12
Dec
More History of the 503B and 503A Bulk Drug Substance Lists Significant and Welcomed Changes_LachmanBlog

More History of the 503B and 503A Bulk Drug Substance Lists: Significant and Welcomed Changes?

Last week, the FDA has announced the availability of two draft Guidances for Industry regarding compounding of human drugs: Interim Policy on Compounding Using Bulk Drug Substances Under Section 503B of the Federal Food, Drug, and Cosmetic Act (here); and Interim Policy on Compounding Using Bulk Drug Substances Under Section 503A of the Federal Food, Drug, and […]

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07
Sep
Compounding - What About the Birds and the Queen Bees and Our Furry Friends

Compounding – What About the Birds and the Queen Bees and Our Furry Friends?

In a recent issue of a veterinary journal, vaccines for bees (for American Foul Brood – AFB) made the headlines. Veterinarians would oversee administering the vaccine and possibly in “compounding” the vaccine for specific queen bees. Honeybees are food animals because they produce honey for human consumption and because they have a role in crop […]

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10
Aug

Limited, Inordinate, and Extended Can Kicking?

On 8/6/2021, a Federal Register Notice (here) was issued announcing an extension of the period before FDA intends to begin enforcing the statutory 5 percent limit on out of state distribution of compounded human drug products. FDA is extending the period for states to decide whether to sign the final MOU, (“Memorandum of Understanding Addressing […]

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29
Oct

Along with Witches, Time Flies By

How long has it taken for a Final Standard Memorandum of Understanding (MOU) for States regarding Compounding Pharmacies to be issued?  Are States or appropriate agencies (referred to as States below) ready to sign, acquire infrastructure, hire the necessary human resources, develop the enabling documentation, execute the requirements of the provisions, create the necessary records, […]

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03
Aug

History of the 503B Bulk Drug Substance List – We’ve Come A Long Ways in a Long Time….and the List Is Getting Longer and Longer?

As part of the Agency’s ongoing efforts to ensure patient’s access to drugs, FDA is continuing to develop and evaluate a list of bulk drug substances that 503B Outsourcing Facilities can use in compounding, when it has been determined that there is a clinical/medical need that can’t be met by an available FDA-approved drug.  On […]

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08
Jul

Just When you Thought it Was Safe to Come out of the Compounding Hood: Apparent Dearth of Evidence for the Effectiveness & Safety of Compounded Bioidentical Hormone Therapy

In late 2018, FDA entered a contract with the National Academies of Sciences, Engineering, and Medicine (the National Academies) to examine the clinical utility (effectiveness), safety and uses of compounded bioidentical hormone therapy (cBHT).  A high-level committee was formed and examined in detail the clinical utility of cBHT drug preparations, especially those containing estradiol, estrone, […]

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20
Apr
Capsules in mortar

Emergency Preparedness – FDA Continues Active Oversight in the Compounding Space

FDA has been discussing using temporary enforcement discretion in two April 2020 Guidance for Industry documents for sterile compounding during the Covid-19 crisis: “Temporary Policy for Compounding of Certain Drugs for Hospitalized Patients by Outsourcing Facilities During the COVID-19 Public Health Emergency (here)” and “Temporary Policy Regarding Non Standard PPE Practices for Sterile Compounding by […]

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08
Apr
flying money

Out of Sight – Out of Mind – Not Hardly and No Refunds

FDA issues Guidance for Industry: “Fees for Human Drug Compounding Outsourcing Facilities Under Sections 503B and 744K of the FD&C Act, April 2020”. With all that’s going on with Covid-19, FDA is diligently executing their priorities for this fiscal year.  In FY19, FDA’s priorities for Compounding (human drugs) were to: maintain quality manufacturing and compliance; […]

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12
Sep
Bending, Breaking or Moving On Image

Bending, Breaking or Moving On: FDA Expands on its 2018 Compounding Policies Priorities

On September 7, 2018, FDA Commissioner Scott Gottlieb stated that the FDA will expand on their implementation of their 2018 Compounding Priorities Plan and that they feel like they must continue to balance the need to preserve access to appropriately compounded drugs for patients who have a medical need for these products with the need […]

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