I want to thank the Board for considering revision of the requirements for automated dispensing devices.  The technology and processes in place for these devices greatly enhances drug security over prior floor stock distribution models.  The changes to the requirements will indeed save many hours of labor that are currently required to perform administration audits.  The 3 standard deviation and usage reports currently available in the technology provide adequate systems to monitor for diversion and fraudulant use of controlled substances. 

I do suggest that section C-2 state in the final sentence "Any discrepancy noted shall be recorded on the delivery record and immediately reported to the pharmacist in charge OR THEIR DESIGNEE....

In section E, will the discrepancy reports be required to be printed or is electronic storage and documentation acceptable?

Thank you for the opportunity to provide input.