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OSHARulemakingOSHA-2020-0004

COVID-19 Emergency Temporary Standard Rulemaking

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American Pharmacists Association (APhA) filings
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American Pharmacists Association (APhA) filed 1 comment on this docket between Aug 27, 2021 and Aug 27, 2021. 198 other organizations filed here. The comment window closed 269d ago.

What American Pharmacists Association (APhA) filed (1)

Aug 27, 2021· Comment from American Pharmacists Association (APhA)· OSHA-2020-0004-1343

The American Pharmacists Association (APhA) is pleased to submit comments on the "Occupational Exposure to COVID-19; Emergency Temporary Standard ["ETS"], Interim final rule; request for comments (Docket Number: OSHA-2020-0004)." APhA is the largest association of pharmacists in the United States advancing the entire pharmacy profession. APhA represents pharmacists in all practice settings, including but not limited to community pharmacies (including independent and retail (chain, mass merchandise, grocery stores, etc.), hospitals, long-term care facilities, specialty pharmacies, community health centers, physician offices, ambulatory clinics, managed care organizations, hospice settings, and government facilities. Our members strive to improve medication use, advance patient care and enhance public health. Many of our members have already implemented the OSHA ETS requirements (especially if they provide COVID-19 testing) and do not support developing/implementing plans that exceed current ETS requirements (§ 1910.502(d)—Patient screening and management; § 1910.502(e)—Standard and transmission-based precautions.; § 1910.502(f)—Personal protective equipment (PPE).; and § 1910.502(g)—Aerosol-generating procedures on a person with suspected or confirmed COVID-19). As you know, the Centers for Disease Control and Prevention (CDC) has issued "Guidance for Pharmacies, Guidance for Pharmacists and Pharmacy Technicians in Community Pharmacies during the COVID-19 Response." Thus, in accordance with the CDC Guidance, APhA believes the ETS should apply to all settings where any employee provides healthcare or healthcare support services, including retail pharmacies in grocery stores. The Interim final rule also stands in stark contrast to OSHA's existing "COVID-19 Guidance for Retail Pharmacies." Accordingly, we strongly urge OSHA to remove the exception in the Interim final rule under paragraph (a)(2)(ii) which "exempts the dispensing of prescriptions by pharmacists in retail settings (e.g., pharmacies in grocery stores)." It is important to point out that the process of "dispensing of prescriptions by pharmacists in community / retail settings," involves more than simply putting pills in bottles. The process of dispensing of prescriptions / medications by pharmacists and pharmacy team members includes person-to-person interactions with patients and caregivers to attain health information, provide health information and education, and conduct health monitoring activities. In addition, pharmacy team members counsel and assist patients evaluate health conditions and select appropriate over-the-counter medications to address particular needs. These encounters involve reduced social distancing. Every pharmacist and pharmacy is required by law, under the Omnibus Budget Reconciliation Act of 1990 (OBRA '90), many state laws, and along with regulations later implemented by the Centers for Medicare and Medicaid Services (CMS) to provide patient counseling in order to continue to receive federal funding for Medicaid and to meet state practice requirements. Accordingly, the patient counseling requirements for pharmacists under federal law and state practice requirements make all pharmacies, even those in retail settings (e.g., pharmacies in grocery stores), "covered healthcare settings" under the ETS. Please, refer to the .PDF for full comments.

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Abstract

Emergency Temporary Standard

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