[Linnear]

Chapter 2: The Responsible Pharmacist

The main issues with the RP revolve around the fact that the possible responsibilities given to the RP do not at present match the pharmacist’s ability to alter their workplace.
If a pharmacist is to be made truly responsible they must be able to bring about changes in their workplace within a suitable timeframe.
This would need to include being able to report problems to Head Offices without fear of recrimination and for these reports to be catalogued so that if the RP is held accountable for problems he can say that the problem has been reported on this date but nothing has been done about it.

Chapter 3: Pharmacy Procedures

The main changes with procedures would need to see that pharmacists are made completely aware of what they are responsible for. This may have long range effects for how locums work.
We would also need to see a legislated means of “whistleblowing”. i.e. a system whereby any problems could be reported to Head Offices without fear of reprisals and also to be able to report Head Offices if the changes asked for are not implemented or some form of written evidence can be supplied to say that the Head Office does not deem the change necessary.
This would especially hold for staffing levels and staff training budgets.
The idea for the reviewing of procedures is fine as long as the RP can get his voice heard if the procedures are no longer held to be safe.
The timing of reviews would only need to be listed under guidance as pharmacists are professionals and I’m sure they could see when a review would be necessary.

Procedural changes that removed the GSL anomaly would be welcomed.

The role definitions asked for would seem to be thus:

RP: Day to day running
Supt Phc: Responsible for whole chain and putting things right beyond control of RP
Pharmacy Owner: As Supt Phc where the SP does not have the authority to spend money etc.
Prof Reg bodies: To set standards and keep register of RPs if experience etc. required

Chapter 4: Records

There should definitely be spaces for airing problems and complaints and whether this has been passed on up the management chain

No real need for registration date
Reason for and time of absence if off premises
The signing of amendments etc. is part of recognised practice i.e. CD reg
Other staff working only needs to be logged if a perceived problem
An idea was raised that a declaration that the RP understands their responsibilities should be included.
If a major problem occurred this could be recorded, especially if short/poorly staffed and an error occurs

The format isn’t really essential as long as it is readily available

We cannot see why the log would need to be kept longer than 2 years.

The biggest problem that we can foresee for the records would be that they would become too cumbersome and require too much time to fill out. So it is suggested that any entries that are legislated for are thought through very carefully.


Chapter 5: Absence

We are all for extending our roles but do not feel that this justifies abdicating our place in the pharmacy as “the professional on the high street”.
in our opinion absences would dictate the need for a second pharmacist would be the safest option. If a second pharmacist was present we would have thought it would be common sense for that pharmacist to become the RP.
If absences are legislated for then it should be down to the professional discretion of the RP not Head Office and should certainly only be for patient care and not for personal reasons.
We feel that in the case of absences it is important that at least one registered ACT is left in the dispensary.
Re contacting the RP and whether another pharmacist is needed to be contacted by the staff, we feel that this could be covered by guidance only and left to the professional discretion of the RP as it is impossible to legislate for every eventuality.
Lunch breaks should also be legislated for as an absence during which the RP cannot be forced to carry out pharmacist duties.


Chapter 6: Qualifications and Experience

The question we are interested in is, is there any proof that newly qualified Phcs are a risk?
It goes without saying that any changes in responsibility brought about by the new legislation would have to be covered at undergraduate and pre-reg level.
Although we feel there is no real need for a separate register for RPs it might be a good idea for RPs to self certify the fact to RPSGB to show that they are prepared to accept the additional responsibilities.
If experience becomes part of legislation then needing more experience to be allowed to absent yourself sounds good as experience brings with it a better ability to know when things can be delegated.
We don’t believe that sectoral differences are sufficient to require a long transitional training period when moving from one sector to another. The only time that it was thought there might be a problem was if a student did a pre-reg in one sector and then immediately moved to another sector on qualification.
Re long periods of absence from work, it was thought that some form of transition period on return would be required but some thought we would need to be careful to ensure that discrimination, against new mothers for example, did not become apparent.


Chapter 7: One Pharmacy/One RP

We believe that this section could be the cornerstone of the legislation and could be used to ensure that unscrupulous contractors do not try to save money by forcing RPs to cover more than one shop or by bringing in robots in every other shop.
We all believe that if it was allowed that one RP could be in charge of more than one shop this should only be for a very limited length of time and under very well defined parameters.
We all thought that the examples in the consultation were extremely silly in that we cannot see that a horticultural show which is set for the same time every year could be classed as an exceptional circumstance when a pharmacist getting appendicitis is not.
There was a question raised of whether a country the size of the UK really needed robots at all.
It was certainly felt that this legislation should not be used to allow one RP to look after more than 2 shops under any circumstances.
Again if there were any qualms regarding looking after two shops there should be robust procedures in place to allow for whistle blowing.
One idea that came up was that a RP would be allowed to supervise a maximum number of transactions per hour/day. So this would tell the company involved whether a RP was eligible to become RP for more than one shop.

Chapter 8: Supervision etc.

This amounts to remote supervision and is a very slippery slope upon which we do not wish to tread.
This is one part of the legislation which could lead to great abuse of the system by contractors.
Any move toward this destination should be backed up by rigidly enforced legislation and should again be open to whistle blowing should coercion etc. be used.

Chapter 9: Implementation

This is a hard question to answer until we see exactly what the RP will be responsible for.
Dependent on how many changes are made then pharmacists may have to retrain with regard to their new responsibilities and locums will certainly need to think about their position.
We would have thought training packs should be made available to pharmacists so they can make themselves ready for any changes at no cost to pharmacists.