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HomeGlossaryDonor Eligibility
Compliance · The complete guide

Donor EligibilityDonor Eligibility Determination (21 CFR 630 + 21 CFR 1271 Subpart C)

In short

The donor determination behind blood collection and HCT/P use—and why it is different from donation suitability or product release.

2,631 words · ~12 min read
Donor Eligibility: a tissue bank colleague in hair cover, mask, glasses and gloves reviews a donor record on a tablet beside a quarantine-tagged tissue container
For HCT/Ps, identification and quarantine distinguish a pending donor determination; the specific limited-use pathways remain separate.
On this page
  1. 01Regulatory definition: two distinct determinations
  2. 02Blood eligibility: timing and required inputs
  3. 03Eligibility, suitability, and release are different decisions
  4. 04HCT/P inputs: interview, screening, and testing
  5. 05Ineligible, deferred, and pending are not synonyms
  6. 06HCT/P quarantine and two different limited-use pathways
  7. 07What the HCT/P determination record contains
  8. 08Blood deferral records and separate retention clocks
  9. 09Fictional contrast and optional practice
On this page · 9 sections
  1. 1Regulatory definition: two distinct determinations
  2. 2Blood eligibility: timing and required inputs
  3. 3Eligibility, suitability, and release are different decisions
  4. 4HCT/P inputs: interview, screening, and testing
  5. 5Ineligible, deferred, and pending are not synonyms
  6. 6HCT/P quarantine and two different limited-use pathways
  7. 7What the HCT/P determination record contains
  8. 8Blood deferral records and separate retention clocks
  9. 9Fictional contrast and optional practice
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01Regulatory definition: two distinct determinations

Donor Eligibility is the determination whether a donor meets the requirements applicable to a particular donation context. For blood and blood components, Part 630 addresses the donor’s health and factors affecting the donation. For human cells, tissues, and cellular and tissue-based products (HCT/Ps), Part 1271, Subpart C establishes a determination based on communicable-disease screening and testing. These are distinct regulatory determinations, not interchangeable approvals.

Blood and blood components

Under §630.10(a), the collecting establishment must determine eligibility—or determine that an exception applies—before collection. Eligibility requires good health and freedom from transfusion-transmitted infections as determined through the regulatory processes. Factors that could adversely affect the donor’s health or the blood component’s safety, purity, or potency make the donor ineligible.

HCT/Ps

Section 1271.45(b) requires a determination for donors of cells or tissue used in HCT/Ps, except as provided in §1271.90. For embryos or embryo-derived cells, both the oocyte and semen donors require determinations. Each establishment must comply with requirements applicable to the functions it performs.

At the establishment responsible for the determination, a responsible person must determine and document eligibility under §1271.50. This means someone authorized, trained, and qualified for the designated functions. Eligibility requires screening that establishes freedom from the specified communicable-disease risks and clinical evidence, including xenotransplantation-associated risks, and negative or nonreactive required testing, subject to §1271.80(d)(1).

02Blood eligibility: timing and required inputs

Section 630.10(c) requires determination on the day of donation and before collection. It provides exactly two qualified exceptions:

  1. For blood components that cannot be stored for more than 24 hours, eligibility may be determined and the sample for §610.40 testing collected no earlier than 2 calendar days before the day of donation, provided standard operating procedures address these activities.
  2. If review identifies incomplete responses to donor questions asked before collection, a response may be clarified or information required under §630.10(e) obtained within 24 hours of collection, provided standard operating procedures address these activities. This is not blanket permission to determine eligibility after collection.

Under §630.10(d), the establishment must consult both the local and cumulative deferral records required by §606.160(e)(1) and (2). Only the cumulative-record check may move to before release, and only when precollection review is not feasible because that record cannot be consulted at the collection site. This exception does not move the local-record check or the whole eligibility determination to release.

Other inputs are an appropriate interval since the last donation, medical-history assessment, and physical assessment. The precollection medical-history interview addresses good health, relevant transfusion-transmitted infection risks or clinical evidence, and conditions that could adversely affect the donor or the blood, components, or products manufactured from them.

Section 630.10(g) also requires proof of identity and a postal address where the donor can be contacted for 8 weeks after donation, obtained on the donation day. Before each donation, the establishment must provide the required information and obtain a signature or other documented acknowledgement of its review.

03Eligibility, suitability, and release are different decisions

DecisionWhat it addressesRegulatory distinction
Donor eligibilityWhether the donor meets applicable requirements.Blood: §630.10. HCT/Ps: §§1271.45 and 1271.50.
Blood donation suitabilityWhether the particular donation satisfies §630.30(a).Includes donor-related findings, required testing, and other subchapter requirements.
Product release or useWhether the product may proceed under applicable controls.Blood release restrictions and HCT/P quarantine/use restrictions are not replaced by a donor-status label.

A blood donation is suitable under §630.30(a) only when the donor is not currently deferred; the prescribed results indicate good health and donor-protection procedures were followed; medical-history results establish freedom from the specified infection risks and other disqualifying factors; §610.40 testing is negative or nonreactive unless its stated exception applies; and other subchapter requirements are met.

An unsuitable donation must not be released for transfusion or further manufacturing unless it is an autologous donation or a chapter exception applies. Unsuitability under §630.30(a)(1)–(4) requires donor deferral; deferred donors must be notified under §630.40. This release provision is not a blanket autologous exemption from other requirements.

For HCT/Ps, §1271.45(c) prohibits implantation, transplantation, infusion, or transfer until the donor is determined eligible, except under §§1271.60(d), 1271.65(b), and 1271.90. Shipment in quarantine is a different event from clinical use.

04HCT/P inputs: interview, screening, and testing

A donor medical history interview is a documented dialogue about medical history and relevant social behavior. Under §1271.3(n), it is conducted with a living donor able to participate; otherwise, it is conducted with people able to provide the information. It is not simply an undocumented conversation.

Relevant medical records include a current interview and current physical-assessment report for a deceased donor or physical-examination report for a living donor. They also include, when available, other laboratory results, medical records, coroner and autopsy reports, and information from other sources about relevant communicable-disease risks.

Screening under §1271.75(a), subject to §1271.90, means reviewing those records for risk factors and clinical evidence involving HIV, hepatitis B, hepatitis C, human transmissible spongiform encephalopathy including Creutzfeldt-Jakob disease, and Treponema pallidum, as well as xenotransplantation-associated communicable-disease risks. Findings covered by §1271.75(d) require an ineligible determination.

An abbreviated repeat-donor screening procedure may be used on repeat donations only if the establishment has performed a complete donor screening procedure on that living donor within the previous 6 months. It must determine and document changes since the previous donation that would make the donor ineligible, including relevant social behavior. It is not permission to omit the change assessment.

Testing is a separate input

Section 1271.80 requires testing for the agents specified in §1271.85, subject to §1271.90. For a donor 1 month old or younger, the specimen is from the birth mother. The all-donor agents in §1271.85(a) are HIV-1, HIV-2, hepatitis B virus, hepatitis C virus, and Treponema pallidum. That paragraph is not the complete panel for every donor type.

Generally, the specimen must be collected at recovery or within 7 days before or after recovery. Collection up to 30 days before recovery is permitted for peripheral blood stem/progenitor-cell donors, bone-marrow donors if not excepted under §1271.3(d)(4), and oocyte donors. For repeat semen donors with a specimen already collected and tested and retesting required under §1271.85(d), a specimen is not required at every donation.

Testing uses appropriate FDA-licensed, approved, or cleared donor-screening tests according to manufacturer instructions. Section 1271.80(c) specifies interim detection-test provisions for Chlamydia trachomatis and Neisseria gonorrhea, using tests labeled for an asymptomatic, low-prevalence population until appropriate donor-screening tests are available. Cadaveric-specimen-labeled tests must be used when applicable and available. Required testing must occur in a CLIA-certified laboratory or one meeting CMS-determined equivalent requirements.

Reactive required screening tests ordinarily require ineligibility. Section 1271.80(d)(1) provides the specific exception for a reactive non-treponemal syphilis screening test followed by a negative specific treponemal confirmatory test.

Definition scope—not a clinical protocol

This definition does not supply individual blood risk factors, physical-assessment limits, donor-type criteria, the detailed blood testing panel, additional HCT/P donor-type testing provisions, or §1271.90 exception criteria. Screening and testing are explained as inputs, not as instructions for deciding an individual’s eligibility.

05Ineligible, deferred, and pending are not synonyms

StatusBlood contextHCT/P context
IneligibleDo not collect unless a subchapter exception applies; defer and notify under §630.40.A completed determination finds that applicable screening or testing requirements for eligibility are not met.
DeferredA restriction on donation; §610.41 addresses reactive-test deferrals and requalification.Do not substitute the blood requalification rule for an HCT/P eligibility determination.
PendingNot permission to postpone the required precollection determination.Used here descriptively for an unfinished determination; the HCT/P remains subject to §1271.60 quarantine controls.

Section 610.41(a) requires deferral from future blood donations after reactive screening for a relevant transfusion-transmitted infection under §610.40(a), with these specified exceptions:

  • One occasion of anti-HBc or anti-HTLV, types I and II, reactivity does not require deferral by itself. Deferral is required if further §610.40(e) testing establishes HBV or HTLV positivity, a second licensed, cleared, or approved HBV or HTLV screening test on the same donation is reactive, or the specified antibody reactivity occurs on more than one occasion.
  • A deferred reactive donor may provide blood or components shipped or used under §610.40(h)(2)(ii).
  • A donor previously deferred for HBsAg evidence under §610.40(a), (b), and (e) may subsequently donate Source Plasma for Hepatitis B Immune Globulin (Human) if the current donation is HBsAg-nonreactive and the donor is otherwise eligible.
  • An otherwise eligible deferred donor reactive for anti-HBc or evidence of HTLV types I and II may donate Source Plasma.
  • A deferred donor reactive under §610.40(a) may serve as an autologous donor under §610.40(d).

Under §610.41(b), a deferred donor may become eligible through an FDA-acceptable requalification method or process and is then no longer deferred. Section 610.41(c) separately invokes §§610.46 and 610.47 for specified HIV or HCV findings. See Lookback for those clocks rather than treating deferral as the entire lookback process.

06HCT/P quarantine and two different limited-use pathways

Under §1271.60, HCT/Ps must remain in quarantine until the required determination is complete, with identification that distinguishes them from products available for release and distribution. If shipped before completion, they remain quarantined during shipment. Accompanying records must identify the donor, state that the determination is incomplete, and prohibit clinical use until completion except under §1271.60(d).

Pending determination: §1271.60(d)

Documented urgent medical need can permit use before completion. The definition requires that no comparable HCT/P be available and that the recipient be likely to suffer death or serious morbidity without it.

The product must prominently bear “NOT EVALUATED FOR INFECTIOUS SUBSTANCES” and “WARNING: Advise patient of communicable disease risks.” Completed screening and testing results and a list of outstanding required screening or testing must accompany it. The manufacturing establishment must document notifying the using physician that screening and testing were incomplete. The determination must be completed during or after use, and the physician informed of its results.

Already ineligible donor: §1271.65

HCT/Ps from donors determined ineligible require separate, clearly identified storage or other procedures adequate to prevent improper release until destruction or other permitted disposition. Section 1271.65(b) permits limited clinical uses within Subpart C: allogeneic use in a first- or second-degree blood relative, reproductive cells or tissue from a directed reproductive donor, or documented urgent medical need.

These products require the Biohazard legend and “WARNING: Advise patient of communicable disease risks”; reactive results also require “WARNING: Reactive test results for (name of disease agent or disease).” Section 1271.55 records must accompany them, and the manufacturer must document notifying the using physician of screening and testing results. This is not the pending-determination labeling pathway.

07What the HCT/P determination record contains

Section 1271.55(d) requires documentation of screening results and interpretations; testing results and interpretations, including testing-laboratory names and addresses; and the determination, including the responsible person’s name and determination date.

Under §1271.270(a), records must be maintained concurrently with each required step, be accurate, indelible, and legible, identify the person doing the work and entry dates, and provide a complete work history linked to the particular HCT/P.

Once a determination is made, §1271.55(a) requires an accompanying distinct identification code on the container, an eligible-or-ineligible statement, and a summary of the supporting records. The code links the HCT/P, donor, and records. Except for autologous donations, directed reproductive donations, and donations by first- or second-degree blood relatives, it cannot include an individual’s name, Social Security number, or medical-record number. Accompanying records must not contain the donor’s name or other identifying personal information.

The summary includes the testing laboratory’s qualification statement, all communicable-disease test results and interpretations, and the determining establishment’s name and address. For a screening-ineligible donor released under §1271.65(b), it also states the reasons for ineligibility.

Donor-identity information and relevant medical records must be in English or retained in their original language with an English translation and the translator’s document-specific authenticity statement. Required records must be available for authorized FDA inspection or request; records readily retrievable electronically from another location count as retained.

Section 1271.270(c) permits electronic records, original paper, or true copies. Necessary reading equipment must be readily available, and electronic records must be backed up.

08Blood deferral records and separate retention clocks

Section 606.160(e)(1) requires each blood-establishment location to maintain a record of all donors found ineligible or deferred there, preventing collection or release while that status applies.

The cumulative record under §606.160(e)(2) covers locations under the same license or common management. Its scope is donors deferred under §610.41 because §610.40(a)(1) testing was reactive for HIV, HBV, or HCV; establishments other than Source Plasma establishments must also include deferrals for reactive §610.40(a)(2) testing for HTLV or Chagas disease. It must be updated at least monthly for newly covered deferrals and revised to remove donors requalified under §610.41(b).

Record categoryProvisionRetention rule
Blood individual-product records§606.160(d)No less than 10 years after processing records are completed or 6 months after the latest product expiration, whichever is later. Indefinite retention applies when there is no expiration date.
Blood local and cumulative deferral records§606.160(e)This paragraph specifies record scope and maintenance, not a retention period.
General HCT/P records§1271.270(d)10 years after creation unless Part 1271 states otherwise.
Records pertaining to a particular HCT/P§§1271.55(d)(4) and 1271.270(d)At least 10 years after administration; if administration date is unknown, at least 10 years after distribution, disposition, or expiration, whichever is latest.

Section 606.160(d) also requires retention beyond expiration as necessary to facilitate reporting unfavorable clinical reactions. Its indefinite-retention provision is not a rule that deferred-donor records are retained indefinitely. Nor do blood and HCT/P records share one interchangeable 10-year clock.

09Fictional contrast and optional practice

Fictional example: On April 12, 2030, donor FICTION-BLOOD-001 is determined eligible before collection. The unit is still awaiting applicable test results; the donor decision alone therefore does not establish donation suitability. On the same day, tissue is recovered from donor FICTION-TISSUE-002, whose HCT/P eligibility determination remains incomplete. That HCT/P remains in quarantine. Neither product is described as released, and no urgent-use exception is assumed.

Optional practice: keep the decisions visible

Use separate documentation headings for donor determination, donation suitability where applicable, and product disposition. Name the record category and triggering event when discussing retention. For optional operational exercises rather than another definition, use the Donor eligibility guide.

Frequently asked questions

Q.Does Donor Eligibility mean a product can be released?+

No. Blood donation suitability has additional conditions under §630.30. HCT/P eligibility, quarantine, and permission for clinical use are distinct regulatory questions.

Q.Can blood donor eligibility routinely be determined after collection?+

No. The rule is donation-day determination before collection. The 24-hour provision concerns clarifying incomplete precollection responses or obtaining omitted §630.10(e) information found on review, with SOP coverage—not a general postcollection determination.

Q.Are HCT/P screening and testing interchangeable?+

No. Section 1271.50 requires both. Screening reviews relevant medical records; testing examines specimens under §§1271.80 and 1271.85. The all-donor agents in §1271.85(a) are not every donor type’s complete panel.

Q.Is a pending HCT/P determination the same as an ineligible determination?+

No. Pending describes unfinished work. Section 1271.60 addresses quarantine and urgent use before completion; §1271.65 addresses products from donors already determined ineligible, with different labeling and records requirements.

Q.Must blood deferred-donor records be kept indefinitely?+

Section 606.160(e) does not state a retention period. The indefinite-retention language in §606.160(d) concerns product records when no expiration date exists; it should not be presented as a deferral-record retention rule.

Q.Do blood and HCT/P records use the same 10-year clock?+

No. Blood individual-product records use processing completion and expiration triggers. General HCT/P records use creation unless otherwise specified; particular-HCT/P records use administration or the specified alternative events when administration is unknown.

Primary sources

  • 21 CFR §630.10 — Blood donor eligibility
  • 21 CFR §630.30 — Donation suitability
  • 21 CFR §610.41 — Blood donor deferral
  • 21 CFR §606.160 — Blood records
  • 21 CFR §1271.3 — Definitions
  • 21 CFR §1271.45 — HCT/P donor-eligibility requirements
  • 21 CFR §1271.50 — Making the determination
  • 21 CFR §1271.75 — Donor screening
  • 21 CFR §1271.80 — Donor testing requirements
  • 21 CFR §1271.85 — All-donor testing agents, paragraph (a)
  • 21 CFR §1271.55 — Determination records
  • 21 CFR §1271.60 — Incomplete determinations and quarantine
  • 21 CFR §1271.65 — HCT/Ps from ineligible donors
  • 21 CFR §1271.270 — HCT/P records and retention

Further reading

  • Donor eligibility guide
    Operational exercises connecting eligibility decisions, lookback, and deviation readiness.
  • Lookback
    A separate explanation of lookback obligations and their timing clocks.
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HCT/Ps, blood cGMP, donor eligibility, ISBT 128 labeling and forward-tracing lookback.

Lookback
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Blood & Tissue
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  • → eBMR / eDHR — the batch record fills in as the work is done.
  • → 21 CFR Part 11 — signatures and audit history your team can validate.
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Regulatory anchors
  • 21 CFR 630.10
  • 21 CFR 606.160
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