BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 1136
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          Date of Hearing:  April 2, 2013

                            ASSEMBLY COMMITTEE ON HEALTH
                                 Richard Pan, Chair
                    AB 1136 (Levine) - As Amended:  March 20, 2013
           
          SUBJECT  :  Pharmacists: drug disclosures.

           SUMMARY  :  Requires a pharmacist to include a written label on  
          the drug container indicating that the drug may impair a  
          person's ability to operate a vehicle or vessel.  Makes other  
          technical and clarifying changes.  

           EXISTING LAW  :  

          1)Provides for the practice of pharmacy and the licensing and  
            regulation of pharmacies and pharmacists by the Board of  
            Pharmacy (Board) within the Department of Consumer Affairs.

          2)Specifies certain requirements regarding the dispensing and  
            furnishing of dangerous drugs and devices, and prohibits a  
            person from furnishing any dangerous drug or device except as  
            prescribed by a physician, dentist, podiatrist, optometrist,  
            or veterinarian.

          3)Requires that each prescription dispensed by a pharmacist must  
            be in a container meeting state and federal specifications and  
            correctly labeled, as specified, including:

             a)   Unless otherwise ordered by the prescriber, the  
               manufacturer's trade name of the drug or the generic name  
               and the name of the manufacturer, as specified;
             b)   The directions for the use of the drug;
             c)   The name of the patient or patients;
             d)   The name of the prescriber, as specified;
             e)   The date of issue;
             f)   The name and address of the pharmacy, and prescription  
               number or other means of identifying the prescription;
             g)   The strength of the drug or drugs dispensed;
             h)   The quantity of the drug or drugs dispensed;
             i)   The expiration date of the effectiveness of the drug  
               dispensed;
             j)   The condition or purpose for which the drug was  
               prescribed if the condition or purpose is indicated on the  
               prescription; and,








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             aa)  The physical description of the dispensed medication,  
               including its color, shape, and any identification code  
               that appears on the tablets or capsules.

          4)Requires a pharmacist to inform a patient orally or in writing  
            of the harmful effects of a drug dispensed by prescription if  
            the drug poses substantial risk to the person consuming the  
            drug when taken in combination with alcohol or if the drug may  
            impair a person's ability to drive a motor vehicle, whichever  
            is applicable, and provided the drug is determined by the  
            Board, as specified, to be a drug or drug type for which this  
            warning shall be given.  Allows the Board by regulation, to  
            require additional information or labeling.  Exempts from  
            these provisions drugs furnished to patients in conjunction  
            with treatment or emergency services provided in health  
            facilities, as specified.

           FISCAL EFFECT  :  This bill has not yet been analyzed by a fiscal  
          committee.

           COMMENTS  :

           1)PURPOSE OF THIS BILL  .  According to the author, inclusion of  
            an additional label on prescription drug containers will  
            further aid seniors who consume a disproportionate amount of  
            prescription medication.  In addition, a recent study by the  
            National Institutes of Health found that "there is a  
            communication gap between seniors and their physicians around  
            prescription medications.  Meeting these challenges will  
            require that more attention be devoted to medication  
            management during all clinical encounters."  A label  
            requirement as required by this bill is one of several steps  
            that can be taken to increase communication and medication  
            management. 

           2)BACKGROUND  .  

              a)   Medication Errors  .  SCR 49 (Speier), Resolution Chapter  
               123, Statutes of 2005, established the Medication Errors  
               Panel (Panel) which published a report in March 2007  
               entitled, "Prescription for Improving Patient Safety:  
               Addressing Medication Errors."  The report listed six  
               general goals to reduce medication errors.  Under each goal  
               were recommendations (12 in all) and methods to accomplish  
               each recommendation.  The Panel report states that "the  








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               information that consumers need to know about their  
               medication is often complex and may include unfamiliar  
               language or concepts.  Expecting a consumer to retain all  
               the pertinent knowledge from a brief verbal encounter may  
               not be reasonable in many instances."  Although the Panel  
               did not come to consensus on the most important subset of  
               consumers that are at "high risk" for medication errors, it  
               did acknowledge that there are a variety of factors which  
               may increase an individual's risk for experiencing a  
               medication error.  These include: i) low health literacy;  
               ii) limited English proficiency; iii) cultural incongruence  
               with healthcare providers; iv) physical, cognitive and/or  
               other impairments that make understanding and/or complying  
               with medication instructions difficult; v) age at either  
               end of the age spectrum (the variability of a medication's  
               response, metabolism and dose increases in children and  
               seniors); vi) multiple medications; vii) multiple  
               prescribers; viii) non-prescription medication use  
               (including herbals, dietary supplements, alcohol, and  
               tobacco); and, ix) medication procurement from more than  
               one pharmacy including mail-order. The Panel did state that  
               these factors must be taken into consideration in the  
               development of any consumer education efforts.  

             One bill was pursued in response to the Panel report.  SB 472  
               (Corbett), Chapter 470, Statutes of 2007, established the  
               California Patient Medication Safety Act which required the  
               Board to promulgate regulations on or before January 1,  
               2011 that require a standardized, patient-centered,  
               prescription drug label on all prescription medicine  
               dispensed to patients.  Additionally, the Board was  
               required to report to the Legislature by January 1, 2010,  
               on its progress in implementing these regulations.

              b)   Board of Pharmacy Report to the Legislature  .  Pursuant  
               to SB 472, the Board submitted its report entitled  
               "Prescription Drugs: Labeling Requirements" to the  
               Legislature on January 2010.  The report indicated the  
               steps the Board took prior to adopting the final  
               regulations to implement SB 472.  Specifically, the Board  
               conducted public hearings to collect information from the  
               public, developed a survey filled out by consumers at  
               various public outreach events and surveys, including a  
               radio-sponsored survey.









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             The final regulations adopted by the Board required drug  
               containers to conform to a specified format, including a  
               12-point sans serif typeface, which lists the name of the  
               patient, name of the drug (manufacturer's trade name or  
               generic name and name of the manufacturer) and strength of  
               the drug, directions for use, and purpose or condition, if  
               entered onto the prescription by the prescriber, or  
               otherwise known to the pharmacy and its inclusion on the  
               label is desired by the patient.  The regulations also  
               require the Board to publish on its Web site translation of  
               the directions for use into at least five languages other  
               than English to facilitate their use by California  
               pharmacies.  Examples of labels must also be collected and  
               published on the Board's Web site to aid pharmacies in  
               label design and compliance.  Additionally, the regulations  
               provide that for patients who have limited English  
               proficiency, upon request by the patient, the pharmacy must  
               provide an oral language translation of the prescription  
               container label's information.  The Board is also required  
               to re-evaluate the requirements of the regulations by  
               December 2013.
                 
           3)SUPPORT  .  The California Senior Legislature states that  
            disclosure of harmful effects of drugs on the actual label  
            container will further help protect the vulnerable group of  
            elders and dependent adults.

           4)DOUBLE REFERRAL  .  This bill is double referred, should it pass  
            out of this Committee, it will be referred to the Assembly  
            Business, Professions & Consumer Protection Committee.

           5)RELATED LEGISLATION  .  

             a)   AB 396 (Fox) requires that every prescription include a  
               legible, clear notice of the condition or purpose for which  
               the drug is prescribed, unless the patient or prescriber  
               requests that this information be omitted.  AB 396 would  
               also require that every prescription container be correctly  
               labeled to include that information, if so indicated on the  
               prescription, unless the patient or prescriber requests  
               that this information be omitted.  AB 396 is currently in  
               the Assembly Rules Committee awaiting referral.

             b)   SB 204 (Corbett) requires a pharmacist to use  
               translations of the directions for use in non-English  








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               languages published on the Board's Internet Web site, as  
               applicable, when labeling a prescription container;  
               authorizes a pharmacist to translate the directions for use  
               into additional non-English languages if certified  
               translation services are utilized to complete the  
               additional translations.  SB 204 is pending in Senate  
               Business, Professions and Economic Development Committee.

             c)   SB 205 (Corbett) requires the information on the  
               prescription label to be printed in at least a 12-point  
               sans serif typeface. SB 205 is pending in Senate Business,  
               Professions and Economic Development Committee.

             d)   SB 289 (Correa) makes it unlawful for a person to drive  
               a motor vehicle if his or her blood contains any detectable  
               amount of a drug classified in Schedules I, II, III, or IV  
               of the California Uniform Controlled Substance Act, unless  
               the drug was consumed in accordance with a valid  
               prescription issued to the person by a licensed health care  
               practitioner.  SB 289 is pending in Senate Public Safety  
               Committee.

           6)PREVIOUS LEGISLATION  .  

             a)   SB 472 (Corbett), Chapter 470, Statutes of 2007,  
               requires the Board to promulgate regulations that require,  
               on or before January 1, 2011, a standardized,  
               patient-centered, prescription drug label on all  
               prescription medication dispensed to patients in  
               California. 

             b)   AB 1276 (Karnette) of 2007 would have required  
               prescribers of medications to ask the patient, whether to  
               indicate the intended purpose of the prescription on the  
               prescription's label.  AB 1276 died in Assembly Business  
               and Professions Committee.

             c)   SCR 49 established a panel to study the causes of  
               medication errors and recommend changes in the health care  
               system that would reduce errors associated with the  
               delivery of prescription and over-the-counter medication to  
               consumers.

             d)   AB 657 (Karnette) of 2005 would have required  
               prescription labels to include the intended purpose of the  








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               drug, if indicated on the prescription, and required a  
               physician, dentist, optometrist, podiatrist, and other  
               specified drug prescriber, to ask the patient, or patient's  
               representative whether to indicate the intended purpose of  
               the prescription on the label.  AB 657 died in Senate  
               Business, Professions and Economic Development Committee. 

             e)   AB 288 (Mountjoy) of 2005 would have required the  
               prescription container to be labeled with the condition for  
               which the drug was prescribed, unless the patient,  
               physician, or a parent or legal guardian of a minor patient  
               requests that the information be omitted.  AB 288 died in  
               Assembly Health Committee. 

             f)   AB 2125 (Levine) of 2004 would have required a physician  
               and surgeon to indicate a patient's diagnosis on each  
               prescription, as specified, and required the prescription  
               label to include the condition for which the drug was  
               described, unless the patient directs the pharmacist not to  
               include this information on the label.  AB 2125 died in  
               Assembly Health Committee. 

             g)   SB 292 (Speier), Chapter 544, Statutes of 2003, required  
               prescription labels to include a physical description of  
               the drug, including the color, shape, and any  
               identification code that appears on the tablet or capsule.

             h)   AB 2099 (Epple) Chapter 397, Statutes of 1993, required  
               that the condition for which the drug is being prescribed  
               must be included on the label if the patient requests that  
               information on the label.

           7)POLICY QUESTIONS  .

              a)   Is this bill necessary  ?  Current law already requires a  
               pharmacist to inform a patient orally or in writing of the  
               harmful effects of a drug dispensed if the drug poses  
               substantial risk to the person consuming the drug when  
               taken in combination with alcohol or if the drug may impair  
               a person's ability to drive a motor vehicle, and provided  
               the drug is determined by the Board to be a drug or drug  
               type for which this warning shall be given.   

             b)   Is this bill too broad  ?  The way this bill is drafted,  
               it requires a pharmacist to include a written label on  








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               every drug container that the drug may impair a person's  
               ability to operate a vehicle or vessel.  Should this bill  
               apply only to drugs that are of the type for which such  
               warning is necessary?  It is also unclear why the risk of  
               driving a vehicle or vessel is particularly required to be  
               included in a label given that there are a variety of  
               warnings that a pharmacist may include (e.g. do not drink  
               alcohol, or drinking may increase the effect of the drug,  
               take on an empty stomach or take with plenty of water)  
               depending on the particular drug.  

           REGISTERED SUPPORT / OPPOSITION  :  

           Support  

          California Senior Legislature

           Opposition  

          None on file.
           
          Analysis Prepared by  :    Rosielyn Pulmano / HEALTH / (916)  
          319-2097