Wednesday, December 4, 2013

503A: Qualifiying for exemptions so as to use a bulk drug substances to compound as a traditional compounder

Nominations for Lists 

 
Sections 503A and 503B contain various requirements for FDA to develop lists of drugs that may or may not be compounded and lists of bulk drug substances that may be used to compound. Specifically, section 503A specifies that to qualify for the exemptions under section 503A, a compounder may only use bulk drug substances to compound if: 

 The bulk drug substances comply with the standards of an applicable United States Pharmacopoeia (USP) or National Formulary (NF) monograph, if one exists;
  • If such a monograph does not exist, the drug substance(s) is a component of an FDA-approved human drug product; or
  • If such a monograph does not exist and the drug substance is not a component of an FDA-approved human drug product, it appears on a list of bulk drug substances for use in compounding developed by FDA through regulation (section 503A(b)(1)(A)(i) of the FDCA).

 

Section 503B specifies that an outsourcing facility may only compound with a bulk drug substance which appears on an FDA-established list of bulk drug substances for which there is a clinical need or which are on FDA’s drug shortage list.

 

Sections 503A and 503B also prohibit compounding drugs that are on a list of drugs that present demonstrable difficulties for compounding, as published by FDA.

 

FDA has published notices3 requesting nominations for these three lists.

 

In addition, 21 CFR 216.24 contains a list of drugs that may not be compounded because they have been withdrawn or removed from the market because the drugs or components of the drugs have been found to be unsafe or not effective. Compounders may not compound any drugs that appear on this list. FDA intends to issue a proposed rule to update this list by amending section 216.24 and will apply the list to compounders seeking to qualify for the exemptions in either section 503A or section 503B. Nominations for this list can be submitted in comments on the proposed rule.
 
quoted from FDA website

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