Committee leans toward policy-based approach to implement AB 1902 on accessible prescription labels

The committee responsible for implementing recent pharmacy-related laws discussed how to put Assembly Bill 1902 — the prescription label accessibility law — into practice, and members signaled a preference for requiring pharmacies to adopt written policies and procedures rather than imposing a uniform, prescriptive turnaround time.

The issue arose during the committee’s agenda item on AB 1902, which requires pharmacies to provide accessible prescription labels in formats appropriate to a requesting patient’s disability or language and to make those accessible labels available “in a timely manner comparable to other patient wait times.” Committee members said that language, as written, would be difficult to apply uniformly across diverse pharmacy business models.

“Timely manner should not be like a month… I don't think it should be an hour,” said Song (vice chair), who asked the committee to focus on a requirement that each pharmacy document, in a policy or standard operating procedure, how it will meet the law’s intent. Song added that vendor implementations can cost “about 10 to $20,000” plus an annual subscription, raising concerns about the burden on smaller, independent pharmacies.

Public commenters and stakeholders voiced similar concerns. John Gray, a registered pharmacist with Kaiser Permanente, told the committee he supports the policy-and-procedure approach and suggested the board consider whether statutory cleanup would be helpful to reduce ambiguity in enforcement. “There’s a lot of tension between what the statute actually says and the facts of pharmacy operations,” Gray said, noting that generating accessible or translated labels often requires extra systems work.

Sean Kim of the California Pharmacists Association urged the board to consider exemptions or special treatment for non‑chain pharmacies, saying independents lack the infrastructure of large chains and that compliance costs could “result in reduced services, increased prices, or even pharmacy closures in underserved areas.” Board counsel Corinne responded that granting an outright exemption might exceed the board’s authority and suggested the board instead consider enforcement discretion as an avenue to address compliance concerns.

Committee members and commenters also emphasized patient choice and tailoring formats to individual needs. Nicole Thiebaud, a licensee member, said that patients with disabilities have different preferences — for example, braille, large print, or spoken labels — and should be able to choose whether they want an accessible label and which format they prefer.

Several members recommended the board rely on existing national guidance where possible. John Gray and others pointed to the United States Access Board and the National Standards for Culturally and Linguistically Appropriate Services as existing sources the board could reference rather than creating conflicting technical specifications.

Next steps: Chair Maria Serpa said the committee will bring the discussion to the full board and, if there is general agreement, staff will draft proposed regulation text for future committee consideration. The committee also signaled interest in requiring pharmacies to document in policy/SOP how they will meet AB 1902 and in including training or designated responsibility for compliance as part of that approach.

The committee did not adopt final regulatory language at the meeting; members repeatedly declined to set a uniform numeric turnaround time, favoring a flexible, documented business‑model approach while asking staff and counsel to explore legal constraints (including whether targeted exemptions are permissible) and practical options such as cooperative arrangements among pharmacies.

Ending: The committee will present the AB 1902 discussion to the full board and asked staff to prepare draft regulatory text reflecting the policy-and-procedure approach for further review.