The Pharmacy Physical Space

Question 1

when is there no access to the pharmacy

Answer 1

when there is no pharmacist within the pharmacy

exception: after an administrative inspection warrant is issued i.e. no pharmacist needs to be present?

Question 2

Minimum square footage of a pharmacy

Answer 2

300 sq. ft

Question 3

Administrative inspection warrants that allow for access to the pharmacy without a pharmacist present

Answer 3

●Warrants for the purpose of inspecting, copying and verifying the correctness of records, reports or other documents required to be kept by a registrant on controlled premises and for the seizure of property appropriate to such inspection and shall

● Directed to the commissioner, commissioner designee, designee of BOP or police officer

● A person executing an administrative inspection warrant may:
o Use reasonable force and means to execute the warrant
o Inspect and copy records required
o Inspect, within reasonable limits everything in the controlled premises
o Inventory any stock of any controlled substance and obtain samples

Question 4

Minimum counter space?

Answer 4

n/a

Question 5

Are there counseling area requirements?

Answer 5

yes

A pharmacy must provide a designated area for consultation with a sign that states “Patient Consultation Area”.

The area must be designed to provide adequate privacy for confidential visual and auditory patient counseling.

The private consultation area must be accessible by a patient from the outside of the prescription dispensing area without having to traverse a stockroom or the prescription dispensing area.

Question 6

What security system requirements are there

Answer 6

The pharmacy must be secured by a floor to ceiling barrier, securely locked and separately alarmed when the pharmacy/pharmacy department is closed

AND

A separate alarm must be present for just the pharmacy/pharmacy department and activated when the pharmacy is closed

Question 7

How to store hard copies of prescriptions

Answer 7

Prescription hard copies will be maintained in 3 SEPERATE files -
1. Schedule II prescriptions (labeled)

2. Schedules III, IV and V prescriptions (labeled)
3. Schedule VI, non-controlled substances and syringes/instruments