Medicines Act 1968 - related to extemporaneous prep
Sections 7 & 8
- manufacture or assemble any medicinal product
- sell, supply or export any medicinal product
- procure the manufacture or assembly of any medicinal product for sale, supply or exportation
Section 9
Does not apply to doctors or dentists
Section 10
Exemptions for pharmacists
What is the orange Guide (1971)
Breckenridge Report (1976)
Increasing frequency of IV administrations plus increasing complexity of reconstitution and administration requirements, plus increasing complexity of drug regimens equals increased potential for error
Conclusion – reconstitute centrally within the hospital pharmacy
Result – CIVAS/TPN/Chemotherapy
Farwell Report (1995)
QAAPS (5th Edition)
Quality Assurance of Aseptic Preparation Services
- NHS response to loss of Crown Immunity and to MCA “Guidance to the NHS on the licensing requirements of the Medicines Act 1968.”
- Nationally agreed quality standards for preparation of aseptic products within the NHS
Supervision & Responsible Pharmacist Regulations
Section 10 exemption vs. MHRA Specials licence
Specials manufacturer licence
Preparation by any suitably trained person
Extended expiry
Batches prepared for stock
Final check and release must be done by separate people (any registered)
External MHRA inspection
Section 10 exemption
Prepared or directly supervised by a pharmacist
Max 7 day expiry
Prepared against a prescription
Final check and release done together by any suitably qualified person
What is a quality management system?
Quality Management System (QMS) –
A structured system that documents processes, procedures, and responsibilities for continuously delivering high-quality products and services that meet regulatory and customer requirements.
The objective of a quality management system is to provide a framework that improves communication, collaboration, and consistency while also reducing waste, and promoting continuous improvement.
What is a quality management system for pharmaceutical products?
Manufacturers must make medicines that are fit for their intended use and do not put patients at risk due to inadequate safety, quality or efficacy
The manufacture of pharmaceutical products requires the establishment and implementation of an effective ‘quality management system’ (QMS)’
The basis of an effective QMS in the production of pharmaceutical products must include the concepts of :
Good Manufacturing Practice (GMP)
Quality Control (QC)
Quality Assurance (QA)
What do I need to know about PQS?
Applicants to become a Qualified Person (QP) will be expected to demonstrate a thorough understanding of the following:
What is Good manufacturing practice (GMP)?
Products must:
- be of consistent high quality
- be appropriate to their intended use
- meet the requirements of the MA
What is Good manufacturing practice (GMP)
Legal framework?
What is Quality Control?
QC is part of Good Manufacturing Practice which is concerned with:
- Inspecting, Sampling, and Testing the final product for adherence to specified quality standards.
- Products are examined and tested against predetermined criteria to identify and correct deviations from quality standards.
- Products may be tested during different stages of manufacture.
What is Quality Assurance?
How do we design an effective PQS?
How do you know your PQS is working?
Key Performance Indicators
- Statistical Process Control
- Trends
- People surveys
- Deviations
- Opinions
- Audits
- Customer Feedback
Limitations of PQS
Specials and unlicensed medicines
Licensed vs Specials - Legal differences
Legal Matters
Conditions of section 10 exemptions
As a pharmacist you must have:
Bona fide unsolicited order
Product is formulated for a specified patient in accordance with the requirement of a practitioner registered in the UK
As a pharmacist you must be sure:
- Product is for use by your individual patients on their direct personal responsibility
broadly includes any form of extemporaneous dispensing, including TPN compounding, IV additives and cytotoxic reconstitution
- If a ‘special’ is manufactured in the UK, the manufacturer must hold a manufacturer’s (specials) licence from the MHRA and / or an Investigative Medicinal Products (Clinical Trials) Licence
- Pharmacies must have the appropriate equipment and facilities available to produce a high quality, safe product
A ‘special’ may not be advertised
Risk assessment: what’s on it?
It should also include (GphC standard)
formula from a recognised source e.g.
- Pharmacopeia
- Method validation
- Calculation verification
- Need/use of specialist equipment
- Contamination & hygiene measures
product-specific risks
- Suitability of premises
- Staff skills / knowledge / training / competence
Essential records must be kept
A record should be kept, including as a minimum
- name of product;
- specification;
- prescriber’s name, if appropriate;
- manufacturer and (if different) supplier;
- date ordered;
- quantity ordered;
- batch number received