All questions
Question 1
A pharmacy maintains compounding records electronically. During an inspection, an investigator requests a Compounding Record from 18 months ago. The pharmacy's system requires an IT password only the IT person can provide, and that person is unavailable. Which of the following best describes the compliance concern?
- There is no compliance concern because electronic records are inherently more secure and the inspector must wait for authorized access.
- There is no compliance concern because 18-month-old records are in an archival period not subject to immediate inspection.
- There is no compliance concern because the pharmacy has maintained the records; access timing is a logistical matter.
- Immediate access to compounding records is required during inspections; delayed access due to IT restrictions is a compliance issue. (correct answer)
Explanation: Compounding records must not only be retained but must be readily accessible for regulatory inspection. A system requiring unavailable personnel to provide access fails the accessibility standard. The pharmacy should have protocols ensuring records can be accessed promptly during inspections without dependency on a single point of failure. A is incorrect because electronic security features do not exempt the pharmacy from accessibility requirements. B is incorrect because records within the retention period must be accessible regardless of age. C is incorrect because accessibility during a regulatory inspection is a compliance requirement, not merely a logistical matter.
Question 2
During an inspection, an investigator finds that the CR for a batch of sterile eye drops does not include gloved fingertip sampling results for the preparing technician. The pharmacist explains the results were performed and filed in the personnel competency file. Which of the following best analyzes this situation?
- There is a compliance concern because all quality and safety documentation for a batch must be located in or cross-referenced by the CR.
- There is no compliance concern; under USP 797, gloved fingertip sampling results are personnel competency documentation and are appropriately maintained in personnel files rather than in the batch Compounding Record. (correct answer)
- The results must be cross-referenced in each individual batch CR to create an audit trail linking technician competency to the specific preparation.
- There is no compliance concern because gloved fingertip sampling is only required for pharmacists, not technicians.
Explanation: Under USP Chapter 797, gloved fingertip sampling is a personnel competency assessment that must be documented in personnel competency records. It is not a batch-specific quality test that belongs in the Compounding Record. Gloved fingertip sampling assesses whether a compounder's garbing and aseptic technique result in acceptable microbial counts on their gloves; this is ongoing personnel-level documentation, not a per-batch quality check. Maintaining these results in a personnel competency file is the correct practice. A is incorrect because not all pharmacy documentation is required to be in or referenced by the CR; personnel competency records are a distinct documentation category. C is incorrect because USP 797 does not require per-batch cross-referencing of gloved fingertip results in the CR; the results belong in personnel files. D is incorrect because gloved fingertip sampling applies to all sterile compounding personnel including technicians, not only pharmacists.
Question 3
A state board inspector requests all compounding records from the past 18 months. The pharmacist realizes that records from 14 months ago were inadvertently discarded during an office reorganization, even though they fall within the required retention period. Which of the following best analyzes the compliance concern and appropriate response?
- The pharmacist must disclose the records' destruction to the inspector, provide available records, and implement corrective measures to prevent future incidents. (correct answer)
- There is no compliance concern because the destruction was inadvertent; intent is required for a record destruction violation.
- The compliance concern is minor because only a portion of records was lost and the remaining records demonstrate general compliance.
- The pharmacist should inform the inspector that the records are temporarily unavailable and request additional time before disclosing that they were destroyed.
Explanation: Record destruction within the retention period -- even if inadvertent -- is a compliance violation. The pharmacist must be forthright with the inspector, disclose the situation, provide all available records, and document the circumstances. B is incorrect because intent is not required for a record-retention violation; the obligation is to have the records. C is incorrect because the severity of a compliance violation is not determined by the proportion lost; any destruction within the retention period is a violation. D is incorrect because the pharmacist knows the records were destroyed and must disclose this; creating a false impression through delay would compound the violation.
Question 4
A pharmacist prepares a batch of oral suspension and records the assigned BUD of 14 days and the required storage conditions in the CR, but does not include the rationale or reference source for the BUD assignment in the CR itself. That information is fully documented in the Master Formulation Record. Which of the following best describes the compliance concern?
- There is no compliance concern because recording the BUD itself is sufficient; storage conditions need not be included.
- The CR must include a full stability study citation justifying the BUD; recording the assigned BUD and storage conditions is insufficient.
- No compliance issue exists; USP 795 requires BUD and storage conditions in the CR, with rationale documented in the MFR. (correct answer)
- The BUD rationale must appear in both the MFR and the CR; documenting it only in the MFR is a documentation deficiency.
Explanation: Under current USP 795, the Master Formulation Record is the document that must contain the BUD reference source and the basis for BUD assignment. The Compounding Record is required to document the assigned BUD and storage requirements for each specific batch. Because both the assigned BUD and storage conditions are present in the CR, and the basis is appropriately located in the MFR, the pharmacy's practice is compliant. A is incorrect because while the BUD is present, storage requirements are also required in the CR -- though the scenario states both are present, making this a misdirection. B is incorrect because a full stability study citation in the CR is not required; the assigned BUD and storage conditions are the CR elements, with the reference basis residing in the MFR. D is incorrect because USP 795 does not require duplication of the BUD basis in both documents; the MFR is the appropriate location for that information.
Question 5
A state pharmacy law requires compounding records to be retained for five years. Federal DEA regulations require controlled substance records to be retained for two years. A pharmacy compounds both controlled and non-controlled preparations. What retention schedule applies?
- Two years for all compounding records, because federal law preempts state law on record retention.
- Two years for controlled substance compounding records and five years for non-controlled substance records.
- The pharmacy may choose which standard to follow since both requirements address the same subject.
- Five years for all compounding records, as the stricter state requirement takes precedence over federal law. (correct answer)
Explanation: When state law imposes a more stringent retention requirement than federal law, the pharmacy must comply with the state standard. Federal law sets a floor; states may impose more stringent requirements. Five years satisfies both the state requirement and the two-year federal minimum. A is incorrect because federal law does not preempt more stringent state record retention requirements. B is incorrect because applying different retention periods based on controlled versus non-controlled status misapplies the principle; the state's five-year requirement applies to all records in its jurisdiction. C is incorrect because there is no choice between competing standards; the more stringent requirement governs.
Question 6
A pharmacy receives a shipment of bulk API and begins using it in compounding without obtaining the Certificate of Analysis (CoA). During an inspection, the investigator asks for the CoA and the pharmacy cannot produce it. Which of the following best describes the compliance concern?
- Compounding without a CoA violates USP standards requiring verification of identity, purity, and potency of bulk drug substances. (correct answer)
- There is no compliance concern if the supplier is on the FDA's list of registered API manufacturers.
- There is no compliance concern because visual inspection of the ingredient is an acceptable substitute for a CoA.
- The compliance concern applies only to sterile compounding; non-sterile compounding does not require CoA documentation.
Explanation: USP compounding standards (795, 797) require pharmacies to obtain CoAs for bulk substances and verify ingredient identity and purity before use. The CoA is the primary documentation that the ingredient meets quality specifications. B is incorrect because FDA supplier registration confirms manufacturing facility compliance but does not substitute for a lot-specific CoA. C is incorrect because visual inspection cannot assess identity, purity, or potency. D is incorrect because CoA requirements apply to both non-sterile (USP 795) and sterile (USP 797) compounding.
Question 7
A software update inadvertently changes the timestamps on several historical CRs in a pharmacy's electronic system, making them appear to have been created after the preparations were actually compounded. The pharmacy discovers this after a routine audit. Which of the following best analyzes the pharmacy's obligations?
- The pharmacy should delete the affected records and recreate them with correct timestamps to restore accuracy.
- The pharmacy must document the error, preserve original records with explanations, and notify authorities if required, without altering or deleting the affected records. (correct answer)
- The pharmacy may correct the timestamps directly in the affected CRs because the purpose of the record is accuracy, and correcting an error restores accuracy.
- There is no compliance concern because timestamps are metadata, not substantive record content.
Explanation: Records must not be altered or deleted to conceal errors, even inadvertent ones. The appropriate response is to document the incident, preserve the original records with an explanatory annotation, and address the root cause. Deleting or altering records is falsification regardless of intent. A is incorrect because deleting and recreating records is falsification; the original records and the error must be preserved. C is incorrect because directly altering timestamps, even to restore accuracy, creates audit trail integrity concerns and may constitute falsification. D is incorrect because timestamps are substantive metadata establishing when records were created, which is material to compounding compliance.
Question 8
A pharmacy prepares the same formulation in multiple batches per week and proposes simplifying its CRs to reference the MFR rather than repeating all information. Which of the following best analyzes this proposal?
- The proposal is not permissible because each CR must be entirely self-contained with no references to other documents.
- The proposal is fully permissible because any information in the MFR need not appear in the CR at all.
- The proposal is permissible if batch-specific details like lot numbers and QC results are still included in each CR. (correct answer)
- The proposal is permissible only for non-sterile preparations; sterile compounding CRs must be entirely self-contained.
Explanation: CRs may reference MFRs for stable, standardized information. However, batch-specific data unique to each preparation must be captured in each CR. This batch-specific data is the core purpose of the CR and cannot be replaced by an MFR reference. A is incorrect because cross-referencing between CR and MFR is an accepted practice. B is incorrect because the CR must still capture all batch-specific information. D is incorrect because the principle applies equally to both sterile and non-sterile compounding.
Question 9
A recall is initiated for a bulk API lot used by a compounding pharmacy. The pharmacy needs to determine which batches used this ingredient lot and which patients received those preparations. Which compounding records are essential to this recall investigation?
- Only patient prescription records are needed; compounding records do not contain enough information for recall tracing.
- The MFR for the recalled ingredient is sufficient to identify all affected preparations.
- Compounding records linking ingredient lot numbers to batch numbers and dispensing records to identify affected patients. (correct answer)
- Recall investigation is the manufacturer's responsibility; the pharmacy's records are not relevant.
Explanation: An effective recall investigation requires a complete documentation chain: the CR must link the recalled ingredient lot number to the specific batch number, and dispensing records must link that batch number to specific patients. Without this chain, the pharmacy cannot identify affected patients. A is incorrect because patient prescription records alone do not identify which ingredient lots were used; the CRs provide this link. B is incorrect because the MFR contains the formula template but does not document which ingredient lots were used in each batch; the CR provides that. D is incorrect because the pharmacy's records are essential to retail-level recall investigation.
Question 10
A pharmacy technician handling a hazardous drug under USP Chapter 800 experiences a minor spill during preparation. She cleans it up using the spill kit and returns to work without reporting the incident or creating any documentation, believing the spill was too small to require documentation. Which of the following best analyzes her compliance?
- The technician's actions are compliant because small spills that are promptly cleaned up do not require documentation.
- The technician's actions are compliant because proper cleanup is the substantive compliance requirement; documentation is secondary.
- Documentation is required only if the spill exceeded a threshold volume defined by USP 800.
- The technician's actions are non-compliant; all hazardous drug spills, regardless of size, must be documented under USP 800. (correct answer)
Explanation: USP Chapter 800 requires documentation of all hazardous drug spills regardless of size. This documentation is essential for tracking potential personnel exposure, identifying systemic problems, and satisfying occupational health and safety obligations. A is incorrect because USP 800 does not exempt small spills from documentation requirements. B is incorrect because documentation is not secondary to cleanup; it is an independent required element of the spill response. C is incorrect because there is no volume threshold exemption from spill documentation requirements under USP 800.
Question 11
During an inspection, an investigator finds that a pharmacy's Compounding Records do not include the lot numbers of the ingredients used. The pharmacist states that lot numbers are available in the pharmacy's purchase records. Which of the following best describes the compliance concern?
- There is no compliance concern because purchase records are sufficient to trace ingredient lot numbers.
- There is no compliance concern because lot number tracking is only required for controlled substance ingredients.
- This is a minor documentation concern that can be corrected prospectively; past records are not affected.
- This is a compliance violation; lot numbers must be directly documented in the Compounding Record. (correct answer)
Explanation: Including ingredient lot numbers in the CR is a core requirement for traceability. The purpose is to enable rapid identification of the specific lots used in a preparation -- essential for recall investigations. Requiring cross-referencing with separate purchase documents defeats this purpose. A is incorrect because lot numbers must be in the CR itself; availability elsewhere is not a substitute. B is incorrect because lot number tracking applies to all ingredients, not only controlled substances. C is incorrect because past records that are incomplete constitute existing violations; they cannot be corrected prospectively.
Question 12
A 503B outsourcing facility is inspected by the FDA. The investigator requests compounding records for a batch distributed six months ago. The facility provides the CR but cannot locate the MFR because a server crashed and the backup failed. Which of the following best analyzes the facility's situation?
- There is no compliance concern for the missing MFR because the CR itself contains sufficient information to reconstruct it.
- There is no compliance concern because the MFR is only required at the time of compounding, not for subsequent inspections.
- The missing MFR is a minor concern because the CR is the primary document and the MFR is supplementary.
- The missing MFR is a significant compliance issue as 503B facilities must maintain complete batch records under cGMP requirements. (correct answer)
Explanation: 503B outsourcing facilities are subject to cGMP requirements including comprehensive document control obligations. The MFR is not supplementary; it is an essential component of the batch documentation system. A server failure resulting in permanent document loss demonstrates failure of document control and backup systems, both of which are cGMP findings. A is incorrect because the CR and MFR serve different purposes and the CR alone cannot reconstruct the MFR's complete specifications. B is incorrect because records must be retained and accessible throughout the applicable retention period. C is incorrect because both the MFR and CR are required compounding documents of equal importance.
Question 13
A pharmacy has used the same MFR for a topical cream formulation for three years. An updated edition of USP 795 changes the BUD requirements for this formulation category, but the pharmacist continues using the old MFR without updating it. Which of the following best analyzes the compliance concern?
- There is no compliance concern because the MFR was accurate when created and changes need not be made until the next scheduled review.
- The pharmacy must update the MFR to reflect current USP 795 standards to ensure compliance with BUD requirements. (correct answer)
- There is no compliance concern because USP 795 standards are advisory for non-sterile compounding and pharmacies may use any reasonable BUD.
- The compliance concern applies only if the new BUD is shorter than the old one; if the new BUD is longer, there is no issue.
Explanation: MFRs must be updated when applicable standards change. An MFR based on superseded USP standards generates CRs with non-compliant BUDs. The pharmacy has an ongoing obligation to maintain current and accurate MFRs. A is incorrect because there is no grandfather provision for outdated formulation standards; the obligation to comply with current standards is continuous. C is incorrect because USP 795 standards are incorporated by reference into most state pharmacy laws and are enforceable. D is incorrect because the compliance obligation applies regardless of whether the new BUD is shorter or longer.
Question 14
Which of the following best describes the purpose and required content of a Master Formulation Record (MFR) in compounding practice?
- The MFR contains the formula, instructions, BUD, storage, and quality control for compounded preparations. (correct answer)
- The MFR is a patient-specific record documenting the dispensing of a compounded preparation to an individual patient.
- The MFR is the DEA-required document for tracking controlled substance ingredients used in compounding.
- The MFR is an optional reference document used only for sterile compounding preparations under USP 797.
Explanation: The MFR is the foundational document for each unique compounded preparation, containing the complete formula and specifications: preparation name, strength, dosage form, all ingredients and quantities, equipment and container specifications, preparation instructions, BUD assignment and its basis, storage conditions, QC procedures, and applicable safety information. Individual Compounding Records reference the MFR for each batch. B is incorrect because patient-specific information is captured in the Compounding Record or prescription record, not the MFR. C is incorrect because the MFR is a pharmacy compounding quality document, not a DEA instrument. D is incorrect because MFRs are required for all compounded preparations under both USP 795 and 797, not only sterile preparations.
Question 15
Under USP Chapter 797, which of the following information is most critical to document in environmental monitoring records for a sterile compounding cleanroom?
- The names of all personnel who entered the cleanroom on each day.
- The cost of each environmental monitoring test performed.
- Whether the pharmacy's cleanroom was inspected by the state board within the past year.
- Sampling locations, dates, methods, CFU counts, action levels, and corrective actions for exceeded levels. (correct answer)
Explanation: USP 797 requires environmental monitoring records to document specific sampling locations, dates, methods, and results including CFU counts, whether action levels were exceeded, and corrective actions taken. This creates a longitudinal record of cleanroom environmental quality. A is incorrect because personnel entry logs are separate and are not the critical content of environmental monitoring records. B is incorrect because cost information is not a required element. C is incorrect because state board inspection history is not part of environmental monitoring records.
Question 16
A compounding pharmacy's CR for a batch of topical pain cream lists the verifying pharmacist but does not identify the technician who prepared the compound. Which of the following best applies?
- This is a recordkeeping deficiency; the compounding record must include the technician's identity. (correct answer)
- This is acceptable because the pharmacist's verification encompasses responsibility for the preparation process.
- This is acceptable because technician identification is only required for sterile compounding under USP 797.
- This is acceptable as long as the pharmacy's general personnel log shows which technician worked that day.
Explanation: The CR must identify both the compounder who prepared the batch and the pharmacist who performed the final verification. These are separate and distinct documentation requirements serving different accountability purposes. B is incorrect because the pharmacist's verification responsibility does not eliminate the separate documentation requirement for the compounder's identity. C is incorrect because compounder identification is required for both non-sterile (USP 795) and sterile (USP 797) compounding records. D is incorrect because a general personnel log does not satisfy the specific requirement to document who performed each particular compounding activity.
Question 17
Which of the following records must a pharmacy maintain related to the periodic certification of a laminar airflow workbench used for sterile compounding?
- Certification records including date, certifier qualifications, test results, and pass/fail status. (correct answer)
- Only the pass or fail result; specific test values are optional.
- Equipment certification records are the certifying contractor's responsibility; the pharmacy need not maintain copies.
- Equipment certification records are only required when the equipment fails certification.
Explanation: The pharmacy must maintain detailed certification records for cleanroom equipment. These records must document the date, certifier information, actual test results including airflow velocities and particle counts, acceptance criteria, and the next certification due date. B is incorrect because specific test values are required, not merely the pass or fail outcome. C is incorrect because the pharmacy bears the record-retention obligation; contractor records are not a substitute. D is incorrect because certification records must be maintained whether equipment passes or fails; failure records are particularly important as they trigger corrective action requirements.
Question 18
Under USP Chapter 797, which of the following represents required personnel competency assessments that must be documented in personnel records for sterile compounding?
- Successful completion of media fill testing demonstrating aseptic technique, gloved fingertip sampling with acceptable results, and documented training in garbing procedures. (correct answer)
- Annual renewal of the pharmacist license, which satisfies all personnel competency documentation requirements for sterile compounding.
- A written examination covering USP 797 content, which is the sole required competency assessment.
- Proof of at least one year of employment in a sterile compounding environment.
Explanation: USP 797 requires documented personnel competency assessments including media fill testing to demonstrate aseptic technique, gloved fingertip sampling after garbing to assess contamination risk, and documented training in donning and doffing personal protective equipment. These must be performed initially and repeated periodically. B is incorrect because pharmacist license renewal is a state licensure matter unrelated to sterile compounding competency documentation. C is incorrect because a written examination alone is insufficient; procedural competency assessments including media fills and gloved fingertip sampling are required. D is incorrect because work experience alone does not satisfy the documented competency assessment requirement.
Question 19
Under USP Chapter 800, which of the following is a required record a pharmacy must maintain related to hazardous drug handling?
- A daily log of the names of all patients receiving hazardous drug therapy.
- Spill occurrence records including date, drug, amount, personnel, response, and cleanup procedures. (correct answer)
- Records of all chemotherapy prescriptions dispensed in the past five years.
- A log of all patients who declined to receive hazardous drug therapy.
Explanation: USP Chapter 800 requires documentation of all hazardous drug spill occurrences. The record must capture the date, drug, quantity, who was present, how the spill was managed, and whether any personnel were potentially exposed. This enables post-incident review, regulatory reporting if required, and medical surveillance follow-up. A is incorrect because patient-level treatment records are not a USP 800 HD handling recordkeeping requirement. C is incorrect because a five-year prescription archive is not specifically required by USP 800 HD handling documentation provisions. D is incorrect because patient refusal of hazardous therapy is a clinical matter, not a USP 800 compounding and handling record.
Question 20
A pharmacist performs weight checks and pH testing as quality control measures on a non-sterile compounded preparation. Where must the results of these QC tests be documented?
- QC results are optional documentation and need not be formally recorded unless a problem is detected.
- QC results should be documented only in the patient's prescription record.
- QC results must be documented in the Compounding Record for the batch, including the specific tests performed, results obtained, and whether results met the acceptance criteria. (correct answer)
- QC results are recorded only in the MFR, which serves as both the formula template and the quality control log.
Explanation: QC test results must be documented in the CR for each batch, capturing what tests were performed, the results obtained, and whether those results met the acceptance criteria defined in the MFR. A is incorrect because QC documentation is a required element of the CR, not optional. B is incorrect because QC results belong in the compounding records, specifically the CR, not the patient prescription record. D is incorrect because the MFR contains the QC procedure specifications while the CR documents the actual QC results for each specific batch.