“…In particular, most of the recent debate has been centred around clarifying the FDA's definitions of “homologous use” and “minimal manipulation,” two requirements relevant to “the 361 HCT/Ps” that fall under this second tier and are exempt from FDA premarketing regulation. Between 2014 and 2015, four controversial FDA draft guidance documents were released, further narrowing the Administration's definitions of these terms:
- Same Surgical Procedure Exception Under § 1271.15(b): Questions and Answers Regarding the Scope of the Exception (October 2014; FDA, 2014c)
- Minimal Manipulation of Human Cells, Tissues, and Cellular and Tissue‐Based Products (December 2014; FDA, 2014b)
- Human Cells, Tissues, and Cellular and Tissue‐Based Products (HCT/Ps) from Adipose Tissue (December 2014; FDA, 2014a)
- Homologous Use of Human Cells, Tissues, and Cellular and Tissue‐Based Products (October 2015; FDA, 2015a)
…”