Friday, May 31, 2013

What are Bulk Ingredients and Why are they Necessary for Compounding?

When a medical practitioner determines that a medication needs to be compounded to meet the needs of patients ... 

... it is because there is no commercially available, FDA- approved medication to fit that patient’s medical need. While there may be commercially available FDA-approved medications containing the active ingredient being prescribed, the dosage form, strength or flavor of the medication may be one that the patient physically cannot tolerate. In other cases, excipients such as fillers and preservatives found within the commercially available medication may prohibit the patient from being able to take the medication due to sensitivities or allergies to these substances.  
When a drug is customized, or compounded, to meet the identified needs of patients or groups of patients, it is common practice to use only ingredients necessary to achieve the prescribed compounded medication. This means starting with the active pharmaceutical ingredients (API) in its purist form, and then adding only the excipients necessary to achieve the prescribed dosage-form, strength, and where specified, flavor. These are the essential ingredients that make the medicine what it is, and are commonly referred to as bulk ingredients. Using bulk ingredients in a compounded medication is the surest, safest way of satisfying the prescriber’s request for medication to meet the special, customized needs of the patient.
Replacing bulk ingredients used in compounds, particularly a bulk API, with an API from an existing commercially available medication, such as a tablet or capsule, has the potential for serious health problems for those patients using that medication, for two main reasons. First, because the active ingredient makes up only a small portion of the overall ingredients used in commercial tablets or capsules, it is impossible to separate the active ingredient from the other excipients (fillers, binders, dyes, flavorings, preservatives and other materials). Without being able to separate these excipients means that they would then become incorporated into the finished compounded medication.
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The Law of Veterinary Medicine: Question of the Day: May 31, 2013 Wouldn't It Be ...

The Law of Veterinary Medicine: Question of the Day: May 31, 2013 Wouldn't It Be ...

20 now sick in new outbreak tied to pain shots

20 now sick in new outbreak tied to pain shots

COMPLAINT IN DR. MARK W. STURDY d/b/a )ROCHESTER VETERINARY CLINIC on behalf of itself and a class, Plaintiff, v. LOWLITE INVESTMENTS, INC., doing business as OLYMPIA PHARMACY, and JOHN DOES 1-10,

The Complaint  alleges that Lowlite/Olympia violated plaintiff's (a class action-too numerous to name) rights in sending or causing the sending of unsolicited advertisements to telephone
facsimile machines in violation of the Telephone Consumer Protection Act, 47 U.S.C. §227
(“TCPA”), the Illinois Consumer Fraud Act, 815 ILCS 505/2 (“ICFA”), and the common law.  The advertisement of course was for compounded medications.  See exhibit A to complaint.  This will be a very interesting case to watch develop.

Lowlite/Olympia Has Recently Been Sued--Dr. Mark W. Sturdy d/b/a Rochester Veterinary Clinic v. Lowlite Investments, Inc., d/b/a Olympia Pharmacy and John Does 1-10

filed April 30, 2013, Case Number 3:2013cv03126.

Here is docket summary.  Will post copy of complaint soon.

Date Filed#Docket Text
04/30/20131 COMPLAINT against John Does 1-10, Lowlite Investments, Inc., d/b/a Olympia Pharmacy ( Filing fee $ 350 receipt number 0753-1579273.), filed by Dr. Mark W. Sturdy d/b/a Rochester Veterinary Clinic. (Attachments: # 1 Exhibit A, # 2 Civil Cover Sheet, # 3 Summons)(Edelman, Daniel) (Entered: 04/30/2013)
04/30/20132 NOTICE of Appearance of Attorney by Daniel A Edelman on behalf of Dr. Mark W. Sturdy d/b/a Rochester Veterinary Clinic (Edelman, Daniel) (Entered: 04/30/2013)
04/30/20133 NOTICE of Appearance of Attorney by Dulijaza Julie Clark on behalf of Dr. Mark W. Sturdy d/b/a Rochester Veterinary Clinic (Clark, Dulijaza) (Entered: 04/30/2013)
04/30/20134 MOTION to Certify Class by Plaintiff Dr. Mark W. Sturdy d/b/a Rochester Veterinary Clinic. Responses due by 5/17/2013 (Edelman, Daniel) (Entered: 04/30/2013)
04/30/20135 MEMORANDUM in Support re 4 MOTION to Certify Class filed by Plaintiff Dr. Mark W. Sturdy d/b/a Rochester Veterinary Clinic. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Edelman, Daniel) (Entered: 04/30/2013)
04/30/20136 NOTICE of Appearance of Attorney by Michelle R Teggelaar on behalf of Dr. Mark W. Sturdy d/b/a Rochester Veterinary Clinic (Teggelaar, Michelle) (Entered: 04/30/2013)
04/30/20137 MOTION to Continue and enter Plaintiff's Motion for Class Certification by Plaintiff Dr. Mark W. Sturdy d/b/a Rochester Veterinary Clinic. Responses due by 5/17/2013 (Clark, Dulijaza) (Entered: 04/30/2013)
05/02/2013  TEXT ORDER by Magistrate Judge Byron Cudmore: Plaintiff's Motion to Enter and Continue Plaintiff's Motion for Class Certification 7 ALLOWED in that Plaintiff's Motion for Class Certification 4 will remain of record and taken under advisement until the parties are at issue. The ECF response date from Motion 4 is stricken. Plaintiff to take steps to serve Defendants. (LB, ilcd) (Entered: 05/02/2013)
05/15/20138 Summons Issued as to Lowlite Investments Inc.. Original returned to attorney for service. (MJ, ilcd) (Entered: 05/15/2013)


FLASHBACK: Olympia Pharmacy Was One of The Pharmacies That Forced the FDA to Get A Warrant in Order to Inspect

The New York Times reported that Olympia Compounding Pharmacy in Orlando forced the FDA to get a warrant in order to enter and inspect the pharmacy.  Scott A. Livingston, Olympia’s lawyer,  said the pharmacy required the warrant because it was concerned about patient privacy.  

Who Will Be the Compounding Pharmacy Exhibitors At These Upcoming Veterinary Conferences?

6/12/2013 - 6/16/2013Sun & Fun Veterinary Conference
6/20/2013 - 6/23/2013PACVET Conference
6/27/2013 - 6/30/2013North Carolina VMA

Question of the Day: May 31, 2013 In Doing Research For this Blog, I Find It Unreal that Without Even Looking I Saw Three Job Openings Relating to Sales or Marketing Reps at Compounding Pharmacies

Is it odd that Pharmacies Seem to Be Expanding in the Compounding World With All the Negativity Surrounding Them Right Now?  Wouldn't One Expect More Pharmacists and Pharmacies to Be Cautious in this Area?  Is the Expansion Just a Sign of the Greed? Or is it simply that Pharmacies and Pharmacists See A Need in this Area at this Time?

IMPORTANT: CDC calls illnesses associated with TN compounder an outbreak--17 states now included

The U.S. Centers for Disease Control and Prevention on Thursday classified illnesses associated with medicines made by a compounding pharmacy in Newbern, Tenn., as an outbreak.
The CDC launched a website to offer guidance on suspected infections among people who received preservative-free methylprednisolone acetate (MPA) 80mg/mL in 10mL vials produced by the Main Street Family Pharmacy. This is the same steroid medicine formerly made by New England Compounding Center linked to last year’s fungal meningitis outbreak.
“The majority of these persons developed skin and soft tissue infections of unclear etiology following intramuscular injection of this product,” the CDC said. “Additional clinical information is being gathered. To date, no reports of meningitis or other life-threatening infections have been reported.”

Question of the Day: May 30, 2013 Isn't it Unbellieveable that No State Seems to Really Knows How Many Pharmacies Compound Mediciations in their State or Ship into Their State, and in some cases

state board of pharmacy don't know how many compounding pharmacies they inspected last year?

One example of this is Texas.  When you research a pharmacy on Texas State Board of Pharmacy (TSBP) website the information for compounding-especially sterile compounds may contain no information simple because the pharmacy failed to submit it; not became it does not do sterile compounds.  It is my understanding that TSBP is working on correcting this flaw in its system. Another example, Oklahoma Board of Pharmacy does not keep track of inspections other than the total number of pharmacies it inspects in a year.  States simple must do a better job of gather, collecting and publicizing this type of information, but his takes resources and money in the budget.