BIO 221 REGULATORY AFFAIRS COMPLIANCE IN BIOMANUFACTURING ASSIGNMENT 7 Heparin Mix-Up The following safety alert was posted by FDA on its MedWatch site. Heparin Sodium Injection 10,000 units/mL, and HEP-LOCK U/P 10 units/mL Medication Errors Audience: Pharmacists, neonatology/pediatric healthcare professionals [Posted 02/07/2007] Baxter and FDA notified healthcare professionals of the potential for life threatening medication errors involving two Heparin products, Heparin Sodium Injection 10,000 units/mL, and HEP-LOCK U/P 10 units/mL. Baxter is aware of fatal medication errors that have occurred when two Heparin products with shades of blue labeling were mistaken for each other. Three infant deaths resulted when the higher dosage Heparin Sodium Injection 10,000 units/mL was inadvertently administered instead of the lower dosage of HEPLOCK U/P 10 units/mL. The currently marketed 1 mL vials of both Heparin products use blue as the prominent background color on their labels. Also read below the Safety Alert issued by Baxter and the news article about the use of heparin of the wrong concentration. Consider the following fictitious scenario. Baxter’s attorney comes to your desk in the Office of Regulatory Affairs for Baxter. He seems rather stressed. He asks if you could come up with reasons that Baxter had acted appropriately when it first became aware of fatal medication errors with its heparin products. He asked you if you could communicate them to him when they are ready. To help clarify your thoughts on this matter you wrote down a list of questions: 1. Did Baxter address the issue when it first arose? 2. What were the five points that Baxter, in its safety alert of February 6 2007, reminded healthcare professionals that they should do? 3. Does the labeling itself appear sufficiently clear to differentiate the two doses? 4. Was Baxter thinking of how the packaging and labels could be changed so as to more readily distinguish the two products and reduce the risk of future medication errors? How would you answer these questions and why would you answer each of them that way? IMPORTANT MEDICATION SAFETY ALERT BAXTER HEPARIN SODIUM INJECTION 10,000 UNITS/ML AND HEPLOCK U/P 10 UNITS/ML February 6, 2007 Dear Healthcare Provider: This important safety information concerns the potential for life threatening medication errors involving two Heparin products: • Heparin Sodium Injection 10,000 units/mL • HEP-LOCK U/P 10 units/mL Baxter is aware of fatal medication errors that have occurred when two Heparin products with shades of blue labeling were mistaken for each other. Three infant deaths resulted when the higher dosage Heparin Sodium Injection 10,000 units/mL was inadvertently administered instead of the lower dosage of HEP-LOCK U/P 10 units/mL. The currently marketed 1 mL vials of Heparin Sodium Injection 10,000 units/mL and the HEP-LOCK U/P 10 units/mL use shades of blue as the prominent background color on their labels. Healthcare professionals should be reminded to: • Never rely on color as a sole indicator to differentiate product identity. • Always carefully read the product label to verify that the correct product name and strength have been selected. • Always carefully review both the drug name and dose on the label before dispensing and administering these products. • Double-check your inventory as soon as possible, to ensure that there is no mix-up of the products. • Notify all staff of the potential for errors in dispensing and administering these products. It is advised that you provide color photographs (see below) to staff to assist in their understanding of the product similarities. To assist you in your review of these two labels, a side-by-side color photograph is provided below: Baxter provides bar codes on its product labels and is considering ways to differentiate the packaging and labels to decrease the risk of medication errors. While Baxter seeks to more clearly differentiate the appearance of these two products, the Food and Drug Administration (FDA) suggests that your institution review your medication identification and administration policies and procedures. Please ensure that all staff responsible for the dispensing and administration of Heparin Sodium Injection and HEP-LOCK U/P products are aware of these medication errors and that the staff are familiar with your policies and procedures. If you have any questions regarding this letter, please contact Baxter at 1-800-ANA-Drug (1800-262-3784). FDA requires hospitals and other user facilities to report deaths and serious injuries associated with the use of drugs and medical devices. If you suspect that a reportable adverse event related to Baxter’s Heparin Sodium Injection and HEP-LOCK U/P has occurred, please report the information to Baxter and to MEDWatch at 1-800-FDA-1088 or online at www.fda.gov/medwatch/report.htm. Sincerely, [ Signature ] Jonathan Deutsch, M.D. Medical Director Anesthesia and Critical Care Baxter Healthcare Corporation DENNIS QUAID'S TWINS AMONG THREE NEWBORNS GIVEN DRUG OVERDOSE Wednesday, November 21, 2007 AP Dennis Quaid and his wife, Kimberly Buffington LOS ANGELES — The newborn twins of actor Dennis Quaid were among three patients accidentally given 1,000 times the common dosage of a blood thinner, but hospital officials said Tuesday that none of the overdose victims had suffered any ill effects. Cedars-Sinai Medical Center declined to identify the patients, but a representative for the actor told The Associated Press that they included the two-week-old children of Quaid and wife Kimberly, Thomas Boone and Zoe Grace. "Dennis and Kimberly appreciate everyone's thoughts and prayers and hope they can maintain their privacy during this difficult time," Quaid's publicist, Cara Tripicchio, said in a statement Tuesday. The hospital declined to release the patients' conditions Wednesday, citing privacy laws. The celebrity Web site TMZ.com, which first reported the overdoses, said the children were in stable condition in the neonatal intensive care unit. A Cedars-Sinai official said tests indicated that none of the patients suffered any ill effects from the overdose on Sunday, but apologized to their families. "I want to extend my deepest apologies to the families who were affected by this situation," CedarsSinai's chief medical officer, Michael L. Langberg, said. The state Department of Public Health is investigating reports of an incident involving newborn twins at the hospital, said agency spokeswoman Suanne Buggy, who declined to elaborate. Langberg said three patients on Sunday each received vials containing 10,000 units per milliliter of heparin, a blood thinner, instead of vials with a concentration of 10 units per milliliter. The patients were receiving intravenous medications and the heparin was used to flush the catheters to prevent clotting. Once the hospital staff realized the error, they tested to measure the patients' blood clotting function, Langberg said. One test was normal, but the other two were given another drug, protamine sulfate, that reverses the effects of heparin. It was not immediately clear which two of the three patients had received the second drug. Further tests on those two "indicated no adverse effects from the higher concentration of heparin," Langberg said. "Doctors continue to monitor the patients." Protamine sulfate is generally effective in restoring normal clotting function, said Steven Kayser, professor of clinical pharmacy at the University of California, San Francisco. Heparin, used to treat and prevent blood clots in the veins or arteries, comes in different concentrations and too much can be life-threatening, Kayser said. Overdose symptoms can include nosebleed and bruising. "Heparin is a good drug, but you have to pay very careful attention because of the varying concentrations," he said. Last year, three premature infants at an Indiana hospital died after a pharmacy technician mistakenly stocked the medicine cabinet with heparin vials containing a dose 1,000 times stronger than what the babies were supposed to receive. Three others also suffered overdoses but survived. Quaid and his wife are the biological parents of the twins, who were born Nov. 8 to a surrogate mother. "God has definitely blessed us," the couple said in a statement announcing their birth. Quaid, 53, has a 15-year-old son, Jack Henry Quaid, from his marriage to Meg Ryan. His screen credits include "Great Balls of Fire!" "Any Given Sunday" "The Big Easy" and "Far From Heaven."