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Vol 279 No 7473 p401
13 October 2007

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Letters to the Editor

Supervision

Job description of the locum pharmacist is set to change

From Dr R. J. Schmidt, MRPharmS

I wonder how many community pharmacists fully appreciate the significance of the forthcoming requirement under the Health Act 2006 to identify a “responsible pharmacist” in each community pharmacy. This new legal entity will be personally responsible in law for the safe and effective running of a pharmacy in relation to the sale and supply of medicines.

In order to fulfil this role, the responsible pharmacist will have to assume personal responsibility for the content, implementation and maintenance of dispensary standard operating procedures (SOPs), not only in a professional sense but now also in a statutory sense. Failure to carry out this role properly will be a criminal offence — currently it is only considered professional misconduct, since 1 January 2005.

By making this change, the Health Act 2006 is extending the regulated chain of traceability and accountability for the quality and safety of medicines and medical devices into community pharmacy. Those who have any experience of the pharmaceutical industry will not be surprised by this development. What will surely follow will be audits by one or more regulatory authorities that will have, we may suppose, the power to close down a pharmacy if dispensary SOPs are not properly implemented and maintained, and if support staff are not properly trained.

This is what happens in the pharmaceutical industry (and is often the reason why a product suddenly becomes unavailable from a manufacturer). And it will be the responsible pharmacist, rather than or as well as the superintendent pharmacist, who will be held to account for inadequate staffing levels in the dispensary and for inadequate training of support staff in the event that a patient safety-related incident occurs.

This development should cause more than a ripple of concern in the minds of both locum pharmacists and those pharmacists currently employed as pharmacy managers. If my experience as a locum pharmacist is anything to go by, having worked in numerous dispensaries operated by both small and large pharmacy chains as well as in independent pharmacies, I have to report that I have worked in only a handful of dispensaries where I would be happy to take on the role of responsible pharmacist, where staffing levels are adequate and where support staff are trained to what I would recognise as an acceptable standard against properly implemented and maintained dispensary SOPs.

This is an important point because a locum pharmacist will surely have to be a “responsible pharmacist” when he or she is the only pharmacist on duty. Does anyone yet know how this issue is to be handled? My guess is that individual locum pharmacists will have to be contractually identified as assuming the position of responsible pharmacist when the usual responsible pharmacist is absent for longer that the yet-to-be-prescribed allowable absence time.

It would be the height of folly for locum pharmacists to enter into such contractual arrangements without first determining how many support staff will be present and, perhaps more importantly, the level of competence and training of support staff. This problem would be particularly acute in those pharmacies that are “run on locums” in which, in my experience, little or no training of support staff seems to occur.

The job description of the locum pharmacist is set to change in a profound way.

Richard J. Schmidt
Penarth, South Glamorgan

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