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.
The short version: patient-specific compounding under one framework, office-stock production under the other, with much heavier obligations on the second.
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.
It helps to be literal here: registration status is published and searchable. Checking it takes a minute and is the single most useful verification available in this whole area.
Current good manufacturing practice applies to the outsourcing category and not to patient-specific compounding, which is the substantive regulatory difference.
Nothing here is legal or medical advice.
The category tells you which standards apply, not how good the preparation is.
This is the clearest description of the two-tier structure I have read. – k_szabo 6 months ago add a comment