I support working conditions that promote a safe workplace for pharmacy professionals and patients.  

I would like to request the Board consider the following unique considerations to amend the language in the regulations:

(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.

• Please consider an exemption in the 12-hour working shift for those pharmacists participating in a residency or fellowship 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.

• Please consider providing an exemption to the 12-hour shift restriction for this unique purpose.

(3) To accommodate acute care/hospital vernacular, please consider language regarding “prescriptions” to include 'medication order’ as relevant for differentiation in the hospital setting.