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The Pharmacy Commission is aware of several drug shortages that have had a deleterious impact on patient care, including shortages affecting certain chemotherapy drugs. What drugs manufacturers choose to produce and how much they choose to produce is out of the commission’s authority. However, there are some aspects of the commission’s rules that may alleviate some of the impact in Washington relating to the transfer of drug supply. As a reminder, while the transfer of drugs from one facility to another may amount to wholesale distribution, there are notable exemptions within the commission’s definition of wholesale distribution found in WAC 246-945-001(81)(d) and (e). Additionally, the commission has an interpretive statement on its website providing guidance on the term “emergency medical reasons” in WAC 246-945-001(81)(e). For clarification, the term “emergency medical reasons” in WAC 246-945-001(81)(e) and the corresponding interpretive statement is not limited to a declared state of emergency.
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