US FDA
21 CFR 1271 Subpart C - Donor Eligibility
Plain-language explanation, inspection context and common violation patterns.
What it says
Donors of human cells, tissues, and cellular and tissue-based products must be screened and tested for relevant communicable disease agents and risk factors, with a documented eligibility determination made and recorded before the donated material is used, except in specifically defined exception circumstances.
Paraphrased for plain-language clarity. Always verify against the current published regulation text.
What it means in practice
- Donor eligibility determination is the upstream gatekeeping step that the current good tissue practice requirements in 21 CFR 1271 Subpart D are built on, since no amount of downstream processing control can compensate for using material from an ineligible donor.
- Screening and testing must be completed and the eligibility determination documented before the product is used, meaning timing matters as much as content, a determination made after the fact does not satisfy the requirement.
- The specific exceptions permitting use of ineligible-donor material are narrowly defined and typically require additional labeling and documentation, so relying on an exception without meeting its specific conditions is itself a compliance gap.
What FDA inspectors look for
- Whether a documented donor eligibility determination exists for each donor and was completed before the donated material was used.
- Whether screening and testing records are complete and address all required communicable disease agents and risk factors.
- Whether any use of ineligible-donor material relied on a properly documented and labeled exception rather than an undocumented shortcut.
Most common violation
Donated material used in manufacturing before the donor eligibility determination was actually completed and documented.
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