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The voice for pharmacy compounding  ✧  8 November 2024

This edition is sponsored by Spectrum Pharmacy Products


 

From our CEO

Sometimes we whisper, sometimes we shout

I’ve apparently become the compounding industry’s reporter whisperer.

Scott Brunner

With the advent of GLP-1s — and more specifically compounded GLP-1s — the media has been looking to APC for information and perspective. It’s an ongoing opportunity to educate reporters and the public about compounding, and we’ve seized it.

On the upside, we’ve positioned APC as a credible source of info about pharmacy compounding. Reporters now know us as the national trade association for the compounding industry, and they are reaching out. Daily. Relentlessly. I now spend a good third of any workday dispelling myths, poking holes in drugmaker misrepresentations, and enunciating what law and regulation actually say about compounding. Ditto for APC advocacy chief Tenille Davis.

The result — without a doubt — is news stories that are more balanced and accurate and in which APC’s perspective is included, often prominently. (You can see some samples of this at a4pc.org/inthenews).

This week has been such a week. We’ve briefed reporters from NPR, Reuters, and Politico. We also briefed ABC News producers for an interview next week with APC Board Chair Joe Navarra and me. We’ve also issued some statements — think of them as shouting as opposed to whispering. Below are excerpts of those, so you’ll know what we’re saying.

ABOUT NOVO’S CEO’S COMMENTS ON COMPOUNDED GLP-1 ADVERSE EVENTS

Any serious adverse event, whether from a compounded or FDA-approved drug, is deeply concerning. But context matters, and there’s plenty Mr. Jorgensen left unsaid in his comments this week to CNN — including not mentioning his own FDA-approved drug products’ adverse events records. Moreover, he’s used FDA’s FAERS dashboard to pluck the alarming number of deaths he says have resulted from compounded semaglutide. But the FAERS database itself specifically reminds that a report in the database does not mean that the drug caused the adverse event.

Moreover, as compounded drugs go, there’s often no indication in the FAERS database who prepared the substance in question — was it a legitimate state-licensed compounding pharmacy or a bogus entity claiming to be a pharmacy? That distinction matters, especially if the aim is to prevent more such adverse events. But if the aim is to spin a headline-grabbing narrative that casts pharmacy compounding in a bad light, maybe not.

ABOUT APC’S RESPONSE TO LILLY’S REQUEST TO ADD TIRZEPATIDE TO THE DDC LIST

On August 28, Eli Lilly submitted a comment letter to FDA urging the agency to take emergency action to add tirzepatide to the “Demonstrably Difficult to Compound” list, thereby permanently prohibiting compounding with it.

This week APC responded with a comment letter of our own asking the agency to deny Lilly’s request. Our letter pokes holes in Lilly’s ask — including pointing out that it sure seemed to take the drugmaker a long time to muster enough concern about patients’ safety to write such a letter. It’s enough to make one question the drugmaker’s motive, isn’t it?

(You can read about our letter below.)

ABOUT FDA’S WARNING ABOUT PRODUCTS FROM FULLERTON WELLNESS

It’s not even a pharmacy, folks, much less a compounding pharmacy.

Notice that FDA’s warning last week scrupulously avoids calling it a pharmacy, even though it refers to the non-compliant sterile drugs they were preparing as “compounded drugs.”

For further proof that this is not a pharmacy, try looking it up on the California Board of Pharmacy website. You won’t find Fullerton Wellness to be licensed in California.

So what gives? Well, it may be a med spa that does ‘physician compounding’ — meaning compounding is overseen by a physician, not a pharmacist. It’s a practice authorized in the laws of all 50 states but is not nearly as well regulated as traditional, USP-compliant pharmacy compounding. Or maybe Fullerton Wellness is a bogus pop-up and therefore a criminal enterprise?

I don’t know. But it’s not a compounding pharmacy. So please don’t refer to it as one.

…

Sometimes we whisper. Sometimes we shout. Either way, we’re telling your story — and looking out for millions of patients who, without compounding, might have nowhere else to turn.

—Scott

Scott Brunner, CAE, is the CEO of the Alliance for Pharmacy Compounding. You can reach him at scott@a4pc.org.

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This Week’s News


 

APC to FDA: Just say no to Lilly

This week APC's lawyers sent a formal comment to the FDA. The subject: Eli Lilly’s request that tirzepatide be added to the Demonstrably Difficult to Compound (DDC) list. Lilly’s request was, to borrow a phrase, a target-rich environment — one full of misleading assertions and conveniently omitted facts easy for us to call out.

You can read the full letter here, but here are some highlights:

  • We pointed out that Lilly’s request was so heavily redacted, it was “impossible for compounders to evaluate and respond to the drugmaker’s complexity claim.”
  • Still, we showed how Lilly was deliberately conflating creating the tirzepatide molecule with creating a compounded injection using that molecule.
  • We also called out Lilly’s assertion that there were an outsized number of adverse events related to compounded tirzepatide injections. Among other issues was the fact that there have been tens of thousands of adverse events related to branded Mounjaro and Zepbound. 
  • And, of course, we questioned Lilly’s newfound sense of urgency: “Yet, after nearly two years and millions of doses dispensed, the drugmaker is suddenly urging the FDA to quickly declare that tirzepatide injection is too difficult to compound.”

We think this sentence from our comments sums it up nicely:

“The drugmaker’s nomination of tirzepatide injection to the DDC Lists does not arise out of a sincere concern for patient safety. Rather, it is merely one of several transparent attempts the drugmaker has recently taken to stifle what it improperly perceives as competition.”

California BOP sends proposed compounding regs to comment period

After five hours of public comment at yesterday's meeting, the California State Board of Pharmacy decided to move the modified proposed sterile compounding regulations forward to a 30-day comment period. There will be a notice of proposed action when that comment period starts, and APC will let you know when that notice is released.

"This is not the action we wanted," said APC Advocacy Chief Tenille Davis. "The Board is moving this forward despite some of the most overwhelming opposition I've ever seen. We're just baffled that they are as intent as they are to regulate sterile compounding out of existence in California."

We will continue to engage as the proposal moves through the rulemaking process.

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Checking in on the post-Chevron fallout. What’s happened in the world of federal regulation since the Supreme Court overturned the decades-old Chevron doctrine in its Loper Bright decision? FDA Law Blog takes a look in “As Jurisprudence Under Loper Bright Develops, Early Scorecard is Mixed.”

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Save the Dates

AZ Regional Meeting_1

This month

  • November 14: ARL Bio Pharma free CE webinar: Peering Beyond the Chapter: Elevating Sterile Compounding Practices
  • November 15-17: Personalized Medicine Certification Course 1: Endocrinology in St. Pete Beach, FL virtually via Zoom
  • November 19–21: FDA’s Environmental Monitoring for Outsourcing Facilities, Carlsbad, CA

Later this year

  • December 4:  PCAC meeting on adding several bulk drug substances to the 503A Bulks List
  • December 5: APC CE webinar: Compounding in Special Populations
  • December 5: CompoundED UpDATE Regional Meeting, Scottsdale, AZ
  • December 12–13: FDA/PDA Visual Inspection Training Course, Raleigh, NC
  • December 13: APC Board of Directors Meeting, Las Vegas
  • December 13-15:A4M Longevity Fest, Las Vegas

On demand

  • APC's "The Ethical, Legal, and Regulatory Foundations of Pharmacy Compounding" 15-hour certificate course
  • APC's "Compounding Law and Patient Safety" 3-hour course
  • APC’s EduCon 2024 Virtual Learning Series (6 CE hours)
  • The FDA Compounding Quality Center of Excellence provides these self-guided online courses:
    • Aseptic Process Simulations (Media Fills)
    • Regulatory Framework for Human Compounding
    • Stability and Beyond-Use Dates

Quick Links

APC Career Center

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APC Resources

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Current Issues

  • Adverse Events Reporting Framework
  • Compounded GLP-1s and Drug Shortages
  • GFI #256 on Animal Compounding
  • Saving Compounded Hormones

Events

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  • EduCon
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Invest in APC Efforts

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Membership

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PFM Affinity Service Providers

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  • Pharmacy Technician Certification Board
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  • Shipment Trackers
  • TUI Total Solutions
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Alliance for Pharmacy Compounding, 100 Daingerfield Road, Suite 100, Alexandria, VA 22314

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