New Repackaging Rules May Violate Current Regs: Comments

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Four groups representing those working in long-term care (LTC) pharmaceutical settings say that an FDA draft guidance on repackaging could impose inappropriate new requirements that may conflict with existing regulation. Oblivious to the voluntary nature of FDA guidances, a statement from the Senior Care Pharmacy Coalition (SCPC), American Society of Consultant Pharmacists, American Health Care Association, and the National Center for Assisted Living (includes link to letter to FDA) says that the agency “must recognize the demands of other regulators that control LTC for our nation’s vulnerable seniors, and avoid imposing inappropriate new burdens on complex and already well-controlled systems. FDA must also recognize that the practice patterns of LTC pharmacies are truly those of a professional pharmacy, not commercial product manufacturers, wholesalers, or repackagers.”

SCPC president Alan Rosenbloom says in the statement that “FDA is contemplating a guidance document that would needlessly limit or require outsourcing of packaging activities that currently occur within LTC pharmacies, driving up cost and waste in the LTC system and potentially risking care for patients. For example, before dispensing medication many LTC pharmacies currently pre-package drug products from bulk into individual blister cards. FDA’s proposed guidance would arbitrarily limit the quantity that pharmacies could package, even if the pharmacy had justification for the quantity based on its dispensing patterns and predictions.”

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