                          Notes from Meeting with CVS
                                       
                                       
Attended by:
CVS Staff:		Pat Perry

Troutman Sanders:	Greg Blount and John Johnson

EPA Staff:	Kristin Fitzgerald

Date:			September 18, 2013


EPA met with a representative of CVS and their outside legal counsel from Troutman Sanders.  

CVS inquired about the progress of the pharmaceuticals proposed rule.  They reiterated the following high priority concerns that they hope the proposed rule will address:

      1.  Nicotine gum, patches and lozenges causing their retail stores to notify and operate as LQGs (approximately 3300 stores), stores that otherwise would be CESQGs
         
      2. National consistency among the state programs for pharmaceutical management; even recognizing that the only way to achieve national consistency is to propose a rule that is considered more stringent rule than current regulations.

CVS also inquired about the status of the Retail NODA.  They indicated that they have already prepared data that they are looking forward to submitting the data when the NODA is published.  They indicated that their peer institutions also have prepared data to submit in response to the NODA.
