Short answer first, then the reasoning. Resolution therefore closed the doors unevenly, and the asymmetry follows from the bulks lists. For 503B the shortage clause was the only route to these molecules, so that route shut completely. A 503A pharmacy can still argue a doorway via "component of an approved drug" — but only for the substance in the form present in the approved product, which is exactly where the base-versus-salt argument lives, and it does nothing about the copy restriction, which came back into force on resolution.
My pharmacy stopped supplying with three weeks notice and a letter that explained nothing, so I went and read the statute.
So the question, as narrowly as I can put it: what actually distinguishes 503A from 503B, in terms of what each may make and from what starting material.
I have searched first, so if this is covered somewhere point me at it and I will read it.
Dr.ObesityLA said:Resolution therefore closed the doors unevenly, and the asymmetry follows from the bulks lists.
Dr.ObesityLA has the substance of this right. The condition it depends on is worth stating. Worth adding the genuine exception, because it is real and narrow: a change made for an identified patient where the prescriber determines it produces a significant clinical difference for that patient. A grid of fixed doses offered to everybody is not that, whatever the intake form says.
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Browse GL BiochemDr.AddMedPHL said:My pharmacy stopped supplying with three weeks notice and a letter that explained nothing, so I went and read the statute.
This matches mine closely enough to be worth saying so. The shortage clause is the answer to the second question and it is a subtraction rather than an addition. Both exemptions forbid compounding something that is essentially a copy of a commercially available approved product. A product FDA has listed as in shortage is not treated as commercially available, so listing removed the objection that otherwise blocked compounding. It never created a permission; it withdrew a prohibition, which is why it evaporated the moment the supply fact changed.
Clinical perspective, offered as context rather than as advice.
Beyond-use dating (BUD) for compounded supply compounded products:
Lyophilized (unreconstituted): typically 9 months from compounding date
Reconstituted with BAC water: typically 28-30 days refrigerated
Reconstituted with sterile water: typically 7 days (no preservative!)
Always use BAC water for multi-dose vials. Sterile water has no preservative and supports bacterial growth after first puncture. This is a common and potentially dangerous mistake.