Clinical Context

The FDA proposal names semaglutide, tirzepatide, and liraglutide for potential exclusion from the 503B bulks list; the 503B bulks list identifies bulk drug substances that outsourcing facilities may use in compounding under section 503B of the FD&C Act [3]. When FDA-approved drugs are available, outsourcing facilities generally cannot lawfully compound using bulk drug substances unless the substance appears on the 503B bulks list, or the compounded drug is on the FDAโ€™s drug shortage list at the time of compounding, distribution, and dispensing [3]. Semaglutide is an FDA-approved glucagon-like peptide-1 (GLP-1) receptor agonist available in subcutaneous injection (OZEMPIC) and tablet forms (RYBELSUS and OZEMPIC tablets) and is marketed by Novo Nordisk Pharmaceutical Industries, LP; its approved indications include improving glycemic control in adults with type 2 diabetes mellitus and reducing risk of major adverse cardiovascular events in adults with type 2 diabetes and established cardiovascular disease, among other labeled indications [1][2][4].