California State Board Of Pharmacy BUSINESS, CONSUMER SERVICES AND .

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California State Board of PharmacyBUSINESS, CONSUMER SERVICES AND HOUSING AGENCY1625 N. Market Blvd, N219, Sacramento, CA 95834Phone: (916) 574-7900Fax: (916) 574-8618www.pharmacy.ca.govDEPARTMENT OF CONSUMER AFFAIRSGOVERNOR EDMUND G. BROWN JR.To:Board MembersSubject:Agenda Item III ‐ Discussion and Consideration of Board Approval of Training Program forDesignated Representative‐Reverse DistributorAttachment 1Relevant Law:Business and Professions Code (BPC) section 4022.6 establishes the definition of the designatedrepresentative‐reverse distributor.BPC section 4053.2 establishes the licensing requirements for the designated representative‐reversedistributor, including experience and training requirements.A copy of BPC sections 4022.6 and 4053.2 may be found in Attachment 1.Background:With the enactment of SB 752 (Stone, Chapter 598, Statutes of 2017), effective January 1, 2018, theboard is required to issue a license to individuals who qualify for a designated representative‐reversedistributor license. Staff is working with the department to implement this license type in theboard’s licensing database. The Designated Representative‐Reverse Distributor application wasmade available on the board’s website March 1, 2018.One of the licensing requirements specified in BPC section 4053.2(b)(3)(A) requires an individual tocomplete a training program approved by the board. The board has not yet approved a trainingprogram.The board has received a request from SkillsPlus Inc. to provide an approved designatedrepresentative‐reverse distributor training program. The program content has been reviewed bySupervising Inspector Janice Dang, PharmD., who has determined that it meets the criteriaestablished in BPC section 4053.2. Skills Plus Inc. currently offers a training program for individuals toqualify to become licensed as a designated representative and a designated representative‐3PL.Due to proprietary concerns, the actual content of the training program was reviewed by Dr. Dang.Included in Attachment 1 is a document provided by SkillsPlus Inc. that lists the laws and regulationscovered in its designated representative‐reverse distributor program. The program consists ofapproximately 7.25 hours of training and includes a final examination of approximately 90‐100questions.Upon board approval, SkillsPlus Inc. could offer the training program immediately. At least oneindividual is waiting to enroll in a board‐approved program to qualify for a designated representative‐reverse distributor license.Board Meeting – March 27, 2018Page 1 of 2

At this Meeting:The board will have the opportunity to discuss the designated representative‐reverse distributortraining program offered by SkillsPlus Inc. Based on the review by Dr. Dang, staff recommends approvalof the designated representative‐reverse distributor program offered by SkillsPlus, Inc.Staff Recommendation:Should the board agree with the staff recommendation, the following motion could be used.Motion: Approve the designated representative‐reverse distributor training program offered bySkillsPlus Inc. for a period of five years and require SkillsPlus Inc. to submit annual updates regardingthe content of the training plan to be reviewed by a Supervising Inspector.Board Meeting – March 27, 2018Page 2 of 2

Attachment 1

4022.6. Designated Representative-Reverse Distributor“Designated representative-reverse distributor” means an individual to whom a licensehas been granted pursuant to Section 4053.2, who is responsible for supervision over alicensed wholesaler that only acts as a reverse distributor. A pharmacist fulfilling theduties of Section 4053.2 shall not be required to obtain a license as a designatedrepresentative-reverse distributor.4053.2. Designated Representative-Reverse Distributor – Licensing; Requirements(a) Notwithstanding Sections 4051 and 4053, the board may issue a designatedrepresentative-reverse distributor license to a qualified individual who shall providesufficient and qualified supervision over a licensed wholesaler that only acts as a reversedistributor. The designated representative-reverse distributor shall protect the publichealth and safety in the handling, storage, warehousing, and destruction of outdated ornonsaleable dangerous drugs and dangerous devices.(b) An individual who is at least 18 years of age may apply for a designated representativereverse distributor license. In order to obtain and maintain that license, the individualshall meet all of the following requirements:(1) He or she shall be a high school graduate or possess a general education developmentcertificate equivalent.(2) He or she shall meet one of the following requirements:(A) Have a minimum of one year of paid work experience in the past three years with alicensed wholesaler, third-party logistics provider, or pharmacy performing duties relatedto the distribution, dispensing, or destruction of dangerous drugs or dangerous devices.(B) Have a minimum of one year of paid work experience in the destruction of outdated ornonsaleable dangerous drugs or dangerous devices pharmaceutical waste.(C) Meet all of the prerequisites to take the examination required for licensure as apharmacist by the board.(3) (A) He or she shall complete a training program approved by the board that, at aminimum, addresses each of the following subjects:(i) Knowledge and understanding of California law and federal law relating to thedistribution of dangerous drugs and dangerous devices.(ii) Knowledge and understanding of California law and federal law relating to thedistribution of controlled substances.(iii) Knowledge and understanding of California law and federal law relating to theremoval and destruction of dangerous drugs, dangerous devices, and pharmaceuticalwaste.(iv) Knowledge and understanding of the United States Pharmacopoeia or federal Foodand Drug Administration standards relating to the safe storage, handling, and transport ofdangerous drugs and dangerous devices.(B) The board may, by regulation, require the training program required under thisparagraph to include additional material.(C) The board shall not issue a license as a designated representative-reverse distributoruntil the applicant provides proof of completion of the training required by this paragraphto the board.(c) A reverse distributor shall not operate without at least one designated representativeor designated representative-reverse distributor present at each of its licensed places ofbusiness as required under Section 4160.

SkillsPlus International Inc.This document shows the flow of the class by sequence of the laws and regulations ed SubstancesControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesPersonnelPersonnelPersonnelDrug Take BackControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesControlled ProductIntroductionUSPEnforcementEnforcement1.3 Product definitions1.4 Person and entities definitions1.5 Activity definitions1.4 Person and entities definitions1.5 Activity definitions1.4 Person and entities definitions3.3 Physical Security Controls9.1 Schedules Sales9.1 Schedules Losses9.1 Schedules Samples9.1 Schedules Shipping9.1 Schedules Narcotic Treatment Program9.1 Schedules Reverse Distributor3.3 Employee Screening3.3 Illicit Activities by Employees3.3 Employee Reporting Drug Diversion8.16 Drug Take Back Program – DEA Record Keeping9.1 ARCOS General9.1 ARCOS Frequency9.1 ARCOS Persons9.1 ARCOS Substances Covered9.1 ARCOS Transactions9.1 ARCOS Exceptions9.1 Power of Attorney General9.1 Power of Attorney Sample Letter9.1 Power of Attorney Revocation9.1 Power of Attorney Signor9.1 Schedules Filing DEA 2229.1 Schedules Cancelling Voiding DEA 2222.3 Application actions2.3 Application actions2.3 Application actions2.3 Application actions4.3 Record retention2.3 Application actions6 .1 Receipt and storage6.3 Loss, theft, discrepancies errors reporting1.3 Product definitions7.2 USP expiration dates10.9 Penalties and consequences10.9 Penalties and 81718.117211723

SkillsPlus International nforcementDrug Take BackDrug Take BackDrug Take BackDrug Take BackDrug Take BackDrug Take BackDrug Take mentEnforcementAdministrationControlled 3.5 Training2.5 Application fees10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences8.10 Drug Take Back Program – Introduction8.11 Drug Take Back Program – Mailers and Packages8.12 Drug Take Back Program – Collection Receptacles8.13 Drug Take Back Program – Skilled Nursing Facilities8.14 Drug Take Back Program – Management Activities8.15 Drug Take Back Program – Record Keeping8.15 Drug Take Back Program – Record Keeping3.1 Job descriptions3.5 Training5.1 Cleanliness standards5.2 Security standards6.2 Handling, delivery and returns4.3 Record retention2.4 Licensing exemptions6.3 Loss, theft, discrepancies errors reporting6.2 Handling, delivery and returns6.3 Loss, theft, discrepancies errors reporting3.1 Job descriptions4.1 Documentation basics4.1 Documentation basics4.3 Record retention1.2 Goals and objectives of the board of pharmacy1.4 Person and entities definitions1.2 Goals and objectives of the board of pharmacy1.4 Person and entities definitions10.2 Rights of the inspector or and inspectee10.3 Appropriate actions of the inspector for violativediscoveries2.3 Application actions9.1 Schedules1.3 Product definitions1.5 Activity definitions3.2 Designated Representative qualifications3.2 Designated Representative qualifications1.3 Product definitions1.4 Person and entities definitions1.5 Activity definitions1.3 Product 44025

SkillsPlus International ductControlled SubstancesEnforcementProductControlled nistrationPersonnel1.5 Activity definitions3.2 Designated Representative qualifications1.4 Person and entities definitions1.5 Activity definitions1.4 Person and entities definitions1.4 Person and entities definitions1.4 Person and entities definitions2.2 License types1.4 Person and entities definitions1.4 Person and entities definitions1.4 Person and entities definitions1.4 Person and entities definitions2.2 License types1.4 Person and entities definitions2.2 License types2.4 Licensing exemptions3.2 Designated Representative qualifications3.2 Designated Representative qualifications6.2 Handling, delivery and returns2.3 Application actions6 .1 Receipt and storage6 .1 Receipt and storage9.2 Prescription rules10.6 Illegal acts: Prescription violations6.1 Who May Order Dangerous Drugs and Devices9.2 Prescription rules10.6 Illegal acts: Prescription violations10.3 Appropriate actions of the inspector for violativediscoveries10.5 Illegal acts: Adulteration and tampering misbranding10.3 Appropriate actions of the inspector for violativediscoveries10.3 Appropriate actions of the inspector for violativediscoveries3.2 Designated Representative qualifications3.2 Designated Representative qualifications3.3 Theft Impaired personnel4.3 Record retention4.3 Record retention Common Carriers2.3 Application actions2.3 Application actions2.3 Application actions3.1 Job 41014104410541054107411041114115

SkillsPlus International cementEnforcementEnforcement5.2 Security standards10.6 Illegal acts: Prescription violations10.6 Illegal acts: Prescription violations10.6 Illegal acts: Prescription violations10.6 Illegal acts: Prescription violations10.6 Illegal acts: Prescription violations2.2 License types2.3 Application actions3.2 Designated Representative qualifications6.2 Handling, delivery and returns2.2 License types4.1 Documentation basics2.7 Surety bond6 .1 Receipt and storage4.4 Product tracing10.1 Types of inspections5.2 Security standards5.2 Security standards2.3 Application actions10.7 Illegal acts: Prohibited acts and unprofessionalconduct10.1 Types of inspections10.1 Types of inspections2.3 Application actions10.4 Illegal acts: Unprofessional conduct10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences2.6 Voiding a license10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and 43144315432043214322432343244325

SkillsPlus International nPersonnelControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesControlled SubstancesProductControlled SubstancesControlled SubstancesEnforcementControlled SubstancesEnforcementControlled SubstancesEnforcementEnforcementControlled SubstancesControlled SubstancesEnforcementEnforcement10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.7 Illegal acts: Prohibited acts and unprofessionalconduct10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences10.9 Penalties and consequences1.5 Activity definitions10.9 Penalties and consequences1.2 Goals and objectives of the board of pharmacy10.9 Penalties and consequences10.9 Penalties and consequences2.5 Application fees3.2 Designated Representative qualifications9.1 Schedules9.1 Schedules9.1 Schedules9.1 Schedules9.1 Schedules6.2 Handling, delivery and returns9.4 Documentation and reporting9.4 Documentation and reporting10.7 Illegal acts: Prohibited acts and unprofessionalconduct9.4 Documentation and reporting10.8 Illegal acts: Controlled substances9.3 Prescription content10.6 Illegal acts: Prescription violations10.6 Illegal acts: Prescription violations9.2 Prescription rules9.3 Prescription content10.8 Illegal acts: Controlled substances10.8 Illegal acts: Controlled 0911153.511162.111162.511162.611164111641116411164

SkillsPlus International rcementControlled onAdministrationAdministrationDocumentation10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.5 Illegal acts: Adulteration and tampering misbranding10.7 Illegal acts: Prohibited acts and unprofessionalconduct10.7 Illegal acts: Prohibited acts and unprofessionalconduct10.7 Illegal acts: Prohibited acts and unprofessionalconduct10.7 Illegal acts: Prohibited acts and unprofessionalconduct9.3 Prescription content10.5 Illegal acts: Adulteration and tampering misbranding10.7 Illegal acts: Prohibited acts and unprofessionalconduct10.8 Illegal acts: Controlled substances3.4 Procedures4.3 Record retention10.8 Illegal acts: Controlled substances1.5 Activity definitions1.6 DSCSA definitions1.7 DSCSA transactions definitions1.8 Wholesale distribution2.1 Licensing standards2.3 Application actions2.5 Application fees2.7 Surety bond4.2 Electronic DSCSADSCSADSCSADSCSADSCSADSCSADSCSADSCSA

SkillsPlus International SPUSPGDPGDPGDPGDPGDPGDPGDP4.4 Product tracing4.5 Transaction documentation6 .1 Receipt and storage6.2 Handling, delivery and returns6.4 Suspect product6.5 Illegitimate product6.6 Returned product6.7 Product information requests7.4 USP and DSCSA labeling10.5 Illegal acts: Adulteration and tampering misbranding10.7 Illegal acts: Prohibited acts and unprofessionalconduct10.9 Penalties and consequences10.9 Penalties and consequences3.1 Job descriptions3.4 Procedures3.5 Training4.1 Documentation basics5.1 Cleanliness standards6 .1 Receipt and storage6.3 Loss, theft, discrepancies errors reporting10.1 Types of inspections1.9 Pure Food and Drug Act1.9 Narcotic Tax Act1.9 Food, Drug and Cosmetic Act1.9 Durham-Humphrey Amendment1.9 Kefauver-Harris Amendment1.9 Drug Abuse Prevention and Control Act1.9 Poison Prevention and Packaging Act1.9 Combat Methamphetamine Epidemic Act7.1 USP temperature ranges7.1 USP Humidity Standards7.2 USP expiration dates7.3 USP storage containers7.4 USP and DSCSA labeling8.1 Good Distribution Practices – Introduction8.2 Good Distribution Practices – Organization andPersonnel8.3 Good Distribution Practices – Facilities8.4 Good Distribution Practices – Vehicles8.5 Good Distribution Practices – Containers8.6 Good Distribution Practices – Transport8.7 Good Distribution Practices – CSADSCSADSCSAFD&C 331FD&C 333Moscone KnoxQCSQCSQCSQCSQCSQCSQCSQCSUS CodeUS CodeUS CodeUS CodeUS CodeUS CodeUS CodeUS CodeUSPUSPUSPUSPUSPWHO Annex 5WHO Annex 5WHO Annex 5WHO Annex 5WHO Annex 5WHO Annex 5WHO Annex 5

SkillsPlus International Inc.GDPGDP8.8 Good Distribution Practices – Product8.9 Good Distribution Practices – FDAWHO Annex 5WHO Annex 5

California State Board of Pharmac. . 1625 N. Market Blvd, N219, Sacramento, CA 95834 Phone: (916) 574-7900 Fax: (916) 574-8618 www.pharmacy.ca.gov . BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY DEPARTMENT OF CONSUMER AFFAIRS . Skilled Nursing Facilities 1776.4 Drug Take Back 8.14 Drug Take Back Program .