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Maximizing the Use of
Single-Dose Vials
Eric S. Kastango, MBA, RPh, FASHP
Clinical IQ, LLC
August 8, 2012
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Disclaimer
Although I am a member of the USP Compounding ExpertCommittee, I am speaking today in my individual capacity andnot as a member of the Committee or as a USP representative.
The views and opinions presented are entirely my own. They donot necessarily reflect the views of USP, nor should they be
construed as an official explanation or interpretation of
.
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Special Thanks and Acknowledgement
Some slides in this presentation were provided by: John W. Metcalfe, Ph.D., Senior Review Microbiologist,
FDA/CDER/OPS/New Drug Microbiology Staff
John presented at PDAs 6thAnnual Global Conference on PharmaceuticalMicrobiology, October 17, 2011
Kathleen Meehan Arias, MS, MT(ASCP), CIC, Arias InfectionControl Consulting, LLC
Kathleen presented during Pharmacy OneSources webinar titled: OutbreaksAssociated with Unsafe Injection and Medication Practices and How We CanPrevent Them , June 20, 2012
Michael R. Cohen, RPh, MS, ScD, FASHP-Institute for SafeMedication Practice (ISMP).
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US SURGEON GENERALS
WARNING:
This presentation contains professional
language, professional content, andpsychological nudity.
Attendee discretion is advised.
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The US has been experiencing a growing problem of drugshortages
Most drugs come in single-dose vials (SDVs) and typicallycontain more drug than one dose
The cost of discarding the remaining drug in a SDV can total
upwards to $750,000 annually, especially for hazardous drugs
Improper use of SDVs has resulted in events of nosocomialinfections and patient deaths
ASHP, CDC, CMS, FDA, ISMP and the USP have all weighed in on
this issue Strict compliance with USP 797 provides a solution to ease the
drug shortage by permitting the repackaging on medicationsfrom SDVs
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What is the issue?
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National Drug Shortages
Note: Each column represents # of new shortages identified during that year
University of Utah Drug Information Service
January 1, 2001 - November 30, 2011
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Shortages by Drug Class
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Therapy Area: % of Products
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Deployment of finite resources (operational and clinical) toblunt patient impact of drug shortages
Delays or postpones patient care/treatment because of lack ofdrug
Adverse patient care events because of medication errors Greater potential for organizational liability associated with
critical drugs acquired through parallel market
Financial impact of purchasing shortage drugs
Lowering safety standards will not address the problem of drugshortages.CDC Single-dose/Single-use Vial Position&Messages, April 27, 2012
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Pain Points
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Definition of SDVs
USP-General Notices 10.20.60. Single-Unit Container
A single-unit container is one that is designed to hold a quantity of drug productintended for administration as a single dose or a single finished device intendedfor use promptly after the container is opened. Preferably, the immediate
container and/or the outer container or protective packaging shall be so designedas to show evidence of any tampering with the contents. Each single-unitcontainer shall be labeled to indicate the identity, quantity and/or strength, nameof the manufacturer, lot number, and expiration date of the article.
10.20.70. Single-Dose Container
A single-dose container is a single-unit container for articles intended forparenteral administration only. A single-dose container is labeled as such.Examples of single-dose containers include prefilled syringes, cartridges, fusion-sealed containers, and closure-sealed containers when so labeled. (See alsoContainers for Injections under Injections 1.)
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FDA Vial, Single-Dose: A vial containing a single unit of a parenteral drug
product.
Vial, Single-Use: A vial where a single dose of a parenteral drug productcan be removed and then the vial and its remaining contents can be
disposed.
CDC
A single-dose or single-use vial: is a vial of liquid medication intended forparenteral administration (injection or infusion) that is meant for use in asingle patient for a single case/procedure/injection. Single-dose orsingle-use vials are labeled as such by the manufacturer and typically lackan antimicrobial preservative.
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Definition of SDVs
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Issued on April 27, 2012 to restate its position on the use of thesevials and seeks to dispel inaccuracies being disseminated tohealthcare providers
CDC guideline call for medications labeled as single dose or singleuse to be used for only one patient
Intended to protect patients from life-threatening infections whenvials become contaminated from unsafe injection practices
include, but are not limited to, reuse of syringes for multiple patients or toaccess shared medications, administration of medication from a single-dose/single-use vial to multiple patients, and failure to use aseptic techniquewhen preparing and administering injections.
CDC Injection safety guidelines are not new. They have been part ofStandard Precautions since 2007.
http://www.cdc.gov/injectionsafety/IP07_standardPrecaution.html
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CDC Single-dose/Single-use Vial Position
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In certain instances, qualified healthcare personnel mayrepackage medication from a previously unopened single-dose/single-use vial into multiple single-use vehicles (e.g.,syringes). This should only be performed under ISO Class 5conditions in accordance with all standards in by the UnitedStates Pharmacopeia General Chapter 797, PharmaceuticalCompounding Sterile Preparations, as well as themanufacturers recommendations pertaining to safe storage ofthat medication outside of its original container.
In 2002, an informal communication to the Centers forMedicare and Medicaid Services (CMS) suggested that certainmedications packaged in a single-dose/single-use vial could beused for more than one patient in dialysis settings, assumingthat certain criteria were followed. In 2008, CDC issued aformal clarification specifically to dialysis providers stating thatthe 2007 guidance superseded the 2002 CDC communicationto CMS
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CDC Single-dose/Single-use Vial Position(continued)
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Single-dose Vials: Safe Practices
Use single-dose medication vials,pre-filled syringes and ampouleswhen possible
Do not administer medicationsfrom single-dose vials orampoules to multiple patients
Do not combine leftover contentsfor later use
Store vials in accordance withmanufacturer's recommendationsand discard if sterilitycompromised or questionable
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HICPAC Guideline for Isolation Precautions, 2007
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SDVs and CMS
Safe Use of Single Dose/Single UseMedications to Prevent Healthcare-associated Infections. CMS Office ofClinical Standards andQuality/Survey & CertificationGroup, June 15, 2012 Ref: S&C: 12-35-ALL
Under certain conditions, it ispermissible to repackage single-dosevials or single use vials (collectivelyreferred to in this memorandum asSDVs) into smaller doses, eachintended for a single patient.
Administering drugs from one SDV tomultiple patients without adhering toUSP standards is notacceptable under CMS infectioncontrol regulations
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"Unfortunately, there are too many inhealth care who feel that if it hasn't
happened to them, the adverse
experiences of others do not apply.
Michael Cohen, MS, FASHP
Institute for Safe Medication Practices (ISMP)
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Bennet et. al. 1995. Postoperative Infections Traced toContamination of an Intravenous Anesthetic, Propofol. NewEngland Journal of Medicine. 333: 147-154.
62 cases of infectious disease.
7 different hospitals.
Nichols & Smith. 1995. Bacterial Contamination of anAnesthetic Agent. New England Journal of Medicine. 333: 184-
185. To prevent further outbreaks, the people administering the agents must
fully understand the ability of these drugs to support microbial growth soas not to put the patients at risk.
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Brutal Facts
Nosocomial Infections-Microbial Contamination Following CSP Preparation
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Hepatitis C Virus Infections From a Contaminated Radiopharmaceutical
Used in Myocardial Perfusion Studies. JAMA, 26 Oct 06, Vol 296, 2005-11.
Scenario
Sixteen (16) patients from three (3) clinics develop HCV infection afteradministration of Tc 99m radioisotope used in cardiac stress tests
Contamination implicated to be a cross-contamination between a blood-labelingprocedure and the preparation of the radioisotope
Sixteen patients contract Hepatitis C: Several patients adversely affected (deathand disease)
Root Cause Breaks in aseptic technique were identified at the pharmacy. SDV of saline was
shared during aseptic procedures. Nuclear pharmacies that handle biologicalproducts should follow appropriate aseptic technique to prevent contaminationof sterile radiopharmaceuticals.
Brutal Facts
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Maryland, December 2004
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2009, Hepatitis B outbreak associated with a hematology-
oncology office practice in New Jersey, 2009. Greeley RD, et
al. Am J Infect Control 2011;39(8):663-70. 2 women (60 and 77 yrs) diagnosed with acute hepatitis B; both received
chemotherapy at same physician's office
Health care-associated transmission suspected
Investigation:
2,700 patients notified
29 HBV cases identified
Brutal Facts
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New Jersey, 2009
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Brutal Facts
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CAUSE?
Common-use saline bags
Reuse of single-dose vials
Poor hand hygiene
Meds prepared in blood processing
area
Results:
Office practice was closed
Physician's license suspended
New Jersey, 2009 (continued)
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August 2011, Contaminated Avastin Syringes-FDA Drug Safety andAvailability (http://www.fda.gov/Drugs/DrugSafety/ucm270296.htm)
FDA Alerts Health Care Professionals of Infection Risk from Repackaged Avastin
Intravitreal Injections
The Florida Department of Health (DOH) notified FDA of a cluster ofStreptococcusendophthalmitis infections in three clinics following intravitreal injection ofrepackaged Avastin.
Investigators traced the tainted injections to a single pharmacy located in
Hollywood, Florida. The pharmacy repackaged the Avastin from sterile injectable 100 mg/4 mL, single-
use, preservative-free vials into individual 1 mL single-use syringes.
Brutal Facts
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Florida, August 2011
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Brutal Facts
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http://www.fda.gov/downloads/AboutFDA/CentersOffices/OfficeofGlobalRegulatoryOperationsandPolicy/ORA/ORAElectronicReadingRoom/UCM304256.pdf
http://www.fda.gov/downloads/AboutFDA/CentersOffices/OfficeofGlobalRegulatoryOperationsandPolicy/ORA/ORAElectronicReadingRoom/UCM304256.pdfhttp://www.fda.gov/downloads/AboutFDA/CentersOffices/OfficeofGlobalRegulatoryOperationsandPolicy/ORA/ORAElectronicReadingRoom/UCM304256.pdfhttp://www.fda.gov/downloads/AboutFDA/CentersOffices/OfficeofGlobalRegulatoryOperationsandPolicy/ORA/ORAElectronicReadingRoom/UCM304256.pdfhttp://www.fda.gov/downloads/AboutFDA/CentersOffices/OfficeofGlobalRegulatoryOperationsandPolicy/ORA/ORAElectronicReadingRoom/UCM304256.pdf7/30/2019 Single Dose Vials
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CDC MMWR, Vol. 61, No.27 July 13, 2012. Invasive Staphylococcus aureusInfections Associated with Pain Injections and Reuse of Single-Dose Vials
This report summarizes the investigation of two outbreaks of invasiveStaphylococcus aureus infection confirmed in 10 patients being treated for pain in
outpatient clinics.
In both investigations, clinicians reported difficulty obtaining the medication typeor vial size that best fit their procedural needs.
If SDVs must be used for more than one patient, full adherence to U.S.Pharmacopeia standards is critical to minimize the risks of multi-patient use.
Since 2007, the year that injection safety was included as part of StandardPrecautions, 20 outbreaks associated with use of single-dose or single-usemedications for more than one patient have been reported (CDC, unpublisheddata, 2012).
Brutal Facts
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Arizona and Delaware; 2012
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When things go bad..Outbreaks Associated with Contaminated Medications by Contaminant Name
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Its aboutcontamination &
preventing it,
STUPID!ClinicalIQ content 1999-2012, ClinicalIQ, LLC - all rights reserved
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Single/Multiple Dose Vials Definitions of SDV and MDV are in the USP General Notices
and Requirements
Single dose vials Opened or punctured in ISO 5 environment
may be used for up to 6 hours. Opened or punctured in worsethan ISO 5 must be used within 1 hour or discarded.
Single dose ampoules must be discarded after opening and notstored for any time period
USP 797 and SDVs/MDVs
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Time (Hours) Microbial Count(CFU per mL)
6 10
9 640
12 41,000
18 1.7 X 107
24 6.9 X 109
Calculated Microbial Growth
Cundell AM, USP Committee on Analytical Microbiology, Pharmacopeial Forum2002; 28 (6) Stimuli to the Revision Process
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Purpose to show that sterility of the vial is maintained. Resultsshould demonstrate 0% growth
The use of a CSTD (PhaSeal) has been claimed to extend thelife of a SDV
Two studies (one unpublished) reported a contamination rateof 1.8%*
Contamination was attributed to poor aseptic technique used whenplating the media
There was no control group (media fills without the use of a CSTD)
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Drug Vial Optimization Studies
*McMichael D, Jefferson D, Carey E, Forrey R. Utility of the PhaSeal closed system drug transfer
device.Am J Pharm Benefits. 2011;3(1):9-16.
De Prijck. K, DHaese E, Vandenbroucke J, et al. Microbiological challenge of four protective devices
for the reconstitution of cytotoxic agents. Ltr Appl Microbiol. 2008;47:543-8.
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Drug Vial Optimization Studies(continued)
De Prijck, et al
., noted: PhaSeal had the lowest transfer of microorganisms
The study demonstrated a 2.2% to 2.5% contamination ratewith PhaSeal
Noted that the level of contamination was dependent on thenumber of couplings.
De Prijck and his coauthors note:
that the use of high inoculum used in the study should be
considered in context of their results as well as the need fora robust disinfection step
De Prijck. K, DHaese E, Vandenbroucke J, et al. Microbiological challenge of four protective devices
for the reconstitution of cytotoxic agents. Ltr Appl Microbiol. 2008;47:543-8.
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Microbiological Growth
All references
listed at the end of
presentation
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Microbiological Growth
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Sterile filters used to sterilize CSPs shall be: Pyrogen-free and have a nominal porosity of 0.2 um or 0.22
um.
Certified by the manufacturer to retain at least 107
microorganisms of a strain of Brevundimonas (pseudomonas)diminuta per cm2 of filter surface area.
The filter dimensions and liquid material to be sterile-filteredshall permit the sterilization process to be completed rapidly,without the replacement of the filter during the process.
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CDC Update on Alabama PN Case
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CDC Update on Alabama PN case
CDC repeated the process usingnon-sterile API and made a batchof amino acid (AA) solution
Inoculated the AA solution withthe Serratia marcescens
Used a 0.22 micron sterilizinggrade filter
Serratia got through both a 0.22micron and 0.1 micron filter
The filters passed its bubble-point
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Dont let the Serratia into your sterile compounding area!
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Critical Factors in Aseptic Technique
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Synder SL, Van Scoik S, et al. Assessing Contamination Rates of Medium-Risk Compounding
With Sterile vs. Non-sterile Gloves in a community Hospital-2011 ASHP MCM Poster-NOLA
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Critical Factors in Aseptic Technique
Synder SL, Van Scoik S, et al. Assessing Contamination Rates of Medium-Risk Compounding
With Sterile vs. Non-sterile Gloves in a community Hospital-2011 ASHP MCM Poster-NOLA
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Critical Factors in Aseptic Technique
Synder SL, Van Scoik S, et al. Assessing Contamination Rates of Medium-Risk Compounding
With Sterile vs. Non-sterile Gloves in a community Hospital-2011 ASHP MCM Poster-NOLA
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"Alcohols used for skin disinfection prior to invasive procedures should
generally be free of spores to avoid any contamination. Although the risk ofinfection is minimal, the low additional cost for a spore-free product isjustified."
Murray PJ, Baron EJ, Jorgensen JH, Pfaller MA, and Yolken RH, Eds. "Manual ofClinical Microbiology, 8th ed." ASM Press, Herndon, VA; 2003:94. (ASM is for
American Society of Microbiology).
Illnesses in Children's Hospital Prompts Discovery of ContaminatedAlcohol Pads
ScienceDaily (June 12, 2012) A small cluster of unusual illnesses at a Coloradochildren's hospital prompted an investigation that swiftly identified alcohol prep
pads contaminated with Bacillus cereus bacteria, according to a report in the Julyissue ofInfection Control and Hospital Epidemiology, the journal of the Society forHealthcare Epidemiology of America. The investigation ultimately led to aninternational recall of the contaminated products.
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Critical Factors in Aseptic Technique
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Sigward E, Fourgeaud M, Vazquez R et al. Aseptic simulation testchallenged with microorganisms for validation of pharmacyoperators. Am J Health-Syst Pharm. 2012; 69:1218-24.
Results:
10 operators previously trained in aseptic technique were assessed.
Overall operator failure rate was 40%
2.3% of the 300 preparations were contaminated
10 of 60 finger dabs were found to be contaminated with E. faecalis, the
challenge microorganism.
NO association between operators years of experience and media-filltest results.
Editorial Kastango, ES. Challenging our aseptic skills using more-rigorousmedia-fill tests, Am J Health-Syst Pharm. 2012; 69:1218-24.
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ASHP Article/Editorial
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Direct Compounding Area (DCA)
The DCA is only the portion of the PEC where the Critical Site is exposed
to unidirectional HEPA-filtered air during an aseptic manipulation.
First Air
2006 -2012 Clinical IQ, LLC and Controlled Environment Consulting
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Principles of First Air
Good aseptic technique insterile compounding requiresthe understanding and properuse of First-Air.
First-Air is the air exiting the HEPA
filter in a unidirectional air-stream andis virtually free of particulatecontaminants.
All critical manipulations must becarried out in the unobstructed firstair zone in the direct path of the HEPA
filter discharge. Proper product and process placement
with respect to the supply anddischarge will provide a contaminationfree compounding area.
Zone of first-airSimulated with smoke to show airflow
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Disinfect the vial prior to use
Vigorously wipe the vial septum in one direction using a steriledisinfectant agent and low-lint wipe.
Allow vial septum to dry prior to penetrating it with a needleor spike
Personnel must use aseptic technique and be properly garbed
Use sterile gloves and perform routine glove disinfection withsterile IPA
Keep the DCA clear of items and work in first-air
SDV checklist
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USP Injections
Sterile preparation for parenteral use that contains many singledoses
Restricted to the preparation of admixtures for infusion orfilling empty sterile syringes
Closure penetrated only once
Used in a suitable work area such as a laminar flow hood
Includes a statement limiting the time frame in which the
container may be used once it has been entered
Pharmacy Bulk Package (PBP)
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Typical package insert After entry, use entire contents of the vial promptly
Dispense within 4 hours of initial entry
Discard PBP vial within 4 hours after initial entry
Cefazolin 10 gram PBP
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FDA NDMS Review of Label-must be approved by FDA-A claim
- how will the product prepared at clinic prior to patientadministration?
Assessment of the information provided to the pharmacist andclinician regarding product preparation.
e.g.: how many preparation and dilution steps prior to final product for
administration to patient?
Assessment of the storage conditions of final product postpreparation.
What are the storage temperature(s)?
What are the storage times? What are the diluents?
Does the application contain data to support the storage conditions?
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FDA and Package Insert Information
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Sterile Products-Container Closure (C/C) Penetration
Significant factor that dictates the sterile integrity of the product in thecontainer
Assumption!
During penetration of the container closure system, microbes may havebeen introduced into the drug product.
What is the microbiological product quality following C/Cpenetration?
Drug product immediately administered vs. drug product prepared andheld for a period of time prior to administration
Post Manufacturing Drug Product Preparation Prior to Patient
Administration Solids that are constituted with a diluent
Liquid admixtures
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FDA NDMS
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FDA NDMS
Reading Recommendation: Metcalfe, JW, Microbiological Quality of Drug Products
after Penetration of the Container System for Dose Preparation Prior to Patient
Administration. American Pharmaceutical Review, Feb 1, 2009
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A product with a pharmacy bulk package-approved, post-penetration
holding time of 4 hours was subsequently approved for an extended
holding time of 10 hours after submission of data in a supplemental
application demonstrating that the product does not support microbial
growth.
Challenge microorganisms (S. aureus, P. aeruginosa, E. coli, C. albicans,and A. niger) satisfied the USP 51 definition of no increase in growth
when inoculated in the product and held at the intended storage
conditions over the proposed extended holding period. The submission
of this study led to approval of the extended post-penetration holding
period of 10 hours
FDA NDMS
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Source: Lolas, Anastasia G and Metcalfe, John W. Evaluation of the Microbial Growth
Potential of Pharmaceutical Drug Products and Quality by Design. . PDA Journal of
Pharmaceutical Science and Technology. Volume 65: 63-70; 2011.
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Ingredient: CSP Relationship Risk Level Example
One to One (1:1)Low-Risk
Compounding
Reconstitution and transfer
of a 1 gram vial of cefazolin
into one syringe or minibag
One to Many or Many to One
(1:) or ( to 1)# components > 3
Medium-Risk
Compounding
A bulk 10 gram vial of
vancomycin distributed
among several final doses
The combination of several
ingredients (>3) into one
final dose (TPN)
Any ingredient-CSP relationship
using nonsterile ingredients and/or
devices or a CSP that requires
terminal sterilization (filtration,steam, heat, gas or ionizing
radiation)
High-Risk
Compounding
Alum bladder irrigation
PCA or epidural frompowdered ingredients
Kastango ES. A Blueprint for Implementing USP Chapter , Pharmaceutical Compounding: Sterile
Preparations; Am J Health-Syst Pharm. 2005. 62:1271-88.
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USP Risk Levels
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To care for the patient, we must properly handle limited and life-
saving medication through compliance with USP 797.
Aseptic Technique is key
Proper vial and vial septa disinfection practices with a steriledisinfectant is critical in preventing contamination from entering theSDV during the initial use and should be routinely repeated
The use of sterile gloves and a sterile disinfecting agent is required tocomply with the chapter
Substantial compliance with these requirements is not acceptable
Maintain the vial in the ISO Class 5 PEC at all times
Discard vial after 6 hours or according to the manufacturers packageinsert
Treat all CSPs repackaged from SDVs as a medium-risk level CSP
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Our responsibility
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You can avoid reality, but youcannot avoid the consequences of
avoiding reality.
Ayn Rand (1905-1982)
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4. Karstens A, Krmer I. Viability of micro-organisms in novel anticancer drug solutions. European Journal of Hospital Pharmacy Science.
2007; 13(2): 27-32
5. Krmer I. Viability of microorganisms in novel antineoplastic and antiviral drug solutions. J Oncol Pharm Practice. (4):1; 1998. 32-37
6. Paris I, Paci A, et al. Microbial growth tests in anti-neoplastic injectable solutions. J Oncol Pharm Practice (2005) 11: 7-12
7. Rawal, BD. Nahata MC. Variation in microbial survival and growth in intravenous fluids. Chemotherapy. 1985; 31(4): 318 -323
8. Holmes CJ, Kubey WY, et al. Viability of microorganisms in fluorouracil and cisplatin small-volume injections. Am J Hosp Pharm; 198845:
1089-1091.
9. Goldmann DA, Martin WT, Worthington JW. Growth of bacteria and fungi in total parenteral nutrition solutions. Am J Surg 1973; 126:
314-318.
10. Kim CH, Lewis DE, Kumar A. Bacterial and fungal growth in intravenous fat emulsions .Am J Hosp Pharm. 1983; 40: 2159-61.
11. Scheckelhoff DJ, Mirtallo JM, et al. Growth of bacteria and fungi in total nutrient admixtures. Am J Hosp Pharm. 1986; 43: 73-7.
12. Mirtallo JM, CAryer K, et al. Growth of bacteria and fungi in parenteral nutrition solutions containing albumin. Am J Hosp Pharm. 1981;
38: 1907-10.
13. Arduino MJ, Bland LA, et al. Microbial Growth and Endotoxin Production in the Intravenous Anesthetic Propofol. Infect control Hosp
Epidemiol. 1991; 12(9): 535-539
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References
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