Joint Submission: South African National Blood Service (SANBS) & Natal Bioproducts Institute (NBI): National Health Bill (B 32 of 2003) 19 August 2003 Cape Town
Joint Submission: SANBS & NBI • Technical submission made jointly on behalf of SANBS and NBI – Prof. Anthon du P Heyns – CEO SANBS – Mr Duncan Armstrong – Executive Director / Applicant NBI • Duly authorised by the respective Board of Directors • Ultimately representative of the Blood Donors of South Africa 2
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National Health Bill, 2003 “ 58(1) The Minister must establish a blood transfusion service by granting a license to a non-profit organisation, which is able to provide a blood transfusion service throughout the territory of the Republic” (c) has the sole right to provide a blood transfusion and blood fractionation service in the Republic. ” 6
Introduction to SANBS and NBI • Both SANBS and NBI …. – Have close governance and strategic links – Are registered and operate as Section 21 “not for profit” companies – Are the largest providers of specialised blood product services to both the public and private sectors: • SANBS provides about 83% of all blood transfusion services in SA (exclusively in all provinces, except for Western Cape Province and a part of the Northern Cape Province). • NBI is the largest fractionation centre in SA and the only one capable of providing a comprehensive national fractionation service 7
SANBS and NBI Governance Relationship 8
SANBS and NBI Legislative Differences 9
Regulatory differences SANBS and NBI • External Regulation of SANBS and NBI are different – SANBS • Licensed Blood Transfusion Service • Human Tissue Act, No 65 of 1983 (currently) – NBI • Licensed Pharmaceutical Manufacturing Company • Medicines and Related Substances Control Act, No 101 of 1965 • Pharmacy Act, No 53 of 1974 • Legislative and operational differences form the basis for why blood transfusion and blood fractionation should not be regarded in the 10 same manner
Definitions 11
Recommendation • The National Health Bill be amended to delete provisions that the national blood transfusion service have the sole right to provide blood fractionation services in the Republic. • Specifically delete references to Blood fractionation service appearing in Sections 58(2)(c) and 58(3). 15
Definition of “Blood Product” • In keeping with the aforementioned discussion and specifically the distinction between products of a blood transfusion and blood fractionation service, it is also recommended that the definition of a blood product be amended as follows: “Blood product” means any product derived or produced from twelve or less human blood donations, including circulating progenitor cells, bone marrow progenitor cells and umbilical cord progenitor cells. (Underlined text denotes new text) 16
Definition of “Blood Product” Reasoning This amendment will draw a clear distinction between blood products (made from 12 or less donations) and plasma derived medicinal products (greater than 12 donations). 17
Conclusion • By means of a conclusion SANBS and NBI would like to re-confirm that: – Fully support the objects and intent of the Bill wrt creation of a single national blood transfusion service. – SANBS is ideally poised to deliver on the expectations of this bill – For reasons highlighted in this presentation we do believe, however, that the link between blood transfusion and blood fractionation services is unwarranted and unnecessary. – The bill be amended as outlined in this submission – Avoid conflict in legislation. 18
Conclusion Thank you for your time. We will be happy to answer any questions that you may have. 19
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