It is helpful that Messrs Cox and Fox have opened up the debate on the important topic of the future structure of the Royal Pharmaceutical Society (PJ, August 19, p263). It merits separate study. A structure should not be something that just emerges as the inevitable result of decisions taken on quite separate matters, such as whether the Society should be the registering body for pharmacy technicians.
In my experience, the Society is unique in the world of pharmacy bodies in having not two, but three separate roles - professional, regulatory and law enforcement. It is this combination that gives the Society its strength. It should not lightly be cast aside because of some remarks made at a weekend school or concerns that some other health regulatory body may be the subject of serious criticism over the way that it appears to have discharged its responsibility. Only if regulation of a profession loses the confidence of the public will the Government be given an opportunity to intervene to exert greater control.
In that respect, I would agree with Messrs Cox and Fox that pharmacy is in a good position. This is, however, not only because of the "exemplary dedication" of the inspectorate and the Statutory Committee, although that dedication has undoubtedly been consistently demonstrated, but also - and just as importantly - because of the stewardship of successive Councils over many decades. It is not the inspectors or the members of the Statutory Committee who decide the contents of the Code of Ethics and the Standards of Good Professional Practice, which are an integral part of the code; it is the Council. And it is not the inspectors or the members of the committee who decide whether there is a prima facie case to be put to the courts (in the case of alleged infringements of the law) or to the Statutory Committee (in the case of alleged professional misconduct); it is the Council. Professional self-regulation is, in the words of the United Kingdom Inter-Professional Group, only a part of a spectrum of regulatory mechanisms which, taken together, are designed to protect consumers. I have to say, however, that the "regulatory committee" as proposed by Messrs Cox and Fox, which would apparently comprise those who collect evidence (the inspectors) and the judges of that evidence (the members of the Statutory Committee) plus some lay members, would not for one second, in my view, withstand scrutiny alongside the Charter of Human Rights.
The authors also suggest that none of the objects in the Society's Charter is concerned with regulation. I would take issue with them on that point. It is surely under the object of maintaining the honour of the members that the Code of Ethics and professional standards are promulgated by the Council for adoption by members. The code and standards have teeth only because the Society is also a statutory regulatory body. In contrast, the codes of professional bodies with voluntary membership only have teeth in relation to those who decide to remain in membership.
The authors, concentrating as they do on the disciplinary machinery, also seem to overlook the fact that it is the Society's regulatory function that underlies its equally important roles in accreditation of pharmacy degrees, administration of preregistration training and setting the registration examination. All of these combine to ensure a voice in bodies like the Pharmaceutical Committee of the European Union, which oversees the implementation of the directives on free movement of pharmacists. And it is the Society's role in law enforcement that places it in a special relationship with bodies like the Medicines Control Agency. These are important elements in establishing the public status of the Society.
Messrs Cox and Fox also suggest that, after the break-up, the Society might merge with the Pharmaceutical Services Negotiating Committee and the National Pharmaceutical Association, and refer to the recent suggestion that these two bodies might merge. They overlook the fact that the PSNC's predecessor was, in practice, a committee of the then National Pharmaceutical Union with a few additional co-opted members. It was found by some players not to work then and I very much doubt if it would work now. And one of the strengths of the Society, not least in its relationship with Government departments, is the knowledge that it negotiates to improve pharmaceutical practice, in the interest of those who use the services of pharmacists, but not remuneration. That, too, would be lost if Messrs Cox and Fox have their way.
I have had the experience of giving oral evidence to select committees of the House of Commons. On one occasion, members of the committee spontaneously took the opportunity to say that they knew of no instance in which a matter referred by them to the Society on behalf of a constituent had not been properly dealt with and satisfactority resolved. That is a reputation that is not gained lightly but is earned, as Messrs Cox and Fox say, by exemplary dedication to duty by all involved, and that means the Council and all the staff of the Society, not just the inspectors and the Statutory Committee. The Society must ensure that this continues to be the driver and that every proposed policy option is measured against the five principles set out in January, 1998, by the Government's Better Regulation task force - transparency, accountability, targeting, consistency and proportionality.
If the authors have got it right when they say that "the Society has completely missed the point", then pharmacists will go along with their proposal to break up a unique organisation which has not been the subject of any justified criticism for the way it has dicharged its regulatory and law enforcement duties, while continuing, within the terms of its Charter, to promote the interests of its members "in the exercise of the profession of pharmacy". By ensuring that the Code of Ethics is continuously revised to meet modern circumstances and is designed for the protection of the public, the Society will promote the long-term interests of the members.
Messrs Cox and Fox will no doubt accuse me of "making a last ditch effort to maintain the status quo". I may even be described as a dinosaur. However, I would prefer to think that by looking to our history, we can often see further ahead and can appreciate the long-term implications of what might seem to be "a good idea at the time".
I do hope that the Royal Pharmaceutical Society's members will ask why they should emasculate their professional body and, in the name of what is described as the current mood of the Government, however temporary that may be, vote to break up a structure that is seen by independent observers to serve the public well - and will be even better when it gets the reforms that it has requested.