Regulations regarding Pharmacist-in-charge (18VAC110-60-170) must be retained as they are essential to safe therapeutic use of medical cannabinoid products.

In 18VAC110-60-C, clarify that continuing inservice training may be conducted by an external organization accredited by the American Council for Pharmaceutical Education. 

Section 18VAC110-60-220. A.2 "Sell, deliver, transport or distribute Cannabis, including cannabidiol oil or THC-A oil, to any other facility;"  and A.4 "Provide cannabidiol oil or THC-A oil samples" should be revised to allow delivery and/or samples to qualified external laboratories for testing. 

Sections relating to pharmacist-on-duty and pharmacist-in-charge should be revised to allow a pharmacy student intern to work in the facility under the direction of the pharmacist.