HealthMarch 16, 2026

A timeline of turning points: How key events drove the evolution of sterile compounding pharmacy standards

USP <797> established enforceable standards in response to patient harm from unsafe sterile compounding. This timeline chronicles the events that led to its development and updates over time.

USP Chapter 797 was the first set of enforceable sterile compounding standards created by the United States Pharmacopeia, as minimum requirements intended to ensure the quality and safety of compounded sterile preparations, developed largely in response to serious patient harm caused by poor-quality compounded sterile preparations (CSPs) and unsafe compounding practices.

The following key sentinel events illustrate the critical gaps that existed before USP 797 and highlight the driving forces behind its creation and subsequent revisions.

Early 20th Century

Sterile compounded preparations were widely used long before the first iteration of USP <797> appeared in 1995. By the 1930s, injections were common, and by the 1940s, hospitals were already reporting problems with compounded IV drugs and preparation techniques. The 1960s brought innovations such as laminar airflow hoods and parenteral nutrition, among other technological advances. Yet standards lagged behind these advances, and a series of fatal contamination events in the years that followed highlighted the serious risks posed by CSPs, driving the development of enforceable sterile compounding safeguards.

Sterile compounding standards evolve

  • As a result of multiple reports and concerns, in 1975 the US Department of Health and Human services provided a grant to USP to develop recommendations for the production and administration of intravenous drugs. USP forms the National Coordinating Committee on Large Volume Parenteral.
  • The FDA issued its Alert Letter to pharmacists in 1989, reminding them of the gravity of performing sterile compounding responsibly.

1990s

1990: Four patients die in a Nebraska hospital due to a contaminated solution

The patients died after contracting a bacterial infection from a non-sterile cardioplegia solution, which was compounded in a Nebraska hospital.

1990: Two patients lose vision due to contaminated materials

Two patients went blind in Pennsylvania after becoming infected with pseudomonas aeruginosa. The bacteria was found in their eye drops, which were compounded in a community pharmacy. At the time, commercial non-steroidal drops had been available.

Sterile compounding standards evolve

  • The American Society of Health System Pharmacists (ASHP) conducted a national survey and found that the quality assurance procedures of sterile product preparation required major improvement. And the following year, ASHP drafts guidelines on quality assurance for preparing sterile products.

1994: Two patients die and others injured due to calcium phosphate precipitates in parenteral nutrition

Two deaths and two cases of respiratory distress due to pulmonary emboli as a result of calcium phosphate precipitates.

Sterile compounding standards evolve

  • FDA issues a Safety Alert, and compounding practices were reevaluated, including the use of filters and prescribing practices for calcium and phosphate in parenteral nutrition.

1995: First standards are published

  • 1995: ASHP conducts a follow up survey and finds little improvement since 1991.
  • 1995: After collecting and reviewing data from surveys reported by state boards and pharmacy associations for 5 years, USP produces Chapter <1206> Sterile Drug Products for Home Use, which was originally <1074> and later renumbered, and would eventually become <797>.
    • <1206> did not mention beyond-use dates (BUDs) until the second revision, and even then, the only BUD mentioned was 7 days refrigerated.

1997 FDA Modernization Act

  • The FDA Modernization Act of 1997 was passed, specifying that bulk ingredients used to compound must comply with USP standards.
    • It also required USP and Health and Human Services to collaborate: An advisory committee is formed with USP, FDA, NABP, and experts from the pharmacy community, consumer organizations and others. Their recommendation was that <1206> be revised to become the foundation of sterile preparation techniques and practices.

1998: Ten children test positive for Enterobacter cloacae

Ten children in California tested positive for the bloodstream infection after being exposed to contaminated, pre-filled saline syringes. Poor employee hand hygiene and garbing routines were thought to be the root causes.

21st Century

2001: Pediatric patients fall ill as a result of a hospital pharmacy

Four patients in Missouri developed an infection after receiving IV ranitidine that had been mixed with Automated Compounding Devices. Poor employee hand hygiene and garbing were thought to be the causes of the issue.

2002: Five patients receive contaminated steroids, one dies

In South Carolina, five patients were given contaminated injectable steroids, resulting in one death. Researchers identified exophiala as the primary issue, and the incidents occurred up to 152 days following the injections. In this instance, untrained compounding personnel were deemed the main cause.

2004: Contaminated radioisotope equipment causes hepatitis C

Sixteen patients in Maryland contracted hepatitis C infections after being exposed to a Tc 99m radioisotope used during their cardiac stress tests. At the pharmacy responsible for preparing the radioisotopes, breaks in aseptic technique were cited.

Sterile compounding standards evolve

  • On January 1, 2004, USP <797> Pharmaceutical Compounding – Sterile Preparations became an official chapter, replacing <1206>.
    • Included BUD storage limits for the first time.

2007: Study reveals lack of prepared pharmaceutical graduates

A study conducted in 2007 regarding the extent of sterile compounding training at U.S. pharmaceutical schools revealed a lack of prepared graduates. About 13 percent of the school's deans claimed that their students were adequately trained in sterile compounding before graduation.

2008: USP revises <797>

  • USP proposed a revision to Chapter <797> on November 27, 2007, placing an emphasis on individual training and evaluation of sterile compounding standards, and this revision became official on June 1, 2008.

Despite the fact that USP 797 was first introduced in 2004, its adoption and compliance was slow. A compliance survey of compounding pharmacists conducted in 2011 revealed that financial constraints and budget limitations were holding many compounders back from complying with the regulations.

2010: Pediatric patient dies in hospital due to compounding error

The child died after receiving a sodium chloride concentrate that was not compounded properly prior to administration.

2011: Multiple patients blinded due to Avastin contamination

Patients in California, Florida, and Tennessee were blinded after receiving compounded Avastin intravitreal injections. The injections had been contaminated during repackaging from large vials into single dose syringes. Additionally, one patient suffered permanent brain damage.

2012: New England Compounding Center (NECC) fungal meningitis outbreak

A widespread fungal meningitis outbreak was linked to contaminated preservative-free methylprednisolone acetate injections, compounded at a pharmacy that was not in compliance with USP 797 standards. The U.S. Centers for Disease Control and Prevention found 751 cases and 64 deaths across 20 states, primarily from Exserohilum rostratum fungus. The New England Compounding Center meningitis outbreak led to the closure of the facility, criminal charges, and new legislation to improve oversight of compounding pharmacies.

2013: A Connecticut hospital identifies contaminated magnesium sulfate

Yale-New Haven Hospital identified visible mold in 5 bags of IV Magnesium Sulfate, which were prepared and repackaged by a repackaging pharmacy in New Jersey. Upon investigation of the New Jersey pharmacy, the FDA found multiple contaminated products and risky compounding practices that were far below industry standards, including contaminated non-sterile equipment in the cleanroom, compounding personnel with an active eczema condition, and mislabeled preparations, both in drug and strength. The pharmacy has since been shutdown.

2013: A Georgia pharmacy recalls 79 lots of products

Products intended for retinal injections were recalled due to a risk of eye infection.

2013: 15 patients are infected in Texas, 2 die

Patients are infected and two individuals die due to a batch of compounded IV calcium gluconate.

2013: The Drug Quality and Security Act (DQSA) becomes law

  • Congress passes the DQSA, Title I of which is the Compounding Quality Act.
    • This act amended section 503a of the Food, Drug and Cosmetic Act (FD&C), to increased FDA authority to regulate compounding pharmacies.
    • It created a new entity, outsourcing facilities, under section 503b, and revised 503a to require that traditional compounded preparations must comply with USP chapters on compounding.
    • This law requires the FDA to engage in two-way communication with regulators—state boards of pharmacy must inform the FDA when they send a warning letter or impose sanctions in regards to compounding medications.

2014: Patient dies after receiving the wrong drug

An Oregon patient dies after receiving rocuronium instead of fosphenytoin. The labeling was correct, but the rocuronium went unnoticed.

2015: Voluntary recalls continue across the U.S.

Recalls impacting compounded drugs continue across the U.S.

  • The FDA announced in Sept. 2015 that U.S. Compounding, Inc., had issued a voluntary recall of all sterile compounded products.
  • Downing Labs, Inc., issues a voluntary recall of compounded materials in Oct. 2015.
  • Hospira begins a recall in March 2015 due to mold contamination in its compounded drugs.

2015: USP releases revisions to <797> for public comment

  • In 2014, USP met with FDA and CDC to prepare for revisions to <797>. The proposed revisions were released for public comment in 2015.
  • The revisions received over 8,000 public comments from stakeholders, so the draft was further revised by USP.
  • Between 2015 and 2020, extensive stakeholder engagement events were held.

2016: CDC and New Mexico Health Department link unsafe compounding and injection practices to multiple abscesses and osteomyelitis in patient

Multidose vials at an outpatient facility were found to be contaminated, resulting in abscesses at an injection site and osteomyelitis requiring surgery. Investigations cited lapses in infection control, environmental monitoring, compounding, and safe injection practices.

2016: 17 reported cases of fungal bloodstream infections and 2 deaths linked to contaminated compounded IV flush solutions

An outpatient oncology clinic in New York City had administered compounded saline, heparin, vancomycin, and ceftazidime IV flush bags that did not meet <797> and <800> standards, nor CDC infection control and FDA guidelines. They were improperly stored and used for multiple patients far beyond the BUDs allowed by <797>.

2017: Contaminated pharmacy bulk packaged products (PBP) result in 41 cases of septic arthritis

41 cases of septic arthritis at a NJ outpatient knee clinic were linked to contaminated intraarticular injections. An investigation identified multiple breaches of sterile compounding and infection-control standards, including inadequate hand hygiene, improper garbing, substandard injection techniques, and improper handling of pharmacy bulk packages (PBPs). Injections were prepared several days in advance, outside of appropriate compounding environments, not in compliance with sterile compounding requirements, and were used for multiple patients.

2018: CDC releases report on compounding related outbreaks

The report highlighted the frequency of non–patient-specific compounding from non-sterile ingredients and the repackaging of products as a source of contamination. The report also cited failures in aseptic technique and weaknesses in sterilization methods, as well as in sterility and endotoxin testing.

2018: USP releases second <797> draft revision

This draft considered all the stakeholder feedback on the 2015 draft, as well the available scientific evidence, including the 2018 CDC report. Public comments indicated further stakeholder feedback and additional revisions were required.

2019: USP publishes <797> revision in USP-NF

Upon publication of the chapters, USP received appeals, in accordance with USP By-laws, to the chapters from stakeholders regarding key provisions. An appeals panel determined that further dialogue and consideration was warranted, and <797> was remanded to the Compounding Expert Committee for further revision.

2021: USP proposes fourth draft revision to <797> for public comment

On September 1, 2021, after extensive deliberation and stakeholder engagement, and a review of over 14,000 public comments, USP proposes a fourth draft for public comment. This public comment lasted until beyond the typical 90 days to March 2022. This draft received 1400 public comments, which were reviewed and a final draft was published 6 months later.

2022: USP publishes final revision of <797> in USP-NF

  • After nearly a decade of revision, public comments, and stakeholder engagement, USP publishes the final revisions to <797> on November 1, 2022. This revision becomes official and enforceable on November 1, 2023.

2023: USP <797> 2022 revisions become official and enforceable

 

Recent developments and emerging concerns (2019–present)

The long-awaited revision of USP <797>, completed after nearly a decade of work, reflects meaningful advances in science, technology, and best practices for sterile compounding. The hope is that these updated standards will reduce the frequency of preventable compounding-related incidents. Yet, the impact of <797> is ultimately dependent on compliance and enforcement. USP itself has no enforcement authority, and implementation depends on state adoption and oversight. Alarmingly, not all states have incorporated the standard fully into their regulatory codes, and a 2015 survey found that only 30% of states required reporting of serious adverse events, leaving significant gaps in surveillance and accountability.

Against this backdrop, the FDA continues to document insanitary conditions and issue Safety Alerts for compounded medications. These recurring findings underscore a persistent truth: USP <797> provides only the foundation from which compounders must build a robust quality-driven practice. The reality of ongoing risks is reflected in a 2020 ISMP survey in which 74% of respondents reported awareness of at least one compounding error in the previous year.

As compounding practices evolve, new challenges continue to emerge. The rise of compounded GLP-1 agonists, for example, has prompted significant concern; as of December 2024, the FDA had identified over 900 adverse events linked to compounded GLP-1 products, including 17 deaths. Similarly, the growth of IV infusion services in medspas—often staffed by individuals without medical training and operating without clear regulatory oversight—has led to additional injuries and fatalities linked to contaminated infusions.

Taken together, these contemporary developments illustrate that while standards continue to evolve, the core issue is not the absence of guidance, but rather inconsistent adherence to the standards already in place. Nearly all of these incidents are preventable. A sustained commitment to implementing USP <797> as the minimum standard, coupled with facility-specific SOPs and robust quality assurance systems, is essential. Strengthening compliance, reporting, and regulatory harmonization will be critical to reducing avoidable harm and improving patient safety in sterile compounding pharmacy practice in the years ahead.

Learn About Simplifi 797
Annie Lambert
Clinical Program Manager for Compliance Solutions
Compliance Solution Clinical Program Manager Annie Lambert, PharmD, BCSCP is committed to providing up-to-date USP content and expert compliance guidance, and to work with you to optimize the use of our Simplifi+ pharmacy compliance solutions.

References

  1. Mitiche S. A Tale of Two Compounding Chapters. Presentation: United States Pharmacopeia, Compounding Implementation Workshop: Evolution and Advances in Compounding; February 7, 2023; Rockville, MD.
  2. Myers CE. History of sterile compounding in U.S. hospitals. Am J HealthSyst Pharm. 2013;70(16):14141427. Available at: https://academic.oup.com/ajhp/articlepdf/70/16/1414/28364198/ajhp1414.pdf. Accessed November 9, 2025.
  3. McKinnon BT. FDA safety alert: hazards of precipitation associated with parenteral nutrition. Nutr Clin Pract. 1996;11(2):59-65. doi:10.1177/011542659601100259.
  4. "Moving Forward For Safer Sterile Compounding." Institute for Safe Medication Practices. November 1, 2012. https://home.ecri.org/pages/ismp
  5. "USP's Revised General Chapter Pharmaceutical Compounding – Sterile Preparations 797 Tightens Patient Safety Guidelines." U.S. Pharmacopeia. November 27, 2007. http://nuclearpharmacy.uams.edu/
  6. Newton, David. "USP 797 - Pharmaceutical Compounding - Sterile Preparations." American Association of Colleges of Pharmacy. July 10, 2011. http://www.aacp.org/
  7. Douglas, Kate. "The 2012 USP 797 Compliance Survey: Measuring Progress." Pharmacy Purchasing and Products Magazine. October 1, 2012. http://www.pppmag.com
  8. St. John, Keith. "USP 797: IP + Pharmacist as Partners in Medication Safety." Pharmacy One Source. Retrieved Oct. 12, 2015.
  9. "Drug Recalls." U.S. Food and Drug Administration." Retrieved October 12, 2015. www.fda.gov
  10. "USP's Revised General Chapter Pharmaceutical Compounding – Sterile Preparations 797 Tightens Patient Safety Guidelines." U.S. Pharmacopeia. November 27, 2007. http://nuclearpharmacy.uams.edu/
  11. The Pew Charitable Trusts. U.S. Illnesses and Deaths Associated With Compounded or Repackaged Medications, 2001-19. March 2, 2020. https://www.pew.org/en/research-and-analysis/data-visualizations/2020/us-illnesses-and-deaths-associated-with-compounded-or-repackaged-medications-2001-19. Accessed November 9, 2025.
  12. Simpson HR, Selvage WD, Onishuk L, Kellie S, Baumbach J. When ignorance is not bliss: complications associated with homeopathic injections from a chiropractor. Paper presented at: Council for State and Territorial Epidemiologists Annual Conference; June 4-8, 2017; Boise, ID. Available from: https://cste.confex.com/cste/2017/webprogram/Paper8601.html
  13. The Institute for Safe Medication Practices. ISMP survey on sterile compounding in pharmacies reveals gaps, challenges. ECRI. October 26, 2020. https://home.ecri.org/blogs/ecri-news/ismp-survey-on-sterile-compounding-in-pharmacies-reveals-gaps-challenges. Accessed November 20, 2025.
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