Law and deadlines

Beratungsraum

In one sentence

Beratungsraum is the space a pharmacy uses for confidential advice. The Apothekenbetriebsordnung requires consultation that cannot be overheard rather than a closed room in every case, so whether a separate room is needed depends on the service being offered.

Beratungsraum is where a pharmacy speaks to a customer about something the queue should not hear. The Apothekenbetriebsordnung requires the Offizin to allow confidential advice, but it does not oblige every pharmacy to build a closed room with a door. In a great many pharmacies the requirement is met by a screened area, a separated corner or a counter placed so that a quiet conversation stays between two people. What the supervisory authority asks is whether the customer can speak without being overheard.

The answer changes as soon as the pharmacy offers a service rather than a conversation. The more physical the service becomes, and the more the customer has to stay still, roll up a sleeve or expose an arm, the harder it is to argue that a screen is enough. Expectations also differ between the federal states and between service types, so the reliable route is to describe the intended service to the Landesapothekerkammer and ask what local supervisory practice expects before anything is built.

For blood collection the legal minimum and the working minimum are not the same thing. Offering a draw as an apothekenübliche Dienstleistung under Paragraph 1a Absatz 11 ApBetrO comes with no room specification attached, though the general duties still apply. Aufklärung und Einwilligung has to happen somewhere the customer can ask an awkward question, and Hygiene bei der Blutentnahme is far easier to maintain in a defined space than at the counter.

What a blood draw actually needs in the room is concrete rather than a matter of taste:

  • The customer needs a chair with arm support that allows a reclined position if someone feels faint.
  • The working surface is smooth and wipeable rather than wooden or fabric covered.
  • There is room for the person drawing to stand on the correct side of the customer.
  • There is room for the tray and the Abwurfbehälter as well.
  • A hand basin belongs in the room, or at minimum disinfectant at the point of use.
  • The customer can stay seated for a few minutes afterwards without blocking the room, which matters more for a venöse Blutentnahme than for a capillary sample.
  • Good lighting helps more than it sounds like it should, while a door that closes removes the privacy argument entirely.

A pharmacy that already runs a vaccination room usually has everything it needs.

This glossary entry is general information about German pharmacy law and practice. It is not legal advice. For binding guidance on your own pharmacy, contact your Landesapothekerkammer.

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