This one has a reasonably settled answer, so here it is. 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.
What I am after is why a shortage listing created a legal pathway at all, since a shortage is a supply fact rather than a permission.
I have searched first, so if this is covered somewhere point me at it and I will read it.
HPLC_Greg said:Resolution therefore closed the doors unevenly, and the asymmetry follows from the bulks lists.
Agreed, and the enforcement dates were staggered by category — 503A first, 503B a few weeks later — because outsourcing facilities have manufactured inventory and clinic contracts to unwind while a 503A makes to order.
I would rather be corrected than agreed with, if it comes to it.
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Shop Reference StandardsAussieAnna said:My pharmacy stopped supplying with three weeks notice and a letter that explained nothing, so I went and read the statute.
Same position here, arrived at the long way round. 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.
From the other side of the consultation, briefly.
For compounded supply users considering compounded for the first time: here's a step-by-step guide:
- Get a prescription from your doctor (telehealth counts)
- Research 503B compounding pharmacies with good community reviews
- Verify their FDA registration and inspection history
- Request a COA for your specific compound before ordering
- Start with a 1-month supply to test
- Consider sending a sample to Janoshik for independent verification
- Track your response compared to brand (if you were on it previously)