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Writer's pictureBill Huff

Navigating FDA Regulations in Regenerative Biologic Treatments: Understanding Homologous Use

Updated: Mar 14

In recent years, regenerative biologics have emerged as promising treatments for

various medical conditions, offering the potential for tissue repair and regeneration.

However, with this promising technology comes a need for stringent regulation to

ensure patient safety and efficacy. The Food and Drug Administration (FDA) plays a

crucial role in this regulatory landscape, overseeing the approval and clearance of

regenerative biologic products.


One key aspect of FDA regulations governing regenerative biologics is the concept of

homologous use. In simple terms, homologous use refers to the use of a biologic

product in a manner that is consistent with the way the tissue is used in/by the body

naturally. Ex. Bone can be used where bone naturally exists. Skin can be used where

skin naturally exists. This principle is vital in ensuring that regenerative biologic products

are used safely and effectively.


Products such as exosomes, amniotic tissue, and Whartons Jelly have garnered

significant attention in the field of regenerative medicine. However, despite their

potential benefits, these products are subject to heavy scrutiny by the FDA, particularly

when it comes to certain indications such as joint, soft tissue, or subcutaneous aesthetic

treatments.


Why is this the case? The answer lies in the principle of homologous use. While

exosomes, amniotic tissue, and Whartons Jelly may have regenerative properties,

using them for indications that are not homologous – i.e., not consistent with the tissue

or organ they are derived from – raises concerns about safety and efficacy.

For example, using these products for joint treatments may not be considered

homologous use because they are not naturally found in the joint tissue. Similarly, using

them for soft tissue or subcutaneous aesthetic treatments may not align with their

intended biological function.


As a result, the FDA requires manufacturers of regenerative biologic products to provide

evidence demonstrating that their intended use is homologous and consistent with the

tissue or organ they are derived from. This evidence typically includes preclinical and

clinical data supporting the safety and efficacy of the product for its intended use.

Failure to demonstrate homologous use can result in the FDA denying clearance or

approval for specific indications, limiting the scope of use for these products. This

regulatory oversight is crucial in protecting patients from potential harm and ensuring

that regenerative biologics are used appropriately.


It's essential for healthcare providers and patients alike to understand the regulatory

landscape surrounding regenerative biologics. While these treatments hold immense

promise for addressing a wide range of medical conditions, adherence to FDA

regulations, particularly regarding homologous use, is paramount for their safe and

effective use.



In conclusion, FDA regulations mandate that regenerative biologic products undergo

scrutiny to ensure they are used in a manner consistent with their intended tissue or

organ. Exosomes, amniotic tissue, and Whartons Jelly products are subject to these

regulations, and indications such as joint, soft tissue, or subcutaneous aesthetic

treatments may not be cleared if they are not deemed homologous. By adhering to

these regulations, we can promote the responsible use of regenerative biologics and

ultimately improve patient outcomes in regenerative medicine.

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