WA board of Pharmacy hearing set for March 29
A Strong presence at the Board Hearing is needed to prevent this Draft Rule from becoming official. Presence of all supportive family & friends is needed, whether or not they testify. Numbers will count! All children are welcome.
Transportation available; Contact us: 206.239.8363 or HumanRightToConscience@yahoo.com. If you have room in your car/bus and all whom are traveling from afar, please contact us.
Please read ALL details of the meeting below.
§ Indicate on the sign-in sheet located either in lobby of the before entering the meeting room or at the entrance of the meeting room.
§ Order to testify will be first come, first served, based on the sign-in sheet.
§ Only 2 min. will be given per person.
§ First, introduce yourself to the Board using your name (first & last), city, occupation/"concerned citizen"
In effort to gain the ears of the Board of Pharmacy members, without being judged, please do not indicate which organization(s), if any, you belong to.
In your testimony:
1. Reject: the Board of Pharmacy's current Draft Rule,
i. The Board's June 1st Draft Rule, -OR-
ii. Composing a comprehensive conscience clause to protect pharmacists and public -OR-
iii. Making "No New Rules"
3. Question: **Most important**
i. the Board of Pharmacy's rule-making process
ii. the pharmacy survey that the Board Staff conducted, last year
iii. the Board's Small Business Economic Impact Statement (SBEIS)
the Board to re-evaluate their rule-making process,
most especially their questionable survey method & the
Small Business Economic Impact Statement (SBEIS)
The Board of Pharmacy conducted a hasty survey that required pharmacies to respond immediately. These surveys had 13 questions and were used to write the Board of Pharmacy's Small Business Economic Impact Statement (SBEIS). After thorough review, the method in which the Board of Pharmacy staff conducted the survey, the questions used and the analysis made, contains many flaws. Thus the validity of the SBEIS is questionable. The Board of Pharmacy staff is required to conduct a thorough and valid study of the economic impact this Draft Rule may have on small businesses. Without thorough examination, the Board can not move forward to officially adopt this Draft Rule.
The SBEIS is the left & first item in the table at http://www3.doh.wa.gov/policyreview/ . Guidelines for the SBEIS is at: http://apps.leg.wa.gov/rcw/default.aspx?cite=19.85 No need to go into the specifics of this, but it is important state #4.
§ Consider the practical aspects of the proposed rule; the cost, the adverse economic impact on small businesses, etc.
§ The Small Business Economic Impact Statement, SBEIS, (attached) and the SAR did not give a clear picture of cost, though they did indicate 1) that there will be an adverse impact on small businesses and 2) the rule will cost millions, state-wide (we just don't know how many millions). The proponents of the rule didn't present evidence that there is an access problem to begin with, so why would the BOP vote in favor of something so costly? The costs will be passed on to consumers. The BOP should be promoting programs, which reduce or contain costs, not increase costs.
Board Hearing Details:
Location: Renton Community Center
1715 SE Maple Valley Highway
Renton, WA 98057
Gathering before the Board Hearing:
All are invited to attend the 7:50 am Mass (church prayer service) at St. Anthony Catholic Church (314 South 4th St Renton, WA 98057 (425) 277-6150) prior to the meeting. A special blessing will be given to all those who will be attending the Board Hearing. Regardless of the church or denomination you belong to, all are highly encouraged to join together as a community in prayer. It is asked that those who are not Catholic not come up to receive Holy Communion during the given time, but instead, are invited to receive a personal blessing by crossing their arms across their chest in the Communion line that the Priest is attending.
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