Virginia Regulatory Town Hall
Department of Health Professions
Board of Pharmacy
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
Action Pharmacy working conditions
Stage Emergency/NOIRA
Comment Period Ended on 11/22/2023
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11/21/23  8:53 am
Commenter: Brad McDaniel, Virginia Society of Health-System Pharmacists

Pharmacy Working Conditions

The Virginia Society of Health-System Pharmacists supports working conditions that promote a safe workplace for pharmacy professionals and patients.  We appreciate Delegate Hodges’ leadership in the creation of a baseline expectation for safe working conditions for pharmacists and pharmacy staff and ensuring staff can provide services safely to the public. 

VSHP asks that the Board consider the following unique considerations to amend the language:

(1) Residency/ Fellowship Training Programs:  Residency training program accreditation requirements outline duty-hour limitations for pharmacy residents similar to medical training programs.  VSHP and pharmacy residency training programs value wellness for our trainees and wish to maintain flexibility to ensure trainees are meeting the program goals.

  • VSHP requests an exemption in the 12-hour working shift for those pharmacists participating in a residency training program. 

(2) Pharmacy On-Call Programs: There are unique circumstances that require on-call pharmacy team member support. Examples include: emergency condition support such as unscheduled technology/ automation downtime, needs for USP <800> compounding in non 24/7 pharmacies, and other supportive programs that enable timely access to pharmacy care or medications.

  • VSHP requests that the Board provide an exemption to the 12-hour shift restriction for this unique purpose.

(3) Lastly, VSHP recommends considering language regarding “prescriptions” to include 'medication order’ as relevant for differentiation in the hospital setting.

Thank you for your time and consideration.

The Virginia Society of Health-System Pharmacists


CommentID: 220671