WHAT HAPPENS NOW? A REVIEW OF USP CHAPTER <797> REVISIONS
Liz Fredrickson, PharmD, BCPS
Liz Fredrickson is an Associate Professor of Pharmacy Practice and Pharmaceutical Sciences at the Northeast Ohio Medical University College of Pharmacy. She serves as the Director of Instructional Labs and is course director for the Basic Pharmaceutics Lab and Parenteral Products and Parenteral Products Lab courses.
Topic Overview
The wait is finally over, and revisions to USP General Chapter <797> Pharmaceutical Compounding – Sterile Preparations have been released. This chapter was first published in 2008 by the United States Pharmacopeial Convention as a result of and response to patient harm and death that resulted from compounded sterile preparations (CSPs). Years later, a process of revisions, appeals, and a public comment period resulted in the 2022 updates. These revisions are the culmination of scientific and clinical practice advancements and stakeholder input. This course will review pertinent sections of the revised guidelines and provide guidance for personnel involved with sterile compounding.
Accreditation Statement:
RxCe.com LLC is accredited by the Accreditation Council for Pharmacy Education (ACPE) as a provider of continuing pharmacy education.
Universal Activity Number (UAN): The ACPE Universal Activity Number assigned to this activity is
Pharmacist 0669-0000-22-088-H07-P
Pharmacy Technician 0669-0000-22-089-H07-T
Credits: 1 hour of continuing education credit
Type of Activity: Knowledge
Media: Internet Fee Information: $4.99
Estimated time to complete activity: 1 hour, including Course Test and course evaluation
Release Date: December 17, 2022 Expiration Date: December 17, 2025
Target Audience: This educational activity is for pharmacists.
How to Earn Credit: From December 17, 2022, through December 17, 2025, participants must:
Read the “learning objectives” and “author and planning team disclosures;”
Study the section entitled “educational activity;” and
Complete the Course Test and Evaluation form. The Course Test will be graded automatically. Following successful completion of the Course Test with a score of 70% or higher, a statement of participation will be made available immediately. (No partial credit will be given.)
Learning Objectives: Upon completion of this educational activity, participants should be able to:
Recall training and evaluation requirements for compounding personnel
Assign beyond-use dates to compounded sterile preparations (CSPs)
Identify components of Master Formulation and Compounding Records
Recall sterility testing and endotoxin requirements
Disclosures
The following individuals were involved in the development of this activity: Liz Fredrickson, PharmD, BCPS, and Susan DePasquale, MSN, PMHNP-BC. There are no financial relationships relevant to this activity to report or disclose by any of the individuals involved in the development of this activity.
ⓒ RxCe.com LLC 2022: All rights reserved. No reproduction of all or part of any content herein is allowed without the prior, written permission of RxCe.com LLC.
Introduction
The new guidelines for the United States Pharmacopeia, General Chapter <797> were released on November 1, 2022. Institutions must now prepare for implementation of these new guidelines, looking to their state boards of pharmacy to understand how to comply with Chapter <797>. Compounding personnel now need to be educated on the changes as well. This course will review pertinent sections of the revised <797> guidelines and provide guidance for individuals involved in sterile compounding.
Where We’ve Been with USP <797>
United States Pharmacopeia, General Chapter <797>, titled Pharmaceutical Compounding – Sterile Preparations, was first published in 2008 by the United States Pharmacopeial Convention.1 The purpose of the chapter was to set standards for the safe practice of sterile compounding.1 In part, this chapter was a result of and response to patient harm and death that resulted from compounded sterile preparations (CSPs).1 Three years following its publication, a survey found many institutions were unable to comply as a result of financial limitations.2
Since that time, the chapter has undergone a process of revisions, appeals, and public comment. Chapter revisions were originally planned for June 2019, but by September 2019, the publication was postponed.3 In March 2020, a panel issued decisions on appeals to USP <797>, and in September 2020, an open forum for beyond-use dating provisions was held.3 In September 2021, the revised guidelines were published for review, with a comment period held open until March 2022.3
The new guidelines were finally released on November 1, 2022.3 These revisions are the culmination of scientific and clinical practice advancements and stakeholder input. During the public comment period, USP received more than 1,400 public comments from stakeholders.4 Compounding personnel may find the <797> commentary provided by USP to be useful as it reviews the
changes to the guidelines. This document includes public comments and the Expert Committee’s response on whether to incorporate those comments.5
List of Useful Acronyms
CAI = compounding aseptic isolator
CACI = compounding aseptic containment isolator
CR = compounding record
CSP = compounded sterile preparation
MFR = master formulation record
RABS = restricted access barrier system
SOP = standard operating procedure
USP = United States Pharmacopeia
USPC = United States Pharmacopeial Convention
Compounded Sterile Preparations Categories
Previously, CSPs were categorized by risk level of low, medium, or high, which were assigned based on specified criteria and conditions for each level.4 Compounding personnel should now be familiar with three categories of CSPs: Category 1, Category 2, and Category 3.6 These categories differ based on three factors:6
The environment in which they are compounded
The probability for microbial growth during the time they will be stored
The time within which they must be used
Category 1 CSPs are compounded under the least controlled environmental conditions and thus have the shortest beyond-use dates of the three categories.6 Category 2 CSPs have stricter environmental controls and testing requirements and may be assigned longer beyond-use dates than Category 1 CSPs. Category 3 is the newest category.6 These CSPs undergo sterility testing and endotoxin testing when applicable.6 Compared to Category
1 and 2 CSPs, they have more requirements for personnel qualifications, garbing, sporicidal disinfectants, environmental monitoring, and stability determination.6 When applicable requirements are met, Category 3 CSPs are assigned the longest beyond-use dates of the three categories.6 Table 1 provides a comparison of the three CSP categories.6
Table 1. Comparison of CSP Categories
Category | Criteria | Beyond-use date (BUD) |
Category 1 | Must be prepared in an ISO Class 5 or better primary engineering control (PEC) that can be in an unclassified segregated compounding area (SCA) | Have shortest BUDs |
Category 2 | Must be made in a cleanroom suite | BUD assigned based on risk elements (compounding method, sterility testing, & starting ingredients) Longer BUDs than Category 1 |
Category 3 | Undergo sterility testing, supplemented by endotoxin testing when applicable More requirements than Category 2 CSPs | BUD assigned based on compounding method and storage conditions Longest BUDs (up to a maximum of 180 days) |
Immediate-use CSPs
Immediate-use CSPs are intended to be directly and immediately administered to a patient.6 Category 1, 2, and 3 CSPs requirements are not applicable when the following criteria are met:6
Aseptic techniques, processes, and procedures are followed
Written standard operating procedures (SOPs) are in place to minimize contamination and mix-ups with other CSPs
Personnel are trained and demonstrate competency in aseptic processes
The preparation is compounded using evidence-based information for the physical and chemical compatibility of the drugs
No more than 3 different sterile products are used
Unused starting components from a single-dose container are discarded after the preparation is complete
Single-dose containers are not used for more than one patient
Administration begins within 4 hours following the start of preparation
If the administration of the drug or product has not begun within 4 hours following the start of preparation, it is promptly discarded.
The CSP is labeled with the names and amounts of all active ingredients and the name or initials of the compounding pharmacist unless it is directly administered by the person who prepared it or administration is witnessed by the preparer, the CSP
There are notable differences from the previous version of the chapter. Previously, administration of an immediate-use CSP had to begin within one hour following the start of the preparation. Additionally, it is important to note personnel who prepare these types of CSPs now need to demonstrate competency.7
Preparation Per Approved Labeling
The newest guidelines state compounding does not include mixing, reconstituting, or performing similar acts via manufacturer directions.6 This information may help in reducing sterile compounding workload for facilities.7 When a conventionally manufactured sterile product is prepared via manufacturer directions, it is out of the scope of the chapter if: 6
The product is prepared as a single dose for an individual patient, and
The approved labeling includes information for the diluent, the resultant strength, the container closure system, and storage time
Establishing Beyond-Use Dates
The process of assigning beyond-use dates was significantly revised within the guidelines.4,6 The USP Compounding Expert Committee utilized the previously published chapter and stakeholder input to revise the BUD limits.4 Due to the challenge of predicting stability and sterility concerns for all sterile products, these limits were created using a risk-based approach.4
Longer BUD limits are permitted in certain specific circumstances based on additional requirements.4 Tables 2, 3, and 4 detail the BUD limits for Category 1, Category 2, and Category 3 CSPs, respectively.6
Table 2. BUD Limits for Category 1 CSPs
Storage Condition | Controlled Room Temperature (20- 25°C) | Refrigerator (2-8° C) |
BUD | ≤12 hours | ≤24 hours |
Table 3. BUD Limits for Category 2 CSPs
Preparation Characteristics | Storage Conditions | |||
Compoun | Sterility | Controlled | Refrigerator | Freezer |
ding Method | Testing Performed | Room Temperature | (2-8 °C) | (-25 to -10 °C) |
and Passed | (20 to 25 °C) | |||
Aseptically | No | Prepared from | Prepared | Prepared |
processed | one or more | from one | from one | |
CSPs | nonsterile starting | or more nonsterile | or more nonsterile | |
component(s): | starting | starting | ||
1 day | component(s) | component(s) | ||
: 4 days | : 45 days | |||
Prepared from | Prepared | Prepared | ||
only sterile | from | from |
starting compo nents: 4 days | only sterile starting comp onents: 10 days | only sterile starting comp onents: 45 days | ||
Yes | 30 days | 45 days | 60 days | |
Terminally sterilized CSPs | No | 14 days | 28 days | 45 days |
Yes | 45 days | 60 days | 90 days |
Table 4. BUD Limits for Category 3 CSPs
Compounding Method | Controlled Room Temperature (20-25°C) | Refrigerator (2-8°C) | Freezer (-25 to -10°C) |
Aseptically processed, sterility tested, and passing all applicable tests for Category 3 CSPs | 60 days | 90 days | 120 days |
Terminally sterilized, sterility tested, and passing all applicable tests for Category 3 CSPs | 90 days | 120 days | 180 days |
Use of Conventionally Manufactured Products as Components
There have been updates regarding the use of conventionally manufactured products as components within CSPs.6 These changes are compared to the previous guidelines in Table 5 below.6
Table 5. Other Beyond Use Dates
Type | Previous Guidelines | Current Guidelines |
Single Dose Vials | ||
Multiple Dose Vials | ||
Read-to-use products | ||
Ampules |
6 hours if opened in an ISO 5 or cleaner air
12 hours if opened or punctured in ISO 5 or cleaner air
28 days unless otherwise stated by the manufacturer
28 days unless otherwise stated by the manufacturer
Per manufacturer instructions
Per manufacturer instructions
Do not store for any amount of time
Do not store for any amount of time
If 1–39 CSPs are compounded in a single batch: sterility testing must be performed on a number of units equal to 10% of the number of CSPs prepared, rounded up to the next whole number.6
If 39 CSPs are compounded: 10% of 39 rounded up to the next whole number would indicate that 4 additional CSPs must be prepared for sterility testing6
Endotoxins Testing
Requirements for endotoxins testing also depend on the category of CSPs.6 Category 1 CSPs do not require testing for bacterial endotoxins.6 Category 2 CSPs compounded from one or more nonsterile component(s) should be tested for bacterial endotoxins.6 Category 3 CSPs compounded from one or more nonsterile component(s) also must undergo this testing to ensure that they do not contain excessive bacterial endotoxins.6
If an official USP–NF monograph or other CSP formula source does not specify an endotoxin limit, the CSP must not exceed the endotoxin limit calculated as described in Chapter <1085> for the appropriate route of administration for humans.6,9
Personnel Training and Evaluation
The concept of the designated person is new within the chapter.6,10 This individual (or individuals) is responsible for ensuring personnel who enter the sterile compounding area can maintain its environmental quality. Their responsibilities include overseeing daily operations to make sure the facility is USP <797> compliant.6,10
The guidelines also include important information regarding compounding personnel.6,10 Notably, training and evaluation are not limited to individuals who directly compound CSPs.6,10 Per the guidelines, any personnel involved with compounding CSPs, handling CSPs, or accessing the compounding area must demonstrate competency to maintain the environmental quality and CSP safety.6 The following individuals must be trained and qualified:
Compounders
Personnel who have direct oversight of compounders
Personnel who perform restocking or cleaning and disinfection duties
The designated person may choose to train personnel themselves or they can assign a trainer. The frequency of training for individuals who compound CSPs differs from those who do not directly compound, and facilities should note these differences in training records and standard operating procedures (SOPs) to make this distinction clear. Personnel who compound or oversee direct compounding must be trained initially and then every 12 months, while those who perform restocking or cleaning duties should complete training as noted within the facility’s SOP.6
Personnel who directly compound or have oversight of compounding must demonstrate competency in the following areas:6
Hand hygiene and garbing
Cleaning and disinfection
Calculations, measuring, and mixing
Aseptic technique
Achieving and/or maintaining sterility
Use of equipment
Documentation of the compounding process
Principles of high-efficiency particulate air (HEPA)-filtered unidirectional airflow within the ISO Class 5 area
Proper use of PECs
Principles of movement of materials and personnel within the compounding area
Competency in Garbing and Hand Hygiene
Before compounding a Category 1, Category 2, or Category 3 CSP, personnel must complete an initial garbing competency evaluation no fewer three times in a row.6,10 Prior to each evaluation, personnel should perform a complete hand hygiene and full garb procedure.
United States Pharmacopeia, Chapter <797> provides the gloved fingertip and thumb sampling procedure as described below.6 To ensure proper pressure is applied during the gloved finger-tip test, experts recommend holding the plate vertically.6,7
Use one sampling media device (e.g., plates, paddles, or slides) per hand, containing general microbial growth agar (e.g., trypticase soy agar [TSA]) supplemented with neutralizing additives (e.g., lecithin and polysorbate 80) as this agar supports both bacterial and fungal growth.
Label each media device with a personnel identifier, right or left hand, and the date and time of sampling.
Do not apply sterile 70% isopropyl alcohol (IPA) to gloves immediately before touching the media device because this could cause a false- negative result.
Using a separate media device for each hand, collect samples from all gloved fingertips and thumbs from both hands by rolling fingertip pads and thumb pad over the agar surface.
Incubate the media device at 30°–35° for no less than 48 hours and then at 20°–25° for no less than 5 additional days. Samples must be incubated in an incubator.
Handle and store media devices to avoid contamination and prevent condensate from dropping onto the agar during incubation and affecting the accuracy of the cfu reading (e.g., invert plates).
Record the number of cfu per hand (left hand, right hand).
Determine whether the cfu action level is exceeded by counting the total number of cfu from both hands
Failure is noted either via visual observation or exceeding action levels of the gloved fingertip and thumb sampling (Table 6).6 Personnel who fail any of the three evaluations must undergo repeat testing until they can pass three in a row.6 After initial evaluation, personnel must demonstrate competency at least once every 6 months for Category 1 and Category 2 CSPs and at least once every 3 months for Category 3 CSPs. Designated persons should consider implementing thorough training of personnel prior to competency evaluation to help ensure success.
Competency in Aseptic Technique
In addition to demonstrating competency in garbing, personnel must also complete an aseptic manipulation competency evaluation. This consists of the following:
Visual observation
Media-fill testing
Gloved fingertip and thumb sampling on both hands
Surface sampling of the direct compounding area.6
This evaluation should be done initially and at least once every 6 months for those compounding Category 1 and Category 2 CSPs and at least once every 3 months for those who prepare Category 3 CSPs.6
United States Pharmacopeia, Chapter <797> provides the media-fill testing procedure as follows:6
If all the starting components are sterile, to begin with, manipulate them in a manner that simulates sterile-to-sterile compounding activities, and transfer the sterile soybean–casein digest media into the same types of container closure systems commonly used at the facility. Do not further dilute the media unless specified by the manufacturer.
If some of the starting components are nonsterile, to begin with, dissolve a commercially available nonsterile soybean–casein digest powder in nonbacteriostatic water to make a 3% nonsterile solution. Manipulate it in a manner that simulates nonsterile-to-sterile compounding activities. Prepare at least 1 container as the positive control to demonstrate growth promotion, which is indicated by visible turbidity upon incubation.
Once the compounding simulation is completed and the final containers are filled with the test media, perform a gloved fingertip and thumb sample on each hand and surface sample of the direct compounding area inside the PEC. Take the samples prior to disinfecting gloves and PEC. Handle and store samples to avoid contamination and prevent
condensate from dropping onto the agar during incubation and affecting the accuracy of the cfu reading (e.g., invert containers).
Incubate the final containers at 20°–25° and 30°–35° for a minimum of
7 days at each temperature band to detect a broad spectrum of microorganisms. The order of the incubation temperatures must be described in the facility’s SOPs. Final containers must be incubated in an incubator.
Failure is indicated by visible turbidity or other visual manifestations of growth in the media in one or more container closure unit(s) on or before 14 days
Failure is indicated by visible turbidity or visual manifestations in the growth media. Gloved fingertip and thumb sampling failure is noted by more than 3 cfu from both hands (Table 6).6
Table 6. Action Levels for Gloved Fingertip and Thumb Sampling
Gloved Fingertip and Thumb Sampling | Action Level (cfu total from both hands) |
After garbing | >0 |
After media-fill testing | >3 |
Tables 7 and 8 are provided within USP <797> and offer useful information related to the requirements for personnel involved with sterile compounding.6 These beneficial tables can be included within an institution’s SOP and designated persons can modify them to include the specific requirements of their facility.
Table 7. Initial Training and Competency
Required <797> and Supplemented by Facility SOP | |||||
Personnel | Defined | Training and | Training and | Garbing | Media Fill |
Function | by | Competency | Competency | Competency | and Post- |
Facility | in Maintaining | in Sterile | (Including | GFT and | |
SOPs | the Quality of | Compounding | GFT) | Surface | |
Sterile Compounding Environment | Principles and Practices | Sampling |
Compounder | X | X | X | X | |
Designated person and personnel with direct oversight of compounding personnel | X | X | X | X | |
Personnel who restock or clean and disinfect the sterile compounding area | x | ||||
Personnel who perform in-process checks or final verification of CSPs | x | ||||
Personnel who only compound immediate- use CSPs | x | ||||
Others (e.g., maintenance personnel, certifiers, contractors, inspectors, surveyors) | x |
Table 8. Ongoing Training and Competency
Required <797> and Supplemented by Facility SOPs | ||||
Personnel Function | Defined by Facility SOPs | Training and Competency in Sterile Compounding Principles and Practices | Garbing Competency (including GFT) | Media fill with post-GFT and surface sampling |
Compounder | At least every 12 months | Category 1 and 2 at least every 6 months | Category 1 and 2 at least every 6 months
Category 3 at least every 3 months |
Category 3 at least every 3 months | ||||
Designated person and personnel with direct oversight of compounding personnel | At least every 12 months | At least every 12 months | At least every 12 months | |
Personnel who restock or clean and disinfect the sterile compounding area | x | |||
Personnel who perform in-process checks or final verification of CSPs | x | |||
Personnel who only compound immediate-use CSPs | x | |||
Others (e.g., maintenance personnel, certifiers, contractors, inspectors, surveyors) | x |
For facilities compounding Category 3 CSPs, it’s important to note specific garbing requirements.6,11 These are as follows:
Compounders are not allowed any exposed skin in the buffer room
All low-lint garb must be sterile
Once a compounder leaves a classified area, disposable garbing items must be discarded, and laundered garb must not be reused without being laundered and re-sterilized with a validated cycle
Facilities and Engineering Controls
Compounding Aseptic Isolators (CAI) and Compounding Aseptic Containment Isolators (CACI) are now referred to as Restricted Access Barrier Systems (RABS) within this section of the guidelines.6,10 If Category 2 CSPs are being prepared, these systems must be located in a cleanroom suite.6 Additionally, personnel should note that Category 1, Category 2, and Category 3 CSPs must be compounded in an ISO Class 5 or better primary engineering control (PEC).6 If a facility only compounds Category 1 CSPs, the PEC may be placed in an unclassified SCA.6 Table 9 summarizes the minimum requirements related to the placement of PECs when compounding nonhazardous CSPs.6
Table 9. Summary of Minimum Requirements for Placement of PECs for Compounding Non-HD CSPs
PEC Type | Device Type | Placement for Category 1 CSPs | Placement for Category 2 and 3 CSPs |
LAFS | LAFW | Unclassified SCA | ISO Class 7 positive-pressure buffer room with an ISO Class 8 positive-pressure anteroom |
IVLFZ | N/A b | ISO Class 7 positive-pressure buffer room with an ISO Class 8 positive-pressure anteroom | |
BSC | Unclassified SCA | ISO Class 7 positive-pressure buffer room with an ISO Class 8 positive-pressure anteroom |
RABS | CAI or CACI | Unclassified SCA | SO Class 7 positive-pressure buffer room with an ISO Class 8 positive-pressure anteroom |
Pharmaceutical isolator | Pharmaceutical isolator | Unclassified SCA | ISO Class 8 positive-pressure room |
Certification and Recertification
United States Pharmacopeia, Chapter <797> states areas used for compounding must be independently certified. Recertification must be performed at least every 6 months.6 Certification should meet the requirements of the chapter and manufacturer specifications where applicable. This includes:
Airflow testing: performed to determine acceptability of the air velocity, the room air exchange rate, and the room pressure differential in doorways between adjacent rooms to ensure consistent airflow
HEPA filter integrity testing: filters must be leak tested at the factory and then leak tested again after installation
Total particle count testing: must be performed under dynamic operating conditions using calibrated electronic equipment
Dynamic airflow smoke pattern test: performed for each PEC during dynamic operating conditions to demonstrate unidirectional airflow and sweeping action over and away from the preparation(s)
Cleaning, Disinfecting, and Applying Sporicidal Disinfectants and Sterile 70% IPA
This section includes requirements for cleaning and disinfecting. The minimum frequency for cleaning and disinfecting surfaces is described in Table
10 below. Experts recommended triple-cleaning all equipment before
introducing it into the sterile compounding area. This includes uses an EPA- registered one-step bacterial cleaner first and then using an EPA-registered one-step sporicidal cleaner twice.7
Table 10. Minimum Frequency for Cleaning and Disinfecting Surfaces and Applying Sporicidal Disinfectants in Classified Areas and in the SCA
Site | Cleaning | Disinfecting | Applying Sporicidal Disinfectant |
PEC(s) and equipment inside the PEC(s) | Equipment and all interior surfaces of the PEC daily on days when compounding occurs and when surface contamination is known or suspected | Equipment and all interior surfaces of the PEC daily on days when compounding occurs and when surface contamination is known or suspected | Monthly for entities compounding Category 1 and/or Category 2 CSPs Weekly for entities compounding Category 3 CSPs |
Removable work tray of the PEC when applicable | Work surface of the tray daily on days when compounding occurs All surfaces and the area underneath the work tray monthly | Work surface of the tray on days when compounding occurs All surfaces and the area underneath the work tray monthly | Monthly for work surfaces of the tray Monthly for all surfaces and the area underneath the work tray |
Pass-through chamber | Daily on days when compounding occurs | Daily on days when compounding occurs | Monthly for entities compounding |
Work surfaces outside the PEC | Daily on days when compounding occurs | Daily on days when compounding occurs | Category 1 and/or Category 2 CSPs Weekly for entities compounding Category 3 CSPs |
Floors | Daily on days when compounding occurs | Daily on days when compounding occurs | |
Walls, doors, door frames
Ceilings Storage shelves and bins Equipment outside the PEC | Monthly | Monthly | Monthly |
Sterilization and Depyrogenation
The terms aseptic processing and terminal sterilization are better defined within the newest guidelines.10 United States Pharmacopeia <797> states terminal sterilization includes compounding with sterile and/or nonsterile starting ingredient(s) and subsequent sterilization with a process intended to achieve a PNSU of 10−66 The PNSU is also called the sterility assurance level (SAL), and a PNSU of 10−6 is equivalent to a probability that 1 unit in a million is nonsterile.6 Aseptic processing includes 1) compounding with only sterile starting ingredient(s) or 2) compounding with nonsterile ingredient(s) followed by sterilization by filtration.
Terminal sterilization is noted as the preferred method unless the specific CSP or container closure system cannot tolerate terminal sterilization.6,7 Steam sterilization is not an option in cases where moisture, pressure, or the temperatures used would degrade the CSP, or if there is insufficient moisture to sterilize the CSP within the final, sealed, container
closure system.6 Filtration may not be best for CSP preparations with suspended drug particles or emulsions with a significant droplet size.6
Records and Labeling Master Formulation Records
The role of proper record keeping is highlighted within the revised guidelines. This involves the completion of two records: a master formulation records (MFR) and compounding records (CR).6 An MFR is a detailed record of procedures that describes how to prepare the CSP. An MFR can be thought of like a recipe, and the intent is to ensure repeatable, accurate compounding every time the CSP is prepared. The guidelines state an MFR must be created for any CSP prepared from nonsterile ingredient(s) or for CSPs prepared for more than one patient. Required MFR components include the following:6
Name, strength or activity, and dosage form of the CSP
Identities and amounts of all ingredients and relevant characteristics of components if applicable
Type and size of container closure system(s)
Complete instructions for preparing the CSP, including equipment, supplies, a description of compounding steps, and special precautions
Physical description of the final CSP
Beyond-use date and storage requirements
Reference source to support the stability of the CSP
Quality control (QC) procedures
Other information as needed to describe the compounding process and ensure repeatability
Compounding Records
A CR documents the compounding process of each CSP. A medication order or prescription can serve as the CR.6 United States Pharmacopeia <797> requires a CR be created for all CSP categories.6 Additionally, a CR must be created for immediate-use CSPs prepared for more than one patient.6 The
MFR is the basis for preparing the CR. Designated persons could make a copy of the MFR that includes spaces for recording information needed to complete the CR.
Requirements for compounding records include the following:6
Name, strength or activity, and dosage form of the CSP
Date and time of preparation of the CSP
Assigned internal identification number (could be a prescription or lot number)
A method to identify individuals involved in the compounding process and those verifying the final CSP
Name of each component
Vendor, lot number, and expiration date for each component for CSPs prepared for more than one patient and for CSPs prepared from nonsterile ingredient(s)
Weight or volume of each component
Strength or activity of each component
Total quantity compounded
Final yield
Assigned BUD and storage requirements
Results of QC procedures
MFR reference for the CSP (if applicable)
Calculations (if applicable)
Labeling
Per USP <797>, all categories (Category 1, Category 2, and Category 3) of CSPs must be labeled with appropriate, legible identifying information. This assists with preventing errors during storage, dispensing, and use of these products.6 The terms “labeling” and “label” differ in their meanings. Labeling refers to all labels and other written, printed, or graphic matter on the immediate container or on or inside any package or wrapper in which it is enclosed, except any outer shipping container.6 Label refers to parts of the
labeling that is on the immediate container. More information regarding labeling can be found in USP <7> - Labeling.6,12
Labeling must comply with regulatory jurisdictions and should minimally contain the following on the immediate container of the CSP:6
Assigned internal identification number (like a barcode or prescription number)
Active ingredient(s) with amount(s), activity(ies), or concentration(s)
Storage conditions if other than controlled room temperature
BUD
Dosage form
Total amount or volume if it is not obvious from the container
If it is a single-dose container, a statement stating such when space permits
If it is a multiple-dose container, a statement stating such
The labeling on the CSP must display the following information, as applicable:6
Route(s) of administration
Special handling instructions
Warning statements
Compounding facility name and contact information if the CSP is to be sent outside of the facility or healthcare system in which it was compounded
SOPs and Documentation Standard Operating Procedures
Facilities that prepare CSPs must develop SOPs for the compounding process and other support activities.6 These should be prepared in a way that ensures consistency and repeatability and should be written in a user-friendly manner. It has been recommended that facilities utilize Chapter <797> as the
basis for SOP development and then customize it with additional quality elements.7 SOPs must include the types of CSPs that are prepared.6 Designated person(s) should ensure SOPs are appropriate and are implemented, and they must follow up to ensure corrective actions are taken if problems, deviations, failures, or errors are identified. If such problems are noted, these must be documented.6
Documentation
Documentation, whether written or electronic, is required for all facilities that prepare CSPs.6 Documentation records must be legible and comply with USP <797>.6 This documentation must minimally include the following:6
Personnel training, competency assessments, and qualification records including corrective actions for any failures
Certification reports, including corrective actions for any failures
Environmental air and surface monitoring procedures and results
Equipment records (e.g., calibration, verification, and maintenance reports)
Receipt of components
SOPs, MFRs (if required), and CRs (if required)
Release inspection and testing records
Information related to complaints and adverse events including corrective actions taken
Results of investigations and corrective actions
Importantly, all documentation must comply with all laws and regulations of the institution’s applicable regulatory jurisdiction. Documents must be stored in a way to ensure they are not lost and will not deteriorate, and all documentation must be readily retrievable.6
Next Steps for Compounding Personnel
As institutions prepare for the implementation of these newest guidelines, they should highlight important revisions and changes.
Compounding personnel, in particular designated persons, should thoroughly read through the revised guidelines and take notes.13 These guidelines can serve as an important basis for facility SOPs.13 Boards of pharmacy may have more stringent requirements than those recommended by USP <797>.13 An example of additional requirements may include obtaining a certain number of sterile compounding CEUs. This is true for states such as Massachusetts.14 The deadline for enforcement of USP <797> is November 1, 2023, but state boards could implement an earlier deadline.6 Importantly, any institution should refer to its state board(s) of pharmacy to ensure they are compliant with those specific regulations.
Summary
The revisions to USP General Chapter <797> Pharmaceutical Compounding – Sterile Preparations have been released. These revisions are the culmination of scientific and clinical practice advancements and stakeholder input. Previously, CSPs were categorized by risk level of low, medium, or high, which were assigned based on specified criteria and conditions for each level. Compounding personnel should now be familiar with three categories of CSPs: Category 1, Category 2, and Category 3. These categories differ based on the environment in which they are compounded, the probability for microbial growth during the time they will be stored, and the time within which they must be used. These guidelines can serve as an important basis for facility SOPs. Boards of pharmacy may have more stringent requirements than those recommended by USP <797>.
Course Test
Individuals who directly compound sterile preparations must complete how many successive garbing competency evaluations prior to compounding CSPs?
a. 1
b. 2
c. 3
d. 4
How often should a garbing competency evaluation minimally be completed for individuals who compound Category 2 CSPs?
Initially and then every 3 months
Initially and then every 6 months
Initially and then every 12 months
Initially and then every 2 years
Which of the following is the action level for gloved fingertip and thumb sampling after media-fill testing?
0
>1
>2
>3
Which of the following CSP Categories does not require sterility testing?
Category 1
Category 2
Category 3
All categories require sterility testing
Which of the following CSP categories may require endotoxin testing?
Category 1
Category 2
Category 3
Category 2 and Category 3
Which of the following best defines a master formulation record?
A record of procedures describing how to prepare a CSP
A record that documents the process of compounding a CSP
A record containing a medication order or prescription for a CSP
A record that contains a method to identify individuals involved in compounding and verifying the final CSP
Which of the following is a required component of a master formulation record?
Date and time the CSP was prepared
Assigned internal identification number of the CSP
Beyond-use date
Total quantity compounded
Which of the following beyond-use dates would be assigned to a Category 1 CSP stored at controlled room temperature?
≤ 6 hours
≤ 12 hours
≤ 24 hours
≤ 48 hours
Which of the following beyond-use dates would be assigned to a Category 2 CSP that has been aseptically processed, did not pass sterility testing, is prepared from one or more nonsterile starting ingredients, and is stored in the refrigerator?
1 day
4 days
45 days
60 days
Of the three CSP categories, which includes the longest beyond- use dates?
Category 1
Category 2
Category 3
Categories 1 and 2
References
Assuring a sterile environment. US Micro Solutions. https://www.usmslab.com/usp-797-and-pharmaceutical- compounding/#:~:text=Launched%20in%202008%20by%20the,recall%20 by%20U.S.%20Compounding%2C%20Inc. Accessed November 30, 2022.
How sterile compounding has evolved and actions taken. Wolters Kluwer. 2015. https://www.wolterskluwer.com/en/expert-insights/a-timeline-of- sterile-compounding-events-and-actions-taken. Accessed November 30, 2022.
General Chapter <797>. USP. 2022. https://www.usp.org/compounding/general-chapter-797. Accessed November 30, 2022.
USP Compounding Standards and Beyond-Use Dates. USP. 2021. Accessed November 30, 2022.
Commentary. USP-NF. https://www.uspnf.com/sites/default/files/usp_pdf/EN/USPNF/usp-nf- commentary/797-commentary-20221101.pdf. Accessed November 30, 2022.
General Chapter: USP. Pharmaceutical Compounding-Sterile Preparations
<797>. In: USP-NF. Rockville, MD: USP; September 2022.
USP 797 Chapter Release Countdown Tips. Pure Microbiology. https://www.puremicrobiology.com/app/uploads/2022/12/USP-797-Chapter- Release-Countdown-Tips-12.12.22.pdf. Accessed December 18, 2022.
General Chapter: USP. Sterility Testing <71>. In: USP-NF. Rockville, MD: USP; September 2013.
General Chapter: USP. Guidelines on Endotoxin Testing <1085>. In: USP- NF. Rockville, MD: USP; September 2020.
The crosswalk of changes to USP 797 update. Wolters Kluwer. 2019. Available at https://www.wolterskluwer.com/en/expert-insights/the- crosswalk-of-changes-to-2019-usp-797: Accessed November 2022.
Martin M. Proposed changes to USP 797. 2022. https://www.pccarx.com/Blog/proposed-changes-to-usp-797. Accessed November 30, 2022.
General Chapter: USP. Labeling <7>. In: USP-NF. Rockville, MD: USP; September 2020.
Pharmacy Times. Expert: What Pharmacies Should Be Prioritizing to Stay Compliant With Updated USP Chapters <797>, <795>, <800>. https://www.pharmacytimes.com/view/expert-what-pharmacies-should-be- prioritizing-to-stay-compliant-with-updated-usp-chapters-797-795-800-. Accessed November 30, 2022.
Pharmacist continuing education requirements. Pharmacist Licensing.
Mass.gov. 2022. https://www.mass.gov/service-details/pharmacist-
continuing-education-requirements. Accessed December 18, 2022.
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