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Matthew T. Jenkins, PharmD, MSPharmacy Operations Manager
University of Virginia Health System
USP Chapter <800>: Handling Hazardous Medications in
Healthcare Settings
I have no financial interest in and/or affiliation with any external organizations in relation to this CE program
Disclosures
• Review core elements of the proposed USP General Chapter <800> and potential effects on procedures for preparation, storage, transportation, and administration of hazardous drugs
• Articulate the method for medications to be placed on The National Institute for Occupational Safety and Health (NIOSH) Hazardous Drug List
• Describe how current technologies which can reduce healthcare worker exposures to hazardous drugs will be implemented to address proposed provisions of USP <800>
Objectives ‐ Pharmacists
• Describe the method for medications to be placed on The National Institute for Occupational Safety and Health (NIOSH) Hazardous Drug List
• Review core elements of the proposed USP General Chapter <800> and potential effects on procedures for preparation, storage, transportation, and administration of hazardous drugs
• Understand how current technologies which can reduce healthcare worker exposures to hazardous drugs will be implemented to address proposed provisions of USP <800>
Objectives – Pharmacy Technicians
• Chapter 800: Hazardous Drugs ‐ Handling in Healthcare Settings Proposed standard to protect personnel and environment when handling hazardous
drugs (HDs) Purpose: To define processes intended to provide containment of hazardous drugs to as
low as reasonably achievable (ALARA)• There is NO acceptable level of personnel exposure to HDs ‐ revised• Ex. Radiology
Scope: Builds upon <797> and <795>• All healthcare settings
• USP Expert Committee: “Harmonization of ASHP, NIOSH, OSHA guidelines”
USP <800>: Overview
• <800> focuses on containment of hazardous drugs (HDs) as defined by the NIOSH list
• Currently there is not a federal standard that exists to protect healthcare workers
• Extended scope than other compounding chapters General Chapters below <1000>: Mandatory General Chapters above <1000>: Considered
Interpretations
USP <800>: OverviewPrimary Challenges to Compliance with USP <797>
RequirementsBarrier % of Respondents
Financial 27
Physical Plant Limitations 21
Training/Competency Resources Needed 19
Time Required 16
Compounding Staff Resistance to Change 7
Lack of Leadership Support 3
Leadership Lack of Knowledge 2
Pharmacy Purchasing & Products. 2014; 11(10 suppl):S6‐24
• USP <797>: HDs shall be prepared under conditions that protect healthcare workers and others in preparation and storage areas
• USP <795>: HDs shall be stored, prepared, and handled under conditions that protect the healthcare workers and other personnel
• Proposed USP <800>: Both sterile and non‐sterile compounding
Current USP Application to HDs
• NIOSH Alert
• ASHP Guidelines on Handling Hazardous Drugs
• Focused on principles of worker and medication safety
Current Resources
HD List Personnel responsibilities Personal Protective Equipment (PPE) Facility design and engineering controls Receiving Compounding Administering Cleaning Environmental control Medical Surveillance
USP <800>: Major Sections
• Scope includes the entire flow of a hazardous medication through the facility:
• Inclusion of sterile and non‐sterile products and preparations
• The new standards apply to all personnel who are involved with manipulation of HD and where HDs are prepared, stored, transported, and administered Ambulatory Clinics Housekeeping Physician offices Outpatient Pharmacy
Review of Proposed USP <800>
Receipt Disposal
<797> vs. <800>Category USP‐797 USP‐800
Application to compounding Sterile only Sterile and non‐sterile
Scope Receipt of inventory to start of administration
Receipt of inventory through drug administration
Exemption for low‐volume Exemption No exception
CSTD use A should Shall during administration (when dosage for permits)
Drug storage Separate from other inventory to prevent contamination and personnel exposure
Separate storageNegative pressure
Surveillance Does not require environmental and medical surveillance
Requires environmental & medical
The Low Volume Exemption
Function C‐PEC C‐SEC Airflow Maximum BUD
Compounding sterile HD in a cleanroom
BSC or CACI ISO 7 Cleanroom
30 ACPH (HEPA) Per <797>
Compounding sterile HD in a CAVI that meets the requirements listed in <797>
CACI C‐SCA 12 ACPH(exhaust)
Per <797>
Compounding low‐risk or medium‐risk sterile HDs in a BSC
BSC C‐SCA 12 ACPH (exhaust)
12 hours
NO Exceptions!
• <797> allows for facilities to prepare a low volume of HDs with the placement of a biological safety cabinet (BSC) or compounding aseptic containment isolator (CACI) in a non‐negative pressure room Should have a secondary containment device in place: CSTD
• All compounding involving HDs shall be done in a separate area designated for HD compounding
Removal of Low Volume Exemption
• Containment segregated compounding area (C‐SCA)• This is a separate, negative‐pressure room that is vented to the outside and
has at least 12 air changes per hour (ACPH) Does not need to meet ISO cleanroom standards 12‐hour Beyond Use Date (Time) Should contain a BSC or CACI
Alternative to the Low‐volume Exemption:
• Clarification added: HDs may be unpackaged only in a neutral, normal, or negative‐pressure area
• Statement concerning no acceptable level of personnel exposure to HDs REMOVED
• For non‐sterile compounding: either venting or redundant HEPA filtration in C‐PECs is allowed
• Revised section on list of HDs, allowing entities to perform an assessment of risk for non‐antineoplastic drugs and reproductive risk‐only HDs to determine alternative containment strategies and/or work practices
• Additional clarifications
Major Changes from First Comment Period
• ONS‐1982 Chemotherapy• ASHP‐1983, 1985 Cytotoxic Drugs• OSHA‐1986 Cytotoxic (Antineoplastic) Drugs• ASHP‐1990 Cytotoxic and Hazardous Drugs• NIH‐1992, 2002 Cytotoxic Drugs• OSHA‐1995 Hazardous Drugs• NIOSH‐2004 Antineoplastic and Other Hazardous Drugs• ASHP‐2006 Hazardous Drugs• USP ‐2008 Sterile (Hazardous) Drugs• ONS‐2011 Hazardous Drugs• NIOSH‐2014 Antineoplastic and Other Hazardous Drugs• USP 800‐2015 Hazardous Drugs
History of US Guidelines Related to Hazardous Drug Handling
• National Institute for Occupational Safety and Health (NIOSH) List of Antineoplastic and Other Hazardous Drugs in Healthcare Settings Most recent update: 2014 Next expected update: 2016
• Includes drugs that exhibit one or more of the following six characteristics in humans or animals Carcinogenicity Tetratogenicity or other developmental toxicity Reproductive toxicity Organ toxicity at low doses Genotoxicity Structure and toxicity profiles of new drugs that mimic existing drugs determined hazardous by
the above criteria
Hazardous Drugs (HDs)
NIOSH Hazardous Drug List: A Brief History
3133
28
0
15
1210
76
0
5
10
15
20
25
30
35
2010 2012 2014
Num
ber o
f Cha
nges
Year of Update
Drugs Added
Drugs Removed
Drugs with Manufacturer'sWarnings
NIOSH Classification of HDs
• Antineoplastic Drugs (AHFS Classification 10:00) [ASHP/AHFS DI 2013]Group 1
•Non‐antineoplastic drugs that meet one of more of the six NIOSH criteria for a hazardous drugGroup 2
•Drugs that primarily pose a reproductive risk to men and women who are actively trying to conceive and women who are pregnant or breast feeding, because some of these drugs may be present in breast milk.Group 3
2014 Update: guidance for making a facility‐specific list
NIOSH and USP <800>
Hazardous Drug Stratification (NIOSH) USP 800 Containment Requirements
Antineoplastics Must use all containment strategies
Non‐antineoplastics Can opt to conduct an internal assessment of risk to determine if practices ensure safe HD handling
Reproductive Hazards only
Notes:• API = Active Pharmaceutical Ingredient
Site‐specific HD List
Carcinogenicity
Teratogenicity
Reproductive Toxicity
Organ Toxicity at Low Doses
Genotoxicity
Similar Drugs
• Must include all NIOSH listed drugs
• Must perform toxicity review of own drugs and add, if appropriate
• Review ANNUALLY and when a NEW agent or dosage form is added
Hierarchy of Potential Toxicity
LOW
HIGH
• Not all HDs on the NIOSH list are cytotoxic agents
• Some dosage forms defined as hazardous may not pose a significant risk of direct exposure due to formulation of dosage
• Should include: Type of HD Risk of exposure Packaging Manipulation needed
Assessing Risk
• Example: Oxytocin– Use: OB‐GYN– Hospital’s assessment should include:
• Purchase: FDA‐approved dosage form in a vial, premixed IV bag from an FDA‐registered outsourcing facility (403B)
• A minimal number of doses are prepared in‐house, under controlled conditions• Employees know oxytocin is a reproductive hazard• Pharmacy only dispenses oxytocin in a final form:
– IV bag to be administered (dispensed in overwrap)– Powder is not utilized, vials are not opened, and individuals are not exposed unnecessarily
Performing Your Risk Assessment
Receiving Not to be in a positive pressure area (neutral is OK)
Competency of personnel• Containers may be damaged• Accessibility of spill kit
Standardization of identification
Facility Design and Process
• Storage of hazardous drugs (HDs) are to be negative or normal/neutral pressure• Compounding should occur in:
– CACI or BSC– Separate room that is:
• Negative pressure• Vented externally• Appropriately air changes per hour
• Focused to protect the environment, personnel, patient
Facility Design
Facility Design Example: Non‐sterile HD Compounding
Negative for HDs
C – PEC
Buffer ISO 7Negative for HDs
BSC or CACI
Ante ISO 7
positive
Facility Design Example: Sterile HD Compounding
Facility Design Example: Sterile HD Compounding
Buffer ISO 7Negative for HDs
BSC or CACI
Ante ISO 7 Positive
Buffer ISO 7Positive for non‐HDs
LAFW or CAI
Cleaning Steps
Cleaning Step Purpose AgentsDeactivation Render compound inert or
inactiveRefer to HD labeling, sodium hypochlorite or other EPA‐registered oxidizer
Decontamination Remove inactivated residue Sterile alcohol, sterile water, peroxide, or sodium hypochlorite
Cleaning Remove organic & inorganic material
Germicidal detergent & sterile water
Disinfection Destroy microorganism Sterile alcohol or other EPA‐registered disinfectant appropriate for use
• PPE: Personal Protective Equipment• Impervious gowns• ASTM‐tested chemotherapy gloves (Standard D6978)
Sterile & Powder‐Free• PPE should be based upon function
Garb and PPE
PPE and Engineering Controls for Working with HDs in Healthcare Settings
NIOSH 2014: Table 5
Formulation Activity Double Gloves Protective Gown
Eye Protection
Respiratory Protection
Ventilated Engineering Controls
Intact tablet of capsule
Administration from unit‐dose package
No (single glove should be used)
No No No N/A
Tablets orcapsules
Cutting, crushing or otherwise manipulating tablets or capsules
Yes Yes No Yes, if not done in a
control device
Yes
Adminsitration Yes Yes No Yes, if powder generated
N/A
Utilization of Closed System Transfer Devices (CSTD) Should be used when compounding HDs when the dosage form allows
Shall be used when administering HDs when the dosage form allows
Utilization of Supplemental Controls
Timeline of CSTD Development in the United States
Phaseal(1998)
Spiros(2005)
Texium with Smart Site,
OnGuard with Tevadaptor(2006)
ChemoClave(2008)
Equashield(2009)
SureConnect(2010)
ChemoLock(2013)
Vialshield(2013)
Equashield II (2014)
• Currently, there are 6 FDA‐Approved Products: BD: Phaseal* Carefusion: Texium B.Braun: On‐Guard ICU Medical: Spiros/ChemoLock* Equashield Q‐Flo 13 Infusion Innovations
• *= FDA ONB Code FDA ONB is a product code granted by the FDA, designated that a CSTD is a device for
transferring liquids to reduce hazardous drug exposures in specific workplace settings
• None are 100% perfect, but they make cleanrooms safer
CSTD
• ONB Class II Medical Device Product Code Closed Antineoplastic & Hazardous Drug Reconstitution and Transfer System FDA ONB is a product code granted by the FDA, designated that a CSTD isa device for
transferring liquids to reduce hazardous drug exposures in specific workplace settings• Criteria
Prevention of microbial ingress No escape of HDs or vapor concentration No transfer of environmental contaminants
The FDA ONB Code
CSTD Usage Rates by Facility Size
27%
32%
45%
35%33%
35%
54%
42%
0%
10%
20%
30%
40%
50%
60%
1 ‐ 100 101 ‐ 200 201 ‐ 400 500+
Nursing Pharmacy Pham Purch Prod. 2014; 4(4): 58.
Gaps in current systems: Management of ampules
Arsenic trioxide Limitation to dose size Specialized routes of administration
Intrathecal Itravesical IrrigationTopicalOphthalmic
Secure bag spike to prevent unspiking
Assessing Closed‐System Transfer Devices
• Segregation from non‐hazardous medications
• Manipulations: Crushing of a product Compounding
• Automated packaging devices
• Automated dispensing cabinets
Non‐sterile Hazardous Drugs
• Involves collecting and interpreting data to detect changes in health status of employees potentially exposed to hazardous substances
• Identify workers potentially exposed to HDs on the basis of their job duties• Consistent with Human Resources Policies• Should be appropriate to the exposure
Medical Surveillance
Challenges Related to Medical Surveillance
<800> OSHA
“Appropriate to the exposure….”“Develop a systematic approach”
NIOSH refers to OSHA
Occupational exposure monitoring is required by lawPre‐placement exam historyRepeated every 3 yearsDocumentation of routine and any acute exposures
Developing a Surveillance Program
Tier 1•Education and Self Surveillance
Tier 2
•Employer/Supervisor Surveillance•Annual reproductive questionnaire•Trending of sick calls
Tier 3
•Comprehensive Medical Surveillance•At hire & annually•CBC, urinalysis and LFTs
Tier 4•Medical record notation
Wipe sampling should be routinely performed• Initial (benchmark) then at least every 6 months• Should include:
Interior of the C‐PEC and equipment contained in it Staging or work areas near the C‐PEC Areas adjacent to C‐PECs (e.g., floors directly under staging and dispensing area) Patient administration areas
Currently there is no standard for acceptable limits for HD surface contamination
Environmental Surveillance
• Designated individual Develops and implements appropriate procedures Hazard Communication Program Annual review of SOPs
• Assures environmental quality and control of the compounding areas Routine monitoring Environmental wipe sampling
• Oversees facility compliance with USP Chapter <800> and other applicable laws, regulations, and standards
• Ensures personnel training is completed and documented Demonstration Observation of competence
• Ensures products and components received are consistent with principles of Good Distribution Practices
The Compounding Supervisor
• Storage The organization stores HD in a negative pressure room such as the hazardous drug
compounding room: 55.6%
• Medical Surveillance and Competency There is a written confirmation by each compounding employee of reproductive age
(male or female) that they understand the risk of handling hazardous CSPs: 42.3%
Organizational Compliance with USP <800>
• Update your facilities list of hazardous drugs• Review your policies• Review PPE currently used• Develop familiarity with <800>• Remain engaged
– Public comment period is open until May 31, 2015• Note that standards in USP‐NF become official 6 months after publication
– Allows for a delayed implementation
Next Steps
• Evaluate what medications are being manipulated at the point of administration Workflows – observe and understand what is really happening Drug delivery models
• Engage Nursing & Housekeeping– Understand your disposal pathways
What You Should Be Doing Now
• Develop a site‐specific hazardous drug list• Resources Cost of compliance: facility redesign and renovation New requirements for:
Personal protective equipment (PPE)Engineering and containment devices
• Surveillance Review OSHA Technical Manual online
Challenges for your Practices
1. Which drugs are listed by the 2014 NIOSH Update as being hazardous?a. Drugs with reproductive hazardsb. Drugs that are hazardous, but not antineoplastic drugsc. Antineoplastic drugsd. All of the above
2. Proposed USP General Chapter <800>a. Replaces USP Chapter <795>b. Replaces USP Chapter <797>c. Replaces USP Chapters <795> and <797>d. Supplements USP Chapters <795> and <797>
Self‐Assessment Questions
3. Which of the following was the most commonly reported barrier to compliance with USP Chapter <797> requirements for pharmaceutical compounding of sterile preparations in a 2014 survey of pharmacies?a. Compounding staff resistance to changeb. Financial and budget restrictionsc. Leadership lack of knowledged. Time required
Self‐Assessment Questions
In closing……
“Doveryai, no proveryai““Trust but verify”
Former President Ronald Reagan