Thursday, September 26, 2013

KUDOS to Texas State Board of Pharmacy (TSBP) for Proposed Rules Relating to Compounding; TSBP Final Report dated August 6, 2013, of Task Force on Preparing Sterile Prepartions

Great Law Review Article by Paul C. Kuhnel entitled Pharmacists and the People Who Sue Them (note article was published in 2007 and some areas such as HIPPA has changed since it was written)

read here

September 26, 2013 Just printed the entire 146 page draft of federal compounding legislation. Note to readers if you are only interested in the compounding part you can just print the first 30 pages!!!

Let the dissecting and digesting of this compounding legislation begin.  I would love to hear what the readers think about this version.

A Quick Read through of the Draft of the ‘‘Drug Quality and Security Act’’ Is leaving Me With More Questions than Answers At this Point? Anyone else feeling the same way about this draft federal legislation?


Copy of the Draft of New Compounding Federal Legislation, ‘‘Drug Quality and Se- 5 curity Act’’, that Believe House and Senate Have Agreement About September 26, 2013

can be reviewed here

Veterinary Feed Directive Proposed Rule Lands At OMB A proposed rule specifying how drugs should be used under veterinary supervision is under review at the White House Office of Management and Budget, according to OMB's website.


At least 19 pharmacies have shut down their compounding operations in the past year, and at least 17 have recalled drugs, according to the FDA.


The FDA has inspected about 70 compounding firms in the past year, said Howard Sklamberg, the director of the FDA Office of Compliance.


MUST READ Interesting Details in this Article!!! September 26, 2013 FDA Inspections Put Compounding Pharmacies In Regulatory Gray Zone

 


Now, a follow-up on a series we aired earlier this year on drug shortages in hospitals. We called it Critical Supply, and we found that compounding pharmacies help hospitals fill the gap with somechemotherapy treatments, emergency crash-cart injections and even basic vitamins that go in IV fluids.
A compounding pharmacy that served many hospitals in the Carolinas remains shut down months after its state board of pharmacy said it could get back to work. That's because the Food and Drug Administration has effectively kept it shut down. But whether the FDA has the authority to do that is unclear. Today, WFAE’s Michael Tomsic reports on the challenges of meeting the FDA’s standards.
From the front, Medi-Fare Drug Center in Blacksburg, SC, looks like your traditional mom-and-pop, small-town pharmacy. Owner Pat Stephens even works the cash register on occasion.
From the front, Medi-Fare Drug Center in Blacksburg, SC, looks like your traditional mom-and-pop, small-town pharmacy. Owner Pat Stephens even works the cash register on occasion.
Credit Michael Tomsic
The front of Medi-Fare.
"Six, seven, eight, nine, ten, and ten is $20," Stephens said as she gave change to a young man who bought an ointment to treat poison ivy about two months ago.
But in the back of Medi-Fare, it’s a different world.
Air roars through the clean room. This is where technicians are supposed to mix and customize prescription drug cocktails that aren’t commercially available.
It was a test day for a newair filtration system in mid August. The air has to flow to a certain way to meet FDA standards. Jesse Gillikin is a consultant working with Medi-Fare.
"We're preparing to do some smoke testing over the newly installed HEPA filters," Gillikin said.
Gillikin broke a glass vial, and white smoke began pouring out. He held it near the vents, which pushed the smoke straight down over the area where technicians will compound. The idea is to have clean air flowing over a drug mix.
"You can see that the smoke is getting below where the top of the tables would be," Gillikin said. "I think the tables are 40 inches. It's a big improvement from the last design."
It’s been a long 9 months for Medi-Fare's owner. FDA inspectors have come several times since December, telling Stephens her clean room isn't up to par. She's trying to comply. And in the meantime, the biggest part of her business is shut down.  
"We've laid off 23 people," Stephens said. And that's out of a staff of close to 30.
It's also meant that about two dozen hospitals in the Carolinas are forced to go elsewhere to get some drugs in short supply. That includes hospitals in Carolinas HealthCare System.
But whether the FDA has the authority to effectively shut down Medi-Fare, or other compounders, is unclear. Sheldon Bradshaw was the FDA's chief counsel from 2005 to 2007.
"The FDA has the authority to regulate drug manufacturing," Bradshaw said. "The FDA does not regulate the practice of pharmacy. That's regulated by the states."
Bradshaw said the line between manufacturers and compounding pharmacies used to be clear. Compounders mixed drugs for specific patients in their communities, while manufacturers created drugs in bulk and often shipped them across the country.
But that line blurred as some compounders grew into big businesses.
"They're going out and creating an entire line of drug products," he said. "They'rehiring a sales force. They're going out and marketing these products to doctors like a drug manufacturer would."
An example is the compounder in New England linked to a deadly meningitis outbreak that started a year ago. There were hundreds of infections across the country, and more than 60 people died.
In response, the FDA has increased inspections of compounders, arguing they're more like manufacturers. But Bradshaw said that can be a tough argument.
"Where you have a gray area is in these cases where you have a smaller mom and pop pharmacy like the one in South Carolina that’s engaged in some compounding, perhaps even in bulk, in response to a request from a hospital for products that aren't commercially available," he said.
Hospitals have made more of those requests to Medi-Fare and other compounders as drug shortages have intensified in the past few years.
The FDA has inspected about 70 compounding firms in the past year, said Howard Sklamberg, the director of the FDA Office of Compliance. Sklamberg acknowledged the FDA's authority over compounders is unclear. But he said, "We don't send into a firm lawyers with law books."
"We send scientists and trained professionals who know how sterile drugs are supposed to be made," Sklamberg continued. He said inspectors have found startling conditions, like pharmacists using a coffee filter to filter drugs.
"We inspect and we look at the conditions in a firm, then we come back to FDA, and if there's an emergency, we take care of it," he said. "But when we think of using the law, we then consult our lawyers."

Prevent Tennessee Families From “Living Through Another Nightmare Like Last Year’s Tragic Meningitis "The FDA commissioner has warned us that, without fixing oversight, a similar outbreak will happen again, so I have worked hard with my colleagues in the House and Senate to make it clear at every..

read here