Like time, regulatory compliance waits for no one. Following official enforcement of USP General Chapter <800> Hazardous Drugs—Handling in Healthcare Settings on December 1, 2019, all institutions handling hazardous drugs (HDs) must meet the standards and will be held liable through federal, state, and accrediting bodies.
With the effective date quickly approaching, it is crucial that institutions facilitate collaboration and engagement among all disciplines at risk for HD exposure. Critical to USP <800> compliance is the development and maintenance of an organization-specific HD list to ensure safe handling throughout the health system. (The history and development of USP <800> is discussed in the SIDEBAR.)
The University of North Carolina (UNC) Health Care System is a not-for-profit, academic medical system whose flagship campus, UNC Medical Center (UNCMC), located in Chapel Hill, comprises six hospitals. The NC Cancer Hospital, serviced by the UNC Lineberger Comprehensive Cancer Center, is one of 49 National Cancer Institute-designated centers in the United States and is the only public comprehensive cancer center in the state of North Carolina.
Within our department, several pharmacy operational areas store, compound, dispense, and transport HDs, although the vast majority of HDs are prepared in the Cancer Hospital Infusion/Inpatient Pharmacy (CHIP). To ensure HD safety throughout the medication-use process, UNCMC is committed to USP <800> compliance. As such, developing an entity-specific HD list is a critical priority. While the methodology for developing the HD list is being utilized across our entire health care system, the HD list described is specific to UNCMC.
Conduct a Compliance Assessment
Protecting our employees and meeting USP <800> requirements were the driving forces behind the pharmacy department’s decision to conduct a baseline USP <800> compliance assessment. This assessment identified areas of noncompliance, including outdated policies and procedures (P&Ps) for the institutional risk assessment review process and the lack of an up-to-date, entity-specific HD list.
To address these areas of noncompliance, an interdepartmental USP <800> work group was established with the mandate of ensuring key stakeholder involvement, identifying risks, and supporting continual compliance efforts through ongoing planning. In addition to pharmacy, the work group included leadership from environmental health and safety (EHS), epidemiology, operational excellence, and nursing.
Assess Existing Institutional P&Ps
The pharmacy department is well positioned to assume ownership of developing and maintaining the institution-specific HD list. All UNCMC pharmacy operational leaders who handle HDs collaborated to address existing gaps in our outdated HD list. The group revised the HD list to incorporate the 2016 NIOSH updates and information from pertinent literature for drugs handled by the facility.
UNCMC risk categories for drug classification were organized into the following two categories:
Developing clear processes to assess drug risk ensures that all drugs will be evaluated in a uniform manner moving forward. To determine the classification for the NIOSH Table 2 drugs as either hazardous or reproductive-risk, we developed an internal risk assessment algorithm (see FIGURE 1). Classifying HDs into two categories for the institutional HD list both met the USP <800> requirement and simplified the HD management process across UNCMC’s medication-use system. The simplified process was developed following recommendations made by the institutional multidisciplinary USP <800> working group. This working group determined that redundant P&Ps for HD handling across disciplines would be significantly reduced by developing and incorporating these classifications into the electronic health record (EHR). Integrating the two designated classifications (hazardous or reproductive risk) into the EHR and on printed medication labels provided clarity to pharmacy, nursing, and support staff who frequently handle HDs.
Prior to operationalizing the category changes, proposals were approved by appropriate hospital pharmacy leadership, a clinical informatics group, and the collaborative USP <800> work group. Assignment into either risk category, HD or reproductive-risk, dictates the recommended procedures to follow when handling, preparing, administering, and disposing of each drug listed.
HD Classification and Assessment of Risk
An HD risk assessment and subsequent risk category assignment is routinely performed during the review process for any new drug being considered for formulary addition. FIGURES 1 and 2 outline the approach used by UNCMC to assess the risk of new drugs considered for formulary addition and the associated handling recommendations. The risk assessment requires the following steps:
The risk classification of each drug on the HD list is reassessed annually by the pharmacy department, and the list is updated each time a new HD is added to formulary.
Implementation, Education, and Staff Training
Ensuring frontline staff is aware of and knowledgeable about institutional HD list changes requires deliberate, frequent communication. At UNCMC, the HD list is stored on an internal shared drive that is accessible to all personnel and embedded within our HD P&P. While the policy area is designated as EHS, the content applies to UNCMC as a whole. Various departments, including pharmacy, are responsible for implementing this policy and reviewing the requirements at least annually.
The pharmacy department is accountable for the list, which is available in the TABLE. Pharmacy oversees the following actions regarding HD list evaluation and changes:
When considering a drug for formulary addition, the P&T committee utilizes a checklist to ensure that the appropriate committees are made aware of changes. All drugs approved for formulary use at UNCMC go through the pharmacy informatics committee to ensure the drug is built appropriately within the EHR medication list. When the P&T committee deems a drug to be a hazardous or reproductive risk, the pharmacy informatics team is responsible for adding a banner that prints at the top of the drug label designating it as such. In addition, administration instructions are configured to auto-populate, instructing the handling employee as to which PPE to don and referring them to the appropriate HD policy.
FIGURES 3 and 4 provide visual examples of the UNCMC drug labels for drugs deemed hazardous and reproductive risk, respectively. Any changes in the hazardous risk status of existing medications are brought through the pharmacy informatics committee for approval and implementation of any necessary changes.
An overview of the HD list, including a review of the risks associated with handling HDs, is included in the training for all new personnel. We evaluate staff knowledge and document competency after the first training session and then annually thereafter for all personnel prior to permitting independent HD handling. All P&P changes are communicated to staff verbally via in-person meetings, through email communications, or by signage posted in the work area.
Pharmacy personnel play a significant role in handling, preparing, distributing, and disposing of hazardous medications throughout the medication-use process. Thus, pharmacy departments have a responsibility for implementing P&Ps that are designed to protect the safety of those handling hazardous medications, as well as the environment.
It is reasonable for pharmacy departments to assume accountability for maintaining the institution-specific HD list in a manner that is compliant with USP <800> standards, and for ensuring that the institution is carefully and conservatively assessing any medications new to the formulary. The creation of a pharmacy operational work group to oversee gap assessment, development of risk categories and a risk assessment, and implementation of a standardized process to review new drugs for hazardous risk is an effective method of identifying and addressing compliance gaps.
Pharmacy departments must take an active role in continually reviewing, educating, and training personnel on their institution’s specific HD list to ensure successful USP <800> compliance, and ultimately, to keep their staff and patients safe.
Elissa King, PharmD, MS, BCPS, is the clinical manager of pharmacy for the offsite infusion centers at the University of North Carolina (UNC) Medical Center. She earned her Doctor of Pharmacy Degree from the University of Maryland and her Master of Science degree with an emphasis in health-system pharmacy administration from the UNC Eshelman School of Pharmacy while completing her 2-year health system pharmacy administration residency at UNC Hospitals. Elissa is a board-certified pharmacotherapy specialist. She maintains active professional involvement as a new practitioner mentor for the Carolina Association of Pharmacy Students and within the American Society of Health-System Pharmacists.
Samuel M. Eberwein, PharmD, MS, BCPS, is the clinical manager of pharmacy for the sterile products area, perioperative services, and special formulations at the University of North Carolina (UNC) Medical Center. He earned his Doctor of Pharmacy degree from Campbell University and his Master of Science degree with an emphasis in Health-System Pharmacy Administration from the UNC Eshelman School of Pharmacy while completing his 2-year Health System Pharmacy Administration residency at UNC Hospitals. Sam is a board-certified pharmacotherapy specialist. He maintains active professional involvement in ASHP.
The History of NIOSH and the Development of USP <800>
Evidence documenting the immediate and long-term adverse health effects of hazardous drug (HD) exposure has led to the development of the United States Pharmacopeia (USP) General Chapter <800> Hazardous Drugs—Handling in Healthcare Settings. USP <800> contains the first enforceable standards, developed to significantly reduce the risks of HD exposure.1 The standards were written to protect health care workers, patients, and the environment from the dangers associated with handling HDs.
Chapter <800> references the NIOSH List of Antineoplastic and Other Hazardous Drugs to define specific criteria for drugs and dosage forms exhibiting hazardous or toxic properties.1,2 Originally developed in 2010, the NIOSH list has been updated every 2 years, with the 2018 update expected to be released in December 2019.2 The NIOSH list divides HDs into three overarching categories based on exposure risks2:
Table 1: Antineoplastic drugs
Table 2: Non-antineoplastic drugs
Table 3: Non-antineoplastic drugs posing reproductive risk
Non-antineoplastic drugs in Table 2 are defined as exhibiting one or more of the following properties2:
NIOSH utilizes these six properties as the criteria to determine whether a non-antineoplastic drug is considered hazardous.
Per USP <800>, all drugs listed in NIOSH Tables 1, 2, or 3 handled by the institution must be addressed and categorized within an internal HD list.1 Any new medication not addressed by the most current NIOSH list, including investigational drugs, must be analyzed using the six NIOSH criteria to determine if the drug is hazardous.
In certain circumstances, institutions can perform an assessment of risk to classify HDs and specific dosage forms requiring less stringent requirements depending on how they are handled.1 An assessment of risk cannot be conducted for drugs listed on the NIOSH list as HD active pharmaceutical ingredients or antineoplastic drugs requiring HD manipulation.1
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