January 11, 2017
On December 28th, the FDA issued two draft guidances that describe FDA’s proposed policies regarding the compounding and repackaging of radiopharmaceuticals for human use by state-licensed nuclear pharmacies or federal facilities, and outsourcing facilities. According to FDA, "the policies proposed in the draft guidances attempt to strike an important balance between patient access to radiopharmaceuticals compounded or repackaged by state-licensed nuclear pharmacies, federal facilities, and outsourcing facilities, and the risks that such unapproved drugs present to patients."
The first draft guidance, "Compounding and Repackaging of Radiopharmaceuticals by State-Licensed Nuclear Pharmacies," explains that, under current law, radiopharmaceuticals compounded or repackaged by state-licensed nuclear pharmacies and federal facilities are subject to all applicable provision of the FD&C Act related to the production of drugs. However, FDA recognizes that state-licensed pharmacies and federal facilities sometimes compound or repackage radiopharmaceuticals for patients who need them without obtaining FDA approval or meeting certain other requirements.
The second draft guidance, "Compounding and Repackaging of Radiopharmaceuticals by Outsourcing Facilities," highlights that section 503B of the Federal Food, Drug, and Cosmetic Act applies to the compounding of radiopharmaceuticals, but not to radiopharmaceuticals that are repackaged, by outsourcing facilities. It proposes how FDA would apply the conditions of section 503B to radiopharmaceuticals compounded by outsourcing facilities. This guidance also specifies the conditions under which FDA does not intend to take action for violations of provisions of the FD&C Act regarding new drug approval requirements and labeling with adequate directions for use against an outsourcing facility that repackages radiopharmaceuticals.
SNMMI has submitted comments on other general guidances related to compounding, but has long awaited specific guidance for radiopharmaceuticals. The society also recently provided recommendations to USP on sterile compounding of radiopharmaceuticals. SNMMI commends the FDA for the release of the new guidances and will submit comments to FDA. The comment period for each of the draft guidances closes in 60 days. To submit your own comments, visit regulations.gov.