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California State Board of Pharmacy

Staffing Ratio of Pharmacists to Intern Pharmacists and General Supervision and Interprofessional Supervision - Immunizations - BPC section 4114

In light of Governor Gavin Newsom’s declaration of emergency and the national declaration of emergency, and consistent with Business and Professions Code (BPC) section 4062, the California State Board of Pharmacy (Board) or the Board president through delegated authority has issued the following waiver.

Ratio for Pharmacists not Solely Engaged in Immunization-Related Activities

The ratio of pharmacists to intern pharmacists may increase to allow for one additional intern pharmacist for each supervising pharmacist under the following conditions:

  1. The additional intern pharmacist is administering immunizations consistent with the provisions of Pharmacy Law.
  2. The pharmacy maintains a readily retrievable record documenting the date(s) and time(s) when the ratio is increased pursuant to this waiver and the staff operating under the waiver. Records must be maintained for one year following the end of the declared emergency.

Intern pharmacists providing immunizations under the provisions of this waiver may do so under the general supervision of a pharmacist at the discretion of the supervising pharmacist.

Ratio for Pharmacists Solely Engaged in Immunization-Related Activities

Alternatively, the ratio of pharmacists to intern pharmacists may increase to allow for two additional intern pharmacists for each supervising pharmacist under the following conditions:

  1. The supervising pharmacist is solely engaged in immunization-related activities.
  2. The additional intern pharmacists are administering immunizations consistent with the provisions of Pharmacy Law.
  3. The pharmacy maintains a readily retrievable record documenting the date(s) and time(s) when the ratio is increased pursuant to this waiver and the staff operating under the waiver. Records must be maintained for one year following the end of the declared emergency.

Intern pharmacists providing immunizations under the provisions of this waiver may do so under the general supervision of a pharmacist at the discretion of the supervising pharmacist.

Supervision of Pharmacist Interns Performing Solely COVID-19 and/or Influenza Vaccine-Related Functions in Connection with State, Local, Federal or Institutional Vaccination Efforts

In connection with state, local, federal or institutional vaccination efforts, an intern pharmacist may perform authorized COVID-19 and influenza vaccination-related functions consistent with the provisions of Pharmacy Law, including COVID-19 and/or Influenza vaccine administration, at the direction of and under the supervision of a pharmacist, or other California-licensed physician and surgeon, nurse practitioner or physician assistant who are experienced in administering intramuscular injections, who are statutorily authorized to order and administer vaccines, supervise the performance of vaccinations, perform such vaccination duties as a part of their statutorily authorized scope of practice, and whose license is in good standing with the respective regulatory board. 

The vaccine sponsoring entity at such sites shall determine whether other healthcare professionals are experienced in administering intramuscular injections such that they may appropriately supervise pharmacist interns at such sites.

For pharmacist interns operating within the scope of this waiver, the designated vaccination provider organization (i.e., pharmacy, clinic, health department, or other applicable entity) shall maintain a record that identifies the supervising health care professional under whose supervision the intern pharmacist performed vaccination-related functions.  The record must be maintained and readily available for three years following the end of the declared emergency and provided to the Board upon request.

Amended and reissued:  October 14, 2021

Expiration: December 31, 2022 or until 30 days after the emergency declaration is lifted, whichever is sooner.