5.2 Pharmacist-in-Charge Duties

Key Takeaways

  • Minn. Stat. 151.01 subd. 22 defines the pharmacist-in-charge (PIC) as a Minnesota-licensed pharmacist designated under Board rules.
  • Rule 6800.2400 requires every pharmacy to have a PIC who is regularly employed in the pharmacy department and professionally responsible for compliance.
  • PIC duties include policies for drug procurement/storage/compounding/dispensing, supervision of professional and drug-related nonprofessional staff, technician procedures and registration, record systems, deficiency responses, and error-reduction quality assurance.
  • A pharmacist may be PIC of only one pharmacy, with a limited public-health waiver for part-time hospital pharmacy service.
  • PIC termination requires immediate Board notification and prompt successor designation; the successor files Board forms (including variance acknowledgment) within ten days of receipt.
Last updated: July 2026

5.2 Pharmacist-in-Charge Duties

Quick Answer: Under Minn. Stat. 151.01, subd. 22, the pharmacist-in-charge (PIC) is a Minnesota-licensed pharmacist designated under Board rules. Rule 6800.2400 requires every pharmacy to have a PIC who is regularly employed in the pharmacy department and who bears professional responsibility for policies, supervision, technician systems, storage, records, deficiency responses, and operational quality assurance. A pharmacist may be PIC of only one pharmacy (limited hospital waiver). PIC changes must be reported immediately, with successor forms filed promptly.

If renewal/CE is about keeping your personal credential alive, PIC law is about who owns the pharmacy’s legal operating system. On the MPJE, PIC questions often look operational (“Who must fix this inspection deficiency?”) rather than clinical.

Statutory Definition

Minn. Stat. 151.01, subdivision 22 defines “pharmacist in charge” as a duly licensed pharmacist in the state of Minnesota who has been designated in accordance with Board of Pharmacy rules. Key pieces of that definition:

  • Minnesota license (not merely a pharmacist licensed only in another state)
  • Designation under Board rules (not informal title-only status)
  • Role tied to a specific pharmacy’s licensure/renewal apparatus

Title inflation does not create PIC status. The Board looks for the designated PIC on applications, renewals, and change forms.

Rule 6800.2400 — The Operating Rule

Subpart 1: Core duty

No person shall conduct a pharmacy without a pharmacist-in-charge. The PIC must be a pharmacist regularly employed in the pharmacy department and designated in the license application, each renewal, or under the succession procedures in Subpart 4.

The rule frames the PIC’s duty as consistent with accepted standards of professional conduct and practice and compliance with all applicable laws. That dual framing matters: the PIC is not a paper figurehead; the PIC is accountable for building systems that make legal practice possible day after day.

Subpart 1 items A–J (memorize the map)

ItemPIC responsibility (paraphrased for study)
AEstablish policies and procedures for employees regarding procurement, storage, compounding, and dispensing of drugs and communication of drug-therapy information to the public
BSupervise all professional employees of the pharmacy
CAssure that persons in internship/residency/fellowship programs are appropriately licensed or registered with the Board
DSupervise nonprofessional employees insofar as duties relate to procurement, sale, and/or storage of drugs
EDevelop detailed written procedures directing pharmacy technician activities; make procedures available to the Board; ensure technicians are registered (see Rule 6800.3850)
FEstablish and supervise storing and safekeeping of drugs
GEstablish and supervise the recordkeeping system for purchase, sale, possession, storage, safekeeping, and return of drugs
HNotify the Board immediately upon knowledge that PIC services have been or will be terminated
IRespond to deficiency reports
JEnsure staffing and operational quality assurance policies are developed, implemented, and followed to decrease and monitor prescription errors

How to use the A–J list on exam day

When a stem describes a failure, map it:

  • Missing tech SOPs or unregistered techs → E (and related tech rules)
  • Chaotic controlled-substance storage → F (plus federal/state CS rules)
  • No purchase/return logs → G
  • Inspection punch list ignored → I and Subp. 2
  • Chronic wrong-drug errors with no QA process → J
  • Owner fires the PIC and no one tells the Board → H and Subp. 4

Deficiency Reports (Subpart 2)

If the Board or its staff notes deficiencies on inspection, the PIC must, within 30 days of receiving notice, submit in writing the steps taken or proposed to eliminate the deficiency. Failure to submit the report or to eliminate the deficiency is grounds for disciplinary action. This is a high-yield timing and accountability fact: 30 days to respond in writing; silence is not a strategy.

One Pharmacy Only (Subpart 3)

No pharmacist shall be designated PIC of more than one pharmacy. In the interest of public health, this requirement may be waived when a pharmacist serves a hospital pharmacy on a part-time basis. Do not generalize the waiver to “any two community stores if the hours don’t overlap.” The rule’s explicit exception language is hospital part-time service, not free-form multi-site community PIC duty.

Termination and Succession (Subpart 4)

PIC turnover is tightly regulated because a pharmacy cannot operate without a designated PIC.

Required sequence (exam checklist):

  1. Pharmacy notifies the Board immediately upon knowledge of PIC service termination.
  2. Pharmacy immediately designates a successor PIC and notifies the Board of that designation.
  3. Board furnishes prescribed forms to the successor.
  4. Successor completes and files forms with the Board within ten days after receipt.
  5. On the approved form, the successor acknowledges awareness and understanding of any variances granted to the pharmacy under Rule 6800.9900.
  6. The successor is responsible for ensuring conditions imposed on variances continue to be met.

Board communications also emphasize practical tools such as a Certificate of Responsibility (or equivalent designation paperwork) and reviewing Board Guidelines for Pharmacists-in-Charge during handoff. For MPJE purposes, prioritize the rule’s immediate notice + successor designation + 10-day form filing + variance continuity chain.

What “Regularly Employed” and “Professional Responsibility” Mean

The PIC must be regularly employed in the pharmacy department—not a remote signature with no operational presence. The professional-responsibility concept means the PIC’s compliance duty is personal and professional, not fully outsourced to corporate compliance staff. Corporate policies help only if the PIC actually implements and supervises them under Minnesota rules.

PIC responsibility does not mean the staff pharmacist is free of individual professional duties. Staff pharmacists still counsel, verify, refuse illegitimate prescriptions, and follow law. The PIC is the system owner; every pharmacist remains a licensed professional.

PIC Intersections with Other Minnesota Topics

TopicPIC angle
Technician registration/CEWritten tech procedures; registration compliance (6800.2400 E; 6800.1500; 6800.3850)
Supervision ratiosSystems must keep practice within §151.102 and Rule 6800.3850 constraints
Controlled substancesStorage/safekeeping and record systems (F/G) overlay DEA/CSA duties
Counseling and public drug informationPolicies for communicating drug-therapy information (A)
CompoundingProcurement/compounding/dispensing policies (A) plus compounding standards elsewhere in Rule 6800
Quality/errorsStaffing and QA policies to decrease and monitor Rx errors (J)
VariancesSuccessor must know and continue variance conditions (Subp. 4)

Common Exam Vignettes

  1. Inspection deficiency: PIC receives written notice, does nothing for 45 days → violation of 30-day written response duty; discipline risk.
  2. Dual PIC claim: Same pharmacist named PIC at two community pharmacies without a valid waiver → violates one-pharmacy rule.
  3. Sudden resignation: Owner continues operating for a week with no designated PIC while “searching” → pharmacy may not operate without a PIC; immediate designation/notice duties.
  4. Unregistered techs: PIC “assumed HR handled registration” → PIC still responsible to ensure tech registration and written procedures.
  5. Variance amnesia: New PIC ignores conditions on a Board-granted variance → successor responsibility failure under Subp. 4.

Action Checklist for Section 5.2

  1. Recite the statutory PIC definition (MN-licensed + designated).
  2. List A–J duties in plain English without looking.
  3. State the 30-day deficiency-response rule.
  4. State the one-pharmacy rule and hospital part-time waiver concept.
  5. Walk the termination → immediate notice → successor → 10-day forms → variance acknowledgment path.

Next, section 5.3 converts compliance failures into Board discipline and unprofessional conduct under Rule 6800.2250 and §151.071.

Test Your Knowledge

Under Minn. Stat. 151.01, subd. 22, who is a pharmacist-in-charge?

A
B
C
D
Test Your Knowledge

After the Board notes inspection deficiencies, what must the PIC do under Rule 6800.2400 Subp. 2?

A
B
C
D
Test Your Knowledge

Which statement best reflects Rule 6800.2400’s one-pharmacy PIC rule?

A
B
C
D
Test Your Knowledge

When PIC services terminate, which succession step is required under Rule 6800.2400?

A
B
C
D