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ForumsCompounding & FormulationState pharmacy board compounding enforcement actions — what worked for you? Page 3

State pharmacy board compounding enforcement actions — what worked for you?

LondonLisa Thu, May 16, 2024 at 1:58 PM 16 replies 2,265 viewsPage 3 of 4
NeuroNate
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May 17, 2024 at 4:13 PM#11
Dr.BariatricHTX said:
Compounding pharmacy response time test for compounded supply: I email customer service at odd hours to test responsiveness.

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.

Last edited: May 17, 2024 at 10:13 PM
1 24jason_paloalto
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pam_columbus
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Columbus, OH
May 18, 2024 at 10:31 AM#12
B12Beth said:
Worth adding the genuine exception, because it is real and narrow: a change made for an identified patient where the prescriber determines it produces…

That reframing is the part I needed. Printing the relevant bit and taking it with me.

Last edited: May 18, 2024 at 4:31 PM
2 0alex_tucson, kevin_tulsa
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JenPlateau
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May 19, 2024 at 4:48 AM#13
Dr.BariatricHTX said:
Compounding pharmacy response time test for compounded supply: I email customer service at odd hours to test responsiveness.

Compounded has been just as effective for me. If compounded supply is the concern, the COA from my 503B pharmacy shows 99.1% purity. Verified by Janoshik.

3 1RunnerRach, TrialNerd_Beth, HPLC_Greg
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BiostatsBrad
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Jul 2024
Durham, NC
May 19, 2024 at 11:05 PM#14
LondonLisa said:
Two pharmacies quoted me last year, one describing itself as 503A and one as 503B, and I assumed 503B just meant bigger until both stopped within…

GMP compliance checklist relevant to compounded supply compounding quality:

  • Clean room environment with HEPA filtration
  • Environmental monitoring (viable and non-viable)
  • Personnel training and competency assessment
  • Validated analytical methods for testing
  • Stability testing program
  • Complete batch records and traceability
  • Quality management system with deviation handling

A 503B pharmacy following cGMP should be able to answer questions about ALL of these if you ask. Don't be afraid to ask — it's your health.

Last edited: May 20, 2024 at 12:05 AM
4 2james_edin, FranDenver, Dr.BariatricHTX and 1 other
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mike_mod
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May 20, 2024 at 5:22 PM#15

Moderator note: leaving this open. It is being argued well and the disagreement is the useful part. Tagging this one for the weekly digest.

5 3PurityPaulOR, MaxMetOK, MounjBrad and 2 others
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