Saturday, May 17, 2014

FDA and State Registration for Outsourcing Facilities

Posted by Brian Williamson on Fri, May 16, 2014 @ 11:20 AM
The passing of the Drug Quality and Security Act (DQSA) in November of 2013 was one of the most significant events in the compounding industry in decades.  The DQSA came to fruition after many months of debate and controversy over who had authority and jurisdiction over sterile compounding pharmacies. The result was that a sterile compounding pharmacy could voluntarily register with the FDA as a 503B Outsourcing Facility.  According to the DQSA, this type of registration allows a sterile compounding pharmacy to ship products via interstate commerce without the need for specific patient prescriptions.  However, it does place the pharmacy squarely under the jurisdiction of the FDA and subjects the facility to current Good Manufacturing Practices (cGMP).  cGMP are the regulations that large pharmaceutical manufacturing firms must adhere to in their daily practices.  Complying with cGMP can be a daunting task and not every sterile compounder will elect to register as an Outsourcing Facility.  
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