Human Medications, Human Drugs, Animal Medications, Animal Drugs, Pharmacy law, Pharmaceutical law, Compounding law, Sterile and Non Sterile Compounding 797 Compliance, Veterinary law, Veterinary
Compounding Law; Health Care; Awareness of all Types of Compounding Issues;
Pharmacy Benefit Managers (PBMs), Outsourcing Facilities
Food and Drug Administration and Compliance Issues
Monday, June 3, 2013
Compounding Pharmacy Regulation: A Matter of Life and Death On 06/03/2013
When deciding whether to prescribe a medicine to a patient, a doctor will worry about whether it is the best treatment for the situation. And the patient will worry about whether the treatment will work and what the side effects might be. But neither the doctor nor the patient will think about whether or not the medicine that is dispensed is truly what the label says it is, or whether it might be harbor a dangerous contaminant.
NECC was operating as a compounding pharmacy. The basic assumption in these types of facilities is that they comprise individual pharmacists creating specific formulations in response to doctors’ prescriptions for particular patients. This is a needed function in hospitals and street-corner pharmacies. However, some compounding “pharmacies” (like NECC) are really operating as pharmaceutical manufacturers, filling batches of thousands of units and then offering them for sale to doctors, often at deep discounts compared to medicines produced by actual manufacturers.
Unlike pharmaceutical manufacturers, these mass-production compounding pharmacies are not required to adhere to Current Good Manufacturing Practices (cGMPs), a system required by FDA that establishes processes and procedures that assure consistently high quality drugs, as well as reactive programs to promptly detect and then prevent recurrences of problems. Instead compounding pharmacies are subject to widely varying state-by-state regulations.
Instead of cGMPs, the U.S. Pharmacopoeia (USP) chapter <797> is the recognized standard of practice for compounding pharmacies manufacturing sterile products in the US, but USP <797> is far less rigorous than the expectations of cGMPs and is really appropriate only for small pharmacies filling specific prescriptions for specific patients, not for large-scale production. Additionally, only 23 states currently require compliance with USP chapter <797>, and even in the states that do require compliance, it is unclear whether the states have the resources to enforce the regulations. The result is that tens of thousands of Americans are unwittingly being exposed to potentially dangerous medicines.