Chapter 1 fed Flashcards
Following deaths caused by sulfanilamide elixir in 1937, Congress passed the first legislation that required new drugs to be proven to be safe prior to marketing.
Which Act?
Food, Drug, and Cosmetic Act of 1938
pg 21
Which Act established the FDA and is the primary federal law dealing with food, drug, cosmetic, and medical device safety today (with many amendments).
Food, Drug, and Cosmetic Act of 1938
pg 21
Which amendment established two classes of drugs: prescription and OTC
Durham-Humphrey Amendment of 1951
pg 21
T or F:
Under Florida law, medical oxygen may be supplied to a patient by a medical oxygen retail establishment licensed by the FL department of business and professional regulation (DBPR) pursuant to a valid prescription.
TRUE
It is one of the few drugs in FL that can be dispensed by a business that does not have a pharmacy permit.
pg 21
Which amendment authorized verbal prescriptions and prescription refills?
Durham-Humphrey Amendment of 1951
pg 21
Which amendment required new drugs to be proven safe and effective for their claimed use?
Kefauver-Harris Amendments of 1962
Prior to this amendment, new drugs only had to be safe. This amendment required new drugs to also be effective for their stated use.
pg 21
Which amendment increased safety requirements for drugs and established Good Manufacturing Practices (GMPs) for manufacturing of drugs?
Kefauver-Harris Amendments of 1962
pg 22
Which amendment gave the FDA jurisdiction over prescription drug advertising?
Kefauver-Harris Amendments of 1962
pg 22
Which Act banned the re-importation of prescription drugs and insulin products produced in the United States (except by the manufacturer) and banned the sale, trade, or purchase of prescription drug samples?
Prescription Drug Marketing Act of 1987 (PDMA)
pg 22
T or F
Starter packs are subject to regulation as prescription drugs in the same manner as stock shipments of prescription drugs. Starter packs are NOT drug samples.
True
pg 22
What Act mandates the storage, handling, and record keeping requirements for prescription drug samples?
Prescription Drug Marketing Act of 1987 (PDMA)
Pg 23
Which Act does the following pertain to?
- obtaining written requests for samples from practitioners and requiring signatures of practitioners upon receipt
- samples may only be provided to practitioners or, upon request of a licensed practitioner, to an institutional pharmacy or to pharmacies of other healthcare facilities
-community pharmacies should not possess prescription drug samples, except for prescription drugs that may be ordered by a pharmacist. The only exception to this would be a community pharmacy that is part of a healthcare entity such as a community pharmacy owned by a hospital
Prescription Drug Marketing Act of 1987 (PDMA)
Pg 23
In Florida, what permit is required to hold distribute, or dispose of prescription drug samples.
Complimentary Drug Distributor Permit from the Division of Drugs, Devices, and Cosmetics (DDDC) of the Department of business and professional regulation
required to by the Prescription Drug Marketing Act of 1987 (PDMA).
pg 23
Who may not be in possession of prescription drug samples?
A community pharmacy that is not affiliated with a healthcare entity
pg 23
Which Act prohibits, with certain exceptions, the resale of prescription drugs purchased by hospitals or healthcare facilities?
Prescription Drug Marketing Act of 1987 (PDMA)
*this is intended to prevent diversion of drugs due to price diversion because hospitals generally receive lower prices for drugs than community pharmacies
pg 23
The Drug Quality and Security Act of 2013 - these amendments to the FDCA addressed which two primary topics?
1) large-scale compounding by pharmacies
2) establishment of a frame-work for uniform track-and-trace system for prescription drugs throughout the supply chain to prevent counterfeit drugs
pg 23
Which Act passed in response to an outbreak of fungal meningitis in over 20 states in the fall of 2012, which was traced to a contaminated injectable steroid produced by the New England Compounding Center?
Drug Compounding Quality Act (DCQA)
*This outbreak resulted in the death of 60 patients and over 750 cases of infection
pg 23
Which Act allows outsourcing facilities, often referred to as 503B facilities to compound sterile products without receiving patient-specific prescriptions or medication orders?
Drug Compounding Quality Act (DCQA)
*these 503B facilities are primarily regulated by the FDA and are subject to FDA’s current Good Manufacturing Practices (cGMP) – there are currently only 70 registered outsourcing facilities in the entire country
pg 24
True or False
Outsourcing facilities that meet the Drug Compounding Quality Act are exempt from:
- premarket approval requirements for new drugs
-adequate directions for use requirements
-drug trace-and-track provisions
TRUE
pg 24
What is the difference between 503A and 503B?
503A pharmacies may only compound products pursuant to an individual prescription or medication order; permitted to do limited anticipatory compounding and primarily regulated by the states, and are subject to USP Chapter 797 quality standards for sterile compounding; NOT registered with the FDA as an outsourcing facility
503B no rx required; registered with the FDA
pg 24
Are outsourcing facilities exempt from good manufacturing practices?
No
pg 24
T or F
Outsourcing facilities MUST:
1) have a licensed pharmacist who provides direct oversight over the drugs compounded
2) register as an outsourcing facility
3) Report to the Secretary of HHS upon registering and every 6 months thereafter, the drugs sold in the previous six months
4) be inspected by FDA according to risk-based inspection schedule and pay annual fees to support it
5) report serious a/e experiences within 15 days and conduct a f/u investigation and reporting similar to current drug manufacturers
6) label products with a statement identifying them as a compounded drug and other specified information about the drug
True
pg 24
When are outsourcing facilities allowed to compound a drug product that includes a bulk drug substance?
1) the bulk drug substance appears on a list identifying bulk drug substances for which there is a clinical need
OR
2) the drug product compounded from such bulk drug substance appears on FDA’s drug shortage list at the time of compounding, distribution, and dispensing
pg 25
Section 503A limits interstate distribution of compounded drugs to __% unless the compounder is located in a state that has entered into a memorandum of understanding (MOU) with FDA addressing inordinate amounts of compounded drugs in interstate commerce and providing for appropriate investigation of complaints by a state
5%
pg 26
In states that have entered into an MOU with FDA, a pharmacy is considered to have distributed an inordinate amount of compounded drug products in interstate commerce if the number of prescription orders for compounded human drug products that the pharmacy distributed interstate during any calendar year is great than 50% of the sum of:
1)
2)
1) # of prescription orders for compounded human drug products that the pharmacy sent out of (or caused to be sent out of) the facility in which the drug products were compounded during that same calendar year
PLUS
2) the number of rx orders for compounded human drug products that were dispensed (eg picked up by patient) at the pharmacy during that same calendar year.
pg 26
T or F
In states that have not entered into an MOU with the FDA, a pharmacy may not distribute (or cause to be distributed) compounded drug products out of the state in which they are compounded in quantities that exceed 5% of the total prescription orders dispensed or distributed by such pharmacy
True
pg 26
NOTE: beginning Oct 2022, FL pharmacies may not distribute (or cause to be distributed) compounded drug products out of state in quantities that exceed 5% of the total prescription orders dispensed or distributed by such pharmacy ***this COULD change
Which Act?
1) provides for a uniform national framework for an electronic track-and-trace system for prescription drugs as they move through the supply chain, and sets national standards for state to license drug wholesaler distributers
2) applies to prescription drugs for human use in finished dosage form, but certain products are exempted, including blood and blood components, radioactive drugs, imaging drugs, certain IV products for fluid replacement, dialysis solutions, medical gases, compounded drugs, medical convenience kits containing drugs, certain combination products, sterile water, and products for irrigation
Drugs Supply Chain Security Act (DSCSA) (Track and Trace)
Pg 27
Per ______ Act, manufacturers are required to provide “Transaction Data” for each product sold. Wholesalers are required to receive transaction data upon purchase and subsequently provide transaction data to buyer (pharmacies or other wholesalers), and pharmacies are required to receive transaction data and pass this information along if they further distribute the product
Drugs Supply Chain Security Act (DSCSA) (Track and Trace)
**transaction data INCLUDES:
> transaction information (product’s name, strength, dosage form; NDC #; container size and number of containers; date of transaction; and name and address of the person from whom ownership is being transferred and to whom ownership is being transferred. A unique product identifier or serialized numerical identifier (SNI) will also be required that identifies an individual bottle or unit of sale),
> transaction history (a paper or electronic statement that includes prior transaction back to the manufacturer)
> AND a transaction statement (a paper or electronic statement by the seller that the seller is authorized (licensed), received the product from an authorized person (licensed), received the transaction info and transaction history from the prior owner if required, did not knowingly ship a suspect or illegitimate product, has systems and processes to comply with verification requirements, and did not knowingly provide false transaction information)
pg 27
How long must transaction data be maintained for by each supply chain partner?
6 years
pg 28
When pharmacies are investigating any suspect or illegitimate product, a pharmacy must verify the product identifier of at least __#__ products or ___% of the suspect product, whichever is greater, or all of the packages if there are fewer than _#__.
= at least 3 products, or 10%
pg 28
What form do pharmacies use when notifying the FDA of an illegitamate product?
Form FDA 3911 and notify trading partners within 24 HOURS
pg 29
Drug Supply Chain Security Act (DSCSA - Track and Trace)
What are the 4 exceptions to having a distribution license and passing transaction data?
1: when the distribution is between two entities that are affiliated or under common ownership
2: when a dispenser is providing product to another dispenser on a patient-specific basis
3: when a dispenser is distributing under emergency medical reasons
or
4: when a dispenser is distributing “minimal quantities” to a licensed practitioner for office use
pg 29
Adulterate or misbranded?
the drug contains any filthy, putrid, or decomposed substance
adulterated
pg 29
Adulterate or misbranded?
the drug has been prepared or held under insanitary conditions where it may have been contaminated
adulterated
pg 29
Adulterate or misbranded?
the methods of manufacture do not conform to current good manufacturing practices
adulterated
pg 30
Adulterate or misbranded?
the drug has been manufactured, processed, packed, or held in any factory, warehouse, or establishment and the owner, operator, or agent of such factory/warehouse/establishment delays, denies, or limits and inspection or refuses to permit entry or inspection
Adulterate
pg 30
Adulterate or misbranded?
the container is composed of any poisonous or deleterious substance which may contaminate the drug
adulterated
pg 30
Adulterate or misbranded?
the drug contains an unsafe color additive
adulterated
pg 30
Adulterate or misbranded?
it purports to be a drug in an official compendium and its strength differs from or its quality or purity falls below the compendium standard, unless the difference is clearly stated on the label
aka the product claims to meet USP standards and its strength or quality does not meet those standards
adulterated
pg 30
Adulterate or misbranded?
it is not in a compendium and its strength differs from or its quality falls below what it represents
aka even if the product does not claim to meet USP standards, if the strength or quality differs or falls below what is stated on its label or labeling, it is…… _______________
adulterated
pg 30
Adulterate or misbranded?
the drug is mixed or packed with any substance that reduces its strength or quality, or the drug has been substituted in whole or in part
adulterated
pg 30
Adulterate or misbranded?
If a products strength is less than what is represented on its label
it could be BOTH misbranded and adulterated
pg 30
Adulterate or misbranded?
the labeling is false or misleading in any particular way
misbranding
pg 30
Adulterate or misbranded?
it is a prescription drug and the manufacturer’s labeling fails to contain the following information:
-the name and address of the manufacturer, packer or distributor
-brand and/or generic name of the drug or drug product
-the net quantity (weight, quantity, or dosage units)
-the weight of active ingredient per dosage unit
-the federal legend “rx only”
-if not taken orally, the specific routes of administration
-special storage instructions, if appropriate
-manufacturers control number (lot number)
-expiration date
-adequate information for use. for rx drugs, this is the package insert and medication guide or patient package insert if required. this also includes other information required (certain products, including opioids and benzos, required black box warnings to alert healthcare professionals about essential info about the product)
misbranded
pg 30
NOTE: these labeling requirements are for the manufacturer; when a pharmacist dispenses a drug to a patient pursuant to a valid prescription, the label does not have to contain all of these elements. refer to the state prescription labeling requirements
Adulterate or misbranded?
It is an OTC drug and fails to contain the following:
a. A principle display panel, including a statement of identity of the product
b. The name and address of the manufacturer, packer or distributer
c. net quantity of contents
d. cautions and warning needed to protect user
e. adequate directions for safe and effective use
f. content and format of OTC product labeling in drug facts panel format (active ingredients, purpose, uses/indications, warnings, directions, other info, inactive ingredients, questions+telephone #)
misbranded
pg 31
*pharmacists should know labeling requirements for OTC drugs
Adulterate or misbranded?
It is a drug liable to deterioration unless it is packaged or labeled accordingly
misbranded
pg 31
Adulterate or misbranded?
The container is made, formed, or filled as to be misleading
misbranded
pg 31
Adulterate or misbranded?
the drug is an exact imitation of another drug or offered for sale under the name of another drug
misbranded
pg 31
Adulterate or misbranded?
it is dangerous to health when used in the dosage or manner suggested in the labeling
misbranded
pg 32
Adulterate or misbranded?
it is packaged or labeled in violation of the Poison Prevention Packaging Act
misbranded
pg 32
Dispensing a prescription without authorization causes the drug to be ____________ even if it is labeled correctly by the pharmacist. This is because a prescription drug product is only exempt from the manufacturers labeling requirements when it is dispensed pursuant to a valid prescription
Adulterate or misbranded?
misbranded
pg 32
Misfiling a prescription with the wrong drug, strength, or directions for use will always cause the drug to be _____________.
if a misfiled prescription involves the wrong strength of the drug prescribed, it would also be ___________.
Adulterate or misbranded?
misbranded
adulterated – this is because the definition of adulteration includes when the strength differs from or quality falls below that which it represents
pg 32
If a drug is subject to REMS and it is prescribed or dispensed without meeting the requirements of the REMS, it is ______________
Adulterate or misbranded?
misbranded – because the REMS program is part of the official labeling of the drug
pg 32
The advertising or promotion of a compounded drug that is false or misleading would be ______________
Adulterate or misbranded?
misbranding
pg 32
An expired drug product in a manufacturer’s bottle is adulterated because after the expiration date, the strength cannot be assured. If a prescription is filled using an expired product, it may also be ______________ if the pharmacist placed a BUD that is after the expiration date of the drug
Adulterate or misbranded?
misbranded
pg 33