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What occurred in NECC?
Steroid inj contaminated w/ fungus
How were the hospitals complicit with the inappropriate creation of meds by NECC?
Gave fake names so they could get compounded drugs that were cheap
How did NECC purposely avoid the regulations?
Compounding for fake people
Salespeople selling to many people
Cleaning after investigation started
What was the punishment for the supervisory pharmacist at NECC?
8 yrs in prison, 2 yrs of supervised release, restitution
How many people were affected by NECC?
Killed 64
Infected 800ish
What were there problems that NECC RPh overlooked?
Improperly sterilization and verification
Shipped meds w/o test results
Mislabeled drugs
Used expired ingredients
What does the US pharmacopeia do?
Set standards for
Drug products and ingredient quality and purity
Testing and analysis methods
Compounding
What are the USP chapters and which are enforceable?
Nonsterile: 795
Sterile: 797
Hazardous: 800
Chapters under 1000 become part of FDCA by state board, FDA, TJC
What does USP 797 do?
Establish MINIMAL standards to prevent harm from
Contamination
Excessive endotoxins
Variability from strength or correct ingredients
Control people, places, processes
What are examples of CSPs?
Inj
Aq bronchial inhalation
Baths and soaks for live organs and tissues
Irrigations for body cavities
Ophthalmics
Implants
What does USP 797 apply to?
All CSP preparers
All places where CSP are prepared
All employees responsible for ensuring standards are upheld and resolve issues
What is the training required for sterile compounding?
Hand hygiene and garb
Cleaning and disinfectiing
Measuring and mixing
Aseptic tech
Proper cleanroom behavior
Sterilization and depyrogenation methods
Documentation
Understanding direction of HEPA air flow
Proper PECs use
Potential impact of personnel activities
What is the reevaluation that has to be done for sterile compounding?
Written and hands-on every 6 mnths
Visual observation of hand hygiene and garbing
Gloved fingertip sampling
Media-fill test
Cleaning and disinfection
Requalification after pause in compounding
What is the most likely cause of contamination?
Personnel
When should you not compound?
Rash
Sunburn
Sores
Conjunctivitis
Acute resp infection
What are the hygiene and PPE steps required before compounding?
Remove outer garments, cosmetics, jewelry, earbuds
Clean neatly trimmed non-polished nails
Shoe covers
Facial covers, mask, beard cover
Wash hands and forearms w/ water and soap w/ nail picks
Alcohol-based hand scrub w/ persistent activity (chlorhexidine)
Non-lint disposable gown or coverall
Sterile globes and sterile sleeves
What are PECs and examples?
Primary engineering controls (ISO class 5)
Vertical LAFW
Horizontal LAFW
Isolator/restricted access system barrier (RABS)
What is the air movement in LAFWs?
Room air drawn through prefilter on top to get large paricles out
Through 99.99% HEPA filter and projected unidirectionally
Used to minimize cross-contamination in work area and create particulate-free environment
What are the rules of LAWFs?
Run 24/7
If closed, clean thoroughly and run for at least 30min
Draw room air through pre-filter before HEPA filter
Replace HEPA according to manufacturer's recs
What is the direct compounding area?
Critical area w/in PEC where critical sites are exposed to unidirectional air flow
6inch from all sides
What is first air?
Unidirectional air from HEPA filter that shouldnt be blocked
What are the SECs and the classes?
Clean room, buffer room: 7
Ante & prep rooms: 8
What are the other controls in compounding?
Temp: 20 or lower
Humidity: <60%
Pressure: positive for clean rooms, negative for hazardous
Lighting
What does ISO class mean?
Amount of particles allowed in air
Class 3: <35.2
Class 4: <352
Increasing class = 10x amount of particles
What did the particle shedding study show?
Particles generated by humans, clothes, other activities can transport microorganisms to critical sites
What are the types of environmental monitoring for sterile compounding?
Nonviable air: particulate count
Viable air: living contaminates using growth plate
Surface sampling: cleanrooms, hoods, equipment, gowns, work surfaces
How are PECs cleaned?
Use sterile water for inj and sterile low-lint wipes to remove water-soluble residue
Go top to bottom, back to front
Allow surface to dry
What are the cleaning agents used for PECs and why?
SWFI: dissolution of messy spills
70% isopropyl: primary disinfectant
Quat ammonium cleaner: soap for sticky spills
Sporicidal agent: monthly
2% sterile bleach: economic disinfectant that can remove sporicidal residue
What is the minimum freq for cleaning of PECs besides isolators?
Beginning and end of shift
Before each batch
After spill
Suspected contamination
What is the minimum freq for cleaning of isolators?
Every time opened
Once it is closed after each time it has been opened or after each cleaning cycle if cleaning occurs w/o opening
What is the minimum freq for cleaning of work surfaces outside PEC and floors?
Daily
What is the minimum freq for cleaning of walls, ceilings, storage shelving?
Monthly
What is required for components?
Establish, maintain, follow SOPs for selection, receipt, invetory of all components, containers and closure from receipt to consumption
What type of ingredients can you use?
USP/NF when available
APIs from FDA-registered facility w/ CoA
non-APIs need to be verified for identity, strength, purity, quality if not from FDA-registered
Can use chemically pure, analytic reagent grade or ACS grade cautiously
What is required during receipt of components?
Visual inspection
Lot
Evidence of deterioration
Labeling w/ date of receipt, quantity, supplier, exp date, results of testing
CoA which verifies that material met compendium monograph
Reject, label and segregate unacceptable ingredients
What should be done if ingredients dont have vendor exp?
1yr after receipt from facility
What are the sterilization methods and when are they used?
Filtration: 0.2 or 0.22micron sterile, depyrogenated filter, used for ingredients in solution
Steam: autoclave at 121C, 15PSI for 20 to 30min, for heat-stable
Dry heat: 150C for 2.5hr for powders, ointments, oils
What are the types of terminal sterilization?
Steam
Dry heat
Verified w/ biological indicators
How is depyrogenation done?
Utensils and material in direct contact w/ CSP by 250C for 30min
Validate using endotoxin challenge vials: should see >3 log decrease in pyrogens
What are the SOPs required for sterile compounding?
Training and qualifcation
facility design
Cleaning and disinfection
Environmental monitoring
Sterilization and depyrogenation
BUD
Documentation
What do master formulation records include?
Name, strength, dosage form
Physical description of final prep
ID and amounts of all ingredients and approp container-closer system
Complete instructions including equipment, supplies, each step
BUD and storage
Quality control procedures
Sterilization method
Any other info needed to describe operation and ensure repeatability
What do compounding records include?
Name, strength, dosage form
Master formulation record reference
Date and time of prep
Assigned internal ID
Sig or initials of individuals involved in each step
Name, vendor, manufacturer, lot number, exp of each ingredient, container-closer system
Weight or measurement of each ingredient
What are the 2008 USP 797 risk levels?
Immediate use: emergency, immediate admin
Low risk: up to 3 additions using commercially manufactured sterile products
Medium: 1 into many or many into one
High: sterile prep from nonsterile ingredients
What are the 2015 risk levels based on?
Category 1 CSP: not required to be in classified area
Category 2 CSP: in classified area
When is BUD applied?
Manufacturer container opened and drug product transferred to another container
What is the purpose of BUD?
Balancing chemical stability and sterility
What are the current BUD for immediate and low segregated compounding area?
Immediate: 1hr from start of compounding
Low segregated compounding area: 12hrs or less from compounding at RT
What are the current BUD for low risk?
RT: 48hrs
Cold: 14d
Frozen: 45d
What are the current BUD for medium risk?
RT: 30hrs
Cold: 9d
Frozen: 45d
What are the current BUD for high risk?
RT: 24hrs
Cold: 3d
Frozen: 45d
What are the proposed BUD for category 1 CSPs?
RT: ≤12hrs
Fridge: ≤24hrs
What are the proposed BUD for category 2 CSPs aseptically processed and sterility test not done?
One or more nonsterile used
RT: 1 day
Fridge: 4d
Freezer: 45d
All sterile used
RT: 4d
Fridge: 10d
Freezer: 45d
What are the proposed BUD for category 2 CSPs aseptically processed and sterility test done?
RT: 30d
Fridge: 45d
Freezer: 60d
What are the proposed BUD for category 2 CSPs terminally sterilized and sterility test not done?
RT: 14d
Fridge: 28d
Freezer: 45d
What are the proposed BUD for category 2 CSPs terminally sterilized and sterility test done?
RT: 45d
Fridge: 60d
Freezer: 90d
What are the release tests that can be done?
Physical inspection for particulate, defects, cracks
Sterility inspection using USP71 membrane filtration
Bacterial endotoxin using USP85 gel clot
Which release tests are used depending on category of CSP?
Physical: both
Sterility: only category 2 based on BUD
Bacterial: only category 2 if prepared from nonsterile
What does the label on CSP need to have?
Assigned ID
Brand and/or generic or API amounts or concs
Dosage form
Total amount
Storage condition
BUD and in-use time
Single dose or multiple dose
Indication that prep is compunded
Pt name or owner name + species of pt
Route of admin
Special handling instruction
Warning statements
Name, address, contact info of compounder if CSP sent outside facility
What is quality assurance?
Written processes that at minimum verify, monitor, review adequacy of compounding process
Must be formally written down and followed
What is quality control?
Observation of tech and activities that demonstrate reqs are met
Must be formally written down and followed
What needs to be done if storing CSP w/in compounding facility?
Monitor conditions
Check controlled temp area daily
Fluctuations
If temp limits exceeded, discard
What needs to be done in handling CSPs?
Properly
Prevent depression of plunger or dislodging
Prevent attachment of admin set
What needs to be done in packaging CSPs?
Maintain integrity, sterility, stability
Written SOP for containers, insulation, stuffing
Tamper evident closures
Light sensitivity
Coolers
What needs to be done in transporting CSPs?
Delivery to make sure undamaged, sterile, stable
Include specific handling instructions exterior to container
What is the documentation that must be done?
All processes
Training and retraining
Environmental monitoring
Compounding and dispensing
Cleaning and disinfection
Equipment use and maintenance
Complaints and resolution
Release testing
What are the DOs of documentation?
Written policy on good documentation practices
Accurate and clear
Ink
Directly on document
Sign and date
Cross out and initial mistakes
What are the DONTs of documentation?
Document another's work
Assume documentation is complete
Erase, write over, scribble, white out
Ditto marks or arrows
Trust memory
Leave paperwork for next day
When do clean rooms and hoods need to be recertified and what do the tests include?
Every 6 months under dynamic/typical/worst conditions
Airflow volume
ACPH
Room pressurization
HEPA filter leak test
Smoke pattern test
Non-viable particulate count
Viable air and surface count
What are the air pressure relationships in each area?
Ante room to unclassified: positive
Nonhazardous buffer to ante: 0.02 to 0.05
Hazardous buffer to ante: -0.01 to -0.03
What are the air exchanges per hr in each area?
Both 30 APCH
What is nonviable air testing measuring?
Engineering control performance
Number of particles 0.5micrometers or bigger/m3
What is the frequency of non-viable air sampling?
Q6M
What is the nonviable air sampling max for each ISO class?
ISO 5 (PEC): ≤3250
ISO 7 (buffer): ≤325000
ISO 8 (ante): ≤3250000
What does viable air testing measure?
Colony forming units/m3
Measures proper hand hygiene, garbing, aseptic tech, pressure of surface contamination, employee competency
What is the frequency of viable air sampling?
Q6M
What is the viable surface sampling max for each ISO class?
ISO 5 (PEC): ≤3 CFU
ISO 7 (buffer): ≤5 CFU
ISO 8 (ante): ≤50 or 100 CFU
Unless highly pathogenic
What is the frequency of viable surface sampling?
Every month
What is the viable air sampling max for each ISO class?
ISO 5 (PEC): ≤1 CFU
ISO 7 (buffer): ≤10 CFU
ISO 8 (ante): ≤100 CFU
Unless highly pathogenic
What are the highly pathogenic microorganism that require immediate remediation?
Coagulase positive staphylococcus
Gram negative rods
Fungi (yeasts, molds)
What are environmental test results needed for effective ante room?
30 APCH
Positive pressure to pharmacy department
Viable and non-viable tests based on ISO 8
HEPA filter leak test
What are environmental test results needed for effective buffer room?
30 APCH
Nonhazardous: positive pressure to ante room (0.02 to 0.05)
Hazardous: negative pressure to ante room (-0.01 to -0.03)
Viable and non-viable tests based on ISO 7
HEPA filter leak test
What are environmental test results needed for effective PEC?
Viable and non-viable tests based on ISO 7
HEPA filter leak test
Smoke study test
What is the smoke study test?
Tells direction of HEPA airflow
What needs to be done if PEC fails?
Cease to use
Report w/in 48hrs
What are the biannual tests?
Non-viable airborne count
Viable air count
Compounding goods
What are the monthly tests?
Surface sampling
When should temp and humidity be tested?
2x w/in 8hr interval
When should air pressure differential be measured?
Every shift
What is the controlled room temp?
15 to 25C
What is the pharmacy temp?
20 to 25
What is the fridge temp?
2 to 8C
What is the freezer temp?
-25 to -10C
What is the humidity of controlled rooms?
<60%
How often should hood filters be changed?
Prefilter: QM
HEPA: annually
CLOSE HOOD WHILE CHANGING
How many microbes does each person carry?
3 to 5lbs
How many skin cells are shed every day
500milliojn
How many times do people touch face?
23 times/hr
Need to make conscious effort to stop
What do artificial nails and long nails harbor?
Fungus, bacteria
How many particles in makeup and mascara?
5.1 billion
Mascara: 3 billion
What does packaging contaminated with and what are the consequences?
60% bacteria
40% bacterial spores
Need to disinfected before into clean room