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January 20, 2017  |  Volume 14  |  Issue 3
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Loyd V. Allen, Jr., Ph.d., R.Ph Letter from the Editor
U.S. Food and Drug Administration (FDA) Compliance Policy Guidelines: 503A Draft Guidances

Please note that these Draft Guidances are NOT FINALIZED; when they become finalized, they will represent the current thinking of the FDA on the specific topics.

Date Issued Title
 
August 2016     Insanitary Conditions at Compounding Facilities
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/
Guidances/UCM514666.pdf

Background
The FDA considers "any drug that is produced under insanitary conditions as adulterated, including compounded human and animal drugs, repackaged drug products, compounded or repackaged radiopharmaceuticals and mixed, diluted, or repackaged biological products."

The FDA issued this guidance to assist compounding facilities in identifying insanitary conditions so that they can implement appropriate corrective actions.

Policy Summary

  1. Examples of Insanitary Conditions are Presented in the Following Categories:
    • Insanitary conditions applicable to the production of sterile and/or nonsterile drugs.
    • Insanitary conditions in a sterile operation
      1. Aseptic practices
      2. Equipment/Facilities
      3. Sterilization
      4. Cleaning and Disinfecting

  2. Identifying Insanitary Conditions
    • Conduct routine environmental monitoring.
    • Certify the ISO 5 area every six months.
    • Measure pressure differentials during operations to help ensure proper airflow.
    • Conduct media fill studies.

  3. Corrective Actions
    • Assess the impact of insanitary conditions on compounded preparations.
    • Determine if compounding should be suspended until problem corrected.
    • If a recall is indicated, notify the local FDA District recall coordinator.
    • Initiate a comprehensive assessment of operations.
    • Do not rely on sterility tests as an indicator of cleanliness.

  4. Regulatory Action
    If a compounding facility produces drugs under insanitary conditions, the facility and responsible individuals may be subject to Federal regulatory actions.


Loyd V. Allen, Jr., PhD, RPh
Editor-in-Chief
International Journal of Pharmaceutical Compounding
Remington: The Science and Practice of Pharmacy Twenty-second edition

 

News

Fungus in Vials Sparks NIH Crisis
Fungus found growing in two medicine vials in an NIH hospital pharmacy 19 months ago has escalated into a crisis. It has stalled medical trials for prostate cancer, melanoma, and gastrointestinal and chest tumors. There have been delays for scores of patients, including those seeking a new colon-cancer treatment that in December completely reversed metastatic colon cancer in a patient and could help tens of thousands more.

NIH Director Francis Collins, MD, asked outside experts to review practices at the NIH hospital, known as the Clinical Center. Next, he ordered changes in safety procedures and personnel that closed drug-producing labs while they responded. Within NIH, some senior doctors and scientists say Collins overreacted, triggering months-long delays in research and treatment and they are critical of an outside report Collins commissioned.
http://www.wsj.com/articles/mystery-fungus-sparks-nih-crisis-imperiling-trials-patients-and-its-boss-1484753489

Chinese Drug Company Faked CoAs
The FDA has increased its inspection presence in China and has issued warning letters to a Chinese drugmaker and an active pharmaceutical ingredients (API) supplier. They found the company was selling APIs in the U.S. that were from another supplier claiming it had manufactured them itself. The big problem was the original supplier of some of those was on an FDA import alert list at the time.

Suzhou Pharmaceutical, the FDA said in its June 2016 inspection, was creating fake certificates of analysis (CoA) for the products it was selling by copying and pasting analytical results from the original API manufacturer, replacing the manufacturer's information with its own letterhead, then issuing the CoAs to its customers.
http://www.fiercepharma.com/manufacturing/chinese-api-company-found-faking-coas-selling-potentially-tained-products

FDA Has Never Inspected a Backlog of 1,000 Foreign Plants
Even though the FDA in the last eight years has nearly doubled the number of annual foreign plant inspections it conducts, the agency still has a huge backlog of foreign plants that have never been seen. Since safety concerns were realized during the last decade, slow and steady improvements were made in foreign production oversight. The FDA has dramatically reduced its catalog of uninspected foreign plants that ship to the U.S. but about 1,000 still have never seen a U.S. inspector.
http://www.fiercepharma.com/manufacturing/fda-has-a-backlog-1-000-foreign-plants-have-never-been-inspected-gao-report-finds

England Considers Drug Rationing
England's patients have legal access to drugs that have been approved by the cost watchdogs at National Institute for Care and Excellence (NICE), but that could change. They may face yet another barrier to access as a tough budget situation has forced the country's healthcare system to consider rationing costly drugs.

The country's pharmaceutical association, ABPI, chief executive Mike Thompson, described a �20 million budget cap for drugs as "both heavy-handed and unrealistic," adding in a statement that it "will mean more patients face delays in accessing appropriate NHS care."
http://www.fiercepharma.com/pharma/u-k-weighs-drug-rationing-as-nhs-england-s-budget-tightens-report

 

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Did You Know ...

�that when I was a student, our class was going to have patches made for our lab coats designating our affiliation at the university? We wanted to use the terminology "Student Pharmacist," but were prohibited from using that designation because we were not pharmacists. We were approved to use the designation "Pharmacy Student," which we admitted accurately described our status.

 

Tip of the Week

A "pharmacist" is a "person trained in pharmacy"; not being trained.
A "student" is defined as "one who attends a school, college or university."
"Pharmacy" is defined as "the art of preparing and dispensing drugs."
Terms such as student doctor, student nurse, student attorney are not used, but instead medical student, nursing student, law student, etc.

 

Looking Back

Put your brush,
Back on the shelf,
That darn thing,
Needs a shave itself!
     Burma Shave

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