13.3 Nuclear Pharmacies, Class E Outlets & Dispensing Medical Practitioners

Key Takeaways

  • A Utah nuclear pharmacy must have or have applied for a Utah Radioactive Materials License, and a Utah pharmacist with the required radiation training must be immediately available on site whenever it is open (R156-17b-614d).

  • A Utah hospital nuclear medicine department or practitioner office with a Utah Radioactive Materials License does not need a Class B pharmacy license (R156-17b-614d(7)).

  • Every Utah Class E pharmacy must keep a written protocol naming its supervisor, plan of care, drugs, and associated licensed health care providers (R156-17b-617a).

  • A Utah third-party logistics provider must comply with DSCSA and may not employ anyone convicted of a felony related to product tampering (R156-17b-617g).

  • A Utah dispensing medical practitioner must tell patients the drug may be obtained from an unaffiliated pharmacy, and must report controlled substance dispensing to the CSD (Utah Code § 58-17b-803(4)).

Last updated: September 2026

13.3 Nuclear Pharmacies, Class E Outlets & Dispensing Medical Practitioners

Blueprint item 4.7 covers the registration, licensure, and operating requirements of all practice settings. Utah's less common settings each have their own operating standards.

Nuclear pharmacies (R156-17b-614d)

  • License class: a nuclear pharmacy preparing medications for a specific person is Class B if in Utah and Class D if outside Utah.
  • Radioactive materials: it must hold, or have applied for, a Utah Radioactive Materials License, with enough space and equipment for its services.
  • Staffing: a licensed Utah pharmacist must be immediately available on the premises whenever the facility is open. That pharmacist must also have the classroom and laboratory training and experience the Utah Radiation Control Rules require. Interns and technicians may work under the direct supervision of a qualified preceptor.
  • Quality: it may dispense only radiopharmaceuticals that meet acceptable quality-assurance standards, and it must keep an appropriate library.
  • Compounding: sterile preparations follow USP <797>, and Utah's compounding rule also requires USP <825> (radiopharmaceuticals) (R156-17b-614e).
  • Exemption: a hospital nuclear medicine department, or the office of a physician, osteopathic physician, veterinarian, podiatric physician, or dentist, that holds a current Utah Radioactive Materials License does not need a Class B pharmacy license.

Class E pharmacies

Class E covers "all other pharmacies" and does not require a PIC (R156-17b-302(5)). Every Class E pharmacy must keep a written pharmacy care protocol naming its supervisor or director, its plan of care, the drugs it purchases, stores, uses, or accounts for, and any associated licensed health care providers, and it must comply with all applicable law (R156-17b-617a).

Class E typeKey Utah operating standards
Analytical laboratory (R156-17b-617b)Suitable facility; a list of drugs purchased, stored, and used; a list of associated licensed providers; possesses drugs only for analysis; prevents theft or loss of controlled substances. Labs using pre-diluted drug standards at no more than 1 mg/mL are excluded from the definition.
Animal control / animal narcotic detection training (R156-17b-617c)Perpetual inventory of all drugs, including controlled substances; a list of authorized, trained employees; stock kept to the smallest quantity needed; a secured safe or steel cabinet with self-closing, self-locking doors and key control; a single responsible party who purchases and reconciles drugs; written policies. Employees may be exempt from individual CS licensure if the facility holds a Utah CS license and DEA registration and uses a written protocol (R156-37-306(3)).
Durable medical equipment (R156-17b-617d)Suitable facility and storage; prescription records kept five years; locked and closed to non-personnel when closed; license posted. A practitioner who administers DME to a patient does not need a Class E license.
Human clinical investigational drug research (R156-17b-617e)Operates under 21 CFR Part 312; controlled substance research requires the appropriate license at each location
Medical gas provider (R156-17b-617f)Written SOP manual; employee training records; records of batch production, certificates of analysis, and gauge calibration; secure tanks; return and quarantine areas; labeled products; no adapters when filling cylinders; FDA compliance
Third-party logistics provider (R156-17b-617g)Complies with DSCSA; may not employ anyone convicted of a felony related to product tampering
Non-drug-handling central processing (R156-17b-614f(3))See Section 13.2
Veterinarian pharmaceutical facilityListed in R156-17b-302(5)

Dispensing medical practitioners (Part 8)

  • Who: a physician, osteopathic physician, PA, APRN, or optometrist (acting within optometric scope) who is also licensed under Part 8 as a dispensing medical practitioner (DMP). Their existing license substitutes for pharmacist licensure requirements (§ 58-17b-803(1)–(2)).
  • What they may dispense: cosmetic drugs and injectable weight-loss drugs they prescribed, following DOPL's approved list (for example, Latisse, hCG, hormonal contraception other than injectable or implantable methods, hydroquinone up to 4%, tretinoin up to 0.1%) (R156-17b-623); cancer drug treatment regimens under § 58-17b-805; and prepackaged drugs at an employer-sponsored clinic. DMPs may not dispense controlled substances except as § 58-17b-805 allows (§ 58-17b-102(56)(b)), and may not dispense gabapentin.
  • Duties (§ 58-17b-803(4)): tell the patient that the drug may be obtained from an unaffiliated pharmacy, give directions and side effects, and explain how to contact the DMP. Report to the CSD like a pharmacist. A DMP may delegate dispensing to an employee acting under the direction of a DMP who is immediately available on site. DMP designees must complete a formal or on-the-job dispensing training program (R156-17b-622).
  • DMP clinic pharmacy (§ 58-17b-804): a closed-door pharmacy in the DMP's place of practice. It needs no PIC if a DMP is designated as responsible and it follows DOPL rules. It renews on September 30 of odd-numbered years.

Exam strategy

For a specialty-setting question, answer three things:

  1. Which license class applies? Nuclear pharmacies are Class B in Utah or Class D out of state. Labs, animal control, DME, research, medical gas, and 3PLs are Class E. A DMP clinic pharmacy is its own category.
  2. Is a PIC required? Class E does not need one. A DMP clinic pharmacy may designate a responsible DMP instead.
  3. Which record or security rule is unique? Animal control needs a perpetual inventory and one responsible party. DME records are kept five years. Medical gas cylinders are filled without adapters. 3PLs follow DSCSA and screen out product-tampering felons.
Test Your Knowledge

A Utah hospital's nuclear medicine department holds a current Utah Radioactive Materials License and prepares radiopharmaceuticals for its own patients. Does it need a Class B pharmacy license?

A

No, because a hospital nuclear medicine department with a current Utah Radioactive Materials License does not require licensure as a Class B pharmacy

B

Yes, every facility that handles radiopharmaceuticals must be a Class B nuclear pharmacy

C

No, because radiopharmaceuticals are not drugs

D

Yes, it must be licensed as a Class C manufacturer

Test Your Knowledge

What staffing does R156-17b-614d require at a Utah nuclear pharmacy?

A

No pharmacist is required if the pharmacy holds a radioactive materials license

B

Only a certified nuclear medicine technologist is required

C

A licensed Utah pharmacist with the radiation training required by the Utah Radiation Control Rules must be immediately available on the premises whenever it is open

D

A pharmacist may supervise remotely by telepharmacy from any location

Test Your Knowledge

Which requirement applies to a Utah animal control agency licensed as a Class E pharmacy to hold euthanasia drugs?

A

It may store controlled substances on open shelves if the building is alarmed

B

It must keep a perpetual inventory of all drugs, including controlled substances, store them in a secured safe or steel cabinet, and designate one responsible party to purchase and reconcile them

C

It must have a pharmacist-in-charge on site during all business hours

D

It needs no written policies because it is not a retail pharmacy

Test Your Knowledge

A dermatologist licensed as a Utah dispensing medical practitioner dispenses tretinoin 0.05% cream to her patient. Which duty applies under Utah Code § 58-17b-803(4)?

A

She may dispense any controlled substance she prescribes

B

She must have a pharmacist verify every dispensing

C

She must send the patient to a pharmacy for counseling

D

She must tell the patient the drug may be obtained from an unaffiliated pharmacy and explain directions, side effects, and how to reach her with questions

Sections you finish are checked off in the contents.