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Bureau of Enforcement Investigative Services Unit PHARMACY INSPECTION OVERVIEW CONTINUING EDUCATION TRAINING November 8, 2018 Orlando, Florida Introduction Workshop Purpose Topics Program History Introduction of Inspectors


  1. Hand Hygiene and Garbing Selection of Gloves used in compounding • Use of sterile gloves •Single pair acceptable for Non-hazardous compounding •Double gloves for Hazardous compounding • Examine product information for gloves -to suggest rated for handling hazardous drugs •Conformance to ASTM 6978 standards

  2. Questions?

  3. Certifications Importance of reviewing Certification reports prior to an inspection

  4. Certifications The What, the When, and the How

  5. Certifications The What A Certification is an independent evaluation of the critical environments

  6. Certifications The When • Prior to operation • Every six (6) months • When equipment is moved, replaced or repaired

  7. Certifications The How • Must be conducted by a CETA certified agent • Equipment used by agent must be calibrated annually • Certifier must follow garbing procedure of facility • Dynamic Conditions

  8. Review of a Certification Report • Primary Engineering Controls • LAFW • BSC • CAI • CACI • Secondary Engineering Controls • Ante Room • Buffer Room

  9. Review of a Certification Report - Continued Primary Engineering Controls  Smoke Studies  Non Viable Air  HEPA Filter Leak Testing

  10. Review of a Certification Report - Continued

  11. Review of a Certification Report - Continued

  12. Review of a Certification Report - Continued ISO Class (Non Smoke Studies HEPA Filters Vented to outside Viable Air) LAFW 5 Yes Yes No CAI 5 Yes Ante Chamber No and Main Chamber CACI 5 Yes Ante Chamber Yes and Main Chamber BSC * 5 Yes Yes Yes *Alarm Testing

  13. Review of a Certification Report - Continued Secondary Engineering Controls  Non Viable Air  HEPA Filter Leak Testing  Air Changes Per Hour  Pressure Differential – Ante Room and Buffer Room

  14. Review of a Certification Report - Continued

  15. Certifications Review of a Certification Report - Continued ISO Class ACPH Pressure HEPA (Non Viable Differential Filters Air) Ante Room 8 20 0.02 – 0.05* Leak Tested Buffer Room 7 30 0.02 – 0.05* Leak Tested Buffer Room 7 30 < -0.01* Leak Tested – Hazardous ** * Inch Water Column ** CACI for compounding minimum of 12 ACPH

  16. Review of a Certification Report - Continued What else could be part of the report?  Viable Sampling  Air  Surface

  17. Review of a Certification Report - Continued • Are they Actionable or Non- Actionable? • Remediate immediately • What do we do with these results? • Trend

  18. Review of a Certification Report - Continued ISO Class AIR (cfu’s per SURFACE cubic meter) (cfu’s Per (1000 liters of Plate) air per plate) 5 >1 >3 7 >10 >5 8 >100 >100

  19. Review of a Certification Report - Continued • Identify to the genus level • Actionable organisms • Gram Negative Rods • Coagulase Positive Staph • Molds • Yeast

  20. Review of a Certification Report - Continued • Remediation • What is the source? • Personnel work practices • Cleaning procedures • Operational procedures • Air filtration efficiency

  21. Review of a Certification Report - Continued • Remediation • Immediate • Documentation • Resample

  22. Review of a Certification Report - Continued Trending of Bioburden Surface Sampling Trending 4.5 4 3.5 3 2.5 2 1.5 1 0.5 0 January 2017 July 2017 January 2018 July 2018 LAFW 1 Organism CFU's LAFW 2 Organism CFU's

  23. Questions?

  24. Certifications Dynamic Conditions

  25. Certifications Significance of Smoke Studies

  26. Certifications PEC VS SEC

  27. Questions?

  28. MEDIA FILLS AND GLOVE FINGER TESTS Clear documentation of Incubator temperatures, length of incubation

  29. MEDIA FILLS AND GLOVE FINGER TESTS Low, Medium and High-risk Media fill testing

  30. MEDIA FILLS AND GLOVE FINGER TESTS Glove Fingertip Sampling • New personnel • Annual or Semi-Annual • Random

  31. MEDIA FILLS AND GLOVE FINGER TESTS Glove Fingertip Sampling - Continued • Media • Technique • Incubation • Documentation

  32. Questions?

  33. CLEANING

  34. Cleaning • Importance of Cleaning Documentation • Accountability • OOS remediation • Training requirements • Initially (before compounding) • Annually/semi-annually (after media fill – DCA) • EVS / Housekeeping records • Common Observations

  35. Cleaning • Review of Cleaning Documentation • Non pharmacy staff housekeeping/EVS • Who’s watching? • EVS competencies • Shall be evaluated by qualified compounding expert

  36. Cleaning • PEC’s • Most critical • Cleaning and disinfecting of surfaces required • Must allow 30 seconds for sIPA to dry • Documentation • Common Deficiencies

  37. • PEC’s (continued) • Implement DCA SOP • Critical factors to consider • Dwell times: bleach < or = 1 min bact; 5-10 min for spores * • Effectiveness • RTU vs dilution *5,000ppm chlorine soln against C difficile spores- Reference: “American Journal of Infection Control” , August 2005, pgs 320-325.

  38. Cleaning • SEC’s • Work surfaces: daily • Ante room • Buffer rooms • SCA’s • Agent must not degrade ISO 7 or 8 air quality (USP <1072>)

  39. Cleaning • SEC’s (continued) • Floors • required to be done daily • ISO 7, ISO 8 and SCA’s • Follow SOP • Consider germicidal compatibility with surfaces (USP <797> appendix II)

  40. Cleaning • Factors to consider in choosing chemicals • Compatibility • Effectiveness • Toxic Residues

  41. Cleaning USP <797> Appendix II

  42. Cleaning • SEC’s (continued) • Monthly cleaning • Shelving, ceilings and walls • Careful consideration when cleaning ceiling

  43. Cleaning Cleaners VS Disinfectants Cleaner • Removal, usually with detergent and water or enzyme cleaner and water, of adherent visible soil, blood, protein substances, microorganisms and other debris from the surfaces, crevices, serrations, joints, and lumens of instruments, devices, and equipment by a manual or mechanical process that prepares the items for safe handling and/or further decontamination Source: www.cdc.gov/infectioncontrol/guidelines

  44. Cleaning Cleaners VS Disinfectants - Continued Disinfectant • Usually a chemical agent (but sometimes a physical agent) that destroys disease- causing pathogens or other harmful microorganisms but might not kill bacterial spores. It refers to substances applied to inanimate objects Source: www.cdc.gov/infectioncontrol/guidelines

  45. Cleaning Cleaners VS Disinfectants - Continued • Cleaning is a mechanical process • Cleaning prepares a surface for disinfection • Cleaning agents contain surfactants and/or detergents to remove dirt, debris and microbes • Many cleaning agents work to disinfect but does not replace the need of sIPA!

  46. Cleaning Cleaners VS Disinfectants - Continued • EPA Registered One-Step Disinfectant Cleaners • Cavicide • Pre-empt RTU • Vesophene llse • Sporicidin • Peridox RTU • Oxivir Five 16 concentrate • Spor - Klenz

  47. Cleaning Cleaners VS Disinfectants - Continued sIPA and sodium hypochlorite do not contain surfactants or detergents

  48. Cleaning Tools and Materials • Non-shedding wipers, mops and sponges • Dedicated to use in buffer rooms, ante-are and SCA’s • MUST NOT be removed from these areas

  49. Cleaning Tools and Materials – Continued • Considerations • EVS / Housekeeping bringing cleaners from outside • Are they diluting agents? • What is the stability of diluted agents?

  50. Cleaning Policy and Procedure • Who, What, Where, When, How • WHO cleans what? • EVS vs Compounding personnel

  51. Cleaning Policy and Procedure - Continued • Who, What, Where, When, How • WHAT? • Cleaning/disinfecting agents- RTU or dilution? • Include dilution instructions • Non shedding mops/ wipes • Mop handles

  52. Cleaning Policy and Procedure - Continued • Who, What, Where, When, How • WHERE? • Ante room • Buffer rooms • PEC’s • SCA’s

  53. Cleaning Policy and Procedure - Continued • Who, What, Where, When, How • WHEN? • Daily (floors and work surfaces) • Weekly (optional) • Monthly (ceilings, walls, storage bins, shelving) • Frequently (PEC’s)

  54. Cleaning Policy and Procedure - Continued • Who, What, Where, When, How • HOW? • Method of Cleaning • PEC’s : CAI’s, CACI’s, LAFW’s, BSC’s • SEC’s: floors, ceilings, walls, shelving, storage bins

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