Accepted answer
Section 503A is an exemption, not an approval, and it is conditional on four things. A patient-specific prescription; a licensed pharmacist or physician doing the compounding in a licensed facility; bulk substances that either have a USP monograph, appear on the FDA's 503A bulks list, or are components of an approved drug, each with a certificate of analysis from a registered supplier; and the preparation must not be essentially a copy of a commercially available drug. That last condition is the one that moves: it turns on the shortage list, and what was lawful under 503A while a product was in shortage stops being lawful when the shortage is resolved. None of the four requires the finished preparation to be tested, which is the gap that independent assay fills.
Answer first: the two categories differ in whether a prescription for a named patient is required and in which quality standards apply, and that difference decides everything downstream.
Beyond-use dating differs by category and by the preparation environment, and an unusually long date on a compounded sterile preparation is worth asking about.
The relevant detail is that registration status is published and searchable. Checking it takes a minute and is the single most useful verification available in this whole area.
The two-tier structure separating patient-specific compounding from outsourcing facilities is established in federal law and the registration lists are published.
The caveat is that this structure is specific to one jurisdiction and does not describe the position elsewhere.
This structure is jurisdiction-specific. It does not describe your country unless it does.
This is the clearest description of the two-tier structure I have read. – stopper_core 9 months ago add a comment