Hi there.
I have put together a response from the people that emailed me.
I am posting it here. Sorry it's so long. (And trust me I am sorry!
)
Anyone thinks they could agree with it please email me.
It took a lot of work and the greater the value of "x" in the intro the bigger the impact.
Thanks in advance.
Response to Responsible Pharmacist Consultation
Chris Morris MRPharmS Reg 88687 Speaking for a cohort of x pharmacists
*For expediency when the pharmacist is referred to as his/he it is implied her/she where appropriate
The feeling that has come across from the respondents was that there are anomalies that need to be addressed. The GSL legislation is frankly ludicrous as is the fact that pharmacists are held accountable for prescriptions given out on their shift that another pharmacist has dispensed/checked.
If the Responsible Pharmacist (RP) legislation can counter this then this would be felt to be a good thing but it was also felt that if the legislation allowed pharmacist absences then it would be unfair for the absent RP to be held accountable for mistakes made during their absence.
The rest of the document seems to raise issues which could pave the way for a newer more clinical practice of pharmacy but the legislation raised many worries about how it might be abused. It was felt by many that new roles should not be developed at the cost of the traditional.
The fact that the RP will be held more responsible for his surroundings seems inappropriate as employees and especially locums have no say in staff levels, payment for staff training or payment for other services which might be deemed to be necessary for the safe and proper running of a pharmacy establishment.
Regarding SOPs it was felt that for a locum to sign off that SOPs are correct and valid would necessitate taking extra time each morning before opening just to read them all. SOPs are usually the same throughout a company but can be altered at a pharmacist’s discretion as long as Head Office has authorised it so it could not just be assumed that all SOPs were the same.
The first Darzi report mentions that there is a worry that the 100 hour exemption for pharmacy registration may be being abused. The overall feeling is that the RP legislation could fall prey to the same abuse by unscrupulous contractors. It could be seen as a way for the Superintendent Pharmacist (SP) to offload their responsibilities. Also, if it came about that a single RP could be responsible for more than one pharmacy then it could be a way for contractors to cut costs. There were several instances where pharmacists were already aware of companies that used “floating pharmacists” to cover more than one shop, I myself was asked to do this just after qualifying. This is not legal but goes on now, what would happen if it was legislated for?
One idea that was raised was that as part of the changes in legislation “Area Manager” became a legally binding term with its own legislated responsibilities. It is after all the role that is the major link between coal face pharmacists and Head Office.
The feeling regarding absences was that the major strength of community pharmacy is its no appointment, see a pharmacist any time the pharmacy is open system. If the RP could leave the pharmacy then this would be lost and the “Ask your pharmacist” trademark would go the same way. For example, a young girl that needs Emergency Hormonal Contraception, who has summoned up all of her courage to go to her local pharmacy is then told that she must call back later. How would she feel and would she call back?
The only way this could be reconciled would be for a pharmacist to absent themselves from the dispensary but only to go to another part of the building to carry out MURs or the like.
If absences were brought in it was felt that 2 hours would be adequate although many thought that this was too long and certainly that any absences should not be during the first or last two hours of the working day. This would prevent the less conscientious from using the legislation to gain a lie in or an extra round of golf in the evening.
Of course if the RP is absent it was felt that the problem would be who would take over? Many locums felt that they had worked in very few places where the dispensing staff, even ACTs, were up to the job of becoming a proxy pharmacist. Locums working in new shops would certainly not be able to assess whether the staff were up to being left on their own.
This raised the issue that it was felt that very few ordinary people or politicians realised what a pharmacist actually did. Pharmacists that I have spoken to rarely set aside time as “clinical check of script time”. Clinical checks are carried out at each stage and it was felt that pharmacists often pick up different problems at different stages of the process, these problems can include Prescriber errors and the like which some dispensing staff just do not seem to look for. The thought of carrying out a clinical check without seeing the patient’s records certainly seemed very difficult and this would mean that Remote Supervision (RS) could not be safe and could not be held to be in the public interest and even goes against the government agenda of patient choice and easy access.
It was felt that pharmacists have knowledge and experience that the majority of dispensing staff just do not have. This of course may be used as an argument that a newly qualified pharmacist should not be made an RP until they have some experience under their belt but the general feeling was that after a 4 year Masters course and a pre-reg year any pharmacist should have the requirements to be a RP.
The general consensus was that if the role of pharmacist was to be made more clinical and there was a need to absent oneself then another pharmacist needed to be there to keep the running of the pharmacy safe for the general public. A pharmacy running without a pharmacist was considered to be extremely dangerous by most respondents. This would mean legislating for someone to pay for additional pharmacists, preferably the government as they are the instigators of this legislation.
Those were the general ideas raised, as for specific sections of the consultation: