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.
Answering this needs the jurisdiction, since this two-tier structure is a feature of one national framework and does not translate directly elsewhere.
Outsourcing facilities may produce without a patient-specific prescription, register federally, are inspected on a risk-based schedule and are subject to current good manufacturing practice.
Adverse event reporting obligations attach to the outsourcing category and not to the patient-specific one, which is a real difference in the information that exists about what a facility produces.
Inspection findings for registered facilities are published and are directly checkable for a named facility.
Nothing here is legal or medical advice.
The category tells you which standards apply, not how good the preparation is.
Worth flagging that a verbal assurance from a call centre binds nobody. – micron22 4 months ago add a comment