Board of Pharmacy Notices Proposed Amendments to Renewal Requirements


By Stephanie Mendivil

On February 7, 2020, the Board of Pharmacy published notice of its intent to amend sections 1702, 1702.1, 1702.2, and 1702.5, Title 16 of the California Code of Regulations to simplify the 39 separate license types within the Board’s jurisdiction, as set forth in the proposed text. The proposed regulations would consolidate the renewal of license types into two categories: (1) a premises or facility license; and (2) a license issued to an individual, with an exception for the pharmacist and advanced practice pharmacist licenses, as these licensing programs have specialized continuing education requirements that are addressed in other regulations.

According to the Initial Statement of Reasons, as currently written, the Board’s regulations governing licensing categories require frequent amendments to incorporate each new licensing program as they are established, and as the Board’s regulatory jurisdiction continues to increase, it has not been able to update the regulations as frequently as necessary. Thus the purpose of the proposed regulations is to “provide clarity to the regulated public by increasing the readability of the regulations and ensure consistent application of the renewal requirements.”

The proposed regulations would also require all premises or facility license types to report disciplinary action taken by other government agencies to the Board. The Initial Statement of Reasons states that the proposed regulations will allow the Board “to investigate and ensure that the licensee does not pose a risk to the safety of California residents by continuing to operate.”

Opportunity for Action: The Board is accepting public comments on the proposed amendments until March 23, 2020. Comments may be submitted to Lori Martinez via email at


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