I advise that you do not go to this doctor
as it appears that he has been found guilty by the US FDA. See below regarding
Dr. Sapse, he has now, after being chased out of the States set up shop in
Other Compliance Action Letter
By Certified Mail - Return
Receipt Requested
Nov 22
2006
Alfred T.
Sapse, M.D., President
Stem Cell Pharma Inc.
Dear Dr.
Sapse:
This
letter describes the results of a Food and Drug Administration (FDA) inspection
conducted on July 6, 2006. FDA investigator Anthony Keller met with you to
review your firm's clinical investigation involving the implantation of amnion
tissue to treat a variety of illnesses. FDA conducted this inspection under the
agency's Bioresearch Monitoring Program, which includes inspections designed to
review the conduct of clinical research involving investigational new drugs.
The
inspection revealed that under your direction, at least one physician obtained
human placentas from a local hospital, carried them to his office, processed
the tissue, and implanted it in at least 16 subjects that you recruited. You
did not establish or maintain standard operating procedures for the following
critical operations: obtaining the placenta from donors; donor eligibility
screening; procedures for storage, processing of placentas to obtain amnion
tissue and cells, and disposition of the placentas; testing of the placenta for
contaminants; screening of the subjects' suitability in accepting the amnion
tissue and cell implants for a non-homologous use; implantation procedures; and
subject follow-up for adverse experiences subsequent to the implantation. You
did not provide the investigator(s) with a protocol, investigational plan, and
or investigator's brochure for conducting the study.
As
described below, we have determined that your actions have violated the Public
Health Service Act (PHS Act) and the Federal Food, Drug, and Cosmetic Act
(FD&C Act).
The
amnion tissue and cells are a biological product as defined in section 351(i)
of the PHS Act [42 U.S.C. § 262(i)], in that they are a virus, therapeutic
serum, toxin, antitoxin, vaccine, blood, blood component or derivative,
allergenic product or analogous product, or arsphenamine or derivative of
arsphenamine, applicable to the prevention, treatment, or cure of a disease or
condition of human beings. The amnion tissue and cells are also a drug within
the meaning of section 201(g) of the FD&C Act [21 U.S.C. § 321(g)], in that
they are intended for use in the diagnosis, cure, mitigation, treatment, or
prevention of disease in man.
In order
to introduce or deliver for introduction a biological product into interstate
commerce, a valid biologics license (BLA) must be in effect [42 U.S.C. §
262(a)]. A BLA is issued only after a showing of safety, purity and potency for
the product's intended use. Before approval, biological products may generally
be distributed for clinical use in humans only if the sponsor has an
investigational new drug (
The
amnion tissue and cells obtained from the placenta are human cells, tissues, or
cellular and tissue-based products (HCT/Ps) as defined in 21 CFR § 1271.3(d).
Under 21 CFR Part 1271, HCT/Ps are not subject to license or
As a
result, you violated applicable regulations governing the proper conduct of
clinical studies involving investigational new drugs. For example:
- You failed to submit an
application to FDA (21 CFR § 312.20(a); 21 CFR § 312.40(a)).IND - You began a clinical investigation without an
application in effect (21 CFR § 312.20(b)).IND - You failed to comply with the general
responsibilities of sponsors of clinical investigations, specified in 21
CFR § 312.50, such as providing investigators with information needed to
conduct an investigation properly.
You also
failed to permit the FDA investigator to have access to and copy records on the
subjects that you recruited to receive amnion tissue and cell implants, in
violation of 21 CFR § 312.58.
Furthermore,
your firm's web site, www.alfredtrsapsemd.com, promotes these implants and
represents that they are safe and effective in treating a variety of illnesses,
in violation of 21 CFR § 312.7(a).
We
request that you notify this office, in writing, of the steps you have taken or
will take to correct the noted violations and to prevent their recurrence.
Please include any documentation necessary to show that correction has been
achieved.
You may
submit an
Please
send your written response to:
Ms. Bhanu
Kannan
Division of Inspections and Surveillance (HFM-664)
Office of Compliance and Biologics Quality
Center for Biologics Evaluation and Research
1401 Rockville Pike,
Telephone:
We
request that you send a copy of your response to the FDA District Office listed
below.
|
|
Sincerely, /s/ Mary A.
Malarkey |
cc:
Barbara
Cassens, District Director
Food and Drug Administration
http://www.fda.gov/CbER/compl/stem112206.htm