K1. Community Pharmacy Security

Question 1

Security when NO pharmacist is present:

Describe the difference between “closed premises still open to non-registrants” vs “closed pharmacy w/ open premises”

Answer 1

“closed premises still open to non-registrants” means entire premises are CLOSED to the PUBLIC, but still accesible by non registrant staff (i.e. cashers, jannitors).

“closed pharmacy w/ open premises” is when pharmacy itself is CLSOED but other parts of bldg are open to public (ie. grocery store, mall).

Question 2

What are the security requirements for closed premises open to non registrants?

Answer 2

1) dispensary must have a monitored alram system .

2) Sch 1, II, CS and personal health info must be secured behind PHYSICAL barriers (locked cabinets/doors- inaccessible to anyone in bldg after hours)

Question 3

What are the security requirements for “closed pharmacy w/ open premises”?

Answer 3

1) dispensary must have a moniotred alarm system.
2) Sch 1, II, CS and personal health info must be secured behind physical barriers and
3) Sch III drugs (OTC) must be INACCESSIBLE to anyone other than registrants (i.e. cannot be accessible to the public when clsoed) - think save on.

Question 4

What are the 3 Security measures required for sch. IA (CPP) meds?

Answer 4

1) must be stored in a 5-min delay locked metal safe stored securely within the dispensary.

2) pharmacy must have a security camera system that:
- captures images w/ date and time stamps
- sotres images for at least 30 days
- and must be checked daily.

3) MOTION senors must be installed in dispensary area.

Question 5

What is considered a full pharmacist being “present” at a telepharmacy?

Answer 5

remote supervision (doesnt have to be physically present) is considered “present”.

Question 6

What type of pharmacies are excluded from having to display signange at all external entrances that identify the premises as a pharmacy?

Answer 6

any pharmacies that are never open to THE PUBLIC (i.e. specialty or closed door pharmacies in LTC).

Question 7

Do pharmacies that don’t stock Sch. 1A meds (CPP meds) have to declare that they dont stock them?

Answer 7

yes!

Question 8

Permitted Activiites of a cmty pharmacy WITHOUT A FULL RPH PREsent:

In general, can a pharmacy operate w/o a full pharmacist present?

What are the exceptiosn?

Answer 8

generally no, altho there are exceptions.

Exceptions:
pharmcy may continue operations without a full Rph present ONLY IF:

1) the REGISTRAR is notified of the hours during which the full pharmacist is NOT present;
2) the pharmacy is secured adequately (as above security requirements); AND
3) the hours when a full Rph IS ON DUTY is POSTED.

Question 9

What are the ONLY activities that may be carried out if NO full Rph is present?

• what can and can’t they do?

Answer 9

1) techs can only do back-end tasks like preparing Rxs, manage inventory, organize meds.

2) they CAN receive drug shipments and deliveries.

They CANNOT:
- interact/commmunicate with pts
AND
- they cannot do anything that requries Rph supervision.