On January 1, 2004, United States Pharmacopeia (USP)
Chapter <797> became the standard of practice for pharmacy compounding
practices in the United States. The document, known as General Tests
and Assays Chapter 797 or “Pharmaceutical Compounding-Sterile Preparations,” is
the revision of the general information chapter 1206, “Sterile Drug
Products for Home Use” and provides procedures and requirements for
compounding sterile preparations. The chapter was moved into the General
Tests and Assays portion of USP, which has chapter numbers less than
1000. The USP is a quasi-governmental agency, chartered by Congress
to set official standards of drugs and have done so since 1906.
This
means that <797> can be enforced by State Board of Pharmacies and used
by FDA personnel to determine whether a drug has been adulterated.
According to Carmen A. Catizone, Executive Director of the National
Association of Boards of Pharmacy (NABP) as interviewed in AJHP, Vol
60, Sept 15, 2003, USP chapters can be enforced by a state board of
pharmacy, but only if that board stipulates so in its regulations.
Chapters that become the standard of practice in pharmacy can also
be enforced by a state board of pharmacy, he added. The USP does not
have any enforcement authority over pharmacies or any other practice
settings. Historically, attorneys have used USP chapters as the standard
of practice over state board of pharmacy practice acts, especially
if the regulations don’t adequately address the matter being tried.
As published in the chapter’s preamble, the standards of chapter <797> apply
to all practice settings (health care institutions, pharmacies, physician
practice facilities and other facilities) where sterile preparations
are prepared, stored and dispensed.
Patient injury and deaths have
been related to compounding errors. |
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Although state and federal governmental
agencies may not enforce USP <797>, in the event of patient injury
and death, the standard of care that
the provider of compounded sterile preparation will judged against
USP
Chapter <797>.
What should you do in order to be in compliance with USP <797>?
Obtain a copy of USP 27-NF 22 by visiting USP’s website at
http://store.usp.org/OA_HTML/ibeCCtpSctDspRte.jsp?a=b.
Eric will present this topic in April at NJSHP Chapter meetings.
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