Post PN 0620
Post PN 0620
Post PN 0620
3D bioprinting in medicine
Overview
◼ 3D bioprinting is a type of 3D printing that
prints an ink made from biological material,
such as living cells and proteins.
◼ This technology could potentially be used to
print new and bespoke organs, such as skin
or bladders, on demand for transplantation
to relieve the donor organ shortage.
◼ It is currently unclear whether the EU
Advanced Therapy Medicinal Products and
Medical Devices regulations would apply to
3D printing in medicine is usually associated bioprinted organs or whether such products
with the production of medical devices such as would be considered an entirely new class
hip implants and prosthetic limbs. However, of medicines.
new research is applying 3D printing to living ◼ The adoption and widespread use of this
cells and proteins, to print new tissues and technology would raise a range of logistical,
organs for medical use in a process known as financial and ethical challenges, such as
3D bioprinting. This POSTnote gives an manufacturing dynamics, treatment
overview of 3D bioprinting and the associated accessibility and human enhancement.
biological, manufacturing, regulatory and
ethical implications.
The Parliamentary Office of Science and Technology, Westminster, London SW1A 0AA
02072192840 [email protected] parliament.uk/post @POST_UK
POSTNOTE 620 March 2020 3D bioprinting in medicine Page 2
European Medicine Agency’s (EMA, Box 4) Committee for this route as a way of circumventing the clinical trial data
Advanced Therapies (CAT) or by the relevant country’s requirements of market authorisation.81 In response to this, the
Competent Authority on a case-by-case basis.77,78 In the UK, House of Commons Science and Technology Committee has
the Competent Authority is the Medicines and Healthcare recommended that the Government should review how hospital
products Regulatory Agency (MHRA, Box 4). Once approved exemptions are used for ATMPs across the UK, and assess how
and classified, ATMPs can be used clinically in one of two main they might be adapted for the UK post-Brexit to provide a
ways.77 First, developers can apply through the EMA’s balance between safety and accelerated access to cutting edge
centralised system for market authorisation to commercialise technologies.5
the product across all EU member states. Applications must be
backed up with evidence from clinical trials of the product’s Establishing GMP-compliant hubs
safety, quality and efficacy.77 Otherwise, ATMPs may be RDM requires the creation of a series of local production
delivered to clinic via a ‘hospital exemption’ route. This centres equipped with advanced facilities that adhere to GMP
circumvents market authorisation on the basis that they are standards, however, establishing these centres would likely be
one-of’ customised products that address an unmet need, and expensive. The UK currently has 26 GMP-compliant facilities
are not derived from an industrial source.79,80 This route is that are operating at close to full capacity (~73%).86 One of
intended to allow for bespoke treatments in a single member these centres, based at the Royal Free Hospital in London, was
state. opened in 2015 and cost £2.1 million to establish - this total
excludes costs associated with bioprinting equipment or staff
Medical Devices Regulation training.87 Expanding the GMP network to enable UK-wide RDM
If biofabricated constructs are classified as cATMPs, then these for biofabrication would thus require significant investment.88,5
are co-regulated by the new MDR. Compliance with the MDR
brings extra regulatory challenges to biofabrication, and may Ethical and legal issues
add extra complexity and cost to production processes.74,81 Risks of early adoption
Some stakeholders have concerns about the high expectations88
Regulations on the use of human cells of 3D bioprinting and the potential for bioprinted constructs to
The biofabrication process may also fall under regulations be deployed in a medical setting without full knowledge of their
covering human cell use, and standards for the manufacture long-term impacts on human health. This may be exacerbated
and distribution of cell-based medicines. The donation and use in cases where the bioprinted organ would be serving as a
of human cells in the UK is regulated by the Human Tissue replacement (due to the likely irreversible nature of the
Authority (HTA, Box 4), which oversees cell and tissue storage, procedure)89 or where products are used within a hospital
processing and sample traceability requirements.59 The MHRA exemption capacity, where the requirement for clinical trials
also produces standards for the manufacturing and distribution evidence may be lower than for ATMP market authorisation.
of cell-based medicines, which are known as the Good Practice There are reports of historical cases where tissue engineering
(GxP) guidelines. Several GxP guidelines are relevant at constructs used in patients without being tested rigorously in
different stages of biofabrication, such as during manufacture animals may have contributed to patient deaths.90,91
(Good Manufacturing Practice, GMP), and clinical trials (Good
Clinical Practice, GCP).82,83 Producers of bioprinted products Accessibility of treatment and enhancement
would have to meet the GxP standards, regardless of facility The clinical application of biofabrication is potentially highly
size, location, or scale of production. bespoke, tailored to individual patients’ needs. This means that
biofabrication procedures are likely to be costly, which raises
Manufacturing challenges questions regarding accessibility and affordability. 92
A key challenge in adopting biofabrication is deciding where Furthermore, biofabrication represents a potential route to
and who will manufacture these products. While conventional human enhancement. For example, it has been suggested that
medicines are manufactured at a centralised site, the bespoke biofabricated materials could include the integration of sensor
and delicate nature of biofabricated products mean they may technologies, which could be used to detect diseases earlier.93
be better suited to local manufacturing by an approach known This raises a number of ethical questions on whether it is
as redistributed manufacturing (RDM). This involves making appropriate to modify organs in this way.
products in local biofabrication hubs based in private facilities,84
or existing healthcare settings, such as hospitals or NHS Blood Patentability and confidentiality
and Transplant Centres.85 Potential benefits of an RDM There is ongoing debate over whether certain parts of the
approach include reduced waiting times for products, lower bioprinting process are patentable.94,95 It is also not clear who
burden on major hospitals, and more accessible treatments. might be the patent holder of the various components of a
bioprinted organ, given the numerous players in the
However, some stakeholders have questioned whether the biofabrication process and the difficulty in identifying novel
routine use of biofabrication methods in such facilities would invention.96 These difficulties have implications for product
meet good quality assurance standards. 84 Others have also liability should the constructs malfunction, and for organ
questioned whether sustained production under the hospital ownership. In addition, the distribution of CAD files for
exemption pathway would be permitted, because these are biofabrication requires sensitive patient data in order to design
intended to allow bespoke treatments for individual patients. the construct. It is unclear how this stage of biofabrication
There are also general concerns that some groups are using would be compatible with current data protection legislation. 81
POST is an office of both Houses of Parliament, charged with providing independent and balanced analysis of policy issues that have a basis in science and technology.
POST is grateful to Melissa Jackson for researching this briefing, to the BBSRC for funding her parliamentary fellowship, and to all contributors and reviewers. For further
information on this subject, please contact the co-author, Pete Border. Parliamentary Copyright 2020. Image copyright Jordan Miller/Rice University
POSTNOTE 620 March 2020 3D bioprinting in medicine Page 5
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