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ForumsCompounding & FormulationPeptide degradation products — what worked for you?

Peptide degradation products — what worked for you?

mona_PHX Fri, Aug 30, 2024 at 3:56 AM 13 replies 1,843 viewsPage 1 of 3
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mona_PHX
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Phoenix, AZ
Aug 30, 2024 at 3:56 AM#1

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

What I actually want to know is why a shortage listing created a legal pathway at all, since a shortage is a supply fact rather than a permission.

Happy to be told the question itself is wrong.

7 10RetaRick_CA, JenPlateau, SallyK_inj and 4 others
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Dr.SurgeonPGH
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Pittsburgh, PA
Aug 30, 2024 at 4:37 AM#2

This one has a reasonably settled answer, so here it is. 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.

If somebody has the primary source to hand I would rather cite it than paraphrase it.

Last edited: Aug 30, 2024 at 7:37 AM
8 11TomTeleRx, DoseLogDan, SleepFixSam and 5 others
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sophie_paris
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Paris, FR
Aug 30, 2024 at 5:18 AM#3
Dr.SurgeonPGH said:
The shortage clause is the answer to the second question and it is a subtraction rather than an addition.

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.

9 12MariaRD, AussieAnna, BethLabQueen and 6 others
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JakeSmashed95
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Aug 30, 2024 at 5:59 AM#4
mona_PHX said:
My pharmacy stopped supplying with three weeks notice and a letter that explained nothing, so I went and read the statute.

Can confirm the pattern mona_PHX describes. 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.

10 13Dr.LipidDallas, alex_tucson, kevin_tulsa and 7 others
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sean_dublin
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Dublin, IE
Aug 30, 2024 at 9:48 AM#5

From the other side of the consultation, briefly.

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.

11 14quinn_sf, NurseLeah_Nash, gary_naperville and 8 others
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