I am writing in support of the pharmacy regulations on workplace conditions that addresses factors in the work environment and that may impact pharmacy staff's ability to safely provide care to patients.

I support the recommendations submitted by the Virginia Pharmacy Association and the Virginia Society of Health-System Pharmacists regarding requests for clarification and also exemptions given the unique practice settings in which such considerations are appropriate. 

I would like to reiterate the requested exemptions to the scheduled 12 hour shifts due to:

• Residency/ Fellowship Training Programs: These programs must follow duty hour requirements and the accountability process involved in evaluating compliance. These are often modeled after the medical GME requirements. There are also certain programs based on the specialty designed to ensure competency in various environments in order to provide consistent and timely care 
• Pharmacy On-Call programs: The on-call coverage is a scheduled time period, and it may be beyond 12 hours. However, it does not mean that the pharmacist is working during those hours unless services are requested. Examples include paging the pharmacist on-call at a rural hospital to come onsite to compound a methotrexate injection for ectopic pregnancy since the pharmacy is not 24/7 to meet USP <800> requirements. This coverage rotates amongst the team. On-call hours and hours worked when paged are generally recognized in compensation

In addition, I would like to ask that the Board consider the following situation regarding the meal break:

• Smaller hospitals with one pharmacist covering the third shift (i.e., midnight shift): It may not be feasible to have another pharmacist hired for meal coverage. Generally, these pharmacists are compensated through the meal coverage (i.e., no meal deduction on time worked occurs) and they are eating their meal in smaller breaks in order to prioritize urgent/ critical needs of patients. 

To understand the accountability process of the "Staffing Requests or Concerns Form", I ask that the Board clarify the expectations with how the form developed by the Board is operationalized, including who is "permit holder." In addition, please consider who this might be in all practice settings, as the permit holder may be an entity vs. individual. 

Thank you for your time and consideration.