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ForumsPublic SquareCompounded sema shortage — my results so far

Compounded sema shortage — my results so far

mark_tokyo Sat, Aug 16, 2025 at 4:25 PM 32 replies 1,406 viewsPage 1 of 7
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mark_tokyo
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Tokyo, JP
Aug 16, 2025 at 4:25 PM#1

My pharmacy stopped supplying with three weeks notice and a letter that explained nothing, so I went and read the statute.

The narrow version of the question is 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.

31 1pete_manc_UK, anna.melb_AU, mark_tokyo and 28 others
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julia.endo
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Cincinnati, OH
Aug 16, 2025 at 4:38 PM#2

Taking the question as asked, rather than the general version of it. 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.

30 0mark_tokyo, hans_munich, jason_sac26 and 27 others
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denise_HTX
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Jan 2025
Houston, TX
Aug 16, 2025 at 4:51 PM#3
julia.endo said:
The shortage clause is the answer to the second question and it is a subtraction rather than an addition.

Agreeing with julia.endo, and the qualification matters more than the agreement. 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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TinaHashiRN
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Sep 2024
Raleigh, NC
Aug 16, 2025 at 5:04 PM#4
mark_tokyo 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. They are two different exemptions from the same federal requirements and they buy different things. A 503A pharmacy is regulated primarily by the state board, needs a patient-specific prescription, is exempt from CGMP, and may use a bulk substance that has a USP monograph, is a component of an approved drug, or appears on the 503A bulks list — three independent doorways. A 503B outsourcing facility registers with the FDA, is inspected on a risk basis, must comply with CGMP, may compound for office stock without a patient-specific prescription, and has one doorway to a permitted bulk substance: the 503B bulks list, or the drug shortage list.

That is the short version; the long version is somebody else's post.

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Dr.RaviCardio
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Aug 16, 2025 at 6:15 PM#5

Adding the clinical framing, because it changes how the question reads.

Compounding pharmacy licensing verification for compounded supply: before ordering, verify your pharmacy's credentials:

  1. State Board of Pharmacy license — check on your state BOP website
  2. FDA registration (for 503B) — check on fda.gov
  3. DEA registration if handling controlled substances
  4. PCAB accreditation — voluntary but demonstrates commitment to quality
  5. USP <797>/<800> compliance for sterile compounding

This takes 10 minutes of research and could save you from receiving substandard or unsafe medication.

Last edited: Aug 16, 2025 at 7:15 PM
27 22jason_sac26, chris_chi24, tampaLisa73 and 24 others
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