| Enabling pharmacies to operate without the presence of a responsible
pharmacist is the most controversial aspect of changes outlined in the
Health Act 2006 and is due to be introduced by legislation in early 2009.
The Government ultimately expects that the responsible pharmacist should
be able to leave the pharmacy to operate without a pharmacist but, in
the short term, a second pharmacist will be needed to supervise transactions.
The aim is to allow responsible pharmacists to provide pharmacy services
elsewhere, for example, in an adjacent consultation room or in clinics,
nursing homes or patients’ own homes. Pharmacists may also be absent
to undertake continuing professional development or to work on commissioning
and development of local health services as part of a clinical team working
with the local primary care trust, the consultation states. These activities,
it says, will enhance pharmacists’ clinical roles and contribution
to improving health care services in the community.
Although the responsible pharmacist regulations will not in themselves
allow pharmacies to operate without a pharmacist they pave the way for
this to happen when new regulations on supervision are subsequently introduced
(these will be consulted on next).
The Government expects that, in the
future, the supervision regulations will allow the responsible pharmacist
to permit a registered pharmacy technician to supervise the sale and
supply of medicines, including when the responsible pharmacist is absent. However,
the consultation highlights the Government’s expectation
that certain activities, such as the clinical check of a new prescription,
will always be undertaken by a pharmacist.
Until the new supervision regulations come in, the responsible pharmacist
will be able to meet the specified conditions for absence when there
is more than one pharmacist working in the pharmacy at the same time — the
second pharmacist remains in the registered premises to meet the supervision
requirements.
The responsible pharmacist will be required to establish (where necessary),
maintain and review procedures for safe working in the pharmacy. This
will include making sure that suitably trained, experienced and competent
staff are available and will continue to work under the responsible pharmacist’s
authority when he or she is absent.
The Government proposes that the responsible pharmacist must be in the
pharmacy for at least 50 per cent of each period for which he or she
is in charge and the pharmacy is operating. The Government also believes
that there should be a limit on each period of absence.
It suggests that
the regulations should specify a maximum of three hours (including journey
times) but welcomes views on this, and whether the maximum period might
vary, for example when another pharmacist remains in the pharmacy during
the responsible pharmacist’s absence.
A number of conditions of absence are proposed by the Government. These
are: • The responsible pharmacist must be able to return to the pharmacy
with “reasonable promptness”
• The responsible pharmacist should remain readily contactable during
any period of absence so that staff can seek advice and request his or
her return if necessary
• If the responsible pharmacist is unable to remain contactable he or
she must arrange for another pharmacist to be available to provide advice
(who does not need to be in the pharmacy)
The consultation suggests that the responsible pharmacist should be
able to use his or her professional judgement to decide, in individual
circumstances, what reasonable promptness might constitute.
With regard to remaining readily contactable, the Government makes no
suggestions on the best way to do this but highlights the importance
of not placing too much reliance on mobile telephones because of problems
with reception and network failure.
If the pharmacist is not in a position to respond promptly to a call
from pharmacy staff, for example, he or she is undertaking several consultations
with patients, alternative arrangements should be made.
During informal
consultations, most people agreed that the regulations should require
the responsible pharmacist to arrange for another pharmacist to provide
professional advice but that the pharmacist providing advice should
not need to be a responsible pharmacist. Qualifications and experience
The Government does not intend to introduce any significant, additional,
formal or academic qualification in order to be a responsible pharmacist.
However, it does believe that the responsible pharmacist must be
adequately prepared for the role before taking on responsibility for
all activities
within the pharmacy and for pharmacy staff.
EC pharmacists
The consultation specifies that working in a pharmacy in another
EC member state would satisfy the requirement for a responsible
pharmacist to have a relevant period of experience.
It explains that European law dictates that the UK must recognise
the qualifications of pharmacists who qualify in other EC member
states. “The Government does not intend that anything in these
regulations should be inconsistent with that legal requirement,” the
consultation says. |
The consultation suggests
that one option might be to specify a minimum period of experience
following registration before a pharmacist is
eligible for the role (including EC pharmacists, see Panel right).
Another
option is that this minimum period of experience could be an additional
requirement
for absence from the pharmacy. This would allow newly qualified
pharmacists to take on the role without immediately having to decide
whether
the pharmacy can operate safely in their absence.
The Government proposes that the required experience must be recent
and in the sector in which the pharmacist wants to be a responsible
pharmacist.
This might include experience gained during preregistration training.
The consultation also seeks views on the minimum period of experience
required for those pharmacists who are returning to practice after
three or more years away.
Annotation of the appropriate registers is another area addressed.
The Government is seeking views on whether the Royal Pharmaceutical
Society
of Great Britain and the Pharmaceutical Society of Northern Ireland
should annotate their registers to indicate if a pharmacist has
the necessary
experience to be a responsible pharmacist.
During informal consultations most people thought that this proposal
required careful consideration. Several concerns were raised, including
that newly qualified pharmacists could be disadvantaged when looking
for work in the community and hospital sectors.
These chapters throw up some important questions and are essential
reading for those wishing to respond to the consultation.
The next article in this series will look at what procedures the
responsible pharmacist should maintain and what records should
be kept. |
The
Pharmaceutical Journal