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ForumsCompounding & FormulationEndotoxin testing in compounded injectables — anyone have experience?

Endotoxin testing in compounded injectables — anyone have experience?

lucas_SP_BR Tue, Nov 12, 2024 at 2:58 AM 8 replies 1,672 viewsPage 1 of 2
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lucas_SP_BR
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Nov 12, 2024 at 2:58 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 am after is what actually distinguishes 503A from 503B, in terms of what each may make and from what starting material.

I would rather have one careful answer than five confident ones.

41 19NurseKim_ATL, paul_denver, TinaHashiRN and 38 others
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MikeFit_NJ
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Nov 12, 2024 at 3:07 AM#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.

Correct me if the detail matters more than I have assumed.

42 20marcus_mpls, DeniseRN_TPA, SandraNC_45 and 39 others
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emma_london
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Nov 12, 2024 at 3:16 AM#3
MikeFit_NJ said:
They are two different exemptions from the same federal requirements and they buy different things.

Agreeing with MikeFit_NJ, and the qualification matters more than the agreement. 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: Nov 12, 2024 at 9:16 AM
43 21TomFromTexas, mike.trainer_LA, sarah_nash92 and 40 others
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tyler_CSCS
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Nov 12, 2024 at 3:25 AM#4
lucas_SP_BR 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 lucas_SP_BR describes. 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.

44 22amy_econ_NJ, bbq_ray_KC, oliver_london and 41 others
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pete_nash
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Nov 12, 2024 at 4:14 AM#5

Clinical perspective, offered as context rather than as advice.

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 0 Form 483 observations in their last 4 inspections.

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

45 23sarah.morrison, NeuroNate, JessicaH_TX and 42 others
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