The Pharmaceutical Journal
Vol 268 No 7197 p644
11 May 2002

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Three functions, three bodies — how to split the Royal Pharmaceutical Society

By Stuart Anderson

The debate around the future remit and functions of the Royal Pharmaceutical Society has thrown up some interesting and radical proposals. Yet for the more radical options the pros given seem to outweigh the cons. The apparent wish of the Society for only limited change is entirely understandable. Current arrangements have generally served the profession well; but will they continue to do so in the future?

The acid test of whether the right arrangements have been made will be how they stand up to the exceptional rather than how they cope with the routine. Would, for example, the arrangement whereby a professional body also acts as regulator and inspector survive a regulatory disaster, such as a pharmaceutical equivalent of the Shipman case? Pharmacy has so far avoided a disaster on such a scale. But current developments, including pharmacist prescribing and the shift in status of increasing numbers of drugs from prescription only to pharmacy supply, considerably increase the risk of such an event.

Let us suppose that somewhere there is a caring, considerate pharmacist who is quietly killing patients. Such a pharmacist would be murdering victims one at a time over a period of years, perhaps moving on from one area to another relatively frequently. The mechanism being used might be the addition of a slow acting poison to prescribed medication. Simple overdosage would be inappropriate because it would quickly be picked up. Yet such an activity might be sustainable for some time. Let us further suppose that eventually someone becomes suspicious, and a police inquiry follows.

As always, the Society's inspectorate, registration department and practice division all carry out their respective functions impeccably. Unfortunately, that is not how the media are likely to see it. Under these circumstances there would almost certainly be a sense of disbelief and outrage that, incredibly, a professional membership group still also had complete responsibility for the registration, inspection and discipline of its members. The headline writers will have a field day, and the editorials will ask incredulously whether anything at all was learnt from Shipman.

Catastrophic consequences

The consequences of such a scenario for pharmacy are likely to be catastrophic. It would be seen as a wholly self-interested group, concerned only with protecting the livelihoods and profits of its members. The public image of pharmacy will be fatally damaged. Root and branch reform would follow, and there would be few winners within the profession itself.

The question for pharmacy as its undertakes it modernisation debate is therefore a simple one. Can it guarantee that there could never be a pharmaceutical Shipman? Is it prepared to gamble that such a damaging case could never happen? If it did, could the profession live with the consequences? Sadly, no such guarantees can be given. To leave things as they are, with a single organisation acting as professional body, regulatory authority and inspectorate, is surely the highest risk strategy of all.

Today, a historic opportunity exists to carry out a structural realignment of the framework in which pharmacy is practised in Britain. Such an opportunity must not be missed. The time has surely come for a clear and total separation of the professional, regulatory and inspection functions, in a way which will be defensible in the event of a major pharmaceutical incident. The only such approach is for each function to be carried out by an independent body.

One multifunctional organisation, the existing Society, needs to be replaced by three single-function ones: a General Pharmaceutical Council acting as the regulatory body, a Royal Pharmaceutical Society acting as the professional body (and nothing else), and a Pharmacy Inspection Authority carrying out the statutory inspection activities.

Developments in recent years mean that the boundary between professional and regulatory functions has shifted: what once was considered professional is now regulatory. As the Society itself concedes, "the wider remit for regulatory bodies proposed in the Kennedy report suggest that the large majority of what might now be considered 'professional functions' of the Society would in fact fall to the new regulatory body" (PJ, 16 February, Supplement p3). In effect, the Society is already more of a regulatory than a professional body.

The transfer of many of the current activities of the Society to a General Pharmaceutical Council is the essential structural realignment which pharmacy in Britain needs. Unlike the Society's Council, a General Pharmaceutical Council would have a substantial lay membership. In practical terms many of the Society's staff would need to transfer to the GPC, and remain in the Lambeth headquarters. It might also be appropriate for 1 Lambeth High Street to become known as the headquarters of the General Pharmaceutical Council, and for the GPC to pay rent to the Society for the floors it occupies.

An organisation with a single function will find it easier to carry out activities which a multifunctional organisation would find more difficult. It is a logical step for a GPC to register several categories of pharmaceutical personnel, including both pharmacists and pharmacy technicians. It would also be easier for it to stipulate requirements such as continuing professional development. Individual pharmacists would pay their registration fees to the GPC, and those registered with it would be state registered pharmacists (SRPharm, rather than MRPharmS).

Return to historic role

What might the future be for that part of the Society that is not absorbed into the General Pharmaceutical Council? It should return to its historic role as a professional body. Following the Jenkin case in 1921 the National Pharmaceutical Association effectively became the successor to the original aims of the Society. Since then there has been a proliferation of professional organisations for pharmacy. Today, the Pharmaceutical Services Negotiating Committee and the Company Chemists Association have pivotal roles in the profession, and the Guild of Healthcare Pharmacists plays an important part in representing hospital pharmacists.

This suggests two possible ways forward for the Society: it can operate as an "umbrella organisation" for all the existing pharmacy membership organisations, wherever those pharmacists are employed (in community pharmacy, in industry, in academia, in hospital pharmacy or elsewhere), or it can merge directly with other bodies, such as the NPA and the PSNC, and perhaps even relocate to St Albans. A Society narrowed in function but broadened in activity would then have an unambiguous role promoting and supporting the pharmacy profession as a whole.

Both routes offer financially viable options for the Society, particularly since over half its income now comes from its publications arm.

Finally, the Society's inspection function needs to be seen within the broader context of audit and inspection in health care. The Government has recently published its proposals for strengthening this area, and it would seem entirely appropriate that a Pharmacy Inspection Authority becomes part of the new, larger and more powerful Commission for Healthcare Audit and Inspection which was recently announced.

The creation of three separate and distinct bodies, each with a single function, is a bold and radical step. As the Society recognises, primary or secondary legislation would be required to achieve it. This must not be allowed to prevent the right structural changes being made now to secure pharmacy's future throughout the 21st century and beyond.

Stuart Anderson is senior lecturer in the department of public health and policy at the London School of Hygiene and Tropical Medicine