Which Makes More Sense - Employ GMP Validation Personnel or Engage a Third-Party?

Bio/pharmaceutical, advanced therapy, and 503B manufacturing facilities often face the decision of hiring in-house validation personnel or engaging third-party consultants for facility and equipment IQOQPQ. While both approaches have merits, outsourcing validation activities to specialized consultants frequently emerges as a more cost-effective and efficient GMP validation solution.

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Amy Summers
Starting a 503B Outsourcing Facility: What You Need to Know

Starting a 503B outsourcing facility is a significant undertaking, requiring careful planning, investment in infrastructure, and a deep commitment to quality. By thoughtfully considering your capabilities, designing a compliant facility, investing in proper equipment, adhering to cGMPs, and hiring well-trained personnel, you will set the foundation for a successful operation.

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Amy Summers
A Deep Dive into FDA’s Top 483 Observations for 503B Outsourcing Facilities: Insights from the 2024 FDA Compounding Quality Center of Excellence Annual Conference

In August 2024, the FDA held its annual Compounding Quality Center of Excellence Conference, where the agency provided key insights into the most common Form 483 observations for 503B outsourcing facilities. These observations highlight compliance issues that outsourcing facilities must address to ensure regulatory adherence and maintain patient safety. In this article, we’ll examine the top Form 483 observations shared at the conference and discuss best practices for addressing these compliance issues.

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Amy Summers
Considerations for the 503B-to-503A-to-Patient Compounding Model

A recent FDA draft guidance was issued to permit 503B facilities to sell compounded drugs to 503A pharmacies, which can then dispense these products directly to patients pursuant to a valid prescription. This guidance has significant implications for the regulatory landscape, operational practices, and business strategies of 503A compounding and traditional community pharmacies.

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Amy Summers
Strategies for 503Bs to Scale Up and Decrease Costs

For 503B outsourcing facilities, scaling up production and reducing costs is essential for maintaining competitiveness in this niche industry. By applying principles of production volume and economies of scale, 503B facilities can achieve greater efficiencies, streamline workflows, and lower operational costs while ensuring compliance with FDA regulations. Here’s an in-depth approach to achieving this goal.

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Amy Summers
The True Cost of Poor Quality in Drug Compounding — Why 503A and 503B Facilities Must Invest in Quality for Long-Term Success

This article explores why investing in quality within 503A and 503B facilities is not only necessary but also the key to thriving in a highly regulated and scrutinized environment. In the 503A and 503B pharmaceutical compounding industry, poor quality is not an option. From the risks of regulatory penalties to the potential for patient harm, the consequences of inadequate quality management can be devastating. But by making strategic investments in quality systems, fostering a culture of quality, and leveraging regulatory incentives, compounding facilities can reduce risks, improve efficiency, and, most importantly, protect patient safety.

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Amy Summers
The FDA's Proposed Rule on Difficult-to-Compound Drugs: A Comprehensive Overview

The FDA's proposed rule on drugs deemed difficult to compound marks a significant shift in regulatory oversight. This rule targets three specific categories: oral solid modified-release drug products with coated systems (MRCs), liposome drug products (LDPs), and drug products made via hot melt extrusion (HME). The FDA uses six criteria to assess difficulty: complexity in formulation, drug delivery mechanisms, dosage forms, bioavailability, compounding processes, and testing requirements. If implemented, this rule could significantly impact the compounding industry, limiting the ability to produce certain complex medications and potentially affecting patient access to customized treatments.

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Amy Summers
Why 503As & 503Bs Need Advisors — And Why Restore Health Consulting LLC is the Right Partner

The compounding industry is complex, and success requires more than just meeting minimum regulatory standards—it requires a commitment to quality, operational efficiency, and proactive planning. For 503A and 503B drug companies, partnering with a specialized consultant like Restore Health Consulting LLC can make the difference between compliance struggles and long-term success.

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Amy Summers
Conducting a Detailed Risk Assessment for Cleaning Validation in 503A and 503B Compounding Facilities

Risk assessment is a critical component of the cleaning validation process in the compounding industry. It helps identify potential hazards, assess their impact, and prioritize efforts to mitigate risks associated with contamination. Conducting a thorough risk assessment ensures that the cleaning processes are robust, effective, and safeguard patient safety. This article describes a detailed example of how a risk assessment for cleaning validation might be conducted.

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Amy Summers
503B Outsourcing Facility Start-Ups – Commissioning, Qualification, and Validation

As FDA has yet to finalize CGMP guidance or promulgate finalized regulations pertaining to the 503B industry, it can be challenging for 503B outsourcing facilities to fully grasp the key requirements for facility and equipment commissioning, qualification, and validation. This article aims to introduce these concepts and connect decision makers to expert CGMP facility and equipment commissioning, qualification, and validation service providers.  

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Amy Summers
The Fight for Access to Compounded Bioidentical Hormone Therapy (cBHT)

A report published in 2020 by the National Academies of Science, Engineering, and Medicine (NASEM) discussing compounded bioidentical hormone replacement therapies (cBHT) could jeopardize patient access to these drugs if FDA were to follow their proposal. Since the NASEM report was released, however, a grassroots movement lead by the Alliance for Pharmacy Compounding has been mounting aimed to preserve patient access to cBHT. As of October 2, 2023, five senators have formally urged FDA to permit continued access to cBHT.

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Amy Summers
Key Take-Aways From FDA Guidance Document: Prohibition on Wholesaling Under Section 503B

The FDA released a new preliminary guidance regarding the Prohibition on Wholesaling under Section 503B of the Federal Food, Drug, and Cosmetic Act. The document aims to clarify that pharmacies licensed at the state level are permitted to dispense compounded drugs purchased from 503B outsourcing facilities. It provides specific examples of activities that are prohibited and those that are not.

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Amy Summers
FDA Announces Withdrawal Approval of Premature Birth Drug, Makena, Prompting Compounded Vaginal Progesterone as a Potential Alternative

The FDA officially withdrew the accelerated approval of Makena, a hydroxyprogesterone caproate injection, on April 6, 2023. It is suggested compounders steer clear of compounding it to remain consistent with the FDA’s sentiment. Given the lack of FDA-approved alternatives, this could prompt the clinical need for progesterone vaginal preparations as a potentially helpful alternative for this patient population.

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Amy Summers
Hormone Replacement Therapy: Justifications for Compounded Bioidentical Options

Prescribers and regulators may question the clinical need of compounded bioidentical hormone therapies (cBHT) and how they differ from FDA approved drug products. The argument for compounding identical hormones is no longer useful, given the number of estradiol products available in topical forms, but the differences between those and what compounders offer are still unique and significant.

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Compounding Animal Drugs from Bulk Substances - FDA Guidance GFI #256 Update

The US Food and Drug Administration (FDA) published Guidance for Industry #256: Compounding Animal Drugs from Bulk Drug Substances (GFI #256) after careful consideration and significant input from veterinarians, on August 2022. While the guidance specifically addresses compounding from bulk drug substances for animal use, several questions remain. This article aims to provide clarity to some of those questions.

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Amy Summers
Effective Immediately: FDA Releases Guidance for Compounding Industry in Response to Beta-Lactam Shortage

The Food and Drug Administration (FDA) added amoxicillin oral powder for suspension to the drug shortage list and has released guidelines on the creation of compounded versions of specific beta-lactam oral suspension products due to the current lack of amoxicillin oral antibiotic powder for suspension. High demand for amoxicillin oral antibiotic suspension products, coupled with requests for clarification on the preparation of compounded versions, have prompted the Federal Agency to issue compounding recommendations for pharmacists in state-licensed pharmacies and federal facilities not registered as outsourcing sites.

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Amy Summers