Take A Walk
An Intro to the Mechanics of Internal Mock Inspections
Part 2 of 3
Acquiring expertise on proper aseptic processes that significantly enhance the quality of your compounding practices and the safety of your CSPs.
Introduction:
In this three-part blog series, we explore essential tips and tools to perform mock inspections within compounding environments and the benefits they offer such as pharmacist confidence and organization readiness.
Walking the Compounding Area:
Seeing it the Way a Surveyor Will
This segment begins with understanding what an experienced surveyor may encounter during a walk-through inspection of the compounding area. The more the Designated Person (DP) understands the details of day-to-day operations, the more complete, realistic, and useful the local inspection checklist will be. Just as important, this level of engagement helps staff view quality assurance as a daily expectation rather than a rare event.
Many DPs do not actively participate in compounding operations. That is a missed opportunity. A DP does not need to be the primary compounder, but they should have enough direct operational familiarity to recognize when practice drifts from policy, when environmental control is weakening, or when workflow pressures are driving workarounds.
A. Walk the Perimeter
Many organizations conduct daily leadership rounds to get a sense of how operations are going and where support may be needed. When done well, this type of visible leadership can strengthen team culture, build trust, and create opportunities for honest conversation. In the compounding environment, it also serves another purpose: it trains the DP to observe the cleanroom suite the way a surveyor will.
1. Physical Plant
A surveyor’s first impression often begins before they enter the cleanroom. A careful inspection should include not only the condition of the compounding spaces themselves, but also the surrounding and adjacent areas. The entrance to the ante-area should be uncluttered and should not be positioned in a way that exposes the space to unnecessary traffic or disruption.
2. Around the Space
Observe the environment with intention. Are there items that appear misplaced, improperly stored, mislabeled, expired, or left outside of their designated storage location? Small signs of disorder often suggest larger issues with oversight, accountability, and contamination control.
3. Personnel in the Ante-Area
Pay close attention to gowning behavior and staff readiness. Observe garbing sequence, use of personal items, supply availability, and the general condition of the space. If the shoe cover dispenser is empty, for example, is there evidence that old shoe covers are being left behind? Assess sink condition, eyewash documentation, and other details that reflect whether the area is being maintained in a true state of readiness.
Surveyors often probe more deeply when they notice visible inconsistencies early in an inspection. Initial impressions matter. An unkempt physical plant can influence confidence in the rest of the operation in the same way a dirty restroom shapes a customer’s perception of a restaurant. Appearance alone does not determine compliance, but it strongly influences whether a surveyor expects to find control—or drift.
B. Walk Inside: A Closer Look
Entering the compounding space regularly gives the DP an opportunity to reinforce proper garbing technique, remain operationally credible, and normalize their presence inside the cleanroom. This matters. When staff see leadership willing to participate in the same expectations placed on them, it can improve communication, trust, and accountability.
Frequent presence also allows the DP to observe staff under normal conditions. The goal is not to create tension, but to learn how work is actually being done. Feedback should be educational, not punitive. A truth-seeking approach invites staff to discuss real workflow barriers, operational frustrations, and process breakdowns that may otherwise remain hidden.
This is especially important when procedures are technically correct on paper but difficult to execute in practice. Surveyors identify this mismatch often: staff describe one process, the SOP describes another, and actual behavior reflects a third. When that happens, the finding is not simply about staff performance—it is about the gap between written procedure and operational reality.
1. Listen
If you are familiar with the normal sounds of your cleanroom suite, you can often detect meaningful problems before they become findings. Frequent presence helps you learn what “normal” sounds like. In daily life, familiar sounds blend into the background. Unusual sounds tend to signal that something has changed—and sometimes that change matters.
A few examples:
a. Excessive Conversation
Too much chatter in the cleanroom is more than a professionalism issue. Staff may verbalize stress, complain about workflow, or engage in long conversations while compounding. At times, there may even be laughter or unnecessary social discussion during critical tasks. Speaking excessively in the cleanroom is poor practice and can compromise aseptic technique.
This must be addressed thoughtfully but directly. Masks do not eliminate airflow from speech, coughing, or sneezing. Talking in the buffer room should be kept to a minimum, especially while working in a primary engineering control (PEC).
b. Equipment Sounds
Mechanical sounds also deserve attention. Changes in air handler noise may signal equipment problems. If the room is unusually quiet, a PEC may be turned off. If a certifier has increased fan speed to achieve acceptable airflow velocity, the resulting noise level may become an occupational concern.
If the decibel level is significantly elevated, the certification report should document it. In some cases, excessive noise may indicate that replacement of the unit is warranted rather than continued adjustment.
For reference, OSHA’s permissible exposure limit (PEL) for workplace noise is 90 dBA averaged over an 8-hour workday for unprotected ears. Additional OSHA reference points include:
- 90 dBA for 8 hours
- 95 dBA for 4 hours
- 100 dBA for 2 hours
- 105 dBA for 1 hour
- 115 dBA as the maximum peak continuous or impact-type exposure permitted
c. Fire Alarm and Air Handling Response
Fire alarms may trigger changes in airflow if the compounding suite shares an air handler with another area of the facility. This is a fire safety measure designed to prevent feeding oxygen to a fire and dispersing smoke. However, from a cleanroom control perspective, it can create significant vulnerability.
This is one of the strongest arguments for a dedicated, stand-alone air handler for the compounding suite. It is not simply a design preference; it is a critical cleanroom design consideration. In many cases, shared air handling makes it difficult—or impossible—to maintain a consistent state of control.
2. Feel
Putting on a gown and entering the space helps the DP understand the operation in a way that cannot be achieved from outside the room. It creates a more immediate awareness of environmental conditions, staff behavior, and workflow friction points.
Examples include:
a. Temperature, Humidity, and Comfort
Environmental readings matter, but so does direct experience of the room. Is the temperature reasonable? Is humidity affecting comfort or performance? Conditions that seem acceptable on paper may feel very different during actual work.
b. The Tone of the Room
Feel the room. Is the environment calm, focused, and orderly? Or is it tense, hurried, and reactive? If the room feels stressed, ask why. The answer may reveal staffing issues, inefficient workflow, supply shortages, technology barriers, or unrealistic expectations.
3. See
Visual observation remains one of the most valuable inspection skills. Many findings can be identified early by someone with a trained eye. The problem is that people do not naturally see what they have not been trained to notice.
Examples include:
a. Gauges, Monitors, and Lighting
Pressure gauges, temperature and humidity monitors, alarms, and lighting conditions all require regular attention. A DP should know what normal looks like and recognize when readings or conditions are trending in the wrong direction.
b. Physical Condition of Furnishings and Equipment
Inspect the condition of carts, work surfaces, shelving, stools, pass-throughs, refrigerators, and PECs. Worn, damaged, rusted, or poorly maintained surfaces can raise concerns about cleanability and environmental control.
c. Movement of Personnel and Materials
Observe how people and supplies move into and out of the room. Are materials introduced in a controlled and consistent manner? Are personnel entering and exiting in ways that preserve intended workflow and segregation
d. Presence of Non-Compounding Personnel
If maintenance staff or other non-compounding personnel are in the room, ask why. Are they interacting with gowned staff? Have they followed the same garbing and hygiene expectations? Their presence may be justified, but it should never be casual or uncontrolled.
e. Door Function and Pressure Control
Automatic door sensors that are too sensitive may cause doors to open too frequently as staff walk nearby. If hazardous and non-hazardous areas share an ante-area and both doors open at the same time, pressure segregation may be compromised. This is not a minor design inconvenience; it may directly affect environmental control.
4. Touch
To understand the operation fully, the DP should occasionally perform some of the work. This is not about taking over the staff’s role. It is about maintaining practical credibility, recognizing barriers firsthand, and ensuring that leadership remains connected to actual practice.
Examples include:
a. Compound a Dose or Two
Prepare one or two doses periodically. Let staff observe you. Let them critique you. This reinforces a culture in which standards apply to everyone and where feedback is normalized rather than feared.
b. Test Your Workflow Expertise
If your department uses workflow management technology, confirm that you are truly proficient with it. A DP should not only oversee the system conceptually, but also understand how it functions in real use.
c. Participate in Routine Tasks
Organize supplies, perform wipe-downs, and take part in selected routine tasks. Doing so provides insight into whether procedures are practical, whether supplies are where they should be, and whether the room supports compliant work as intended.
What’s Next
In Blog #3, we’ll move further into the mechanics—walking through the structural elements of an internal USP <797>/<800> mock inspection and how to evaluate them realistically, not theoretically.
References
United States Pharmacopeia (USP)
- USP <797> Pharmaceutical Compounding—Sterile Preparations. Revised 2023. Official November 1, 2023.
- USP <800> Hazardous Drugs—Handling in Healthcare Settings.
- USP <795> Pharmaceutical Compounding—Nonsterile Preparations. Revised 2023.
These standards form the technical and operational foundation for:
- Designated Person accountability
- Personnel competency
- Environmental monitoring
- Documentation integrity
- Governance and oversight
Accreditation & Medication Management Standards
The Joint Commission
- Comprehensive Accreditation Manual for Hospitals (CAMH).
- Medication Management (MM) Standards
- MM.05.01.07 – Compounding sterile preparations.
- MM.05.01.09 – Labeling requirements
- MM.08.01.01 – Storage and security of medications
- Environment of Care (EC) Standards
These standards support the blog’s discussion regarding:
- Inspection focuses on differences.
- Medication safety emphasis
- Tracer methodology
- Continuous readiness posture
Federal Oversight of Accrediting Organizations
Centers for Medicare & Medicaid Services (CMS)
- State Operations Manual (SOM)
- Conditions of Participation for Hospitals (42 CFR §482)
- CMS Deeming Authority Requirements for Accrediting Organizations
These documents support discussion around:
- Validation surveys
- Oversight of accrediting bodies
- Regulatory alignment
Hazardous Drug & Safety Guidance
National Institute for Occupational Safety and Health (NIOSH)
- NIOSH List of Antineoplastic and Other Hazardous Drugs in Healthcare Settings (2023).
- NIOSH Alert: Preventing Occupational Exposure to Hazardous Drugs (DHHS 2004-165).
Occupational Safety and Health Administration (OSHA)
- 29 CFR 1910.1450 – Occupational Exposure to Hazardous Chemicals in Laboratories
- OSHA Technical Manual, Section VI, Chapter 2 (Hazardous Drugs)
Professional Practice Guidance
American Society of Health-System Pharmacists (ASHP)
- ASHP Guidelines on Compounding Sterile Preparations (Am J Health-Syst Pharm. 2014;71:145–166).
- ASHP Guidance on Handling Hazardous Drugs (Am J Health-Syst Pharm. 2006;63:1172–1193).
These references support the blog’s emphasis on:
- System strengthening
- Governance structures
- Leadership responsibility in sterile compounding
Environmental & Infection Control References
Centers for Disease Control and Prevention (CDC)
- Guidelines for Environmental Infection Control in Health-Care Facilities (updated 2019).
- Guidelines for Hand Hygiene in Health-Care Settings (MMWR 2002;51[RR-16]).
ANSI/ISEA Z358.1-2014
Seven97 Training Insight
Released June 2026

About the Author
Luis Hernandez, RPh, BCSCP, is a certified sterile compounding pharmacist and the founder of Seven97 Training Solutions. Dedicated to advancing USP 797 pharmaceutical training, validation, and certification, Luis aims to promote and inspire excellence in aseptic processing, medication and patient safety, and regulatory compliance.