Law exam 2 - 247 CMR 2-9 Flashcards
all of the definitions
ACPE means the Accreditation Council for Pharmacy Education.
ACPE-approved Provider means an institution, organization or agency that is recognized by the ACPE, in accordance with its policies and procedures, as qualified to provide continuing education for pharmacists.
Approved College/School of Pharmacy means a college or school of pharmacy which has been accredited by the ACPE or approved by the Board.
Authorized Provider means a person who or agency which, sponsors or co-sponsors one or more contact hours of continuing education for pharmacists and which has received the approval of the ACPE, CME/Category 1, or the Board.
Blood means whole blood collected from a single donor and processed, whether for transfusion or further manufacturing.
Blood Component means that part of blood separated by physical or mechanical means.
Board means the Massachusetts Board of Registration in Pharmacy.
Board-approved Program means a program which has been approved by the Board for continuing education credits. Such program may be sponsored by the ACPE, and/or sponsored or co sponsored by any person who has been granted prior written approval by the Board for the particular program. The Board may, within its discretion, accept comparable continuing education hours approved by other Boards of Pharmacy.
Certificate of Approved CEUs means a document, issued to a named pharmacist by an authorized provider, certifying that the pharmacist has satisfactorily completed a specified number of CEUs.
Certificate of Fitness means a document issued by the Board to a pharmacy or pharmacy department which permits a pharmacy or pharmacy department to use alcohol for the manufacture of U.S. Pharmacopoeia or National Formulary preparations and all medicinal preparations unfit for beverage purposes, and to sell alcohol as authorized under M.G.L. c. 138.
Certified Pharmacy Technician means a pharmacy technician who is currently:
(a) registered by the Board; and
(b) certified by a Board-approved certifying body.
A pharmacy technician may perform the duties authorized to be performed by a certified pharmacy technician in 247 CMR 8.04: Certified Pharmacy Technicians when Board-approved certification is current. If certification lapses, the individual is required to function as a pharmacy technician until certification is current.
Contact Hour means a unit of measure of educational credit which is a minimum of 50 minutes, or the equivalent as determined by the Board, of satisfactory participation in a Board-approved program of continuing education.
Continuing Education (CE) means participation by registered pharmacists in Board-approved educational programs and is a prerequisite for the renewal of a personal registration.
Continuing Education Unit (CEU) means a unit of measure of educational credit which is equal to ten contact hours, or it’s equivalent as determined by the Board, of satisfactory participation in a Board-approved program of continuing education.
Controlled Substance means a drug, substance, or immediate precursor in any schedule or class referred to in M.G.L. c. 94C.
Controlled Substance Registration means a document issued by the Board which allows the holder to receive and dispense, pursuant to a valid prescription, controlled substances.
CME/Category 1 means continuing medical education (CME) credits sponsored by an organization accredited for CME by the Accreditation Council for Continuing Medical Education, the Postgraduate Medical Institute or the state medical society.
Customer Identifier means the identification number on a valid government issued identification, as specified by the Department, which a pharmacy obtains by inspecting the identification of the ultimate user or agent of the ultimate user to whom a prescription is dispensed. (105 CMR 700.001: Purpose)
Department means the Massachusetts Department of Public Health.
Direct Supervision means:
(a) the type of supervision a Board approved registered pharmacist preceptor in a pharmacy, pharmacy department, or institutional pharmacy is required to provide to a pharmacy intern when said preceptor oversees and directs the professional activities of the pharmacy intern, and includes directly reviewing the work of the intern; and
(b) the type of supervision a registered pharmacist in a pharmacy, pharmacy department, hospital pharmacy, or institutional pharmacy is required to provide a pharmacy technician when said pharmacist oversees and directs the activities of the pharmacy technician.
Dispensing means the physical act of delivering a drug, chemical, device or combination thereof to an ultimate user pursuant to the lawful order of a practitioner, as defined in M.G.L. c. 94C, § 1, including the utilization of the professional judgment of the pharmacist and the packaging, labeling, or compounding necessary to prepare the drug, chemical, or device for delivery.
Drug Sample means a unit of a prescription drug that is not intended to be sold.
Electronically Transmitted Prescription means an order of a practitioner which has been transmitted electronically to a pharmacy in accordance with 105 CMR 721.020: Prescription Formats.
Facsimile Machine (fax) means a machine that electronically transmits exact images through connection with an electronic network.
FPGEC means the NABP’s Foreign Pharmacy Graduate Examination Committee.
FPGEC Certificate means a document issued by the NABP evidencing the assessment of the educational equivalency of a graduate of a non-approved college/school of pharmacy.
FPGEC Certification means the NABP’s Foreign Pharmacy Graduate Examination Committee’s process of documenting and assessing the educational equivalency of a graduate of a non- approved college/school of pharmacy.
FPGEE means the NABP’s Foreign Pharmacy Graduate Equivalency Examination.
Good Moral Character means those virtues of a person which are generally recognized as beneficial to the public health, safety and welfare.
Good Standing means the pharmacist’s personal registration is not currently being sanctioned by the Board.
Graduate of Non-approved College/School of Pharmacy means a pharmacist whose undergraduate pharmacy degree was not conferred by an ACPE-accredited or Board-approved college/school of pharmacy yet was conferred by a recognized college/school of pharmacy outside of the United States, the District of Columbia and Puerto Rico. Recognized colleges/schools of pharmacy are those colleges and universities listed in the World Health Organization’s World Directory of Schools of Pharmacy, or otherwise approved by the FPGEC.
Home-study and Other Mediated Instruction means continuing education activities which do not provide for direct interaction between faculty and participants and may include audio tapes, video tapes, cable television, computer assisted instruction, journal articles and monographs.
Institutional Pharmacy means the physical portion of an organization, including but not limited to hospitals, health maintenance organizations and clinic pharmacies, whose primary purpose is to a provide a physical environment for patients to obtain health care services under the supervision and direction of a registered pharmacist and is authorized to dispense controlled substances.
Internship means the period of training under the supervision of a Board-approved registered pharmacist preceptor, which training is a prerequisite to examination for personal registration as a pharmacist in the Commonwealth of Massachusetts.
Legend Drug, Device or Gas means a drug, device or gas which by federal law must bear the legend: “Caution: Federal law prohibits dispensing without prescription.”
Live Program means a continuing education program that provides for direct interaction between faculty and participants and may include, but not be limited to, lectures, symposia, live teleconferences and workshops.
Manager of Record or Pharmacist Manager of Record means a pharmacist, currently registered by the Board pursuant to 247 CMR 6.07: Pharmacist Manager of Record, who is responsible for the operation of a pharmacy or pharmacy department in conformance with all laws and regulations pertinent to the practice of pharmacy and the distribution of drugs.
Manufacturer means a person who is engaged in manufacturing, preparing, propagating, compounding, processing, packaging, repackaging or labeling a prescription drug.
MPJE means the Multistate Pharmacy Jurisprudence Examination. NABP means the National Association of Boards of Pharmacy.
NABP Number is a unique seven digit number issued by the National Council for Prescription Drug Programs.
NAPLEX means the North American Pharmacist Licensure Examination.
National Drug Code (NDC) Number means a nationally recognized standard which identifies drug products using a unique number issued by the United States Food and Drug Administration. The NDC number has three components: the first component identifies the drug manufacturer (“Labeler No.”); the second component identifies the product (“Product No.”); and the third component identifies the package size (“Pkg.”).
NCPDP means the National Council for Prescription Drug Programs.
Over-the-counter Drug means any drug whose availability is not restricted to an order of a practitioner.
Person means an individual, corporation, government, governmental subdivision or agency, business trust, estate trust, partnership or association, or any other legal entity.
Personal Registration means a document issued by the Board to a qualified pharmacist, under the provisions of M.G.L. c. 112, § 24, permitting the pharmacist to engage in the practice of pharmacy.
Pharmacy means a facility under the direction or supervision of a registered pharmacist which is authorized to dispense controlled substances. The term “pharmacy” shall not include institutional pharmacies or pharmacy departments except as otherwise provided in 247 CMR.
Pharmacy Department means that part of a retail store registered by the Board in which a drug business, as defined in M.G.L. c. 112, § 37, is transacted.
Pharmacy Intern means an individual who has completed two years of academic curriculum or who has standing as a student beyond the second-year class in the undergraduate academic sequence of an approved college/school of pharmacy, and who is registered by the Board to acquire, under the direction of a Board-approved registered pharmacist preceptor to whom he or she has been assigned, that practical experience which is a prerequisite to examination for personal registration as a pharmacist. A pharmacy intern may engage in the full range of activities conducted by a registered pharmacist provided that at all time he or she is under the direct supervision of a registered pharmacist preceptor.
Pharmacy Permit means a document issued by the Board to a registered pharmacist in the name of a pharmacy or pharmacy department to manage and operate a pharmacy or a pharmacy department.
Pharmacy Technician means an individual who is registered by the Board, pursuant to 247 CMR 8.02: Pharmacy Technicians, who performs pharmacy duties under the direct supervision of a pharmacist.
Pharmacy Technician Trainee means an individual preparing to be registered as a pharmacy technician who performs pharmacy duties under the direct supervision of a pharmacist.
Postgraduate means graduation and award of an entry-level degree in pharmacy from a Board- approved or ACPE-accredited college/school of pharmacy.
Practitioner means any person with prescriptive privileges as defined in M.G.L. c. 94C, § 1.
Preceptor means a registered pharmacist in good standing who has completed at least one year of the actual practice of pharmacy and who the Board has approved to supervise and direct the training of pharmacy interns and to assist in the training of other pharmacy interns.
Prescription means an order for a drug, chemical, device or combination thereof, either written, given orally or otherwise transmitted to a registered pharmacy by a practitioner or his or her expressly authorized agent, to be dispensed or compounded in a registered pharmacy and dispensed by a registered pharmacist to a patient or his or her agent with necessary and appropriate counseling.
Prescription Drug means any and all drugs which, under Federal Law, are required, prior to being dispensed or delivered, to be labeled with the statement “Caution, Federal law prohibits dispensing without prescription” or a drug which is required by any applicable Federal or State law or regulation to be dispensed pursuant only to a prescription drug order.
Prescription Device means an instrument, apparatus, implement, machine, contrivance, implant, or other similar related article, including any component part or accessory, which is required by federal law and regulations to bear the label, “Caution, Federal law prohibits dispensing without prescription” or a device which is required by any applicable Federal or State law or regulation to be dispensed pursuant only to a prescription order.
Program means an educational course, lecture, seminar, conference, session or exercise.
Registered Pharmacist (R.Ph.) means a pharmacist who, pursuant to the provisions of M.G.L. c. 112, § 24, is registered by the Board to practice pharmacy.
Restricted Pharmacy means a pharmacy licensed by the Board for the limited transaction of a drug business as defined in M.G.L. c. 112, § 37.
Universal Claim Form (UCF) means a nationally recognized standard form developed by the NCPDP used for billing prescription drug claims to insurance plans. Universal Claim Forms are available through a pharmacy’s local wholesaler.
Wholesale Distribution means distribution of prescription drugs and prescription devices to persons other than a consumer or patient, but does not include:
(a) Intracompany sales;
(b) the purchase or other acquisition by a hospital or other health care entity that is a member of a group purchasing organization of a drug or device for its own use from the group purchasing organization or from other hospitals or healthcare entities that are members of such organizations;
(c) the sale, purchase or trade of a drug or device or an offer to sell, purchase or trade a drug by a charitable organization described in section 501(c)(3) of the Internal Revenue Code of 1954 to a nonprofit affiliate of the organization to the extent otherwise permitted by law; (d) the sale, purchase or trade of a drug or device or an offer to sell, purchase or trade a drug or device among hospitals or other health care entities that are under common control; for purposes of 247 CMR 7.00, “common control” means that power to direct or cause the direction of the management and policies of a person or an organization, whether by ownership of stock, voting rights, by contract or otherwise;
(e) the sale, purchase or trade of a drug or device or an offer to sell, purchase, or trade a drug or device for emergency medical reasons; for purposes of 247 CMR 7.00, “emergency medical reasons” includes transfers of prescription drugs or devices by a retail pharmacy to another retail pharmacy to alleviate a temporary shortage;
(f) the sale, purchase or trade of a drug or device, an offer to sell, purchase or trade a drug or device, or the dispensing of a drug or device pursuant to a prescription;
(g) the lawful distribution of drug samples by manufacturers’ representatives or distributors’ representatives; or
(h) the sale, purchase or trade of blood and blood components intended for transfusion.
Wholesale Distributor means a person engaged in wholesale distribution of prescription drugs or devices including, but not limited to, manufacturers; repackers; own-label distributors; private-label distributors; jobbers; brokers; warehouses, including manufacturers’ and distributors’ warehouses, chain drug warehouses, and wholesale drug warehouses; independent wholesale drug traders; and retail pharmacies that conduct wholesale distributions.
section 3
Describe the requirements for obtaining a pharmacist license via the examination process.
what if the school is not accredited
1- graduate ACPE-accredited and Board-approved college/school of pharmacy
- at least 18 years old
- completed an internship according to section 8
- a good moral person
2- apply to take the exam
- correctly filled by the applicant
- passport-size photograph
- birth certificate
- pay
3- take and pass both NAPLEX and MPJE.
4- score at least 75% on both exams (if not apply to take both exams again)
- if failed, reapply for the exam and take it within one year of the reapplication
if the school is not accredited
- at least 18 years old
- has a Foreign Pharmacy Graduate Examination Committee (FPGEC) Certification from NABP
- submit a certification to the board
- completed an internship
- good morals person
3
Describe the requirements for licensure by reciprocity.
in general:
1 - proof that they are licensed by examination in another state or jurisdiction and that the applicant is in good standing in all states where the applicant holds a license
2- submit a preliminary application to NABP for license transfer,
3- if the board does not approve, the applicant may in writing request the Board to review the basis of NABP’s decision.
4- The board makes the final decision
5- the fee paid is nonrefundable
if you graduated from an ACPE-accredited
1- NABP approval
2- documentation of internship experience
- Passing score (at least 75%) on MPJE
- if requested, the applicant shall personally appear before the Board to discuss any matter related to the application
5- if approved by NABP and all fee(s), unless waived are made, the applicant may register with NABP to take MPJE.
if did not graduate from ACPE accredited program
1- Receipt by the Board of an official copy of the applicant’s FPGEC Certificate from NABP
2- documentation of internship experience
3- passing score (at least 75%) on MPJE
4- if requested, the applicant shall personally appear before the Board to discuss any related matter
5- if approved by NABP and all fee(s), unless waived are made, the applicant may register with NABP to take MPJE.
3
Explain the difference between score transfer, reciprocity and examination by license.
license by:
score transfer- allows you to move ahead with licensure in more than one state as soon as you pass the NAPLEX
reciprocity- you are already a pharmacist, but you are applying to practice in another state
examination- you are taking an exam to become licensed and apply to take exam to do that
:)
3
What is the passing grade needed for each component for licensure of a pharmacist by examination.
75% for both NAPLEX & MPJE
3
What is licensure retirement?
uhhh, he did not go over cause we are not thinking of that right now :)
YOU’RE DOING GREAT
4
Provide a chart describing the expiration date of the various types of licenses and registrations (personal, business, DEA)
Personal
- expire on December 31st of each even-numbered year and shall be renewed before January 1st of the following year
- so every 2 years!
business (pharmacy store)
- each uneven year (or I also saw every 2 years)
DEA
- 3 years
4
Provide a chart with dates and requirements for reinstating a lapsed license.
4
Describe the requirements for pharmacist CE.
Be sure to include types of CE needed, max per day, Sterile, Non-Sterile, immunizations, PMP, and Collaborative Practice.
general:
- need 40 hours before renewal
- 20 hours a year
- at least 2 hours per year in law
- no more than 15 contact hours may be at-home study
- cannot be carried over from year to year
- do not have to complete CE in the year you graduated
need for registration renewal!
types of CE
max per day
- 8 hours
Sterile
- if you oversee are involved in sterile compounding: 5 contact hours a year
Non-Sterile
- if you oversee are involved in non-sterile compounding: 3 contact hours a year
immunizations (or vaccines)
- if you oversee are involved in immunizations: 1 contact hours a year
PMP
- for CS
- Have to file and track how much Rx the patient takes and monitor even between other pharmacies
- patient profile for RPh to keep track of what CS the patient gets
- The PMP tracks statewide Schedule II-V prescriptions. With this system in place, we can give practitioners the tools they need to make the best clinical decisions
Collaborative Practice
- RPh can have prescribing authority, and can complete a few prerequiisites and complete CE per year
- CDTM
- 247 16
4
How many CEs are needed per calendar year
20
4
How many CEs are needed per renewal period
40
4
What types of CEs are allowed
Board approved
ACPE
CME
4
How long are you require to keep records of CEs
at least 2 years from the date of completion
5
What are the requirements for electronically transmitted prescriptions.
- can be given by an authorized prescriber
- can be given by the agent of the authorized prescriber
- given to the pharmacy of the patient’s choice
- Rx must maintain patient confidentiality
- pharmacist or pharmacy may not agree to provide to the patient a computer, facsimile (fax) machine, computer modem, or any other electronic device that will affect the patient’s freedom to choose the pharmacy they want
- The pharmacist or pharmacy may not provide to the prescriber or healthcare facility a computer, facsimile (fax) machine, computer modem, or any other electronic device to get an incentive for referring the patient to a pharmacy
5
What types of prescriptions can be sent electronically?
CII-CVI
all prescriptions for controlled substances and medical devices must be issued electronically
5
Describe when an oral CII may be accepted.
for emergencies!
where the prescriber says
- the CII is needed for the immediate treatment of the ultimate user
- there is no other option, not even any other CS
- they cannot give a written Rx by the time of dispensing
where the pharmacist
- only gives enough CS for the emergency
- sees that the Rx has everything an Rx should except for a signature
- makes a good-faith effort to verify the Rx was given by an authorized prescriber
5
Describe the requirements for an Emergency Situation for oral CII.
for emergencies!
where the prescriber says
- the CII is needed for the immediate treatment of the ultimate user
- there is no other option, not even any other CS
- they cannot give a written Rx by the time of dispensing
where the pharmacist
- only gives enough CS for the emergency
- sees that the Rx has everything an Rx should except for a signature
- makes a good-faith effort to verify the Rx was given by an authorized prescriber
5
What are the pharmacist’s obligations for filling a Emergency CII?
where the pharmacist
- only gives enough CS for the emergency
- sees that the Rx has everything an Rx should except for a signature
- makes a good-faith effort to verify the Rx was given by an authorized prescriber
5
What is the time period required to receive a hard copy for an oral controlled substance?
2 days electronic, 7 days hard copy
5
What are the requirements for a prescriber to do on the hardcopy follow-up for a oral controlled CII.
- must include the additional notation, “Authorization for Emergency Dispensing.”
- have “to document an oral prescription.” on its face
- delivered either by mail (post marked for 7 says) or in-person
- No written follow-up is required for schedule VI oral prescriptions
5
What happens if a hardcopy follow up prescription is not provided for a CII
if they fail to issue a follow-up written or electronic prescription within seven business days, the pharmacist is required to notify the U.S. Drug Enforcement
5
Describe the PMP requirements
Pharmacy
- applies to registered pharmacies and pharmacies in a health facility
- give the Department the required information for each Rx according to CMR 7
Penalties
- if fails to comply with CMR 7, or state law or regulation, there will be disciplinary action
- disciplinary action against pharmacist or pharmacy by the board or state and federal law enforcement
6
Describe the application process for a new pharmacy
- signed by a pharmacist who wants to manage and operate a new pharmacy
- include days and hours of operation (opening and closing)
- separate application from the board for an MA CS registration and certificate of fitness
- check or money order for the Commonwealth of MA Board of registration in pharmacy
- any info. given by the board
- a copy of the corporation’s Articles of Organization, signed and sealed by the Secretary of the Commonwealth
- a copy of the corporation’s Foreign Corporation Certificate, signed and sealed by the Secretary of the Commonwealth
- a statement of the name and address of each officer and director of the corporation and the position
6
Will the Board register a pharmacy where the owner has prescriptive privileges?
no
6
Describe the equipment and referenced need for a pharmacy
when inspected, the pharmacy must have:
-equipment compliant with USP
- Massachusetts List of Interchangeable Drugs (MLID)
- Orange book
- current copy of compendia
- a copy of board regulations
- a balance that can weigh as small as 13 mg, tested and sealed by state or local sealer of weights and measured annually
- Rx labels with name and address of pharmacy
- sanitary appliances like sinks with hot and cold water
- 1 bound book for recording CS sold w/o Rx
- 1 book for recording sales of alcoholic beverages and signatures of the purchasers of alcohol
- clean room for IV meds- closed, laminar flow, minimum 72 sq ft, hood,
- consultation area
6
Explain what the patient consultation area is, are there any requirements for a sign and location
- designed to provide adequate privacy for confidential visual and auditory patient counseling
- needs a sign that says “Patient Consultation Area”
- needs to be accessible for the patient to not have to go through the stockroom or Rx area
- 4 by 5-inch sign
6
What is the minimum size requirements for a pharmacy?
- There shall be a minimum working area of 300 square feet;
6
Describe the security requirements for a pharmacy
- CS II-V stored within Rx area
- CS VI stored within Rx area or clean room
- CS II-V must be stored in a securely locked cabinet, or dispersed in the prescription-drug storage area throughout the stock of Schedule VI–obstruct theft
- separate alarm activated for when the pharmacy is closed
- secured by a floor and ceiling barrier
- locked and alarmed separately at all times
- pharmacy manager and pharmacist on duty control access to the Rx area
6
Is a sign required identifying the location as having a pharmacy
yes
visible to signal the presence of a pharmacy
ex: CVS Pharmacy, Wholefoods has a pharmacy sign outside
6
What form is used to report a theft or loss of a controlled substance
106
6
Provide a chart describing the various signs that are requirement in a pharmacy and if there are size requirements for the sign or letters, if yes what are the size requirements
6
What are the requirements for notifying the Board of a loss of a controlled substance
- report within 7 days of the theft or loss
- comply with state and local police reporting requirements
6
Describe the process for a change in the manager of record
- apply to the board
- a statement saying that the old manager is handing off the complete inventory of the CS to the new manager. If the old one is not available then the staff RPh can sign off
- application for a certificate of fitness
- the pharmacy permit
- required fees
- any more info. by the board
6
Provide a chart listing requirements and dates that a pharmacist needs to provide the Board. For example, how many days to report a name change, new manager of record, etc
- changes his or her mailing address or name shall notify the Board in writing within ten working days
- notification to the Board in writing of his or her termination as pharmacist Manager of Record within ten working days
- closure of pharmacy or department is within 10 days
- written plan of correction of violations cited in a deficiency statement within 15 business days after the deficiency statement is sent.
- seven business days to Report Certain Factors of Pharmacy Operations
- changes like withdrawal, discontinuance, termination, revocation, suspension, probation, or warning reported within 7 business days
- report within seven business days of identification of all errors relating to the preparation of medications in that pharmacy inconsistent with United States Pharmacopeia
- seven business days all abnormal results, including failure of certification as required
6
Who is required to verify that a pharmacist is registered by the Board.
the pharmacist’s employer
or
the pharmacist Manager of Record
6
What needs to be done if there is a remodel or change in the square footage of the pharmacy?
submit copies of its structural plans to the Board for approval.
6
Describe the requirements for a pharmacist manager of record
- maintain necessary pharmaceutical equipment and reference
- the proper maintenance of records as required by the Massachusetts Controlled Substances Act
- the maintenance at all times of adequate pharmacy and pharmacy department security consistent Board regulations
- the establishment, monitoring and enforcement of policies and procedures that encourage acceptable standards of practice
- the establishment, monitoring and enforcement of policies and procedures which maintain the standards of professional practice
- the maintenance of adequate staff in the pharmacy or pharmacy department in order to ensure that the practice of pharmacy
- the maintenance of records relating to the responsibilities of pharmacy technicians
- notification to the Board in writing of his or her termination as pharmacist Manager of Record within ten working days;
- taking an inventory of controlled substances in Schedules II, III, IV, and V, based upon federal biennial inventory requirements,
- the establishment of procedures for validating questionable purported controlled sub stance prescriptions and for reviewing existing prescription information, to deter the willful and unlawful dispensing of controlled substances.
6
What is a certificate of fitness, when is it used
certifies an individual or organization as being competent to engage in a particular work activity or industrial project.
6
When can a pharmacy be inspected and by whom?
- before the final approval of application is granted
when inspected, the pharmacy must have:
-equipment compliant with USP
- Massachusetts List of Interchangeable Drugs (MLID)
- Orange book
- current copy of compendia
- a copy of board regulations
- a balance that can weigh as small as 13 mg, tested and sealed by state or local sealer of weights and measured annually
- Rx labels with name and address of pharmacy
- sanitary appliances like sinks with hot and cold water
- 1 bound book for recording CS sold w/o Rx
- 1 book for recording sales of alcoholic beverages and signatures of the purchasers of alcohol
- clean room for IV meds- closed, laminar flow, minimum 72 s
