[NFBWATlk] Accessible prescription labels in Washington

[Jamal Mazrui]

With her permission, I am sharing correspondence below from a local ACB 
member, Judy Brown.This relates to advocacy for accessible prescription 
labels in the state of Washington.I am unsure whether we in the NFB have 
a position on this issue.

Folks who support regulatory action in this area can make a difference 
by conveying personal stories about the need for it with the Washington 
Department of Health.Of course, we can put our own slant on the issue.

Jamal

Begin forwarded message:

*From:*"Trant, Lindsay A (DOH)" 
<lindsay.trant at doh.wa.gov<mailto:lindsay.trant at doh.wa.gov>>
*Date:* September 10, 2021 at 2:01:10 PM PDT
*To:* JEIBroWN726 at gmail.com<mailto:JEIBroWN726 at gmail.com>
*Subject:* *RE: URGENT REVIEW PLEASE: Request for ruling making for 
accessible medication labels*



Hi Judy,

Thank you for contacting the Pharmacy Quality Assurance Commission 
(commission) with your request regarding rulemaking for accessible 
labeling on medication bottles.

We will treat your e-mail request as a formal rules petition, which is 
described in RCW 
34.05.330<https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fapps.leg.wa.gov%2Frcw%2Fdefault.aspx%3Fcite%3D34.05.330&data=04%7C01%7Clindsay.trant%40doh.wa.gov%7Cadb07b94dd414c2b425808d8f5e67268%7C11d0e217264e400a8ba057dcc127d72d%7C0%7C0%7C637529717405433121%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=rD6b2FGVQmis5EnIFAvO73Hc6Yv2hm2kzsQl7tIP0GA%3D&reserved=0>.

The commission will consider your request and you can expect an answer 
by November 7th. If you are not already, you can sign up to receive 
emails from the commission 
here<https://public.govdelivery.com/accounts/WADOH/subscriber/new>, 
which include notices for commission meetings and agendas. If you have 
any questions please feel free to reach me at the contact information below.

We appreciate your interest in our rulemaking process!

*Lindsay Trant, MPP*

Pronouns: She/Her

Interim Deputy Director

Pharmacy Quality Assurance Commission

Health System Quality Assurance

Washington State Department of Health

Lindsay.trant at doh.wa.gov<mailto:Lindsay.trant at doh.wa.gov>

360-236-2932 | www.doh.wa.gov<http://www.doh.wa.gov/>

*From:* Judiith Ingraham Brown 
<jeibrown726 at gmail.com<mailto:jeibrown726 at gmail.com>>
*Sent:* Wednesday, September 8, 2021 3:46 PM
*To:* DOH WSPQAC <WSPQAC at doh.wa.gov<mailto:WSPQAC at doh.wa.gov>>
*Subject:* Request for ruling making for accessible medication labels

External Email



To Whom It May Concern,

The Washington Council of the Blind Advocacy and Governmental Affairs 
Committees are requesting that the Washington Pharmacy Compliance Board 
create rules to require pharmacies in Washington State to offer 
accessible labeling on medication bottles. The Food and Drug 
Administration Safety Innovation Act  of 2012, section 904, tasked the 
US Access Board to develop Best Practices for Accessible Medication 
Labels. The National Council on Disability along with the American 
Council of the Blind put together an online information site 
(www.ncd.gov<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.ncd.gov%2F&data=04%7C01%7Clindsay.trant%40doh.wa.gov%7C4545771fe3234ac04d5f08d9748c6493%7C11d0e217264e400a8ba057dcc127d72d%7C0%7C0%7C637668968587270369%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=%2BUXwJ5GUp2JFABpXVVDWk5EGcl%2B4GP1WeUnpBmpQFD8%3D&reserved=0>) 
and brochure highlighting best practices for pharmacies who serve 
  low-vision and blind persons. However, these were only 
recommendations. Therefore, many pharmacies, including pharmacies based 
in Washington state either do not follow these recommendations or only 
offer large print but no other accessible labeling options.

Over 25 million Americans age 65 and older have low-vision or are blind. 
This makes reading labels impossible without accommodations. I am 
legally blind and cannot see or read  medication labels. When I asked my 
local Costco pharmacy for large print labels, I was told they did not 
offer that service. I then asked how was I, as a legally blind person, 
supposed to read the small print on my medication bottle? I was told I 
needed to find someone to read the label to me. This is insulting. My 
privacy and independence are being taken away due to lack of 
understanding, professionalism and a failure to follow basic best 
practices guidelines for accessible medication labels. This is only one 
example of many such stories throughout Washington state involving other 
visually impaired persons. There is no consistency and therefore, 
patient safety is affected depending the pharmacy a person uses. In some 
areas of Washington, there are very few pharmacy choices. So, if you 
have to use a pharmacy that does not offer accessible labeling you are 
at risk for an avoidable medication error.

With the advances that En-Vision has made with Script Talk labeling, 
accessible medication labels are now available to other patient 
populations. Those who are reading impaired (dyslexia, low reading 
comprehension, English as a second language and others) now have a way 
to have way to know what the label says in an easy to use manner. This 
means many more patients could be positively impacted with this 
technology. Patient/consumer safety will increase.

Patient caused medication errors is a major reason for emergency room 
visits and, at times, hospitalization. The CDC estimates that 
non-adherence to medication treatments cause 30 to 50% of the chronic 
disease treatment failures. Furthermore, medications are not taken as 
prescribed about 50% of the time. While non-adherence to medication 
regimens has several causes, one major cause is understanding or being 
able to properly read the label.

Patient caused medication errors are avoidable. Communication is a key 
component is stopping these errors. Offering accessible medication 
labels will go a long way in improving medication communication.

Thank you for considering this request. Please feel free to contact me 
with any questions.

Judy Brown, RN, BSN

Washington Council of the Blind

Co-Chair Advocacy Committee

Member Governmental Affairs Committee

Jeibrown726 at gmail.com<mailto:Jeibrown726 at gmail.com>

207-944-1837

Shoreline, WA 98133