California Board of Pharmacy Issues Order Waiving Restrictions on Pharmacy Technicians’ Ability to Administer COVID-19 Vaccines

In an effort to keep our clients and potential clients informed of the latest news regarding pharmacy law and the state of affairs involving the Covid-19 pandemic and its impact on pharmacies, pharmacists and pharm techs, we learned today that the Board, pursuant to the Governor’s Executive Order N-39-20, during this State of Emergency, the Director of the California Department of Consumer Affairs has been empowered to waive any statutory professional licensing requirements and amend the scope of practice pertaining to individuals licensed pursuant to Division 2 of the Business and Professions Code which includes California pharmacy technicians.

Under this action, the Director of the DCA has waived Business and Professions Code section 4115(a)(c) and California Code of Regulations, title 16, sections 1793 and 1793.2, to the extent those provisions prohibit pharmacy technicians from administering COVID-19 vaccines to patients three and older which are approved by the Federal Food and Drug Administration (FDA) and, also includes the allowance for provision of epinephrine by injection in cases involving a severe allergic reaction to the vaccine.  These actions are subject to various conditions which include:

  • The pharmacy technician’s supervising pharmacist is also authorized to independently administer COVID-19 vaccine.
  • The supervising pharmacist delegates authority to the pharmacy technician to administering the COVID-19 vaccine or epinephrine, as circumstances warrant.
  • The supervising pharmacist maintains direct supervision and control of the pharmacy technician, pursuant to Business and Professions Code section 4023.5.
  • The pharmacy technician is certified in basic cardiopulmonary resuscitation (CPR).
  • The pharmacy technician has successfully completed at least six hours of a practical training program approved by the Accreditation Council for Pharmacy Education (ACPE) which includes hands-on injection techniques, recognition, and treatment of emergency reactions to vaccines and an assessment of the pharmacy technician’s injection technique.
  • The vaccine is administered in accordance with all relevant United States Food and Drug Administration (FDA) emergency use authorizations and regulations.
  • The supervising pharmacist complies with all applicable Federal and State recordkeeping and reporting requirements.
  • The pharmacy maintains a record of each vaccine administered by a pharmacy technician, with additional requirements which are set forth in more detail in the Board’s advisory letter issued today.

As long as a California pharmacy technician is acting within the scope of the above Order and is fully trained and supervised as set forth above, he or she may administer COVID-19 vaccines and epinephrine injections, in response to severe allergic reactions as specified above.

This order from the DCA is effective immediately but may be amended in the future, so all are advised to join any and all DCA mailing lists to keep up to date in the latest developments in this extremely important situation.

If you have questions regarding this matter or need to discuss a pharmacy law matter with our highly experienced attorneys, do not hesitate to call us today for a free consultation.

We continue to wish all of our clients, friends and associates the best of health and happiness in the coming season.


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This blog is meant to provide information on current news and general information. It is not intended to constitute legal advice, nor is any attorney-client relationship established by its posting on this website. If you are facing a situation that involves your professional license, consult with a licensed attorney.