I support the proposed regulation amendment for the following reaons:

1. Hospital pharmacies have quality control systems in place to look for many of the same items that are required by the Board in 18VAC 110-20-490.  However, it is rare that these quality control audits must be done monthly, since variance is unusual.  While I agree that these audits are important and necessary, requiring that the audits be performed monthly is time-consuming, and takes away time that could be used for other, more productive, activities.

2.  Specifically, 18VAC 110-20-490.5. requires monthly audits for 5 items that are actually reviewed by virtue of the very use of the machines.  Outdated drugs, location of drugs within the device, etc., are vital components of the drug delivery system, and must be part of the day-to-day operation of the department.  It would be more useful for the Board to know that the drug distribution system addresses these items on an ongoing basis than to see the results of monthly audits.

I hope the Board will consider revising these requirements.