Supervision consultation should be agreed first
Consultation on supervision requirements should be brought forward so that the question of a responsible pharmacist’s absence from a pharmacy can be viewed as a whole before the regulations are drafted, according to bodies that represent community pharmacy owners.
In their joint response (PDF, 210K)to the Government’s responsible pharmacist consultation, the Pharmaceutical Services Negotiating Committee, the National Pharmacy Association, the Company Chemists’ Association and the Association of Independent Multiple Pharmacies say that they found it impossible to come to a final conclusion about the amount of time that a responsible pharmacist should be permitted to be absent from the pharmacy due to uncertainty about provisions relating to supervision and NHS legislation, which are yet to be considered.
In addition, the bodies believe that there should be no requirement for extra qualifications or a minimum period of experience to become a responsible pharmacist and that this should be left to the discretion of the superintendent pharmacist. “Any stipulation of postregistration experience would be arbitrary and would take little account of the competence of the individual or of the quality of the experience,” the joint response says. However, the Royal Pharmaceutical Society believes that specific competencies to fulfil the wider responsible pharmacist role will be required.
The four bodies are also of the opinion that superintendent pharmacists should set company frameworks for standard operating procedures that are not intended to change either on a regular or frequent basis. “The SOPs will incorporate guidance to cover a range of predictable eventualities, such as different staffing situations or when there is a technological failure.” When these SOPs are issued they can then be tailored to local circumstances by the responsible pharmacist who best knows that pharmacy, in consultation with the superintendent pharmacist. If the responsible pharmacist on a particular day deems that amendments are needed due to exceptional circumstances these should be discussed with the superintendent pharmacist or, if a unilateral decision is taken by the responsible pharmacist, he must take full responsibility for his actions.
The CCA and AIMp also issued the following joint statement: “From a multiple pharmacy perspective, the responsible pharmacist consultation is key. There is a robust legal and professional framework within which a pharmacy chain currently operates, directed by the superintendent pharmacist. The roles and responsibilities of the responsible pharmacist must dovetail with this existing framework.” They added: “We hope that, taken together, the responsible pharmacist regulations and the reframing of supervision will deliver more flexibility for pharmacy teams working in practice to better meet the needs of patients.”
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