Rachel Celli2 minutes readThe proposed Rule proposes to codify the FDA's existing informal recognition of the 5 percent “minimum quantity” rule, which states that pharmacies can sell up to 5 percent of their total annual prescription drug sales volume to professionals licensed for office use, and such pharmacies not considered wholesalers based on those sales. O'Connor, who certainly reflects the point of view of drug wholesalers, seems to be that anyone who sells drugs in quantity is a wholesaler, including pharmacists who own retail pharmacies; and it seems that board members agree that it should be left to the board's discretion to decide who is wholesaler and license that person after considering advertising, location, method of doing business, and sales representation.