RX PHARMACIST STUDY NOTES Flashcards
What are some tasks of the FDA?
1- Licensing and inspecting manufacturing facilities to ensure they follow GMP
2- Tests products on a smaller scale to evaluate claims and prescription drug advertising
3- Monitors research
4- Reviews clinical trial methods
5- Creates regulations, guidelines, standards, policies
What is the main center in the FDA which reviews prescription drugs?
CDER (Center for Drug Evaluation and Research)
Who regulates the advertising of OTC, medical devices and cosmetics?
Federal Trade Commission (FTC)
What is the role of the United States Pharmacopoeia (USP)?
Regulation of OTC, natural supplements, dietary products
USP 800, 795, 797
What is considered a ‘New Drug’?
-One that is not already recognized as safe and effective for the indications stated by the manufacturer.
-A drug that is already in existence, although never approved by the FDA for marketing in the USA.
-New therapeutic indications
-New dosage form
-New route of administration
-New dosing schedule or any other significant clinical difference
How are OTC medications approved?
OTC medications are only regulated by FDA through the OTC drug monographs.
OTC drug monograph are kind of “ recipe book” covering acceptable ingredients, doses, formulations, and labeling. Monographs are continually updated, adding additional ingredients and labeling as needed. Products conforming to a monograph may be marketed without further FDA clearance.
Otherwise, those that do not conform to the monograph must undergo a separate review and approval through the “New Drug Approval System”.
Investigational New Drug Application (IND)
After the pre-clinical stage (1-2 years), if a drug is proven to be safe and have a therapeutic effect, then the manufacturer may apply for a IND.
The IND must contain information on the characteristics of the proposed drug and the details of its study. sponsors take responsibility for a clinical investigation.
A sponsor can be an individual, pharmaceutical company, governmental agency, academic institution, private, or other organizations such as a nonprofit.
An investigator is the individual who conduct the investigation.
Sponsor-investigator is an individual with a dual role of investigating and overseeing the direction of the investigational drug being administered or dispensed.
Prescription Drug User Fee Act (PDUFA)
-PDUFA allows the FDA to collect fees from sponsor companies who submit review applications.
-This was a result of the Prescription Drug User Fee Act (PDUFA) and the FDA Modernization Act (FDAMA)
-PDUFA must be re-authorized every 5 years
-This act also requires the FDA to speed up the approval timeframe, which is an expectation by the pharmaceutical industry given the increased fees for filing an NDA. Approval rates have increased from 50% to 80%
-It waives the fees for first-time applicants who have <500 employees.
Orphan Drug approval
-An orphan drug is defined under the orphan drug act of 1983. It is a drug used to treat a rare disease that would not normally be of interest to commercial manufacturers. Rare disease is defined in the law as a disease that impacts fewer than 200,000 persons in the United States, or one in which a manufacturer has no reasonable expectation of recovering the cost of its development and availability in the United States.
The Act permits:
1) Grants of assistance for clinical research
2) Tax credits for research and development
3) 7 year market exclusivity to the first applicant. This means that if a sponsor gains approval for an orphan drug, the FDA will not approve any application by any other sponsor for the same drug and the same disease or condition for seven years.
What is an Abbreviated New Drug Application (ANDA)?
-ANDA are used when a patent has expired for a product that has been on the US market, and a company wishes the market a generic version.
-In the United States, a drug patent is valid for 20 years.
-The active ingredient must already have been approved for the indications proposed in the ANDA.
-There can be no changes on the original drug’s NDA.
What is the Orange Book?
Also known as: Approved Drug Products with Therapeutic Equivalence Evaluations
This is a list of all approved drugs. It provides information on therapeutic equivalence evaluations for approved multi-source prescription drugs.
What is meant by Therapeutic Equivalence?
It must be both PHARMACEUTICALLY EQUIVALENT (same dose, dosage form, strength) and BIOEQUIVALENT (the rate and extent of absorption are not significantly different)
What is the Coding System used in the Orange Book?
1) First letter (either A or B) - indicates the drug’s therapeutic equivalence rating.
2) Second letter (several letters) - describes dosage form
First letter:
A - Therapeutically equivalent to other pharmaceutically equivalent products. There is no known or suspected bioequivalence problems
B - Less desirable rating than A. These may still be marketed commercially, but they may not be considered therapeutically equivalent. Often the problem is with the dosage form and not with the active ingredient.
B* - This is assigned to former A-rated drugs if the FDA received new information that raises a significant question regarding therapeutic equivalence.
What happens if there a report of an adverse event in a drug’s Phase 4?
-Must be reviewed by the manufacturer promptly
-If found to be serious or life threatening or unexpected, the manufacturer is required to submit an alert report within 15 business days.
-Other reports are required to be reported quarterly for 3 years after approval of the application, and annually thereafter.
What are the criteria to make a drug “prescription”?
According to the Durham-Humphrey Amendment of 1951:
1) The compound is habit forming
2) The compound requires a prescriber’s supervision
3) The compound has an NDA prescription-only limitation
OTC products do not fall under prescription status if their active ingredients are deemed “generally recognized as safe and effective”
How does a product move from “Prescription” Status to “OTC” Status?
A company who wishes to make this switch can submit an amendment to a monograph to the FDA, who acts as the sole reviewer, or
They may also file an sNDA provided that the product:
1) Had 3 years of marketing experience as a prescription product
2) Relatively high use during that period
3) Mild profile of adverse reactions.
What is the OTC Monograph Reform?
Signed in 2020 under the Coronavirus Aid, Relief, and Economics Security Act (CARES)
- This regulation replaced the 3-phase rule-making process with the Administrative Order Process (This allows for additions, removals or changes to an OTC Monograph)
- This process can be initiated by the FDA or Industry
The law permits the FDA to use an expedited procedure to address drugs that pose imminent safety concerns in a timely manner as well as collect user fees to support OTC monograph activities.
Which regulation governs Prescription Drug Advertising?
1962 Kefauver-Harris Amendment
The FDA has jurisdiction over prescription drug advertising and promotion. The FDA views this information as either “advertising” or “labeling”
Advertising - includes all traditional outlets in which a company places an ad.
Labeling - includes everything else, including brochures, lectures, slide kits, letters to physicians, company-sponsored magazine articles etc.
Basically, all material facts must be disclosed in a manner that is fairly accurate and not misleading. A violation of this is considered “misbranding”.
Drug Samples
1987 Prescription Drug Marketing Act (PDMA)
- Company reps are prohibited from directly distributing or reselling prescription drug samples.
- Companies are required to establish a closed system of record keeping that can track a sample from their control to that of a prescriber in order to prevent diversion.
- Prescribers are required to receive, record and store them appropriately
Enforcement by the FDA
1938 Food Drug and Cosmetic Act, the FDA has the power to
- Enforce regulations
- Inspect a manufacturer’s premises and records
-
What happens after a facility is inspected by the FDA?
- An FDA Form 483 is issued which describes observable violations
- A Warning Letter may be issued if one or more of a company’s practices, products or procedures violate the FDCA. 15 days to respond
-The FDA has no authority to force a company to recall, but it has the authority to force the removal of a product through a seizure.
Types of Recalls
Based on Adverse Effects of the drug product
Class 1: “a product WILL CAUSE either serious adverse effects or death”
Class 2: “a product MAY CAUSE TEMPORARY or MEDICALLY REVERSIBLE adverse effects”
Class 3: “a product is NOT LIKELY to cause adverse health consequences”
What happens if a company refuses to recall a product?
1) Injunction
- The FDA will seek an injunction against the company
- An injunction is recommended to the DOJ by the FDA
- The DOJ takes the request to federal court, which issues an order that forbids a company from carrying out an illegal act, such as marketing a product that the FDA considers a violation of the FDCA
2) Seizure by US Marshals, ordered by the Federal Court
- FDA may also initiate a seizure of violative, misbranded or adulterated products
- It prevents a company from selling, distributing, moving or otherwise tampering with the product.
When was the Controlled Substances Act enacted?
1970
It regulates the manufacturing, distribution, dispensing and delivery of drugs with potential for abuse.
Regulated by the DEA
-The DEA requires federal registration of all individuals involved in the chain of manufacturing, distribution and dispensing.
How long should Controlled Substances records be maintained for?
2 years per the DEA manual
What are the C-1 Controlled Substances?
-Drugs with high potential for abuse
-No acceptable medical use in the US
-They may be ordered for research and investigational use
Examples:
-Marijuana
-Heroin
-LSD
-Peyote
-Salvia
What are the C-2 Controlled Substances?
-High potential for abuse
-Acceptable medical use
-No refills are allowed, however prescribers can write a series of prescriptions for a patient for up to a 90-day supply. Pharmacists can fill these as long as it is a valid prescription with the actual date that the prescription was written and the earliest date to fill is noted on the prescription.
Can a verbal/oral prescription be taken for C-2s?
-Only in emergencies
-The quantity prescribed and dispensed is limited to the amount adequate to treat the patient during the emergency period.
-The written prescription must arrive at the pharmacy within 7 days and the pharmacist should write on the face of the prescription “Authorization for Emergency Dispensing”
-Upon receipt, the dispensing pharmacist must attach the prescription to the oral one.
-If the prescribing practitioner fails to deliver a written prescription within 7 days, the pharmacist needs to notify the DEA and the prescribing practitioner will face criminal charges.
What is ‘Corresponding Responsibility”?
Pharmacists and Prescribers are both liable for prescriptions written in error or with obvious problems.