Reading 6 Flashcards
Covers the PDMA, Federal Anti-Tampering Act, and DSHEA.
What was the Prescription Drug Marketing Act (PDMA)?
enacted to fight drug diversion from normal distribution channels and protect public health
What are the 6 parts of the PDMA?
- reimportation
- preferential pricing
- samples and coupons
- wholesale distributors
- recordkeeping requirements
- whistleblower awards
Although the PDMA normally prohibits reimportation of drugs, what are the two exceptions?
- when done by the manufacturer and no real profit is to be gained (also held to a strict standard when selling drugs in the US)
- when used for emergency use after FDA review
If reimported, drugs are considered __________.
adulterated
What does the preferential pricing section of the PDMA state?
you cannot sell, purchase, or trade (or offer to) drugs purchased at a reduced price by a hospital/healthcare facility or donated to charity
IF IT WAS PREFERENTIALLY PRICED, IT CANNOT BE SOLD TO AN ORGANIZATION WHO WOULD NOT NORMALLY GET THAT PRICE!
True or false: according to the PDMA, drug samples cannot be sold or purchased, but they can be traded.
false
True or false: retail pharmacies cannot have prescription samples on the premises.
true
What are the PDMA recordkeeping requirements?
must keep records relating to PDMA for 3 years (can be electronic if easily retrievable and resistant to changes)
What was the Federal Anti-Tampering Act?
enacted after Chicago Tylenol poisonings, and created 5 new crimes: tampering, tainting, communicating false information, threatening to tamper, and conspiring to tamper
When is tamper-evident packaging required?
for all products available directly to a patient on a retail shelf (OTC and other consumer products)
What three things are required of tamper-evident packaging?
- 1+ indicators or barriers of entry
- distinctive packaging or difficult to reproduce
- ability to remain intact during handling
What type of labeling is also required of tamper-evident packages?
prominently-placed statement of all tamper-evident features
What was the Dietary Supplement Health and Education Act (DSHEA)?
established the dietary supplement category, which allowed manufacturers to make certain claims about their product without being reviewed by the FDA prior to marketing
Dietary supplement manufacturers must notify the FDA within _________ after marketing their product.
30 days
True or false: supplements must show evidence of GRAS/GRAE
false