Pseudoephedrine Daily Limit and Logbook Sale
A 19-year-old man comes into a Bangor, Maine, pharmacy and asks for two 24-count boxes of 30 mg pseudoephedrine tablets and one 20-count box of 60 mg pseudoephedrine tablets. He presents a valid Maine driver's license and signs the electronic logbook. The technician then notices he has also brought a handwritten list from a friend requesting an additional 48-count box of 30 mg tablets and says the friend is waiting in the car. The logbook shows that the same customer purchased one 24-count box of 30 mg tablets at this pharmacy three days earlier. The pharmacy's system is working. The customer is not buying any other products and becomes impatient when asked about the friend. The pharmacy has a policy of refusing suspicious purchases.
1. Calculate the total pseudoephedrine the customer is requesting today, including the friend's additional box, and determine whether the sale may be made under federal daily and 30-day limits. Show your work.
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30 mg x 24 tablets = 720 mg per 24-count box. Two boxes = 1,440 mg. 60 mg x 20 = 1,200 mg. The customer's own request totals 2,640 mg. The friend's extra 48-count box is 30 mg x 48 = 1,440 mg. Including it, the total would be 4,080 mg.
The federal daily limit for a scheduled listed chemical product is 3.6 g, or 3,600 mg, per purchaser per day. The customer's own 2,640 mg is under the daily limit; adding the friend's box would exceed it by 480 mg, so the pharmacy may not sell all of it to him today. The 30-day limit is 9 g; even with the friend's box and the 720 mg purchased three days ago, the total would be 4,800 mg, which is under 9 g. The daily limit is the controlling problem.
2. What logbook and identification requirements apply to the sale, and how long must records be kept?
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Pseudoephedrine is a scheduled listed chemical product. The pharmacy must keep it behind the counter or in a locked cabinet not accessible to the public. Before the sale, the purchaser must present photo identification, and the seller must record the purchaser's name, address, identification number, the product name, quantity, and date and time of sale, and obtain the purchaser's signature. The logbook may be written or electronic and must be retained for two years. The seller must determine that the sale is not a scheme to obtain the product for unlawful manufacture; the logbook is not a prescription and does not require a prescriber. The pharmacy should also ensure the electronic system is functioning and that the entry is complete before the transaction is finalized.
3. The customer insists the friend's box is not for him. How should the pharmacist respond, and what red flags support refusal?
Read the worked answer
Explain that the daily limit applies to the purchaser standing at the counter; the friend cannot avoid the limit by sending someone else, and the pharmacy cannot knowingly participate in that evasion. The friend must come in personally with photo identification and sign the logbook if he wants to purchase. The request for a friend waiting in the car, the handwritten list, and the prior purchase three days earlier are red flags for smurfing. The pharmacist should decline the additional box, sell only what is within the customer's own daily limit if otherwise appropriate, document the refusal and the reason, and notify the pharmacist-in-charge or loss-prevention contact. If the customer becomes threatening, the pharmacy should follow its safety policy.