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ForumsCompounding & FormulationIs it normal for the powder to not fully dissolve — July 2024

Is it normal for the powder to not fully dissolve — July 2024

PedsEndoPhilly Wed, Feb 7, 2024 at 3:59 PM 60 replies 3,510 viewsPage 1 of 12
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PedsEndoPhilly
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Jun 2024
Philadelphia, PA
Feb 7, 2024 at 3:59 PM#1

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

Two things anyone can check: a state licence number for a 503A, and an FDA outsourcing-facility registration for a 503B. Both are publicly searchable, and a pharmacy unwilling to give you either has answered the question.

So the question, as narrowly as I can put it: why a shortage listing created a legal pathway at all, since a shortage is a supply fact rather than a permission.

Numbers rather than impressions, if you have them.

10 13sarah_TO, wendy_avl, jason_paloalto and 7 others
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MikeFit_NJ
Senior Member
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Apr 2024
New Jersey
Feb 7, 2024 at 5:08 PM#2

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

11 14marcus_mpls, DeniseRN_TPA, SandraNC_45 and 8 others
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MounjBrad
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Oct 2024
Kentucky
Feb 7, 2024 at 6:17 PM#3
MikeFit_NJ said:
They are two different exemptions from the same federal requirements and they buy different things.

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.

12 15nick_SD_fit, ben_calgary, patPC_UT and 9 others
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MeganSA_TX
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Jun 2024
San Antonio, TX
Feb 7, 2024 at 7:26 PM#4
PedsEndoPhilly 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. 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.

13 16TomFromTexas, mike.trainer_LA, sarah_nash92 and 10 others
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KevinCompounds
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Nevada
Feb 8, 2024 at 2:02 AM#5

Clinical perspective, offered as context rather than as advice.

For compounded supply users considering compounded for the first time: here's a step-by-step guide:

  1. Get a prescription from your doctor (telehealth counts)
  2. Research 503B compounding pharmacies with good community reviews
  3. Verify their FDA registration and inspection history
  4. Request a COA for your specific compound before ordering
  5. Start with a 1-month supply to test
  6. Consider sending a sample to Janoshik for independent verification
  7. Track your response compared to brand (if you were on it previously)
Last edited: Feb 8, 2024 at 4:02 AM
14 17NurseAsh_DET, BenResearch_OR, MikeKY_noInsulin and 11 others
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