Wyo. Code R. 059-0001-8
Pharmacy, Board of
Chapter 8: Wholesale Distributor Regulations
Effective Date: 08/19/2025 to Current
Rule Type: Current Rules & Regulations
Reference Number: 059.0001.8.08192025
These rules are promulgated as authorized by the Wyoming Pharmacy Act W.S. § 33-24-101 through -301.
The purpose of this rule is to provide for the minimum licensing standards necessary to ensure the safety and efficacy of prescription drugs offered for sale by manufacturers and wholesale distributors.
This Chapter applies to any person, partnership, corporation or business engaging in the wholesale distribution of human prescription drugs either into, out of, or within this State.
(a) 'Authorized Distributor of Record' means a wholesale distributor with whom a manufacturer has established an ongoing relationship to distribute the manufacturer's products.
(b) 'Common Carrier' means any person or entity who undertakes directly or indirectly to transport property, including prescription drugs, for compensation.
(c) 'Designated Representative' means an individual designated by the wholesale distributor and who is actively involved in and aware of the actual daily operation of the wholesale drug distributor at the wholesaler's licensed location.
(d) 'Dispenser' means a retail pharmacy, institutional pharmacy, a group of chain pharmacies under common ownership and control that do not act as a wholesale distributor, or any other person authorized by law to dispense or administer prescription drugs, and the affiliate warehouses or distribution centers of such entities under common ownership and control that do not act as a wholesale distributor; and does not include a person who dispenses only products to be used in animals.
(e) 'Distribute' or 'Distribution' means the sale, purchase, trade, delivery, handling, storage, or receipt of a product, and does not include the dispensing of a product pursuant to a prescription.
(f) 'Drug' means a substance recognized as a drug in any official compendium as listed in W.S. § 33-24-127, designated for use in the diagnosis, cure, mitigation, treatment or prevention of disease in humans or animals.
(g) 'Drug Sample' means a unit of a prescription drug that is not intended to be sold but is intended to promote the sale of the drug.
(h) 'Food and Drug Administration' (FDA) means a federal agency within the United States Department of Health.
(i) 'Illegitimate product' means a product for which credible evidence shows that the product:
(i) Is counterfeit, diverted or stolen;
(ii) Is intentionally adulterated such that the product would result in serious adverse health consequences or death to humans;
(iii) Is the subject of a fraudulent transaction; or
(iv) Appears otherwise unfit for distribution such that the product would be reasonably likely to result in serious adverse health consequences or death to humans.
(j) 'Manufacturer's Exclusive Distributor' means an individual or entity who purchased the product directly from the manufacturer and is the sole distributor of that manufacturer's product to a subsequent repackager, wholesale distributor, or dispenser.
(k) 'Misbranded' means a drug whose label is false or misleading or the label does not bear the name and address of the manufacturer, packer or distributor and does not have an accurate statement of the quantities of the active ingredients or:
(i) If the advertising or promotion of a compounded drug is false or misleading in any particular; or
(ii) If it is a drug and it fails to bear the product identifier.
(l) 'Outsourcing Facility' means a person who registers with the FDA under section 503B of the federal act to compound sterile drugs for human use under the supervision of a pharmacist but without a prescription from a practitioner for a particular patient.
(m) 'Prescription Drug' or 'Legend Drug' means a drug which, under federal law, is required to be labeled with one of the following statements:
(i) 'Caution: Federal law prohibits dispensing without a prescription';
(ii) 'Caution: Federal law restricts this drug to use by, or on the order of, a licensed veterinarian'; or
(iii) 'Rx Only.'
(n) 'Product Identifier' means a standardized graphic that includes in both human-readable form and on a machine readable data carrier that conforms to the standards developed by a widely recognized international standards development organization, the standardized numerical identifier, lot number, and expiration date of the product.
(o) 'Product Tracing' means a dispenser shall not accept ownership of a product unless the previous owner prior to, or at the time of, the transaction, provides:
(i) Transaction Information (TI);
(ii) Transaction History (TH); and
(iii) Transaction Statement (TS).
(p) 'Reverse Processor' means a person who owns or operates an establishment that dispositions or otherwise processes saleable or nonsaleable product received from an authorized trading partner such that the product may be processed for credit to the purchaser, manufacturer, or seller or disposed of for no further distribution.
(q) 'Suspect Product' means there is reason to believe that such product:
(i) Is potentially counterfeit, diverted or stolen;
(ii) Is potentially intentionally adulterated such that the product would result in serious adverse health consequences or death to humans;
(iii) Is potentially the subject of a fraudulent transaction; or
(iv) Appears otherwise unfit for distribution such that the product would result in serious adverse health consequences or death to humans.
(r) 'Third Party Logistics Provider' means an entity that provides or coordinates warehousing, distribution, or other logistics services of a product in interstate commerce on behalf of a manufacturer, wholesale distributor, or dispenser of a product but does not take ownership of the product, nor have responsibility to direct the sale or disposition of the product.
(s) 'Transaction' in general means the transfer of product between persons in which a change of ownership occurs. The term transaction does not include:
(i) Intracompany distribution of any product between members of an affiliate or within a manufacturer;
(ii) The distribution of a product among hospitals or other health care entities that are under common control;
(iii) The distribution of a product for emergency medical reasons including a public health emergency, except that a drug shortage not caused by a public health emergency shall not constitute an emergency medical reason;
(iv) The dispensing of a product pursuant to a prescription;
(v) The distribution of product samples by a manufacturer or a licensed wholesale distributor;
(vi) The distribution of blood or blood components intended for transfusion;
(vii) The distribution of minimal quantities of product by a licensed retail pharmacy to a licensed practitioner for office use;
(viii) The sale, purchase, or trade of a drug or an offer to sell, purchase, or trade a drug by a charitable organization described in section 501(c)(3) of the Internal Revenue Code of 1986 to a nonprofit affiliate of the organization;
(ix) The distribution of a product pursuant to the sale or merger of a pharmacy or pharmacies or a wholesale distributor or wholesale distributors (except that records required to be maintained for the product shall be transferred to the new owner of the pharmacy or pharmacies or wholesale distributor or wholesale distributors); or
(x) The dispensing of a product approved under section 512(c) of the Federal Food, Drug, and Cosmetic Act regarding a new animal drug application.
(t) 'Transaction History' means a statement in paper or electronic form that includes the transaction information of each prior transaction going back to the manufacturer of the product.
(u) 'Transaction Information' means:
(i) The proprietary or established name or names of the product;
(ii) The strength and dosage form of the product;
(iii) The national drug code number of the product;
(ii) The distribution of a drug or an offer to distribute a drug among hospitals or other health care entities which are under common control;
(iii) The distribution of a drug or an offer to distribute a drug for emergency medical reasons, including a public health emergency declaration except that a drug shortage not caused by a public health emergency shall not constitute an emergency medical reason;
(iv) The dispensing of a drug pursuant to a prescription;
(v) The distribution of minimal quantities of drug by a licensed retail pharmacy to a licensed practitioner for office use;
(vi) The distribution of a drug or an offer to distribute a drug by a charitable organization to a nonprofit affiliate of the organization;
(vii) The purchase or other acquisition by a dispenser, hospital or other health care entity of a drug for use by such dispenser, hospital, or other health care entity;
(viii) The receipt of a drug by an authorized third party logistics provider who does not take ownership of the drug;
(ix) A common carrier that transports a drug who does not take ownership of the drug;
(x) The distribution of an intravenous drug that, by its formulation, is intended for the replenishment of fluids and electrolytes (such as sodium, chloride, and potassium) or calories (such as dextrose and amino acids);
(xi) The distribution of an intravenous drug used to maintain the equilibrium of water and minerals in the body, such as dialysis solutions; or
(xii) Facilitating the distribution of a product by providing solely administrative services, including processing of orders and payments.
(a) Every manufacturer, repackager, third party logistics provider, and wholesale distributor of prescription drugs for human use, wherever located, that provides services within this State shall be licensed by the Board and shall annually renew their license using an application provided by the Board. Manufacturers, repackagers, third party logistics providers and wholesale distributors cannot operate from a place of residence. Where wholesale distribution operations are conducted at more than one location, each such location shall be licensed by the Board.
(b) The Board shall require the following minimum information from each manufacturer, repackager, third party-logistics provider, and wholesale drug distributor as part of the initial licensing procedure and as part of any renewal of such license:
(i) All trade or business names used by the licensee (includes 'is doing business as' and 'formerly known as') which cannot be identical to the name used by another unrelated licensee to purchase/distribute prescription drugs in this State;
(ii) Name(s) of the owner and operator of the licensee (if not the same person), including:
(A) If a person: the name, business address, social security number, and date of birth;
(B) If a partnership: the name, business address, and social security number and date of birth of each partner, and the name of the partnership and federal employer identification number;
(C) If a corporation: the name, business address, social security number, date of birth, and title of each corporate officer and director; the corporate names, state of incorporation, federal employer identification number, and name of the parent company, if any; the name, business address, and social security number of each shareholder owning ten percent (10%) or more of the voting stock of the corporation, including over-the-counter (OTC) stock, unless the stock is traded on a major stock exchange and not OTC:
(D) If a sole proprietorship: the full name, business address, social security number, and date of birth of the sole proprietor and the name and federal employer identification number of the business entity;
(E) If a limited liability company: the name of each member, the name of each manager, the name of the limited liability company and federal employer identification number, and the name of the state in which the limited liability company was organized; and
(F) Any other relevant information the Board requires.
(iii) Name(s), business address(es), and telephone number(s) of the person(s) to serve as the designated representative(s) for each facility of the wholesale distributor that engages in the wholesale distribution of prescription drugs. The Board shall be notified of each change in designated representative within 30 days of the change. Fingerprints and a fifty dollar ($50.00) fee shall be submitted for each designated representative application for a criminal background check and with each application for change in designated representative;
(iv) A list of all state and federal licenses, registrations, or permits, including the license, registration, or permit numbers issued to the wholesale distributor by any other state and federal authority that authorizes the wholesale distributor to purchase, possess, and wholesale distribute prescription drugs;
(v) A list of all disciplinary actions by state and federal agencies against the entity as well as any such actions against principals, owners, directors or officers;
(vi) A full description of each facility and warehouse, including all locations utilized for prescription drug storage or wholesale distribution. The description shall include the following:
(A) Square footage;
(B) A general description of security and alarm systems;
(C) Terms of lease or ownership;
(D) Address; and
(E) Temperature and humidity controls in accordance with this
Chapter.
(vii) A copy of the deed for the property on which the entity's establishment is located, if the property is owned by the entity; or a copy of the wholesale distributor's lease for the property on which the establishment is located which has an original term of not less than one (1) calendar year (if the establishment is not owned by the entity);
(viii) Information regarding general and product liability insurance, including copies of relevant policies;
(ix) A description of the entity's drug import and export activities; and
(x) An electronic copy of the entity's written policies and procedures as required by this Chapter.
(c) The information collected pursuant to this Chapter shall be made available only to the Board, a third party recognized by the Board, and to state and federal law enforcement officials. The Board shall make provisions for protecting the confidentiality of the information collected under this section.
(d) All current wholesale distributor licensees and all applicants for licensure as a third party logistics provider or wholesale distributor must submit security in the amount of one hundred thousand dollars ($100,000.00) to the Board. The purpose of these funds will be to secure payment for any administrative penalty assessed by the Board, which remains unpaid thirty (30) days after the liability for the payment is final. A separate bond or other equivalent means of security is not required for each company's separate location or for affiliated companies/groups when such separate location or affiliated companies/groups are required to apply for or renew their wholesale distributor license with the Board. Acceptable forms of security include:
(i) "Surety" bond naming the board as the payee;
(ii) Irrevocable letter of credit naming the board as the payee; or
(iii) Funds deposited in a trust account or financial institution naming the board as the payee.
(e) The Board may waive the security requirement, if the wholesale distributor or third party logistics provider:
(i) Has previously obtained a comparable bond or other comparable security for the purposes of licensure in another state where they possess a valid license in good standing; or
(ii) Is a publicly held company.
(iii) Manufacturers and repackagers shall be exempt from securing a "surety" bond or other equivalent means of security acceptable to the Board or a third party recognized by the Board.
(f) Each facility licensed by the Board and all applicants for licensure must provide evidence of Verified-Accredited Wholesale Distributor (VAWD®) accreditation from the National Association of Boards of Pharmacy or from another third party recognized by the Board and must undergo the re-accreditation process periodically after initial accreditation. Manufacturing facilities are exempt from this requirement provided the manufacturing facilities are currently registered with the FDA in accordance with Section 510 of the Federal Act.
(i) Any applicant that is denied accreditation described under this section shall have the right of review of the accreditation body's decision, by:
(A) The accreditation body; and
(B) The Board.
(ii) The recognized accreditation body shall ensure that the proprietary information obtained during the accreditation process remains confidential and privileged.
(iii) Individual or third party inspectors must demonstrate to the Board that they have received training or demonstrate familiarity with the inspection standards. A letter for certification from a training program, a notice from the inspector's employing third party organization, or other means recognized by the Board shall be accepted as meeting the requirement.
(g) The Board may license by reciprocity a manufacturer, repackager, third party logistics provider or wholesale distributor that is licensed under laws of another state if:
(i) The requirements of that state are deemed by the Board to be substantially equivalent; or
(ii) The applicant is accredited by a third party recognized by the Board. An applicant that is accredited by a third party recognized and approved by the Board shall not be subject to duplicative requirements set by the Board.
(h) Where operations are conducted at more than one location by a single wholesale distributor, each location shall be licensed by the Board.
(i) Changes in any information required by this section shall be submitted to the Board within thirty (30) days after the change.
(j) All wholesale distributors shall publicly display or have readily available all licenses and the most recent inspection report.
(k) Information submitted by the wholesale distributor to the Board or a third party recognized by the Board that is considered trade secret or proprietary information, as defined under the state privacy and trade secret proprietary statutes, shall be maintained by the Board or a third party recognized by the Board as private or trade secret/proprietary information and be exempt from public disclosure.
(l) Any applicant denied licensure by the Board shall have the right of timely review and appeal as authorized by the Wyoming Administrative Procedure Act.
(a) Medical oxygen is a prescription drug and distributors or manufacturers or repackagers shall be licensed by the Board and annually renew their licensure in order to provide medical oxygen in or into this State.
(b) Medical oxygen distributors located in this state may be inspected by the Board.
(c) Medical oxygen distributors shall complete all the requirements in this Chapter with the exception that they do not need VAWD® accreditation.
(a) Third Party Logistics Providers (3PL) shall be licensed as such in this State and annually renew their licensure.
(b) Third Party Logistics Providers shall complete all the requirements in this Chapter.
(a) Veterinary prescription drug wholesale distributors may be licensed as such in this State and annually renew their license.
(b) Veterinary prescription drug wholesale distributors located in this State may be inspected by the Board.
(c) Veterinary prescription drug wholesale distributors applying for or renewing a license in this State shall complete all the requirements of this Chapter with the exception that they do not need VAWD® accreditation and they are not required to provide a designated representative.
(d) Veterinary prescription drug wholesale distributors may sell or deliver to a person responsible for the control of a livestock animal, as defined in Wyo. Stat. § 11-29-101(a)(vi), a non-controlled substance prescription drug intended for veterinary use provided the following conditions are met:
(i) A licensed veterinarian has issued, prior to such sale or delivery, a written prescription order for the non-controlled substance prescription drug in the course of an existing, valid veterinarian-client-patient relationship;
(ii) The original order must be retained on the premises of the veterinary prescription drug wholesale distributor for two years from the date of the last transaction affecting the order;
(iii) The non-controlled substance prescription drug(s) distributed sold or delivered pursuant to the veterinary drug order issued according to (i) of this subdivision are sold in the original, unbroken manufacturer's containers; and
(iv) The non-controlled substance prescription drug(s), once distributed, may not be returned to the veterinary prescription drug wholesale distributor for resale or redistribution.
(e) The prescription order issued by the veterinarian becomes void after two years, unless the veterinarian specifies a shorter expiration date.
(f) The veterinary prescription drug wholesale distributor shall not distribute larger quantities than the order authorizes.
(g) The original order must be retained on the premises of the veterinary prescription drug wholesale distributor filed by client name. The invoices for each distribution authorized by the order must be attached to the order.
(h) A drug distribution log must be retained on the premises of the veterinary prescription drug wholesale distributor. It shall include the following information:
(i) Date sold/delivered;
(ii) Client name;
(iii) Veterinarian name;
(iv) Non-controlled substance prescription drug sold/delivered;
(v) Quantity of non-controlled substance prescription drug sold/delivered;
(vi) Date of issue of order;
(vii) Expiration of order; and
(viii) Invoice number.
Section 10. Repackagers.
(a) Repackagers of prescription drugs for human use shall be licensed as such in this State and annually renew their licensure.
(b) Repackagers shall complete all the requirements in this Chapter.
Section 11. Minimum Qualifications.
(a) The Board shall consider the following factors in determining eligibility for, and renewal of, licensure:
(i) Any criminal convictions, except minor traffic violations, or civil penalties of the applicant under any federal, state or local laws;
(ii) Any findings by the Board that the applicant has violated, or been disciplined by a regulatory agency in any state for violating any federal, state or local laws;
(iii) The furnishing by the applicant of false or fraudulent material in any application;
(iv) Suspension, sanction, or revocation by federal, state or local government against any license currently or previously held by the applicant or any of its owners for violations of state or federal laws regarding prescription drugs;
(v) Compliance with the requirements to maintain or make available to the Board or to federal, state or local law enforcement officials any required records; and
(vi) Any other factors or qualifications the Board considers relevant to and consistent with public health and safety.
(a) Each person that is issued an initial or renewal license as a manufacturer, repackager, third party logistics provider or wholesale distributor of prescription drugs for human use, whether in state or out of state, must designate in writing on a form required by the Board, a person for each facility to serve as the designated representative.
(b) To be certified as a designated representative, a person shall:
(i) Submit an application on a form furnished by the Board and provide information that includes:
(A) Fingerprint cards and fee for a criminal background check;
(B) Date and place of birth;
(C) Occupations, positions of employment, and offices held during the past seven (7) years;
(D) Principal business and address of any business corporation, or other organization in which each such office of the person was held or in which each such occupation or position of employment was carried on;
(E) Whether the person, during the past seven (7) years, has been enjoined, either temporarily or permanently, by a court of competent jurisdiction for violating any federal or state law regulating the possession, control or wholesale distribution of prescription drugs, together with details of such events;
(F) A description of any involvement by the person with any business, including any investments, other than the ownership of stock in a publicly traded company or mutual fund, during the past seven (7) years, which manufactured, administered, prescribed, wholesale distributed, or stored prescription drugs in which such businesses were named as a party in a lawsuit;
(G) A description of any felony criminal offense, or any offense (misdemeanor or felony) involving moral turpitude, or any offense related to the qualifications, functions or duties of that person in connection with the operation of the entity, of which the person, as an adult, was found guilty, regardless of whether adjudication of guilty was withheld or whether the person pled guilty or nolo contendere. If the person indicates that a criminal conviction is under appeal and submits a copy of the notice of appeal of the criminal offense, the applicant must, within thirty (30) days after the disposition of the appeal, submit a copy of the final written order of disposition to the Board; and
(H) A passport type and size of photograph of the person taken within the previous year.
(ii) Have a minimum of two (2) years of verifiable full-time managerial or supervisory experience in a pharmacy or entity or another state where the person's responsibilities included but were not limited to recordkeeping, storage, and shipment of prescription drugs;
(iii) Serve as the designated representative for only one location at any one time, except where more than one licensed entity is co-located in the facility and such entities are members of an affiliated group, as defined in Section 1504 of the Internal Revenue Code;
(iv) Be actively involved in and aware of the actual daily operations of the entity as follows:
(A) Be employed full-time in a managerial position by the entity;
(B) Be physically present at the location during normal business hours, except for time periods when absent due to illness, family illness or death, scheduled vacation, or other authorized absence; and
(C) Be aware of, and knowledgeable about, all policies and procedures pertaining to the operations of the entity.
(c) The information collected pursuant to this Chapter shall be made available only to the Board, a third party recognized by the Board, and to state and federal law enforcement officials. The Board and a third party recognized by the Board shall make provisions for protecting the confidentiality of the information collected under this Section.
(a) The following are required for the storage, handling, transport and shipment of prescription drugs and for the establishment and maintenance of records:
(b) All facilities at which prescription drugs are received, stored, warehoused, handled, held, offered, marketed, transported from or displayed shall:
(i) Be of suitable size and construction to facilitate cleaning, maintenance and proper operations to ensure that all prescription drugs in the facilities are maintained in accordance with the product labeling or in compliance with official compendium standards such as the United State Pharmacopeia-USP-NF;
(ii) Have storage areas designed to provide adequate lighting, ventilation, temperature, sanitation, humidity, space, equipment and security conditions;
(iii) Have a quarantine area for storage of prescription drugs that are outdated, damaged, deteriorated, misbranded or adulterated, counterfeit, or suspected of being counterfeit, otherwise unfit for distribution or wholesale distribution, or that are in immediate or sealed secondary containers that have been opened prior to receipt by the entity;
(iv) Be maintained in a clean and orderly condition;
(v) Be free from infestation of any kind;
(vi) Be a commercial location and not a personal dwelling or residence;
(vii) Provide for the secure and confidential storage of all information with restricted access and policies and procedures to protect the integrity and confidentiality of the information; and
(viii) Provide and maintain appropriate inventory controls in order to detect and document any theft, counterfeiting, or diversion of prescription drugs.
(c) All entities involved in the wholesale distribution of controlled substances shall be duly registered with the Drug Enforcement Administration (DEA) and the Board and in compliance with all applicable laws and rules for the storage, handling, transport, shipment and distribution of controlled substances.
(a) All facilities used for drug distribution shall be secure from unauthorized entry as follows:
(i) Access from outside the premises shall be kept to a minimum and be well controlled;
(ii) The outside perimeter of the premises shall be well lighted;
(iii) Entry into areas where prescription drugs are held shall be limited to authorized personnel;
(iv) All facilities shall be equipped with an alarm system to detect unauthorized entry after hours; and
(v) All facilities shall be equipped with a security system that will provide suitable protection against theft and diversion. When appropriate, the security system shall provide protection against theft or diversion that is facilitated or hidden by tampering with computers or electronic records.
(b) All facilities shall be equipped with inventory management and control systems that protect against, detect, and document any instances of theft, diversion, or counterfeiting.
(c) All entities shall be equipped with security measures to protect the integrity of data and documents and make such data and documents readily available to the Board and other state and federal law enforcement officials.
(a) Upon receipt, each shipping container shall be visually examined for identity and to determine if it may contain suspect products. This examination shall be adequate to reveal container damage that would suggest possible suspect product or other damage to the contents.
(b) The prescription drugs found to be unacceptable under paragraph 'a' above shall be quarantined from the rest of the stock.
(c) Each outgoing shipment shall be carefully inspected for identity of the prescription drug products and to ensure that there is no delivery of prescription drugs that have been damaged in storage or held under improper conditions.
(d) All entities shall comply with reporting requirements and exchange transaction history, transaction information, and transaction statements as outlined in federal law.
(a) All entities shall establish, maintain and adhere to written policies and procedures, which shall be followed for the receipt, security, storage, inventory, transport, shipping and wholesale distribution of prescription drugs, including policies and procedures for identifying, recording and reporting losses or thefts, and for correcting all errors and inaccuracies in inventories. Policies and procedures shall include the following:
(b) A procedure to be followed for handling recalls and withdrawals of prescription drugs due to:
(i) Any action initiated at the request of the FDA or any other federal, state or local law enforcement or other governmental agency, including the board of pharmacy; or
(ii) Any volunteer action by the manufacturer to remove defective or potentially defective prescription drugs from the market.
(c) A procedure to ensure that all entities prepare for, protect against, and handle any crisis that affects security or operation of any facility in the event of a strike, fire, flood, natural disaster, or other situations of local, state or national emergency;
(d) A procedure to ensure that any outdated prescription drugs shall be segregated from other prescription drugs and either returned to the manufacturer or third party return processor or destroyed in accordance with federal and state laws, including all necessary documentation and the appropriate witnessing. This procedure shall provide for written documentation of the disposition of outdated prescription drugs. This documentation shall be maintained for two (2) years after disposition of the outdated prescription drugs;
(e) A procedure for the disposing and destruction of containers, labels and packaging to ensure that the containers, labels and packaging cannot be used in counterfeiting activities, including all necessary documentation, maintained for a minimum of two (2) years, and the appropriate witnessing of the destruction of any labels, packaging, immediate containers or containers in accordance with all applicable federal and state requirements;
(f) A procedure for identifying, investigating and reporting significant prescription drug inventory discrepancies involving suspect products, in the inventory and reporting of such discrepancies within ten (10) business days to the Board and appropriate federal or state agency upon discovery of such discrepancies;
(g) A procedure for reporting criminal or suspected criminal activities involving the inventory of prescription drugs to the board, FDA and, if applicable, DEA, within three (3) business days; and
(h) A procedure for verifying security provisions of common carriers.