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drug shortage
period when the demand or projected demand for the drug within the united states exceeds the supply of the drug
effects of drug shortages
potential threat to public health, healthcare professionals need to find proper solutions, compromise the standard of care, produce waste, and increase costs
FDA
who determines a drug shortage?
ASHP
who has information on drug shortages and collects reports of drug shortage?
limited supply in certain regions, limited supply with certain wholesalers/distributors, limited supply of brand when generic is available
what are causes of limited supply from the wholesaler the pharmacy/hospital uses?
manufacturers
who reports shortages?
required
producers of life-saving medications or those intended to prevent or treat debilitating diseases are _____ to notify the FDA about shortages
six months in advance OR asap, but no later than 5 business days after the disruption
by when should mfg notify the FDA about drug shortages ?
2012 Food and Drug Administration Safety and Innovation Act (FDASIA)
law that requires notifying the FDA of changes in production of certain products to help FDA prevent and mitigate shortages
2020 Coronavirus Aid, Relief, and Economic Security Act (CARES Act)
law that requires reporting if
1) Permanent discontinuance in manufacturing
2) Interruption in manufacturing that could lead to drug shortage
3) Permanent discontinuance of the API of a drug
4) Interruption in the manufacturing of the API that could lead to drug shortage
hospitals and pharmacies
who can voluntary report drug shortage to FDA and ASHP?
email to report drug shortage
sourcing of materials, and cost of drugs
what circumstances can cause drug shortages?
too low
some drugs are priced ____ relative to the full cost of reliably producing a predictable and high quality pharmaceutical product
costs of mfg, demand of drug, number of producers in the market
factors that influence decision to withdraw from the market
FDCA regulations for compounding medications, importation laws
what are government policy or regulations that impact manufacturing and supply chain decisions?
natural disasters, shortages with API, shortages with excipients, manufacturing problems
why are there shortages?
quality issues
largest reason for drug shortage in 2013-2017
preventing shortages, early identification of anticipates shortages, responding by remedying the underlying problems when shortages arise
3 pronged approach by FDA to mitigate drug shortage?
expedite inspections of new facilities used to mfg drug in shortage
expedite review of a new or generic drug application for drugs
review and approve extended expiration dates of mfg inventory
FDA’s role in mitigating shortages
analgesics, sedatives, bronchodilators, antibiotics, hydroxychloroquine
examples of drug shortages during Covid
active pharmaceutical ingredients and raw materials
what does China provide?
India
What country is the largest producer of generic drugs?
extended use dates
What did FDA do to assist with supply interruptions?
foundation of basic IV compounding for 100s of drugs that need further dilution
what is SVP (Small volume parenteral solutions) used for?
emergency syringes, sodium bicarbonate, small volume saline, amino acids, TPN components
what are some severe shortages that impact hospitals?
switch to oral drug, switch to IV drug, compound or outsource
what are some alternatives to help with shortages?
filling RX per patient script
503A compounding pharmacies
producing large volumes of medications in bulk
503B compounding pharmacies
USP requirements 795 and 797
what regulations must a 503A Pharmacy comply with?
USP requirements 795 and 797 and cGMP requirements
what regulations must a 503B Pharmacy comply with?
Drug Quality and Security (DQSA)
who mandates risk-based federal oversight ?
New England Compounding Center (NECC) Meningitis Outbreak
stated that they were only making drugs for patient specific prescriptions, but turned out to be routinely dispensing drugs in bulk without valid prescriptions
multistate fungal meningitis outbreak occurred
LARGEST public health crisis caused by a pharmaceutical drug
contaminated preservative-free MPA steroid injections
what was the contaminated product that pts got in the NECC case?
failure to steralize, proper testing for sterility, not waiting to get results before sending drug to pts, approved use of expired drug ingredients, mislabeling to deceive customers, unsanitary conditions
what are some causes of the NECC outbreak?
2013 DQSA bill
what bill did the NECC outbreak lead to?