Answering the narrow version, because the broad one does not have a single answer. 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.
My pharmacy stopped supplying with three weeks notice and a letter that explained nothing, so I went and read the statute.
Two things anyone can check: a state licence number for a 503A, and an FDA outsourcing-facility registration for a 503B. Both are publicly searchable, and a pharmacy unwilling to give you either has answered the question.
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.
Tell me what I have not thought of.
Dr.ObesityLA said:The shortage clause is the answer to the second question and it is a subtraction rather than an addition.
Agreed, and the enforcement dates were staggered by category — 503A first, 503B a few weeks later — because outsourcing facilities have manufactured inventory and clinic contracts to unwind while a 503A makes to order.
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View ResultsCryptoCarl 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. 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.
Clinical perspective, offered as context rather than as advice.
For compounded supply users considering compounded for the first time: here's a step-by-step guide:
- Get a prescription from your doctor (telehealth counts)
- Research 503B compounding pharmacies with good community reviews
- Verify their FDA registration and inspection history
- Request a COA for your specific compound before ordering
- Start with a 1-month supply to test
- Consider sending a sample to Janoshik for independent verification
- Track your response compared to brand (if you were on it previously)