demonstrably difficult to compound drug products kathleen anderson, pharm. d. division of...
TRANSCRIPT
![Page 1: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/1.jpg)
Demonstrably Difficult to Demonstrably Difficult to Compound Drug ProductsCompound Drug Products
Kathleen Anderson, Pharm. D.Division of Prescription Drug Compliance and Surveillance
Office of Compliance
Center for Drug Evaluation and Research
![Page 2: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/2.jpg)
Section 503A(b)(3)(A)Section 503A(b)(3)(A)
States that “a drug product may be compounded under subsection (a) only if such drug product is not identified by the Secretary by regulation as a drug product that presents demonstrable difficulties for compounding that reasonably demonstrate an adverse effect on the safety or effectiveness of that drug product.”
![Page 3: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/3.jpg)
FactorsFactors
1. Drug Delivery System 2. Drug Formulation and Consistency 3. Bioavailability 4. Complexity of Compounding 5. Facilities and Equipment 6. Training 7. Testing and Quality Assurance
![Page 4: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/4.jpg)
1. Drug Delivery System1. Drug Delivery System
Is a sophisticated drug delivery system required to ensure dosing accuracy and/or reproducibility?
![Page 5: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/5.jpg)
2. Drug Formulation and 2. Drug Formulation and Consistency Consistency
Is a sophisticated formulation of the drug product required to ensure dosing accuracy and/or reproducibility?
Because of the sophisticated formulation, is product-to-product uniformity of the drug product often difficult to achieve?
Is the safety or efficacy of the product a concern if there is product-to product variability?
![Page 6: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/6.jpg)
3. Bioavailability3. Bioavailability
Is it difficult to achieve and maintain a uniformly bioavailable dosage form?
Is the safety or efficacy of the product a concern if the bioavailability varies?
![Page 7: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/7.jpg)
4. Complexity of 4. Complexity of CompoundingCompounding
Is the compounding of the drug product complex?
Are there multiple, complicated or interrelated steps?
Is there a significant potential for error in one or more of the steps that could affect drug safety or effectiveness?
![Page 8: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/8.jpg)
5. Facilities and Equipment5. Facilities and Equipment
Are sophisticated facilities and/or equipment required to ensure proper compounding of the drug product?
Is there a significant potential for error in the use of the facilities or equipment that could affect drug safety or effectiveness?
![Page 9: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/9.jpg)
6. Training6. Training
Is specialized, highly technical training essential to ensure proper compounding of the drug product?
![Page 10: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/10.jpg)
7. Testing and Quality 7. Testing and Quality AssuranceAssurance
Is sophisticated, difficult to perform testing of the compounded drug product required to ensure potency, purity, performance characteristics, or other important characteristics prior to dispensing?
Is there a significant potential for harm if the product is compounded without proper quality assurance procedures and end-product testing?
![Page 11: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/11.jpg)
FactorsFactors
1. Drug Delivery System 2. Drug Formulation and Consistency 3. Bioavailability 4. Complexity of Compounding 5. Facilities and Equipment 6. Training 7. Testing and Quality Assurance
![Page 12: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/12.jpg)
ApproachApproach
Began a preliminary evaluation of products for inclusion on the list
Focusing on products with – evidence in the literature and – potential to affect the public health
![Page 13: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/13.jpg)
ApproachApproach
Some products with similar characteristics raise similar concerns for pharmacy compounding
– tentatively proposing to include both specific drug products and categories of drug products that are grouped by relevant factors
![Page 14: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/14.jpg)
ApproachApproach
Some products could raise concern for pharmacy compounding if minimum standards are not met
– tentatively proposing to include drug products that are demonstrably difficult to compound unless certain minimum standards are met
![Page 15: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/15.jpg)
Preliminary FindingsPreliminary Findings
Our concept paper describes in detail our preliminary findings for tentatively including the following products on the demonstrably difficult to compound list:
Metered Dose Inhalers Dry Powder Inhalers
![Page 16: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/16.jpg)
Preliminary FindingsPreliminary Findings
Transdermal Delivery Systems Sterile Products Compounded Under Procedures
Other Than Those Described in Chapter 1206 of the United States Pharmacopoeia (USP)
![Page 17: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/17.jpg)
Preliminary FindingsPreliminary Findings
Scientific Rationales
![Page 18: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/18.jpg)
Additional ProductsAdditional Products
We intend to identify and evaluate additional products and categories of drug products for the list
![Page 19: Demonstrably Difficult to Compound Drug Products Kathleen Anderson, Pharm. D. Division of Prescription Drug Compliance and Surveillance Office of Compliance](https://reader035.vdocuments.net/reader035/viewer/2022062802/56649ef35503460f94c06676/html5/thumbnails/19.jpg)