Having worked for various chains, Peoples Drug/CVS, Drug Fair/Rite Aid, Kmart, most of those job descriptions called for generally working 12 hour shifts.  This in turn allowed the pharmacist in many cases to work 3 days one week and 4 days the following week, a very desireable situation for many people.  It also allowed the chain to staff stores with fewer people by working 3 people with extra shifts they were able to staff 2 stores, rather than 1&1/2, also saving payroll dollars on benefits. About 11 years ago I decided to open my own independently owned drug store.  I scheduled my hours to be open 10 hours a day monday thru friday and 5 hours a day on saturdays and closed on sundays.  I felt this hourly arangement was about the maximum that I could personally could work "behind the counter", rather than a moral/ religious issue.  I worked in this fashion for 18 months before I was financially able to employ relief pharmacists to lighten the work burden.  I want to emphasize that there are many issues that involve workplace stress and accuracy beyond the actual hours on the clock.  One of the larger issues is ancillary staffing(technicians/clerks), their quality, skill sets, productivity and their relationship with the pharmacy and pharmacist.  The new licensure requirements have had only a modest improvement, primarily because often these newly licensed employees now have considerable leverage over the pharmacist with regard to the nature of their work responsiblities.  Secondly is work load and distractions intrinsic to the actual work enviroment.  We have for years increased access to the pharmacist by both phone, computer(e-mail, ques), and diminishing physical barriers.  While this has been sucessful in raising  the profile of the practicing pharmacist, the work load (ie prescriptions filled per hour)has skyrocketed, at the same time that reimbursement has plumeted.  Ideas of differing revenue streams, such as vaccinations, MTM, and  counseling offer hope of a changing nature of practice, the reality is that with the diminished ability of the public to pay for services through private and public insurance there is little hope that these secondary revenue streams will maintain there current profitability.  Additional to the basic process of filling prescriptions is the new emphasis for detail, documentation and judgement that now accompanies the filling process.  This documentation and judgement requirements decreases the value of pharmacy techinicians, as there are no courses to prepare technicians for this duty.  At times I feel as if the Board is in a race with other Boards to see who can out-regulate each other, and at the same time allowing PBM's and Mega-chains to de-facto set all the rules(PLEASE DON'T).  I requested to transfer a prescription recently from CVS and I noticed that there was no doctor listed on the prescription bottle.  When I called and asked for the information and transfer, I was told that "when the robot fills the prescription sometimes that information is cut off"!!!!! Lets not lose sight of the first responsibility, accurately filling prescriptions.  Additional issue; can the Board of Pharmacy and the Board of Medicine get together and define parameters for pain management.  How about- if a pain management practicioner is prescribing large doses of controlled substances require the patient to undergo periodic blood level studies, to diminish the ability to "sell on the street" their prescriptions.

                                                                          Thank you for your consideration

                                                                          John P. Crowder III