Short answer first, then the reasoning. 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.
The question I want answered is 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.
pete_manc_UK said:Resolution therefore closed the doors unevenly, and the asymmetry follows from the bulks lists.
No disagreement with pete_manc_UK. One condition attached. 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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View Resultsmaria_elpaso 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. 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.
Clinical perspective, offered as context rather than as advice.
503A vs 503B compounding pharmacies for compounded supply — this distinction matters enormously:
| Feature | 503A | 503B |
|---|---|---|
| Regulation | State Board of Pharmacy | FDA-registered |
| Prescription | Required (patient-specific) | Can compound without patient Rx |
| Testing | Varies by state | cGMP required |
| Scale | Small batches | Larger production |
| Quality consistency | Variable | Generally higher |
I strongly recommend 503B facilities. The FDA oversight and cGMP requirements mean more consistent product quality.