Long hours have been a way of life for the past 40 years. There was a period of time where Pharmacies (both chains and independents) made enough gross margin to support a staff large enough to handle the work load adequately. I have owned Grays for the past 24 years. During that time "I had a dream" that someday I would be in a position to have a full time Pharmacist and take a little pressure off of me. Then the insurance companies and Government took control, not the Boards of Pharmacy, and reduced the gross margin to a point that relief is not on it's way(if I'm experiencing this, so aren't the chains).

So here we go again. More rules and regulations on how we are to take care of patients because some still have not got the message. We're having to do more with less in order to survive!

If the Boards of Pharmacy want to survive as an vital part of the practice of Pharmacy then take control and make it a little easier on us rather than more difficult thru more regulations. Suggestioin: Board members should only be Pharmacists that are in the trenches each day-we know what's going on and know how to fix most things!

I support this proposed change to the Regulations Governing the Practice of Pharmacy in Virginia to establish a limitation on the number of hours a pharmacist  can work continuously to 12, and a requirement for breaks during a 12 hour shift.  As a retail pharmacist, I work long days ,standing on my feet, without a break.  The retail environment allows the ptaient access to the pharmacist 12 to 14 hours a day which does not allow too many opportunities to take an appropriate break.  This proposal would allow a pharmacist to reduce fatigue and improve concentration while improving overall work performance.

I DO NOT WANT THE BOARD OF PHARMACY SETTING THE NUMBER OF HOURS A PHARMACIST MAY WORK OR THE NUMBER OF BREAKS REQUIRED.  I DO WANT THE BOARD TO STATE THE NUMBER OF TECHNICIANS ONE PHARMACIST MAY SUPERVISE BECAUSE I THINK BIG BUSINESS WILL TRY TO SQUEEZE BLOOD OUT OF A TURNIP IF POSSIBLE.  I BELIEVE THOSE LIMITS HAVE ALREADY BEEN SET.  AS AN INDEPENDENT PHARMACY OWNER, I WEAR MANY HATS DURING THE DAY AND DO NOT NEED MORE RULES AND REGULATIONS TO COMPLICATE MY ALREADY OVER-REGULATED PRACTICE.  LEAVE IT UP TO THE INDIVIDUAL TO DECIDE WHAT HE/SHE CAN SAFELY FILL DURING THE DAY.  THERE SHOULD BE A MEANS AVAILABLE FOR AN EMPLOYEE PHARMACIST OR TECHNICIAN TO CONTACT THE BOARD ANONYMOUSLY IF WORKING CONDITIONS ARE ABUSIVE, DANGEROUS, OR RECKLESS AND COULD CONTRIBUTE TO MISTAKES OR HARM TO PATIENTS. THE BOARD COULD THEN INSPECT THE SITUATION AND TAKE APPROPRIATE ACTION BASED ON EXISTING REGULATIONS. 

When I was working, mostly I worked in a specialty pharmacy where I was the only pharmacist assigned to the pharmacy for the 8.5hrs that it was open. I did not take a break either as a 15 minute break or a lunch break due to orders that would come if I was gone. My tech could fill orders but I had to check them so being away for more than 5 minutes or so was difficult for me. I ate lunch in the pharmacy at my desk which was away from the sterile production, but on a very busy day it would have been nice to have a break just to rest. I never had that chance for approximately 18 years in which I worked in this pharmacy. To get paid for the time that I worked through lunch, I had to submit a form each week stating that I had not had a break during the day. I was paid for the time that I did not take a lunch break only if I submited the form mentioned previously. Pharmacists need a break. If the time for their break time is posted, the public would get used to the off time and not come during that short time span. In the hospital setting, several rotating pharmacists who had been trained in the speciality areas could cover for a meal break. Standing on your feet for 8 hours or more daily is hard on the body as well as mentally challenging. I would like to see a provision made where pharmacists would be granted time off for a lunch or dinner break.                                                                                                                                                                                                          

I am a retail pharmacist for a chain pharmacy in Virginia.  I am on my feet for 13 hours a shift and really have a difficult time getting a lunch break with the ever increasing volume our stores are seeing.  It would be nice to have a requirment that chain pharmacys set a designated 30 minute break so that we can get our eyes away from the computer for a few minutes.

I also support the limit to a 12 hour workday, as 13 hours is exhaustive to be standing on my feet.  We also have a responsibility to accurately dispense medications to patients and I definitely see fatigue playing a role in dispensing errors at pharmacies around the state.  This change would improve the work environment for pharmacists by allowing us to be more alert and focused.

As someone who has worked in community pharmacy for approximately 20 of my 26 years as a licensed pharmacist, I regret that I seem to be witnessing the de-professionalization of pharmacy.  There was once a time when the pharmacist in charge was afforded the priviledge of doing just that, being in charge of the pharmacy department.  I recall there were certain other regulations in place to prevent non-pharmacist management from making that determination.  Sadly to say we have become a profession of employee pharmacists.

That being said, I believe it inappropriate for the BOP to requlate mandatory breaks in a one size, fits all kind of way for all pharmacies.  In my pharmacy, we are only open for nine hours at a time.  We are not a high volume pharmacy filling 400 prescriptions a day.  We run at a fairly even pace most days and actually less busy than in years past as mandatory mail order or mailorder pharmacies that "steal" our patients and preferred Part D plans are eroding our business.  We try very hard to meet the needs of our existing patients in a timely fashion as it's our greatest strength as the next nearest pharmacy is over twenty miles away.  Quite honestly, if I am forced to step away from the counter for thirty minutes for a mandatory lunch break, I am more concerned I will be likely to allow an error to pass as I attempt to catch up on the prescriptions brought in by patients on their lunch breaks which have been dumped out by the doctor's office for their lunch break.  You can't predict pharmacy, patients don't make appointments.  When I think we're not going to be busy, we are and visa versa.

Otto Wachsmann

I believe what will have a bigger impact on reducing errors in my relatively low volume pharmacy is for the BOP to look into fixing the "noise" generated by false PBM DUR messages that are sent.  Optima Health for example, sends DUR messages for things like Max Day of 3 per day when you are billing for 30 tabs as a 30 day supply.  It is extremely frustrating to receive (and pay for the privilidge of receiving) e-scripts at my pharmacy meant for Stoney Creek Pharmacy in Nellysford by UVA residents who do not provide their NPI number and give the UVA outpatient pharmacy as their office telephone.  You look them up in the NPI directory and get the phone number for the School's admistrative person who registered their NPI number.  There is no way to contact the prescriber.  Manufacturer coupon cards and third party cards with incomplete and wrong information with unreadable 4 point font numbers on them create a lot of wasted effort and frustration.  If the BOP could create some requlations to eliminate or reduce these unnecesary distractions that kill workflow, we will have a lot more time to talk with our patients, check for errors and allow us all a better quality in the workplace.  Community pharmacy is far too focused on trivial things right now that don't do anything that adds to patient care as much as making sure they meet the things that an insurance audit is likely to charge them back for such as calculating 18 drops per ml in an ophthamic preparation instead of 21.5 drops per ml.  Please help us by allowing us to focus back on pharmacy by correcting the things generated by outside forces which are bad for pharmacy.  We have worked hard to be professionals.  Please allow us to determine the best way for us to practice in our particular environment.  If a licensee believes it is unsafe, allow them to make a complaint with the BOP and have it handled on a case by case basis.

I agree with the proposed regulation of limiting work shifts for pharmacists.  In addition, I agree to the mandatory requirement that employers provide pharmacists a 30 minute break for a 6 hour work period with an additional 15 minute break if needed during a longer shift.  It is about time that the pharmacy profession joins the rest of the working population by giving pharmacists the break they need to stay fresh and minimize errors.  It has been far too long that employers have been allowed to force pharmacists to work long hours without a scheduled break.  It would be a complete disservice to all pharmacists as well as the patients they serve if this does not pass.

Thank you,

Amber Y. Darr, PharmD

As a retail pharmacist for 10 years, I would cherish a 30 minute lunch break. Fortunately, I have a great work environment, but some of my colleagues work in stressful situations and need a break! I am 100% for this. And also for the limiting the  work day to 12 hours. Thanks!

 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