Virginia Board of Pharmacy Inspection Thresholds Guidance Document 110-9 “Pharmacy Inspection Deficiency Monetary Penalty Guide,

Inspection Thresholds
Guidance Document 110-9 “Pharmacy Inspection
Deficiency Monetary Penalty Guide,” includes conditions or
thresholds that the Board has provided as guidance to the inspector.
For example, Major Deficiency
14 states, “No incoming change of PIC inventory taken
within 5 days or substantially incomplete, i.e., did
not include all drugs in Schedules II-V.” The Virginia
Drug Control Act in §54.1-3434 states, “The succeeding pharmacist-in-charge
shall cause an inventory to
be made of all Schedule I, II, III, IV and V drugs on
hand. Such inventory shall be completed as of the date

he becomes pharmacist-in-charge and prior to opening for business on that date.”
While the law requires
the incoming pharmacist-in-charge (PIC) inventory to
be performed on the date the individual becomes PIC,
current Board guidance to inspectors is to not cite a
deficiency if the inventory is taken within five days of
that date. Since the Board can change guidance provided
to inspectors, the expectation is that licensees comply
with the requirements of the law or regulation, not the
threshold or condition on Guidance Document 110-9.
To review Board guidance documents, visit  www
.dhp.virginia.gov/Pharmacy/pharmacy_guidelines.htm.

quoted from the Virginia Board of Pharmacy November 2013 Newsletter