Overall, i am in support of these regulations. 

I do have some clarifications I hope the BOP can weigh in on.

In smaller, non-24/7 hospitals it is common for a pharmacist to work 7a to 7p on weekend shifts and take call on that same weekend. This is preferred by most pharmacists so they can limit their weekend work and on-call responsibilities to the same weekend. 

Occasionally pharmacists are called in during their off period between 12-hour shifts. This is usually due to an unforeseen emergency. A couple of questions arise from this. 

1) Does the Board consider on-call hours as part of the 12 consecutive worked hour maximum?

2) Would the Board consider hours that a pharmacist worked after being called back in above the 12 hour max a violation of the regulation, or would these hours be considered an emergency and therefor allowed by the Board?   

Thanks for any clarification that can be provided.