BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 1280
                                                                  Page  1

          Date of Hearing:   May 18, 2011

                        ASSEMBLY COMMITTEE ON APPROPRIATIONS
                                Felipe Fuentes, Chair

                     AB 1280 (Hill) - As Amended:  May 11, 2011 

          Policy Committee:                              Public 
          SafetyVote:  7-0

          Urgency:     No                   State Mandated Local Program: 
          Yes    Reimbursable:              No

           SUMMARY  


          This bill makes a series of changes related to the sale of 
          nonprescription products containing pseudoephedrine or other 
          methamphetamine precursors. Specifically, this bill:


          1)Requires, effective January 1, 2013, ephedrine and 
            pseudoephedrine (PSE) retailers to transmit specified detailed 
            purchase information to the National Precursor Log Exchange 
            (NPLEx) to determine if the proposed sale violates purchasing 
            restrictions. 


          2)Provides that if the Department of Justice (DOJ) enters into a 
            memorandum of understanding (MOU) with the National 
            Association of Drug Diversion Investigators (NADDI), NADDI 
            will provide DOJ real-time transaction record information via 
            NPLEx online law enforcement portals. 


          3)Specifies the NPLEx information may not be used for any 
            purpose other than to meet the requirements of this act, or 
            the federal Combat Methamphetamine Act of 2005.  


          4)Creates a misdemeanor for any retail distributor, except 
            pursuant to a prescription from a licensed practitioner, to 
            sell or distribute specified amounts of nonprescription PSE 
            products (ephedrine, pseudoephedrine, norpseudoephedrine, or 
            phenylpropanolamine) within specified time limits, to sell or 








                                                                  AB 1280
                                                                  Page  2

            distribute those substances to a person whose information has 
            generated an alert, or, except under specified conditions, to 
            sell or distribute any amount of those substances, unless the 
            purchaser provides valid identification, signs a written or 
            electronic log  showing date and time, name, date of birth, 
            and address of the purchaser, and amount of product purchased. 



          5)Sunsets these provisions on January 1, 2018. 


           FISCAL EFFECT


           1)Unknown nonreimbursable local law enforcement costs related to 
            investigating, prosecuting and punishing illegal 
            nonprescription PSE sales.


          2)Minor absorbable costs to DOJ to enter into a MOU with NADDI 
            for NPLEx access.


          3)Minor absorbable costs to the Board of Equalization to modify 
            retailers of NPLEx requirements.





           COMMENTS  


          1)Rationale  . The author intends to address what he sees as a 
            deficiency in current law:  that despite maximum purchase 
            limits and identification requirements, current law does not 
            prevent would-be meth cookers from hitting up multiple drug 
            stores. According to the author, 


            "AB 1280 remedies this deficiency. The bill requires retailers 
            selling over-the-counter PSE products to submit specified 
            information into an electronic, networked, logbook prior to 
            completing the sale. The information would be identical to 








                                                                  AB 1280
                                                                  Page  3

            that already required to be entered into the existing paper 
            logbook. Retailers would immediately know whether a consumer 
            has exceeded the federal purchase limits and would be required 
            to stop the sale."  


          2)NPLEx  is a real-time electronic logging system used by 
            pharmacies and law enforcement to track sales of 
            over-the-counter (OTC) cold and allergy medications containing 
            precursors to the illegal drug, methamphetamine. NADDI 
            provides NPLEx at no cost to states that have legislation 
            requiring real-time electronic monitoring of precursor 
            purchases and agree to use the system.


            NPLEx was developed by, and operated by a private company, 
            Appriss, Inc, which has sold NPLEx to pharmacy chains and 
            states. It appears NAPLEx is being used in 12 states. 


            This bill proposes that NADDI will administer NAPLEx. NADDI is 
            a non-profit organization which appears to be supported, at 
            least in part, by the pharmaceutical industry. According to 
            NADDI, it is a "unique membership organization whose members 
            are responsible for investigating and prosecuting 
            pharmaceutical drug diversion. The organization has proven to 
            be a valuable asset to law enforcement, the pharmaceutical 
            industry and health regulatory personnel."


           3)Support  . This bill is supported by retailers and the 
            pharmaceutical industry, as well as the State Sheriffs 
            Association, the District Attorneys Association, and the Peace 
            Officers Research Association (PORAC). The for-profit 
            supporters oppose a competing effort to crack down on PSE 
            sales that would require a prescription for PSEs. 

            According to the Consumer Healthcare Products Association, 
            "With NPLEx in place, retailers will obtain pre-approval from 
            the system to make a sale, and over-limit sales are denied, 
            stopping illegal sales before they happen.  The sales data are 
            maintained in a highly secure environment and, under federal 
            law and the provisions of AB 1280, are legally available only 
            to law enforcement.  Manufacturers fully fund NPLEx, so there 
            is no charge to retailers, states, or law enforcement.








                                                                  AB 1280
                                                                  Page  4

            
            "In addition, AB 1280 represents an alternative to proposals 
            which would make these FDA approved products available only 
            with a prescription.  Such proposals are an extreme reaction 
            and have serious negative health care access and fiscal 
            impacts.  As you know, over the counter medications are taxed 
            at the point of sale while prescription medications are not.  
            This measure, AB 1280, preserves the sales tax on these safe 
            and effective products estimated at over $ 4 million in 2010, 
            while helping to safeguard the community from illicit meth 
            production."

           4)Opposition  . DOJ and the state narcotics officers association 
            oppose this bill in favor of SB 315 (Wright), which would 
            require a prescription for purchase of PSEs. SB 315, supported 
            by many law enforcement representatives, and opposed by 
            retail, pharmaceutical and business affiliations, is pending 
            in Senate Health Committee, and appears to be finished for the 
            year. A similar bill, SB 486 (Wright) failed in Assembly 
            Public Safety last year.

            According to DOJ, AB 1280 will prove ineffective:  
            "Unfortunately, tracking systems in place in other states have 
            failed to curtail the increase in methamphetamine labs.  In 
            fact, the only states that have documented a significant 
            decrease in methamphetamine labs, as well as decreases in the 
            amount of methamphetamine manufactured, are Oregon and 
            Mississippi. Implementation of the tracking system anticipated 
            by Assembly Bill 1280 would not address California's 
            methamphetamine problem, and could work to delay 
            implementation of a prescription only system."

            The ACLU also opposes this bill, contending it is an 
            infringement on privacy rights. "We strongly oppose the 
            creation of a government-mandated database of all people who 
            purchase any amount of a lawful over-the-counter medication 
            with open access by law enforcement agencies without 
            justification."

           
          Analysis Prepared by  :    Geoff Long / APPR. / (916) 319-2081 












                                                                  AB 1280
                                                                  Page  5