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Framework for regulating pharmacy support staff at S/NVQ level 2
1. Introduction This document contains the provisional recommendations of the Society's steering group on the regulation of support staff (see Appendix) for support staff at Scottish/ National Vocational Qualification (S/NVQ) level 2, ie, dispensary support staff (excluding pharmacy technicians) and medicines counter assistants. The steering group is of the view that the Society is the most appropriate body to regulate all pharmacy support staff and has made a number of recommendations as to how regulation of staff working at S/NVQ level 2 should be achieved. The steering group does not consider a requirement for registration to be necessary for support staff working at this level, given that staff at this level do not work unsupervised. These recommendations therefore build on the Society's existing support staff policy to regulate the environment within which they work though professional requirements for training, competence assessment and written standard operating procedures. (The steering group's recommendations regarding the regulation of pharmacy technicians by the Society are being dealt with separately see Council report, p866) Comments on this document should be forwarded to Janet Flint in the Society's practice division by Friday 31 January 2003. 2. Drivers Department of Health (England) document "Pharmacy workforce in the new NHS"; Royal Pharmaceutical Society policy on support staff, in particular 2005 minimum competence requirement. 3. Assumptions Regulation will become a requirement for those working in the NHS who have a direct impact on patient care. 4. Population 22,500 dispensing assistants in community and hospital pharmacy (excludes those with a pharmacy technician qualification); 40,000 medicines counter assistants. 5. Scope Regulation of dispensary assistants at S/NVQ level 2 and medicines counter assistants. 6. Concerns Costs to employers and to the Society. A transient population, many of whom work part-time. 7. Functions for Society and profession Setting professional requirements for minimum levels of training and/or competence (existing Society policy); Setting professional requirements for written standard operating procedures to be developed and adhered to (existing Society policy); Setting professional requirements for support staff to undertake ongoing training and updating to maintain their competence (existing Society policy); Monitoring compliance with professional responsibilities through inspection. 8. Existing Society support staff policy Since July 1996 it has been a professional responsibility to ensure that each member of staff whose work in the pharmacy regularly includes the sale of medicines has completed an accredited course or is undertaking such a course. (The Society has not issued guidance on the length of time within which a candidate should complete the training); From 1 January 2005 it will become a professional responsibility to ensure that all staff involved in dispensing activities have attained a minimum standard of competence or are undertaking an appropriate course of training. Discussions are currently taking place with employers (via the Pharmacy Sector Committee) on the acceptability of a requirement based on the standards for the Pharmacy Services S/NVQ level 2 qualification and what might be acceptable as equivalent to completion of a S/NVQ. It will also become a professional responsibility to ensure that all qualified dispensary assistants are kept up to date; From the same date, written protocols/ standard operating procedures covering dispensing activities will be required to be in place and operating in all pharmacies. (Standard operating procedures are written procedures specifying in writing what should be done, when, where and by whom.) 9. Proposed regulatory framework for dispensary support staff The minimum standard for dispensary support staff should be S/NVQ level 2 or equivalent; There should be a flexible approach to equivalence at this level; The Pharmacy Sector Committee should be asked to advise the Council on agreed equivalent(s) to S/NVQ level 2 (The sector committee is currently exploring the practicalities of developing a vocationally related qualification at this level which will deliver the underpinning knowledge required for the S/NVQ. This would then become part of the national qualifications framework and could attract funding via the Learning and Skills Councils. Coupled with an assessment of competence by a supervising pharmacist, this might be acceptable alternative to the full S/NVQ); Minimum training requirements should incorporate: A defined period of time following the commencement of employment of a new member of staff before being required to enrol that member of staff on a training programme (for medicines counter assistants the guidance is currently three months). This should be sufficient to enable employers to evaluate a new employee's suitability for continued employment and/or enrolment on a training programme; A defined period of time within which training should be completed (three years from the date of commencement of training); In line with existing Society policy, employers should be advised that existing members of staff must be enrolled on training on or before 1 January 2005 and that training should be completed before 2008; There must be a grandparent clause to enable those who have been working as dispensary support staff to continue to do so; This could be based on one or more of the following: actual work experience in a dispensary, eg, has been working in a dispensary for not less than 16 hours per week for four of the past eight years; completion of a short dispensary training course, eg, Buttercups or National Pharmaceutical Association dispensary assistants course or Boots one-year dispenser training programme; Declaration of competence against the S/NVQ level 2 standards by a supervising pharmacist; Further consideration should be given to methods of assessing the equivalence of "unusual" qualifications, eg, those gained outside the UK; Pharmacists in personal control of a pharmacy should be accountable for ensuring that their dispensary support staff are trained and that their competence is maintained through ongoing training and updating; Society inspectors should have a role in monitoring training records of dispensary support staff. 10. Proposed regulatory framework for medicines counter assistants Training programmes for medicines counter assistants should cover the knowledge and understanding associated with unit 3.10 of the Pharmacy Services S/NVQ level 3, "Assist in the sale of OTC medicines and provide information to customers on symptoms and products"; New members of staff should be enrolled on a programme of training within three months of them commencing employment; Training should be completed within three years of commencement of training (new policy); Pharmacists in personal control of a pharmacy should be accountable for ensuring that their dispensary support staff are trained and that their competence is maintained through ongoing training and updating. Society inspectors should have a role in monitoring training records of dispensary support staff.
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