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CPD issues for industrial pharmacists
Members of the Royal Pharmaceutical Society's Industrial Pharmacists Group have been interested to read about the Society's plans for mandatory continuing professional development (CPD) and particularly the implications of non-compliance. The plans have stimulated debate within the group committee, which has explored possible alternative approaches for industrial pharmacists. This article addresses the background to the CPD requirements, and proposes one possible approach. Background Following a series of high profile fatal incidents involving members of the medical profession, the Government has insisted on health care professions introducing better self-regulation. The Society's response to date has included a review of its disciplinary procedures and the introduction of the concept of clinical governance, published in the 1999 document, "Achieving excellence in pharmacy through clinical governance". It lists the four main components of clinical governance as: defining clear lines of responsibility and accountability for the overall quality of care; establishing a comprehensive program of quality improvement activities; having clear policies aimed at managing risks; and establishing procedures for all professional groups to identify and remedy poor performance. In August 2001, the Department of Health published a consultation document, "Modernising regulation in the health professions", which proposed that selected health care professions, including pharmacy, should be accountable to a Council for the Regulation of Healthcare Professionals for the control of standards. The proposals included specific powers to link continued right to practise with evidence of satisfactory completion of a CPD programme, and regular assessments of competency of all practising members of the profession. The proposals were subsequently incorporated into the provisions of the NHS Reform and Healthcare Professions Bill, The Society, as the regulatory authority responsible for the education and training of pharmacists in Britain, has been requested to submit proposals by September 2002 for meeting the Bill's provisions. Systems for CPD appropriate for all sectors of pharmacy are under discussion and a CPD working group has been established to propose solutions that will satisfy the needs of the new legislation. The Society has undertaken a trial using Kolb's learning cycle as a framework for an organised system of career development. The model is based on the cyclical roles of planning, action, evaluation and reflection, and demonstrates how a personal development plan should be formed, and encourages work-based learning. This pilot has now been run for seven months and includes some 500 pharmacists, 300 community, 150 hospital, and 50 others. The specific number working in industry is not identified but is thought to amount to three; no feedback has been received. However, the Society intends to roll out the system to a further 5,000 pharmacists and has asked for further volunteers. The Industrial Pharmacists Group has expressed concerns regarding the special circumstances of pharmacists in industry. Unlike their contemporaries in hospital and community pharmacy, most industrial pharmacists are not contracted to provide services directly to patients, and they believe that they should not be required to meet the requirements of the NHS Reform and Healthcare Professions Bill. The varied nature of occupations filled by industrial pharmacists make it difficult to have a system focused on the usual competencies for pharmacy. Most companies now have well-organised performance management development schemes, monitoring technical and professional standards, which are used to assess and develop staff. This is not to say that that industrial pharmacists should be exempt from providing evidence of CPD, but rather that written evidence of relevant new competencies gained as part of an in-company assessed personal development plan should be acceptable to the Society for assessment. One key concern for industrial pharmacists is to have a provision allowing transfer between the different sectors in pharmacy. A robust familiarisation programme should be mandatory before commencing practice in a new sector. An industrial pharmacist may well belong to more than one professional organisation that includes professional excellence through CPD among its objectives. Any system needs to allow for this without creating an unworkable system for the individual. The Society's CPD protocols should be flexible and not over-demanding if members are to submit regularly for assessment. Unlike the other sectors of pharmacy, CPD for industrial pharmacists should not be made mandatory, since membership of the Society is not a condition of the right to practise in the industry. Two examples of programmes run by other institutions are provided by the Institute of Quality Assurance and the Royal Society of Chemistry. The IQA, whose members have a professional obligation to maintain a high level of knowledge and competency in their sphere of activity, has instituted a quota system to measure achievement. A strong motivation is the provision of professional indemnity for those members who keep their CPD programmes up to date. The RSC launched a voluntary CPD scheme in 1995, again based on a quota system. Motivation for undertaking CPD is to either qualify for charter membership or to be named on one of two specialist registers as having satisfactorily completed CPD. This enables members to demonstrate a personal commitment to taking responsibility for lifelong learning and career development. Qualified persons (QPs) also have obligations to CPD: in Annex 13 to the Guide to Good Pharmaceutical Manufacturing Practice, which covers certification by a QP and batch release, there is a requirement that a QP maintains an up-to-date knowledge of new technology appropriate to the products which they are releasing. The Society, the Royal Society of Chemistry and the Institute of Biology are responsible for the Joint Register of Qualified Persons. The RSC does not require practising QPs to comply with a mandatory CPD scheme, and as yet the IoB has no scheme at all. Because neither profession is named as a health care profession, they will not be required to meet the additional requirements of the new Bill. It is important that the Society, with the introduction of any future CPD scheme, should not create inconsistencies by introducing additional requirements for pharmacist QPs, who are already declining in number. Recommended system for CPD I recommend the establishment of a protocol for an optional CPD system for all industrial pharmacists, sufficiently flexible to accommodate the competencies for those working in different disciplines of industrial practice. All members should submit their achievements every five years for assessment, supported by evidence gained from employers and of any CPD undertaken. But the issue of licences for the continued right to practice, on submission of satisfactory evidence of CPD, should not become a requirement for the industrial pharmacist. I reluctantly accept that this will require the segregation of names on the Register to note those qualified to work in hospital, community and industry. It is important that any such segregated register is supported by a procedure enabling members to transfer from one sector to another should they require. |
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