Call to Action
Written Comment Period Open! Deadline: 01/27/2025
As of January 08, the California State Board of Pharmacy (BOP) has pushed the regulations forward, despite broad public disapproval. However, they pushed it to a 15-day-comment period which ends on January 27, 2025. The BOP is required by law to consider all public comments received during this time. (See our Instagram post for more details. You may also view our blog post on LymeDIsease.org from the December comment period.)
Instructions:
1. Email written public comments to Lori Martinez at: PharmacyRulemaking@dca.ca.gov by January 27.
2. Reference which proposed regulations you’re commenting on: Title 16 CCR Sections 1735-1738
3. Explain in your own words why you are opposed to the proposed regulations which would severely limit access to widely used Category 1 sterile compounds like GSH and methyl B12, available in the rest of the USA.
Downloads:
Download the BOP's updated Statement of Reasons
Note: The above download is a 92-page document where the BOP attempts to justify harmful, broadly opposed proposed regulations that supersede the FDA and exceed US Pharmacopeia (USP) standards.
Download the BOP's slide show presentations from November 7:
presentation 1 and presentation 2
Note: these slideshows contain misleading and anecdotal information intended to create fear around natural and compounded medicine options. These downloads are especially useful if you are interested in calling the Board of Pharmacy out on misinformation in your written comment.
Download our list of prompts for inspiration. (Updated 09/10/2024)
Download a PDF of the proposed regulations (Latest version)
Join us at the California State Board of Pharmacy board meeting to voice your opposition:
When: February 5-6, 2025
Where: via Webex or in Sacramento
What: Attending and giving public comment
How: Links, prompts, and downloads below!
Exercising your 1st amendment right by sharing your opposition at this meeting will demonstrate to the Board of Pharmacy how their choices are impacting members of the public. You don't need to be a public speaker – just speak from the heart! You will have at least two minutes, and we have prepared a large list of prompts for you in the downloads section below.
Webex Meeting Links & Access Information:
Access links will be available and posted here 7 days before the meeting!
How to give your public comment in Webex:
When our agenda item comes up, click the "raise hand" button in Webex to alert the board members that you want to give a public comment.
IMPORTANT: At the last meeting, the Board made a last-minute change to the agenda, causing many advocates to lose their opportunity to speak. In order to avoid this, we ask that public commenters try to attend both days!
Impossible? Text us your name at 424-422-1807 to let us know you'd like to receive a text when our public comment period is starting. This way you can login to Webex to give your comment without sacrificing your whole day.
Downloads:
Download the official agenda for the Jan. 8 public board meeting
Download our list of prompts for inspiration. (Updated 09/10/2024)
Download a PDF of the proposed regulations (Latest version)
Download the Webex access guide if you run into any trouble
Download our Reasonable Accommodation Doctor's Note Template
Old versions of the proposed regulations to follow our progress:
Original Version | July 2024 version
Reasonable Accommodation:
At the July 31 board meeting, sick patients had to wait 4+ hours to give public comments as reasonable accommodation requests were not invited. We emailed them about this later. They indicated requests should be sent to debbie.damoth@dca.ca.gov with a doctor's note or other documentation proving illness 5 days prior to the meeting. Although we disagree with their requiring documentation just to speak early at a meeting, we highly encourage chronic illness warriors to partake and have done our best to make it easy!
Download our Reasonable Accommodation Doctor's Note Template
Here is a sample email to include with your doctor's note:
Dear Ms. Damoth, I am writing to request a reasonable accommodation for the September 12 board meeting. I suffer from a chronic illness that disables me from having the luxury of attending beyond 1 hour of the board meeting. As such, I am requesting an accommodation to provide my public comment for agenda items at the beginning of the meeting during the non-agenda item public comment period so that I may exercise my First Amendment right. See attached doctor's note. Thank you for ensuring the voices of disabled individuals are still heard.
Attending in-person:
California Department of Consumer Affairs
1625 N Market Blvd.,
Hearing Room, First Floor
Sacramento, CA 95834
Calling in by phone:
We do not recommend attending the meeting by phone as it can be difficult to determine when the public comment period for agenda items will begin. However, if this is your only option, please use access information below.
+1-415-655-0001 US Toll
Access code: 2496 568 9561
Passcode: 272718
Dial *3 when it is time to raise your hand for public comment.
Questions? Visit the California State Board of Pharmacy website at pharmacy.ca.gov or email info@stopthebop.com
Contact your representatives:
Writing to Governor Newsom and your state representatives helps give credibility to our cause. The more they hear from the public regarding a particular issue, the more likely they are to take action.
Find your representatives: https://findyourrep.legislature.ca.gov/
Here is an email template you can copy and paste:
I am writing to express my strong opposition to the California Board of Pharmacy (BOP) proposed regulations on pharmacy compounding that would restrict access to legal Category 1 sterile compounds, including essential treatments such as glutathione, NAD+, and methylcobalamin (vit B12). If enacted, these regulations would severely limit, and in many cases end, access to vital alternative medicines for Californians, particularly those with chronic illnesses, as well as firefighters who depend on glutathione for detoxification after toxic exposure.
The Alliance for Pharmacy Compounding identified 57 instances where the proposed regulations exceed federal and Pharmacopeia standards without scientific or legal justification. This overreach poses a significant threat to the health and well-being of vulnerable populations. The lack of transparency and clarity in these regulations is also concerning. The BOP’s responses to public comments have been largely generic, failing to address specific concerns, undermining genuine public participation.
Respected medical institutions have publicly opposed the regulations, arguing that they are arbitrary and do not align with federal law or scientific evidence. The regulations would disproportionately harm compounding pharmacies, patients, and firefighters who rely on these treatments, which remain available in all 49 other states.
It appears the BOP is exploiting Assembly Bill 973, signed by Gov. Newsom in 2019 to align pharmacy regulations with federal standards. The provision allowing the Board to exceed federal standards should not justify 57 deviations, as this was not the Legislature’s intent.
As this matter may soon be voted on at the Sept 12 BOP board meeting, I urge you to take action to ensure these harmful regulations do not go into effect. The health and lives of countless Californians depend on protecting access to these essential treatments.
Thank you for your attention to this critical issue.
Sending a letter the old-fashioned way? Click here to download our 1-page letter template.
For more immediate updates on what's going on, follow us on instagram: @stop.thebop