Funny you should bring up the beef ban- that was the first thing I thought of when I heard about the FDA letter. The same agency that is taking a hard stance against prohormones allows the Beef industry to pump their cattle with so many synthetic hormones (specifically synthetic estrogen) that the EU has refused to import it for years. They won't feed it to their citizens because it's so unhealthy. (side note: when gymbo's in the US rant and rave about soy increasing estrogen and then run off and eat a bunch of beef instead, I laugh at them)
Welcome to the fun world of the FDA- where the only thing that's consistent is their support for big business.
Interesting conversation- I will chime in- there is one issue that counts when it comes to discussing prohormones and legality: interpretation. For several years leading up to this event, dietary supplement companies were (and some still are) interpreting FDA inaction as acceptance of legality. Unfortunately, the FDA is taking an entirely different stance/interpretation- now they are classifying that PHs are actually unapproved new drug substances, and must be recalled or taken off the market immediately.
cGMP compliance for the industry also plays into this quite a bit- most of the contract mfrs. that manufacture for the rest of the companies on this board (not us, we are cGMP and do it ourselves) are up for inspection as of June 10. If a mandatory inspection occurs at a contract mfr. and they find out they have been mfg. PHs, they are in deep doo-doo.
At best, the inspection is going to be VERY invasive and the agents will do their best to find EVERY violation/observation that they can, and they will stay in the facility for at least a few days, in not weeks going through mfg. records, logs, intake records, plant cleanliness, plant construction, etc. At worst, the responsible person at said contract manfacturing facility and some of the management will end up going to jail (no bs) because they are knowingly manufacturing an unapproved new drug without a license. It is up to arbitrary agent enforcement, unfortunately
It is going to be very hard to find a lot of contract mfrs. that will even touch these compounds, especially since their bread-and-butter is more benign products, like BCAAs, creatine, vitamins, etc. I also don't see a lot of these marketing companies trying to set up their own facility and doing it themselves- it ain't easy, especially now. It takes a lot of technical skill, and knowledge of:
- cGMPs (whole different language)
- pharmaceutical machinery and how to fix something if it breaks (**** happens sometimes)
- validation of processes and process control
- site management and contract management
- training staff properly
- qualatative analysis and quality control
- analytical testing and in-process testing
- calibration and qualification of machinery
- facility design and engineering
- cleaning validation
- keeping proper records (we have 30 different logbooks to keep, plus 3,000+ pages of written SOPs)
- ton of other stuff beyond the scope of this list
It took me a long time to become proficient in all of the above- and a ton of training- the same with the rest of the manufacturers- they probably aren't going to put their livelihood on the line for something like PHs, especially when they account for a very small proportion of their revenue stream- doesn't make any sense. Some guys are undoubtedly going to try to go overseas and try to get these products mfr'd there, but then quality becomes a MAJOR issue- I can tell you some horror stories, LOL. I think this is going to be the end of this side of the market, but more due to enforcement on the cGMP-side of things, and no mfr. wanting to touch the stuff any more.