Appendix
Review and Guiding Principle for Registration
Technology of Fetal Chromosome Aneuploidy
(T21, T18, T13) Test Kit (High-throughput
Sequencing Method)
This guiding principle aims to not only guide the registration
applicant to prepare and write the registered application data of fetal
chromosomal aneuploidy (T21, T18, T13) detection kit (high
throughput sequencing method), but also provide references for the
technical evaluation department to conduct technical evaluation on
registered application data.
This guiding principle is based on the general requirements of
the reagent, and the applicant shall determine which content is
applicable according to the specific characteristics of the product. If
the content is not applicable, the reasons and corresponding
scientific basis are required to be narrated in details, and according
to the specific characteristics of the product, the registered
application information content shall be enriched and refined.
This guiding principle is the guidance document for the
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applicant and the reviewers, but excludes the administrative matters
involved in registration approval, nor as law for enforcement. The
methods able to meet the requirements of relevant laws and
regulations also can be used, but need detail reasons. Meanwhile, its
scientific rationality shall be validated to provide detailed research
and validation data. Relevant personnel shall use this guiding
principle under the premise of following relevant laws and
regulations.
This guiding principle is formulated under the current laws,
regulations and standard systems as well as current cognitive levels.
With the constant improvement of laws, regulations and standards as
well as the continuous development of science and technology, the
related content of this guiding principle will be timely adjusted.
I. Scope
Trisomies 21, Trisomies 18 and Trisomies 13 (T21, T18 and
T13) of fetal chromosome aneuploidies are the most common
chromosome aneuploidy clinical diseases, corresponding to T21
syndrome (also known as Down’s syndrome, mongolian or Down
syndrome), T18 syndrome (also known as Edwards syndrome) and
T13 syndrome (also known as Patau syndrome) with the morbidity
of about 1/700, 1/6000 and 1/10000 respectively. A vast majority of
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child patients have serious mental retardation and organ deformity.
Prenatal screening and prenatal diagnosis are the means to
avoid the children with genetic defects. Routine prenatal screening
methods include early pregnancy ultrasonography combined with
serological screening and second trimester serological screening.
The pregnant women with high-risk screening results are
recommended to be finalized by prenatal diagnosis and informed to
select. The prenatal diagnostic gold standard of fetal chromosomal
abnormalities is the pre-intervention prenatal diagnosis surgery,
referring to use the chorionic villus sampling / amniocentesis /
percutaneous umbilical blood vessel puncture for acquiring
corresponding cells in combination with cell biology method for
karyotype analysis of fetal chromosome.
The principle of high-throughput sequencing method to detect
fetal chromosome aneuploidy is that fetal cell-free DNA (cfDNA)
exists in maternal plasma of pregnant women with a length of about
75 bp – 250 bp, almost all from placental trophoblastic cells, of
which the concentration is closely related to gestational week with a
certain proportion (5%-30%) stabilizing in maternal peripheral blood
plasma. High-throughput sequencing method is to extract the normal
maternal and fetal plasma cell-free DNA from maternal plasma, and
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carry out the library building and fragment amplification for final
implementation of machine sequencing, so as to obtain chromosome
number evaluation results through the software to analyze data.
Taking the detection of T21 syndrome as example, when analyzing
the cell-free DNA data of T21 fetal maternal plasma, the total
cell-free DNA number of chromosome 21 will rise by a small
proportion. The statistical algorithm is used to distinguish such tiny
difference, so as to achieve the application of cfDNA to prenatal
screening of fetal chromosomal aneuploidy. However, the
high-throughput sequencing method is unable to detect the
abnormality of chromosome structure, nor replace the open neural
tube defect screening in traditional screenings.
The fetal chromosome aneuploidy (T21, T18, T13) detection kit
(high-throughput sequencing method) described in this guiding
principle refers to use the high-throughput sequencing method for
detecting the fetal cell-free deoxyribonucleic acid (DNA) of
peripheral blood plasma for pregnant women, through the analysis
of the 21 of cell-free fetal DNA in the samples, analyze the
differences between the numbers of chromosome 21, 18 and 13 in
fetal chromosome aneuploidy of samples, and expect the prenatal
screening detection kit for fetal chromosome aneuploidy diseases,
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i.e., T21 syndrome, T18 syndrome and T13 syndrome.
The high-throughput sequencing method described in this
guiding principle refers to the second-generation sequencing method
through library building and fragment amplification for machine
sequencing, and the third-generation and fourth-generation single
molecule sequencing methods with no need of fragment
amplification are not discussed herein. High-throughput sequencing
technology has developed rapidly, but if the third-generation and
fourth-generation single molecule sequencing methods are
applicable to some aspects, such as enterprise internal reference set,
performance evaluation and clinical evaluation, this guiding
principle can be a reference.
The detection kit mentioned in this guiding principle is
applicable to the pregnant women with gestational week of 12+0 and
above for prenatal screening. But the result is not representative to
confirm the pregnant women with trisomy fetus, and the result of
prenatal screening shall be confirmed by prenatal diagnosis.
The principles of ethics shall comply with relevant national
laws, regulations and industrial rules.
II. Registered information requirement
(1) Survey material
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Survey materials mainly include product expected use, product
description, biosafety description, the summary and evaluation of
major research results related to the product, and other contents.
Among them, the other contents include the approval situation of
similar products at home and abroad, which shall focus on the
methodology, detection limit and other aspects to specify the major
differences between the to-be-registered product and the present
approved similar products. Survey materials shall comply with the
relevant requirements of IVD Reagent Registration Management
Measure (CFDA Decree No. 5, hereinafter referred to as the
“Measure”) and Announcement on Registration Material
Requirement and Approval Certification Document Format for IVD
Reagent (CFDA Announcement No. 44 in 2014, hereinafter referred
to as the “Announcement”).
Survey materials shall expound the test principle in details,
which can be added with graphs to specify all reagent and
consumable material names, manufacturer, product code or
certificate code and detailed compositions for combined use in the
entire test.
(2) Research data of main raw materials
Research data of main raw materials include two parts, i.e., the
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internal reference products of the enterprise and the necessary
reagents to complete the test.
- Internal reference products of the enterprise shall at least
include positive reference, negative reference, test limit reference
and chimera reference, and specific requirements are shown as
follows.
1.1 Positive reference: the simulated samples of T21, T18 and
T13 fetal DNA fragments mixed with normal female plasma in a
certain proportion.
1.2 Negative reference: including the simulated samples of fetal
DNA fragments in normal chromosome number mixed with normal
female plasma in a certain proportion, and the simulated samples of
fetal DNA fragments with anomaly in other chromosomes mixed
with normal female plasma in a certain proportion. The negative
reference with other chromosomal abnormalities is selected
independently by the applicant according to the common
chromosomal abnormality project and the quality control
requirement of the product.
1.3 Detection limit reference: the simulated samples of T21,
T18, T13 fetal DNA fragments mixed with normal female plasma in
a certain proportion such as 5%, 3.5% and 2.5%, 95%. The positive
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detection rate of 95% (n≥20) is recommended to use as the
determination standard for minimum detection limit.
1.4 Chimera reference product: the proportion of simulated T21,
T18 and T13 chimeras is set up independently by the applicant
according to the quality control requirements of the product, such as
70% abnormal and 30% normal, 30% abnormal and 70% normal,
etc.
Fetal DNA fragments with T21, T18, T13 and other
chromosomal abnormality can be prepared from abortion tissue or
amniotic cells, cell lines and other sources.
The applicant shall specify the composition of internal
reference product of the enterprise, the preparation and verification
methods, the determination method of the concentration of fetal
DNA fragments and the selection basis of the proportions. The
samples of various internal reference products shall have different
sources. - The reagents needed to complete the whole testing process
generally shall at least include the extraction and purification reagent
of plasma cell-free DNA, library building reagent, library
quantitative reagent, sequencing reagent, negative quality control
product, positive quality control product and the co-used sequencing
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chip and data analysis software. Specific requirements are shown as
follows:
2.1 Extraction and purification reagent of plasma cell-free DNA:
whether it is included in the registered products or not, the applicant
shall submit the principle of co-used extraction and purification
reagent, detailed composition, manufacturer, produce code, Class-I
medical device registration certificate code and relevant information.
In terms of performance, the length range accuracy and purity
requirements of DNA fragments extracted by the reagent, the
extraction efficiency, repeatability and anti-interference ability shall
be evaluated.
2.2 Library building reagent, library quantitative reagent,
sequencing reagent: the library building reagent is used for
fragmented DNA gap-filling and corresponding partial 5’ terminal
phosphorylation (if necessary) and 3’ terminal dephosphorylation (if
necessary), then the ligase is applied in combination with the tags
and linkers for sequencing and analysis to build the standard library
for machine sequencing. Library quantitative reagent is used to
quantitatively measure the concentration of library by PCR
amplification and the contrast with standard curve, preparing for the
subsequent machine sequencing of normalized library and assessing
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the quality of library building. Library quantification shall clarify the
requirements of library quality, fragment size and concentration,
provide analysis graphs, and interpret the parameters (such as
whether there is an impure peak or not, the causes and whether the
impact on final result exists or not). Library quantification is not
limited to the above methods and can be conducted by other
methods, such as fluorescence dye method and Qubit quantification.
The sequencing reagent is used to expand the fragment of
normalized library, and the gene sequencer is applied to capture the
signal changes caused by base variation in the amplification process,
so as to achieve the purpose of reading sequence.
The above three reagents are generally composed of the
enzyme with corresponding functions (terminal repair enzyme, DNA
ligase, gap repair enzyme DNA polymerase, etc.), nucleotide
sequence (primer, linker sequence, tag sequence, library quantitative
standard), buffer and dNTP. Specific requirements are shown as
follows:
2.2.1 Enzyme: purity, activity and functional test data shall be
submitted. For example, the library building process is including but
not limited to terminal repair enzyme, DNA ligase, gap repair
enzyme, etc., and the selected enzyme shall have terminal blunting,
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gap-filling, tag or linker connection and DNA polymerase activity.