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Vol 279 No 7478 p561
17 November 2007

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Why it is important to respond to the responsible pharmacist consultation

By Chris Morris

Chris Morris is a member of the Royal Pharmaceutical Society’s English Pharmacy Board

The Broad spectrum feature is open to any reader. Contributions of around 1,100 words commenting on topical issues may be posted to Graeme Smith, managing editor, or e-mailed to graeme.smith@pharmj.org.uk for consideration

There is, reputedly, an ancient oriental curse which states: “May you live in interesting times!” I thought I understood what it meant until I became a member of the English Pharmacy Board. Now I realise how time- and energy-consuming interesting times can be.

The responsible pharmacist consultation is one of the most interesting to imprint itself on the profession in a long time. I must admit that if I were not on the board I would probably not have read it and this is why I have given myself the task of trying to persuade as many people as possible to respond.

The actual consultation document is lengthy even by consultation standards. It stands at 103 pages but when you take in the Department of Health title pages, preface and appendices, which just restate the questions presented in the consultation and the legislation that the consultation is based on, it only amounts to 60 to 70 pages that have to be read.

And I believe that they do have to be read. There have been a large number of good articles written so far on the subject, some raising hopes and some raising fears, and the problem is they all seem to be correct.

Let me propose the following scenarios:

Scenario 1 The responsible pharmacist is freed to do medicines use reviews at people’s homes. That pharmacist can leave the premises to sort out a problem with a prescription. He or she can leave to get a sandwich without major recrimination. General sale list medicines can be bought while the pharmacist is absent so the customer does not have to walk to the newsagent to buy his aspirin.

And, best of all, the frankly pathetic ruling that a pharmacist is responsible for all prescriptions given out on his shift, regardless of when they were dispensed or who dispensed them, may have been overthrown. For some, this is paradise.

Scenario 2 The responsible pharmacist is again being given a list of patients by his area manager for whom he should carry out MURs. He has only been on the premises for two hours today and a bank holiday is coming up. An error was made last week while he was on one of his “MUR runs” and someone has fallen over in the shop because the flooring tiles by the door have come loose again. He then finds a primary care trust inspection team and health and safety team are there to talk to him to ask why he did not do something about the lack of well trained staff and why shop maintenance is not up to scratch. This is much less than paradise.

Both of these scenarios are possible under the responsible pharmacist regulations and guidelines.

The document comprises part one of two that could change pharmacy forever. The second part, out next year I believe, will discuss what the responsible pharmacist will be responsible for. That part will really get the matter of remote supervision in its teeth and so let your ire be raised about that then.

What is actually discussed in detail is what the responsible pharmacist will be able, and not able, to do. This includes whether a newly registered pharmacist can be a responsible pharmacist or whether a pharmacist who has had a brief or long hiatus from work can be a responsible pharmacist.

It discusses what records a responsible pharmacist must keep and who must be informed if the responsible pharmacist does decide to leave the premises.

For now let us concern ourselves with the document in front of us.

The responsible pharmacist regulations could free us all to leave the dispensary bench for as much or as little time as we see fit. It could pave the way for the creation of true clinician pharmacists who feel that their education and training is wasted in dispensing factories. It could be the key to the world allowing professional freedom to say, “I am a professional, I feel I can leave the premises to carry out this vital clinical role”.

Or it could pave the way for unscrupulous superintendent pharmacists to offload their work and responsibilities.

How much scope does an employee or locum have to ensure that there are enough shop staff and that they are trained correctly? How many locums have the ability to sign off on vital maintenance required in the branch?

A colleague has mentioned an interesting idea whereby “area manager” should be recognised and defined legally. After all, such people are the true bridge between coalface pharmacists and head offices. This is an idea that I could certainly learn to like and I am sure the DoH will receive this idea as part of its consultation.

My purpose in writing this article is to try to motivate the silent majority. You spoke up in your thousands when the money in your pockets was threatened by a huge hike in retention fees. I am asking you to stand up once again to voice your opinion on something that could affect your income even more.

For example, if you were prosecuted for substandard maintenance which resulted in an injury to a member of the public who would employ you? If you were reprimanded for an error that occurred when you were forced to leave the dispensary, your income could be cut drastically, if not totally.

I am asking everyone to read the consultation document. It is readily available on the DoH website under “Live consultations”. It is only 70 pages long. What is that? It amounts to a Sunday supplement, or a few chapters of a novel. Read the document or read the articles being published in The Pharmaceutical Journal. Preferably, read them both. Read them and form ideas, write them down and then send them in. The best course would be for everyone to send their comments direct to the DoH, but I doubt whether this will happen. So I am offering my services.

If you only have a few words to say that you do not believe worthy of a personal response or you have pages of comments but are worried that it may not sound right and you do not want to send it straight to the Department of Health, then e-mail them to me at resppharmconsult@hotmail.co.uk

This e-mail address will be open until mid December 2007 and I will try to collate all responses. I will then e-mail all respondents with my response before submission for approval and this will then be sent to the Department of Health as “A response from X number of pharmacists.”

This consultation is too important to ignore. We do indeed live in interesting times and it is up to all of us to try to make this work to our advantage.

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