Review PDF Flashcards
Where to find federal laws and regulations?
United States Code (USC)
Code of Federal Regulations (CFR)
***Most in title 21 in both places
Where to find Indiana laws and regulations?
Indiana Code (IC) - title 16, 25, and 35 Indiana Administrative Code (IAC) - title 856
What is adulteration and what are examples?
When something is wrong with the preparation, strength, or purity of a product
- Dirty drug, decomposing, expired
- Made or packaged in unsanitary conditions where it MAY have been contaminated
- Manufactured not according to good manufacturing practices
- Container is composed of poisonous or deleterious substance
- Doesn’t meet official standards
- Strength doesn’t match
- Incorrect substitution
What is misbranding and what are examples?
Something wrong with outside of product or with words associated with product
- False or misleading labeling
- Generic name must be half the size of brand name
- Adequate directions for use and warnings
- Imitation of another drug
- Directions are dangerous
- Not packaged in special packaging when required
Adulteration vs misbranding focus
Adulteration - drug product (strength, purity, quality, manufacturing process)
Misbranding - label and labeling of drug product
Current good manufacturing practice (CGMP or cGMP) definition
Set of regulations that establish the minimum requirements for manufacturing drug products for administration to humans OR ANIMALS
Who do cGMP regulations apply to?
Anyone manufacturing drug products IN the US or who are manufacturing drugs for USE IN the US (even if overseas)
Does not apply to pharmacies unless they engage in manufacturing
How often must manufacturers go through inspection to ensure cGMP?
Every 2 years
What criteria must a COMPOUND meet to be considered pharmacy compounding? Does cGMP apply to it?
- For an individual patient
- Based on the receipt of a valid prescription or drug order from a licensed practitioner
- Compounded by a licensed pharmacist or licensed physician
Is EXEMPT from cGMP, misbranding, and new drug requirements if compound meets all 3 criteria
Can pharmacists compound a medication before receiving a prescription?
Yes! They just can’t dispense it.
Does reconstitution count as compounding?
No! It is not considered compounding if the bottle contains directions on how to reconstitute or mix in approved labeling provided by the product’s manufacturer and other manufacturer directions
Pharmacies cannot compound and distribute more the ___% of total prescriptions dispensed or distributed unless there is an understanding between the pharmacy’s state and the FDA
5%
Outsourcing facility definition
if a location does not meet requirements for pharmacy compounding
Labeling requirements for compounded medications compounded by an outsourcing facility
“This is a compounded drug”
Info of outsourcing facility
Drug info including batch number, expiration date, storage and handling instructions, list of inactive ingredients
Class I medical device definition
Simplest device type
Not used for supporting, sustaining life or for preventing impairment of human health
Do not present a potential unreasonable risk of illness or injury
Class II medical device definition
Require promulgation of performance standards, postmarket surveillance, patient registries, development and dissemination of guidlines, recommendations, and other appropriate actions
Class III medical device definition
Require premarket approval
Used for supporting or sustaining human life or for a use which is of substantial importance in preventing impairment of health or presents a potential unreasonable risk of illness or injury
Class I medical device examples
Stethoscopes, scissors, toothbrushes
Class II medical device examples
Syringes, tampons, condoms, and A1c immunoassays
Class III medical device examples
Pacemakers, replacement heart valves, soft contact lenses
Which class of medical devices do all new devices fall into?
Class III unless otherwise determined by the FDA to be I or II
Restricted devices definition
Devices that require a prescription due to potential for harm and need for collateral measures to ensure proper use
Restricted devices examples
Contact lenses and diaphragms
Custom devices definition
Ordered by HCP to fit the specific needs of a single patient
Ex: orthopedic footwear, certain braces, canes permanently modified for a patient’s height
Banned devices definition
Devices excluded from US market
Ex: prosthetic hair fibers
Does the FDA have the authority to require a manufacturer to recall a drug?
No - they do have the authority to take seizure or injunction (authoritative warning) action if manufacturer is unwilling
For what does the FDA have the authority to require a recall for?
Devices, biological products, and foods
NOT DRUGS
Class I, II, and II recalls severity
I - most serious; reasonable probability that if used or exposed to, the product will cause serious consequences or death
II - use or exposure to may cause temporary or medically reversible adverse health consequences or where probability of serious adverse health consequences is remote
III - Least serious; use of or exposure to is no likely to cause adverse health consequences
Who is responsible for notifying sellers of a recall? Who is responsible for nofitfying customers?
Sellers (pharmacies and wholesalers) - manufactueres
Customers - pharmacies
What is the poison prevention packaging act (PPPA)? What is the goal?
Gives consumer product safety comission (CPSC) the authority to require special packaging of “hazardous substances”
Prevent accidental poisonings of pts <5 years
What requirements must packaging meet to be considered child-resistant?
- 90% of adults must be able to open the container without significant difficulty
- 85% of children <5 years who have never seen the type of packaging undergoing testing should not be able to open the container in 5 minutes
- 80% of children under 5 cannot successfully open the package in 5 minutes after an adult shows them how to open the container
Drug exemptions for child-proof packaging
Non-oral medications (nasal spray, eye drops, ointments)
Pts and prescribers can waive child-resistant packaging
SL nitro
Birth control
Medrol dosepak
When waiving child-proof packaging, what can providers do? Patients?
Providers can grant a waiver on a prescription-by-prescription basis (covers refills for this rx)
Patients and pt representatives can make a blanket waiver for all prescriptions
If a pt brings their rx bottle, can you reuse it to refill their rx?
If plastic - no
If glass - yes but new cap is required
How are the years 2001 and 2006 important with regard to package inserts?
Before 2001 - new format not required
After 2006 - new format required
Between 2001 and 2006 - format slowly updated
What is a patient package insert (PPI)? When should it be given to the pt? Which drugs are required to have a PPI?
FDA-approved labeling written in pt friendly language that explains uses, risks and precautions
MUST be dispensed with drug both on new prescriptions and every 30 days thereafter (upon refills or every 30 days when in institution)
Required: oral estrogens (but manufacturers can make them if they believe it would benefit the patient)
Medication guide definition and when to give to pt
FDA-approved labeling written in pt friendly language that explains issues related to specific drug or class Must be given on new and refill prescriptions for pts not under direct supervision of HCP
When are medication guides required?
When FDA determines one or more of the following circumstances are met:
- Drug product is is one for which pt labeling could help prevent serious adverse effects
- Drug product has serious risks of which pt should be made aware b/c info concerning the risks could affect pt decision to use or continue to use
- Drug product is important to health and pt adherence to directions for use is crucial to drugs effectiveness
Purpose of prescription drug marketing act (PDMA)
Protect public health and to protect the public against drug diversion by establishing procedures, requirements, and minimum standards for the distribution of prescription drugs and prescription drug samples
What does the prescription drug marketing act (PDMA) say about reimportation of drugs?
Prohibits reimportation of rx drug into US unless reimported by manufacturer of drug or for emergency use after evaluation by FDA
What does the prescription drug marketing act (PDMA) say about selling, purchasing, or trading rx drugs purchase at a reduced price?
Cannot do or offer to sell, purchase, or trade rx drugs purchased by hospital or other healthcare facility as well as donated or suppied to charity at a reduced price
What does the prescription drug marketing act (PDMA) say about drug samples and drug coupons?
Bans sale, purchase, or trade drug samples and counterfeiting drug coupons
Requires practitioners to ask for drug samples in writing, prohibits retail pharmacies from having drug samples at any time, establishes record keeping, storage, and handling requirements for drug samples
What does the prescription drug marketing act (PDMA) say about record keeping?
Details how records should be kept and how to respond to record requests
Can be kept in electronic form if they are easily retrievable and resistant to tampering, modification, or unauthorized use and should be maintained for 3 years
What does the prescription drug marketing act (PDMA) say about “whistleblower” award
If you provide info on someone violating the PDMA and that info leads to conviction, you are entitled to one-half of the criminal fine imposed and collected for such violation, but not more than $125,000
What does the prescription drug marketing act (PDMA) say about wholesale distributors?
All states must license
Wholesalers must keep record of purchase of a product and provide a statement of origin if they are not an authorized distributor
Manufacturers must maintain a list of authorized distributors in their corporate office
5 parts of the federal anti-tampering act
1) Tampering or attempting to tamper with a product’s packaging or labeling
2) tainting a product
3) communicating false information that a product has been tainted
4) threatening to tamper with a product
5) conspiring to tamper with a product
What medications require tamper-evident packaging?
OTC drugs directly available to patients
What are requirements for tamper-evident packaging
- cannot be easily replicated (distinctive by design)
- one or more indicators or barriers to entry that use an identifying characteristic like a trademark, pattern, phrase, or picture
- capsules must be sealed to prevent opening
- prominently placed statement identifying all tamper-evident features must be on package in place that cannot be removed
The dietary supplement health and education act allows manufacturers to make statements about dietary supplements if they include any of what 4 things?
1) claims benefit related to a classical nutrient deficiency disease nad discloses prevalence of such disease in US
2) Describes role of nutrient or dietary ingredient intended to affect structure or function in humans
3) Characterizes documented mechanism by which a nutrient or dietary ingredient acts to maintain such structure or function
4) Describes general well-being from consumption of a nutrient or dietary ingredient
Pharmaceutical equivalents vs therapeutic equivalents
Pharm - products with same active ingredients, same dosage form, and same strength
Therapeutic - pharmaceutical equivalents that likely have the same clinical and safety profile
What info does the orange book provide?
If pharmaceutical equivalents are also therapeutic equivalents
What do the following mean in the orange book A B AA BX AN
A - products are bioequivalent to RLD and therapeutically equivalent
B - not bioequivalent or therapeutically equivalent
AA - products in conventional dosage forms not presenting bioequivalence problems
BX - products for which data are insufficient to determine therapeutic equivalence
AN - bioequivalent solutions and powders for aerosolization
What is an investigational new drug (IND) application?
Application sent to FDA asking for exemption to NDA in order to investigate and conduct clinical trials on a new drug
What is a new drug application (NDA)?
Application sent to FDA after all clinical trials and data have been collected on a new drug in order to have the drug approved for marketing
AKA - drug registration process
When should a company submit an IND application to the FDA?
For each clinical trial phase (1-3)
Can apply for more than 1 phase in a single application
When can a company begin human trials?
If they have not received a rejection from the FDA within 30 days of submitting their IND
What does phase 1 of a clinical trial include?
First introduction of drug into human subjects
HEALTHY volunteers
Helps to understand PK, pharmacologic effects, and adverse effects of a drug
<100 patients
What does phase 2 of a clinical trial include?
First introduction of drug into pts with the disease
Evaluates effectiveness of a drug for a particular indication
Determines common short-term side effects and risks associated with the drug
<1000 pts
What does phase 3 of a clinical trial include?
Intended to gather additional information about effectiveness and safety that is needed to evaluate the overall benefit-risk relationship of the drug to provide an adequate basis for physician labeling
Several thousand patients
When can a company submit a new drug application (NDA) to the FDA? How long does the FDA have to respond to the NDA?
Once phase 3 trials have been completed
FDA has 180 days to respond according to law but there are often lengthy delays
Can the manufacturers contest the FDA’s decision to not approve a drug?
Yes but FDA’s decision to not approve a drug has never been overturned
Purpose of REMS
Manage serious risks associated with the use of a medication
Who decides if a drug needs a REMS program? Who is responsible for creating the REMS program? Who approves it?
FDA decides
Manufacturer creates
FDA approves
What are the 4 types of REMS?
1) Medication guides
2) Communication plans for disseminating info to HCP about risks of drugs and REMS program in place
3) Elements to assure safe use (ETASU)
4) Implementation system where drugs sponsor may be required to take reasonable steps to monitor and evaluate those in the healthcare system who are responsible for implementing ETASU measures - this may limit or restrict access to a medication
What is the elements to assure safe use (ETASU)?
Required medical interventions or other actions HCPs need to execute prior to prescribing or dispensing the drug to the patient
Lab monitoring, pregnancy tests, etc
Which agencies may inspect a pharmacy?
FDA (only if the pharmacy manufacturers, prepares, or compounds drugs or devices - aka not retail)
DEA
BoP
When are pharmacies exempt from FDA inspections?
Always unless they manufacturer, prepare, or compound drugs or devices (aka retail won’t be inspected)
What must the FDA do in order to inspect? What happens if you refuse?
Show a notice of inspection and their credentials. They don’t need a warrant or to state a reason
Refusal could result in fines and imprisonment
***don’t usually inspect pharmacies but can
What can the DEA inspect? What can they not inspect?
Can: ANY place controlled substances are kept, all records and reports relating to controlled substances (may make copies), premises, take inventory of controlled substances without a warrant
CanNOT: review financial data, sales data, or pricing data unless given written consent by owner or pharmacist in charge or pursuant to a warrant
What must the DEA do in order to inspect? What happens if you refuse?
Must state purpose of inspection and provide their credentials with a written notice of inspection to the pharmacy owner or pharmacist in charge
You can refuse to give consent to an inspection and require agent to get an administrative inspection warrant (AIW)
Can withdraw consent at any time
What is an administrative inspection warrant?
Similar to search warrants
Can only be served during regular business hours
Can’t refuse to consent to search if presented with an AIW (fines/imprisonment)
When is an AIW not required?
If there is imminent danger to health and safety of the public
Emergency situations where obtaining one isn’t practical
Situations where warrant isn’t constitutionally required
What is the purpose of a board of pharmacy inspection? Can you refuse?
Verify compliance with laws and rules
Cannot refuse in Indiana
What does USP <797> cover?
Sterile compounding
What does USP <800> cover?
Handling of hazardous drugs in healthcare settings
Hazardous drugs meet at least one of what six criteria?
1) Carcinogenicity
2) Teratogenicity or developmental toxicity
3) Reproductive toxicity in humans
4) Organ toxicity at lower doses in humans or animals
5) Genotoxicity
6) New drugs that mimic existing hazardous drugs in structure or toxicity
Has Indiana adopted USP <800> as part of any statute or rule?
Not yet
What are the 8 factors that determine if a drug or substance should be added or removed from one of the 5 controlled substances schedules?
1) actual or relative potential for abuse
2) scientific evidence of pharmacologic effect, if known
3) State of current knowledge regarding the drug or other substance
4) hx and current pattern of abuse
5) scope, duration, and significance of abuse
6) what, if any risk there is to the public health
7) its psychic or physiological dependence liability
8) Whether the substance is an immediate precursor of a substance already controlled
What controlled substances drug schedules have US medical uses? Which don’t?
Do: II-V
Do NOT: I
What is the abuse potential for controlled substances in schedules I-V?
I: High II: High III: lower than I or II IV: lower than III V: lower than IV
What level of psychological and physical dependency is present for controlled substances in schedules I-V?
I: dependence not defined
II: Severe psych and physical dependence
III: High psych and moderate/low physical dependence
IV and V: limited psych and physical dependence
When can schedule I drugs be used?
if approved by DEA for investigation purposes
What is registration based on? What are the different types?
Schedule of drugs handled and activities engaged 1 - schedule I 2 - schedule II narcotics 2N - schedule II non-narcotics 3 - schedule III narcotics 3N - schedule III non-narcotics 4 - schedule IV 5 - schedule V
What are the Indiana registration types?
Manufacturing Distributing dispensing Research Instructional activities Research Research or instruction Chemical analysis
What does a DEA number consiste of?
2 letters followed by 7 numbers
What do the following first letters mean in a DEA number? A, B, F, G, M
A - physician B - dentist F - podiatrist G - vet M - mid-level (NP, PA, etc)
What does the second letter of a DEA number indicate?
First letter of last name during registration (may change d/t marriage)
OR
First letter of business name (if business name starts with number may also be a number)
How to verify DEA number?
Add 1, 3, 5
Add 2, 4, 6 and multiply by 2
Add both numbers - last digit of result should match seventh digit of DEA number
OR
Check on DEA’s list of registrants available as part of the NTIS
Exemptions from registration
- agent or employee of person/company who is registered (pharmacists, nurses)
- UPS, FEDEX, USPS, transport if within usual course of business
- Patient or guardian who received substance through prescription
- Officials from armed services, public health service, bureau of prisons, and other law enforcement officers - e.g. cops who confiscate drugs
How must scheduled drugs be stored?
CII-V can be dispersed throughout the pharmacy (e.g. alphabetically)
CI have to be stored in a securely locked, substantially constructed cabinet
If practitioner has supply of controlled substances in their office they must be in a locked cabinet
Who cannot be employed in a position that involves access to controlled substances?
Anyone convicted of a felony relating to controlled substances or who has had an application for registration with the DEA denied, revoked, or has surrendered their DEA registration
***Registrant can request an exemption from the DEA
How long to keep records and reports of controlled substances?
2 years
Do registrants need to maintain a perpetual inventory of controlled substances?
Nope
What information must pharmacies maintain about controlled substances dispensed?
Name and address of person to whom it was dispensed
Date of dispensing
Number of units or volume dispensed
Written or typewritten name or initials of individual who dispensed or administered substance
How to store records for schedule I-V?
I and II - kept separate from all others
III, IV, V - kept separate from all other records or in a way that information is readily retrievable from ordinary business records of the pharmacy
How to store prescriptions?
3 file system: Schedule II in one file, III-V in another and non-controlled in another
OR
2 file system: Schedule II in one file and all others in another file
***all must be readily retrievable
When is a prescription considered ““readily retrievable”?
Has a red C no less than 1 inch high stamped in the lower right corner of the front of the rx
OR
Pharmacy’s computer system identifies prescriptions by prescription number and can be retrieved by prescriber name, pt name, drug dispensed, and date filled
When can records be kept in a central location rather than in the pharmacy?
If the pharmacy notifies the DEA in writing. Must include:
- nature of records to be kept centrally
- exact location
- name, address, DEA registration number and type of DEA registration
- whether central records will be maintained in manual or computer readable form
- **Can start maintaining 14 days after DEA receives notification unless denied permission
What records can and cannot be maintained in a central location after approved by the DEA?
Can: financial info, shipping records, invoices
Cannot: DEA 222, executed DEA forms, inventories, prescriptions
How to order schedule III-V drugs? What do you use as a receipt?
Same way you order non-controlled drugs
Receipt: invoice
How to order schedule II drugs?
DEA 222 form
How to obtain DEA 222? Who can obtain?
Obtained by registrants who are registered to handle schedule II drugs
Come in books of 7 or 14 forms
Initial form: submit order form requisition (part of application for registration)
Subsequent forms: DEA form 222a (requisition form) or contact local DEA in writing
What is included on a DEA 222 form?
Name Address Registration number Authorized activities Schedules the registrant may handle
How many DEA 222 forms can a registrant have?
Max of 6 books at one time (books contain 7 or 14 forms)
What is a power of attorney (POA)? Can there be more than one?
Legal document that authorizes a designated individual to obtain and execute DEA222
Yes - but need POA for each person
Executed vs unexecuted DEA 222 form
Executed are filled out while unexecuted are blank
Difference between old and new DEA 222?
Old - triplicate carbon copies (keep copy 3 and send 1 and 2 back, supplier then sends form 2 to DEA)
New - one 222 with copies made (phasing in - mandatory after October, 2021)
If a supplier receives an order on a DEA 222 for a controlled substance and cannot fill the entire order, how long do they have to fill it? What happens after this time point?
60 days
Order form is no longer valid after 60 days and purchaser needs to re-order
Supplier must return copies 1 and 2 with reason why it wasn’t filled (must staple to copy 3 and keep in records)
What to do in the case of a lost or stolen DEA 222 form?
If form is filled out and lost in mail or by supplier before being filled - send new DEA 222 with statement saying it was lost - then staple statement and new copy 3 to copy 3 of lost paperwork
If unused form is lost - must notify DEA immediately (if found must also notify DEA immediately)