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Healthcare Compliance Packaging Council Comments on FDA's Look at Unit of Use Blister Packaging for Certain Opioids

The Council notes that limited doses in properly designed blisters will not only mitigate overuse, but also limit excess unused doses—frequently the source of diverted and misused pills.

Healthcare Compliance Packaging Council Comments on “Fixed Quantity Unit of Use Blister Packaging for Certain Immediate Release Opioid Analgesics for Treatment of Acute Pain
Healthcare Compliance Packaging Council Comments on “Fixed Quantity Unit of Use Blister Packaging for Certain Immediate Release Opioid Analgesics for Treatment of Acute Pain

The HCPC supports Congress’ and the FDA’s admission that packaging can play an important role in discouraging opioid misuse by patients and others as noted by the SUPPORT Act of 2018. Unit dose blister packaging can fulfill the CDC’s and the FDA’s requirement to limit initial prescriptions for acute pain by providing pre-packed doses.

Unit dose blister packaging can be designed to contain a 3, 5 or 7 day initial prescription opioid pain treatment for acute care patients. The limited doses in properly designed blisters will not only mitigate overuse by the patient, but limit excess unused doses which are frequently the source of diverted and misused pills. A properly designed blister pack will include messaging to warn patients of addiction risk, provide visible evidence of doses taken and provide child-resistance superior to that offered by standard pharmacy packaging.

Another issue that could be mitigated by unit dose packaging is the onset of decreased dosing intervals some chronic care patients develop. According to Dr. Allan Wilson, MD, PhD, former Full Professor and Head, Section of Addiction Psychiatry, University of Ottawa, some patients develop the need to alleviate the anxiety of anticipated pain between dosing intervals, convincing them to seek another dose even before actual pain is felt. Properly designed packaging can provide dosage reminders for patients and caregivers alike, reducing the likelihood of under or overdosing.

Utilizing unit dose packaging with specific time reminders may help chronic patients better understand the dangers of overdosing and the reduced dosing intervals referenced in Dr. Wilson’s work. The unit dose packaging could provide risk reminders through billboard messaging, or simply provide space for recording dispense events directly on the package. In addition, the dispensing events could be coupled with an app that allows for scanning at each dispense event to notify a medical professional or caregivers. And finally, digital capture of dispense events via Near Field Communication (NFC) or Radio Frequency Identification (RFID) can be designed into the package for added verification. Unit dose compliance prompting packaging can be designed to accommodate the needs of different patient groups.

Blister packaging would protect our smallest population, children.The incidence of hospitalization for prescription opioid poisonings among children and adolescents 1 to 19 years of age increased nearly twofold from 1997 to 2012, with the largest percentage increase occurring among the youngest children, aged 1 to 4 years.1This includes the drug Buprenorphine, an opioid used to treat opioid addiction, which the CDC cited as the number one solid dose drug causing hospitalizations by children less than 5 years old. The CDC equated this to “For every 500 adults treated with Buprenorphine, 1 child was hospitalized from 2007 through 2011.” The 2012 packaging and delivery form change correlated to a 65% drop in Emergency Department visits.2

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INTRODUCING! The Latest Trends for Life Sciences at PACK EXPO Southeast