by normal (clinical) levels of solution heparin anticoagulant.
Replace the third sentence with:
However, under a reduced/challenging level of solution heparin or in a non-anticoagulated model, the effectiveness of the heparin coating (or alternative anti-thrombotic surface treatment) to reduce thrombus formation becomes more apparent.
Bibliography
Add the following references:
[238] ISO 10993-2, Biological evaluation of medical devices — Part 2: Animal welfare requirements1
1 This reference will be added to the Bibliography under the heading “International Standards” in the next revision.
[239] ISO 10993-6, Biological evaluation of medical devices — Part 6: Tests for local effects after implantation1)
[240] ISO/TS 10993-20, Biological evaluation of medical devices — Part 20: Principles and methods for immunotoxicology testing of medical devices1)
[241] ISO 18242, Cardiovascular implants and extracorporeal systems — Centrifugal blood pumps1)
[242] ISO 18193, Cardiovascular implants and artificial organs — Cannulae for extracorporeal circulation1)
[243] Grove K et al. Thrombogenicity Testing of Medical Devices in a Minimally Heparinized Ovine Blood Loop. Journal of Medical Devices 2017, 11 (2).2
2 This reference will be added to the Bibliography under the heading “in vitro models” in the next revision.
[244] Jamiolkowski MA et al. An In Vitro Blood Flow Loop System for Evaluating the Thrombogenicity of Medical Devices and Biomaterials. ASAIO J 2020, 66 (2), 183-189.2)
[245] Jamiolkowski MA et al. Preclinical Device Thrombogenicity Assessments: Key Messages From the 2018 FDA, Industry, and Academia Forum. ASAIO J. 2021;67(2):214-219. doi: 10.1097/MAT.0000000000001226.2)
[246] Wolf MF et. al. In vitro methodology for medical device material thrombogenicity assessments: A use condition and bioanalytical proof-of concept approach. J Biomed Mater Res B Appl Biomater. 2021 Mar;109(3):358- 376. doi: 10.1002/jbm.b.34705.2)
[247] Lu Q et al. Platelet and leukocyte count assay for thrombogenicity screening of biomaterials and medical devices: Evaluation and improvement of ASTM F2888 test standard. J Biomed Mater Res B Appl Biomater. 2021 Dec;109(12):2259-2267. doi: 10.1002/jbm.b.34887.2)
[248] Jamiolkowski MA et al, Comparison of animal and human blood for in vitro dynamic thrombogenicity testing of biomaterials. Artif Organs. 2022 Jul 22. doi: 10.1111/aor.14366.2)
[249] Tim Schatz et al. Improved Method for the ASTM Platelet and Leukocyte Assay: Use of Minimal Heparinization in a Screening Test for Hemocompatibility of Blood-Contacting Medical Devices J. Med. Devices. Mar 2019, 13(1): 011004.2)