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Board opens rulemaking to require policies for accessible prescription labels; members weigh staff sign‑off requirement

5062059 · June 23, 2025
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Summary

The California State Board of Pharmacy voted to begin rulemaking on a new regulation to require pharmacies to establish policies and staff training for accessible prescription labels, and directed staff to remove an explicit requirement that all personnel sign a copy of policies.

The California State Board of Pharmacy authorized staff to initiate rulemaking on a proposed regulation to implement statutory requirements for accessible prescription drug labels, instructing staff to revise draft language in response to member concerns about administrative burden on pharmacy personnel.

The proposed regulation (staff draft labeled 17o7.51 in committee materials) would require covered pharmacies to adopt policies and procedures addressing how they will offer accessible prescription label formats to patients, to assess potential adverse impacts on therapy, and to document staff training on best practices for label accessibility. During committee discussion members raised a point of contention about a subsection in the draft that would have required pharmacy personnel to sign a copy of the policies and procedures.

Several board members, including Renee Barker and Nicole Thiebaud, said they were concerned subsection b could impose an unusual administrative step that many pharmacies do not currently maintain and could be duplicative of ordinary training and competency records. Barker proposed removing the explicit sign‑off subsection and instead revising the paragraph that requires pharmacies to "describe the training provided to personnel" to make clear training and documentation must be maintained and available to the PIC for review. Several public commenters representing large pharmacy operators and associations also urged flexibility and consistency with existing policy practice.

Board members discussed allowing electronic recordkeeping of training and competency documentation. After discussion the board directed staff to adjust the draft by removing the standalone sign‑and‑return requirement and expanding the training/documentation language in the rule so it requires pharmacies to "describe and document the training provided to pharmacy personnel on best practices and pharmacy policies related to prescription label accessibility." The board then voted to initiate rulemaking consistent with that direction.

Public commenters said the committee's policy‑and‑procedure approach is appropriate but asked for clarity in FAQs about how the new requirement would interact with federal accessibility standards and existing pharmacy law. John Gray of Kaiser Permanente asked the board to ensure the regulation and later FAQs explain how pharmacies can reconcile different label standards so a single patient is not left with conflicting or unusable information.

The board’s vote authorized the executive officer to refine the text consistent with the board’s direction, submit it to the Department of Consumer Affairs and to control agencies for review, and complete the rulemaking process if no adverse comments are received.

If adopted, the regulation will require pharmacies to adopt policies and procedures to offer accessible label formats and to document training, but the board explicitly directed staff to avoid imposing an added paper‑signature burden on personnel.