Comment from Field Vitality LLC
AnonymousSupportBusiness
Summary: Kevin McDonagh, Co-Founder of Field Vitality, supports including specific peptides (BPC-157, TB-500, and MOTS-C) on the 503A Bulk Drug Substances List. He argues that regulatory clarity is needed to allow compounding pharmacies to safely and legally provide these therapies to patients.
Dear Committee Members,
I write to you from the front lines of healthcare access. As a
co-founder of Field Vitality, my daily work involves building the
pharmacy and provider infrastructure that will deliver peptide
therapies to patients who need them. What I have learned in this
process is that the current regulatory framework is failing both
patients and the legitimate pharmacies trying to serve them.
Over the past months, I have spoken with dozens of 503A compounding
pharmacies across the country. Every single one reports the same
pattern: demand for peptide therapies is surging, but regulatory
uncertainty prevents them from investing in capacity, formulation
development, and quality infrastructure. Pharmacies that could be
producing pharmaceutical-grade BPC-157, TB-500, and MOTS-C are instead
turning patients away — or watching those patients purchase unverified
products online.
This is not a theoretical problem. I have seen the pricing sheets from
gray market suppliers. I have heard the stories from patients who
received contaminated product. I have spoken with pharmacists who want
to compound these therapies legally but cannot because the regulatory
path is unclear.
The irony is that the infrastructure already exists. America's 503A
compounding pharmacies are FDA-registered, state-licensed, and capable
of producing high-quality peptide therapeutics. What they lack is
regulatory clarity. Placing these peptides on the 503A Bulks List
would immediately unlock this existing capacity.
The July 23-24 meeting is an opportunity to make a decision that will
affect patient safety for years to come. I urge you to act in favor of
access, quality, and patient choice.
Sincerely,
Kevin McDonagh
Co-Founder — Field Vitality
Maui, HI