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ForumsInternationalHas anyone dealt with eu ema compounding guidance? Page 2

Has anyone dealt with eu ema compounding guidance?

paul_denver Mon, Jan 20, 2025 at 9:06 AM 26 replies 1,812 viewsPage 2 of 6
BiostatsBrad
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Jan 21, 2025 at 11:33 AM#6
paul_denver said:
They are two different exemptions from the same federal requirements and they buy different things.

I have been on both brand and compounded, and in the context of compounded supply, my experience has been equivalent with both. The key is finding a reliable 503B pharmacy with independent testing.

Last edited: Jan 21, 2025 at 12:33 PM
49 2LindaRN_retired, tommy_boulder, hyun_seoul and 46 others
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rachel_ABQ
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Dec 2024
Albuquerque, NM
Jan 21, 2025 at 10:06 PM#7

Following on from hyun_seoul — and this may be the naive question:

Why a shortage listing created a legal pathway at all, since a shortage is a supply fact rather than a permission?

50 3DadBodDave, AmyNC_wife, SkepticalSean and 47 others
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Dr.ReproEndo
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Jan 22, 2025 at 8:39 AM#8
BiostatsBrad said:
I have been on both brand and compounded, and in the context of compounded supply, my experience has been equivalent with both.

FDA inspection results for compounding pharmacies selling compounded supply: you can look up any 503B facility's FDA inspection history on the FDA website.

Check for: Form 483 observations (violations), warning letters, and recall history. A clean inspection record is a strong indicator of quality. My pharmacy has had 1 Form 483 observations in their last 2 inspections.

This is public information. Use it. Link: fda.gov/inspections-compliance-enforcement-and-criminal-investigations

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paul_denver
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Jan 22, 2025 at 7:13 PM#9

Closing the loop on my own question.

The bulks-list asymmetry was the piece I had missed entirely. It explains why one of my two pharmacies is still arguing it can supply and the other simply stopped.

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GraceAZ_72
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Jan 24, 2025 at 9:56 PM#10
Dr.ReproEndo said:
FDA inspection results for compounding pharmacies selling compounded supply: you can look up any 503B facility's FDA inspection history on the FDA…

Dr.ReproEndo has the substance of this right. The condition it depends on is worth stating. 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.

Last edited: Jan 25, 2025 at 1:56 AM
32 5RetaRick_CA, JenPlateau, SallyK_inj and 29 others
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