The Pharmaceutical Journal
Vol 279 No 7478 p563
17 November 2007

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• Retention fees (3)
• Pack sizes
• Supervision (2)
• Safety (3)
• Locum pharmacy
• NHS and pricing (3)
• The Society (2)

Letters to the Editor

Supervision

Muddled thinking over future statutory responsibilities

From Dr R. J. Schmidt, MRPharmS

Jonathan Buisson (PJ, 3 November 2007, p496) asserts that the concept of the responsible pharmacist under the Health Act 2006 “always seems to resolve into three distinct categories”. I think this reveals a degree of muddled thinking within the Royal Pharmaceutical Society’s Health Act Working Group as to the nature of [community] pharmacists’ current and future statutory responsibilities.

I would make the counter-assertion that there will be only one category of responsible pharmacist, namely the responsible pharmacist.

We all have heard about good manufacturing practice, good laboratory practice, good clinical practice, etc. The Health Act 2006 is moving us towards good dispensary practice. We are already there in the sense that we have put dispensary standard operating procedures in place. Properly implemented SOPs are a necessary and unavoidable feature of good practice.

A further common feature is the provision that a named individual has to be identified who takes legal responsibility for the content and proper implementation of those SOPs on a minute-by-minute basis. That is why there can be only one category of responsible pharmacist. That is why even a locum pharmacist who has never previously stepped into a particular dispensary will have to be prepared to take immediate and full legal responsibility for not only his or her own professional actions and omissions, but also those of all medicines counter and dispensary support staff (see PJ, 13 October 2007, p401).

It seems that the Society’s Health Act Working Group does not realise that when a patient or customer asks for advice at the medicines counter, he or she is asking for, and is entitled to receive, evidence-based advice from the pharmacist. Accordingly, support staff have to be trained against SOPs to act as the pharmacist’s representative when proffering advice.

In the event of an injury being caused by bad advice, it will be the responsible pharmacist present on the day whose advice will be deemed to have been given, not that of some absent “responsible pharmacist-prime”. Nor do we need to invent the third, Society category, namely the “non-responsible pharmacist”.

Quite simply, each responsible, second or third pharmacist on duty is now, and will continue to be, professionally and legally responsible for all prescriptions he or she has dispensed, as evidenced by an initial on the medicine label generated on the day.

It follows that one of the main changes that the Health Act 2006 is bringing to community pharmacies is the transfer of responsibility for the actions and omissions of medicines counter and dispensary support staff [in the widest sense] from the superintendent pharmacist to the responsible pharmacist.

Richard Schmidt
Penarth, South Glamorgan

What about the whistleblower?

From Mr G. L. Stafford, MRPharmS

It is hard to judge the “responsible pharmacist” document published by the Department of Health without the “remote supervision” element superimposed on it but for me another element seems to be completely missing, namely, protection for the whistleblower who says “no, it would be irresponsible to open this pharmacy”.

How would such a person shutting a multiple or a supermarket pharmacy fare in the rest of his or her career? Would that person ever work again? Would the company just get “company man” in the next day to open up the pharmacy again?

Putting all that responsibility squarely on an individual’s shoulders without published national standards for staffing, training and working conditions is, in my opinion, a complete non-starter.

Graeme Stafford
Morecambe, Lancashire

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