Professional Documents
Culture Documents
Bernadette Belgado, Pharm.D. UF Health at Jacksonville West Paul, M.D., Ph.D. Wake Med Health
Objectives
Explain the reasons for medication shortages Discuss drug shortage legislation
No disclosures
Raw materials
http://www.fda.gov/Drugs/DrugSafety/DrugShortages/ucm277626.htm
Raw Materials
2008 heparin recall Over 200 patients died as a result of contaminated heparin with over-sulfated chondroitin Raw materials plant in China was never inspected by the FDA Foreign markets supply 80% of raw materials Increased quality awareness and regular inspection of foreign raw materials plants mandated by FDA
This family-owned workshop in Xinwangzhuang, a village in Juangsu Province, China, processes pig intestines for heparin
http://www.nytimes.com/2008/03/30/weekinreview/30bogdan
http://www.fda.gov/Drugs/DrugSafety/DrugShortages/ucm277626.htm
Drug Manufacturers
Generic injectable drugs (73%) Lack of redundancy in manufacturing processes
71% of market controlled by 3 manufacturers
Drug Manufacturers
Lack of sterility
http://www.fda.gov/Drugs/DrugSafety/DrugShortages/ucm277626.htm
Regulatory Issues
New FDA Commissioner in 2009 Enforcement and regulatory activities spiked from 20092011 Warning letters to pharmaceutical manufacturers regarding quality increased 42% in 2009 and up 156% in 2010. Simultaneously shutting down 4 major generic manufacturers of generic medications
30% of decrease in manufacturing capacity
Number of letters
Regulatory Issues
FDA increased enforcement of Unapproved Drugs Drug Evaluation & Safety Initiative (DESI)
Drugs approved or deemed identical, related, or similar (IRS) between 1938 1962
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM070290.pdf http://www.ashp.org/DrugShortages/NotAvailable/Bulletin.aspx?id=602
Generic availability erodes selling prices by ~ 85-90% after a year Average selling price (ASP) + 6% MMA limits - Manufacturers only allowed to increase prices by 6% biannually
Cabner BA. N Engl J Med 2011 365:2147-49
http://www.fda.gov/Drugs/DrugSafety/DrugShortages/ucm277626.htm
Speculation that fewer generic manufacturers are a direct result of the GPO structure
http://www.fda.gov/Drugs/DrugSafety/DrugShortages/ucm277626.htm
Health Systems
Heparin recall
FDA Solutions
Allow temporary importation of foreign equivalent
Propoven from UK for propofol shortage Phenylephrine from UK Sodium Bicarbonate from Australia