Pseudoephedrine Purchase Limits and the Logbook
On a weekday afternoon, a 24-year-old man comes to a Montana pharmacy and asks to buy three boxes of a 24-count package of pseudoephedrine 30 mg tablets. He also says he bought one 24-count box at another store yesterday. He presents a valid Montana driver's license, signs the pharmacy's logbook, and pays cash. The pharmacy's logbook shows no other pseudoephedrine purchases by this person at this store. The pharmacy keeps the product behind the counter. The pharmacist is busy, but the technician is at the register. The customer is not purchasing anything else and is acting politely. The pharmacy has a current DEA self-certification for selling scheduled listed chemical products and has trained its employees on the logbook requirements.
1. Calculate the total quantity and determine whether the sale complies with federal daily and 30-day limits.
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Three 24-count boxes contain 72 tablets. At 30 mg per tablet, that is 72 × 30 = 2,160 mg, or 2.16 g. The purchase yesterday was 24 × 30 = 720 mg, or 0.72 g. The combined 24-hour and 30-day total is 2.88 g. The federal Combat Methamphetamine Epidemic Act limits are 3.6 g per day and 9 g in any 30-day period. The sale is within both limits. The pharmacist may sell the three boxes if the log is completed, the customer is at least 18, and photo ID is checked. The pharmacy must keep pseudoephedrine behind the counter and may not allow direct customer access. The technician may complete the log, but the pharmacist remains responsible for compliance and should be available to resolve any discrepancy.
2. What recordkeeping and access requirements apply to this sale?
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The seller must maintain a written or electronic logbook for each pseudoephedrine sale. The log must record the purchaser's name, address, date and time of sale, product name, quantity sold, and signature, and must show the purchaser's photo ID. The log must be kept for at least two years. The pharmacy must have a current DEA self-certification for selling scheduled listed chemical products, must train employees, and must not sell to anyone under 18. The log is not a substitute for the pharmacist's judgment; repeated purchases, altered ID, or a customer who refuses to sign are red flags. The pharmacy must also limit direct access to the product and must not sell more than the federal daily or 30-day limits in a single transaction or through split sales.
3. If the log showed 9.5 g purchased in the past 30 days, what should the pharmacy do?
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If the log showed 9.5 g purchased in the past 30 days, the sale would exceed the 9 g 30-day limit, and the pharmacy must refuse the sale. The pharmacist should explain the limit, document the refusal, and not sell any package that would push the customer over 9 g. If the customer had already exceeded the daily 3.6 g limit, the sale would also be refused. The pharmacy should not "split" the sale between family members or use a different name to evade the limit. Montana may impose additional restrictions, but the federal limits are a floor. A customer who repeatedly approaches the limit or uses multiple identities should be treated as a suspicious purchaser and the pharmacist should consider whether a report to law enforcement or the Board is appropriate under the circumstances.