Relationship between safety data and biocontainment design in the environmental assessment of fermentation organisms--an FDA perspective.

The Center for Veterinary Medicine requires strain/construct-specific data for recombinant fermentation organisms used in the production of animal drugs and feed additives. Fermentation plant biocontainment schemes are chosen based, in part, upon the ability of the organism to survive and persist in the environment and to transfer genetic information to indigenous organisms. Survival and persistence study methods may include one of the following ecosystems: activated sludge, mammalian gut, soil or river water. Gene transfer protocols can be incorporated into a persistence study. These studies are designed to show that the recombinant construct behaves similarly to the host in a representative ecosystem where the organism could be introduced inadvertently. The studies need to provide repeatable results and reflect current state-of-art design and methods. Data verification is conducted by FDA investigators during Good Laboratory Practice inspections. Biocontainment guidelines, such as those developed by the NIH Recombinant DNA Advisory Committee, set general biocontainment goals for large groupings of recombinant organisms. The FDA, as required under the National Environmental Policy Act, must base its decision making on verifiable scientific data specific to each application. Therefore, in addition to using these guidelines as benchmarks, sponsors are required to submit strain/construct-specific data to support the selection of an appropriate biocontainment level. Once additional well-controlled studies for a variety of constructs are available, broader generalizations as to biocontainment may be drawn.