Legal situation?
The terminal can be connected directly to the Pharmacy but it can be used as well outside the pharmacy as part of mail order.
If the terminal is used as part of the mail order business, it can be supplied by the pharmacy’s own staff. It is only necessary to ensure that this method of collection is duly agreed with the patient. Since the dispensing of the drug in the legal sense takes place beforehand in the pharmacy premises, the delivery can take place via the terminal as a subsequent step. In this respect, only the processes in the pharmacy’s QMS need to be adjusted accordingly, for example to determine which deliveries are not suitable for this route. In a further step, consideration can also be given to collecting drug orders at the terminal at the same time.
If the terminal is used in the context of mail order business, the provisions of § 24 ApoBetrO do not conflict with this. After all, it is possible that the terminal will not be installed by the pharmacy, but by a third party, such as a municipality. In this case, a corresponding agreement between the pharmacy on the one hand and the operator of the terminal must be ensured that the delivery via the terminal is in accordance with the requirements of the case law of the BVerwG and that the actual withdrawal of the inserted drugs is documented in such a way that it is Information is provided by the pharmacy.
The use of the station is in accordance with the regulation § 17 ApoBetrO.
(Source: Dr. Douglas report from Friedrich Graf von Westphalen& Partner mbH).