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Responsible Pharmacist response part 1

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  • Responsible Pharmacist response part 1

    Here is a response. I guess it is extreme compared to some of the utter tat i've seen so far. 'Oh RP will move us forward', 'Oh we have to consider locums'. I have only responded to important sections. I considered sections such as procedures, signing off etc to be red herrings. I have raised some points, which, if unanswered, I will personally take time off and harrass everybody at the DoH. If you want to retain your money, fight my corner. If you are a proprietor or a fat, bald, divorced area manager with a comb over/bad breath who thinks it is acceptable to be crap in bed, then you probably shouldn't agree with me as your motives do not include protecting the individual pharmacist. Remember this is a change in the law which will make healthcare cheaper. Then you are stuck with it. This has been split over two parts!!!!!!Please read all

    The Responsible Pharmacist
    APPENDIX A: SUMMARY OF CONSULTATION QUESTIONS
    THE PHARMACY PROCEDURES: Chapter 3
    The Government believes there is a need for a balance to achieve some consistency in the content of the pharmacy procedures whilst allowing the responsible pharmacist sufficient flexibility to ensure these meet the operational needs of the individual pharmacy

    Q. Do you agree with the view, set out in the consultation paper, on requiring the format used to allow the responsible pharmacist to “sign off” that s/he has checked the procedures and is content these support safe working in the pharmacy? If so, what are your reasons for supporting that view?

    A :The responsible pharmacist should only be allowed to sign off procedures when present on the pharmacy premises. This would encourage diversity and regulation of procedures. If procedures can be signed off away from the pharmacy, pharmacies could whittle out potential employees who disagree with procedures that are rightly not fit for purpose.

    ABSENCE FROM THE PHARMACY: Chapter 5
    The Government has stated the regulations specify the minimum proportion of time that the responsible pharmacist should spend in the pharmacy and this should be the majority of his/her time (ie more than 50%)

    Q. Do you support this view? What are your reasons for this?

    A: The pharmacist should be present in the pharmacy 100% of the time. Reasons include the following:
    P Medicine sales breakdown when a patient is concerned about drug interactions, this is where the technician always asks the pharmacist. If the pharmacist is not present, patients will have reduced access to medicines which is the opposite of what the consultation sets out to acheive. On the flip-side, inappropriate medical advice given by a non-medically trained person may be given, which endangers the health of the patient.
    If medicines are out of stock, patients receive owings. If an owing is unwittingly given for anti-arrythmic medicine etc (where long term manufacturing problems are present etc), a patient may be hospitalised. Only the pharmacist can quickly distinguish which medicines can appropriately be ‘owed’, instead of sending the prescription elsewhere. There is no devisable system which would allow a technician to distinguish where owings would be inappropriate, as this would constitute professionalism.
    Any absence from the pharmacy must be in emergency circumstances only, at the discretion of the disciplinary committee. A pharmacist can only take absence following their initial arrival at the pharmacy.

    Q What do you think should be the minimum proportion of time that the responsible pharmacist should be required to be present in the pharmacy?

    A : The pharmacist should always be present except in emergency circumstances.

    Q. If you do not agree, what do you propose and why?
    The Government proposes the maximum time during any one period of absence that the responsible pharmacist may be away from the pharmacy should be three hours. The Government seeks views on whether this period might vary in certain circumstances

    A : There should be no maximum time in an emergency circumstance. In normal circumstance the pharmacist should always be present.

    Q. Do you agree the regulations should specify a maximum time? If so, should this be set at three hours?

    A : There should be no maximum time.

    Q. Do you think the maximum time might vary, subject to meeting conditions set out in the regulations? Eg where another pharmacist or a suitably trained and registered pharmacy technician remain present in the pharmacy? If so, how might this vary and what are your reasons for putting that view forward?

    Q. If you do not agree, what do you propose and why?

    A : I propose that the pharmacist should remain present except in emergency circumstances and toilet breaks. Patients perceive that everybody behind the counter is a pharmacist. We know this to be false, which is why a pharmacy must be under personal control/supervision of a pharmacist. However if a pharmacist is absent, the patient will still presume that a pharmacist is present and that any medical advice received is suitable and appropriate, which it is not as technicians are not medically trained. Before a pharmacist is allowed to be absent, premises must be divided into two types. The Pharmacy (where a pharmacist is always present except in emergencies) and another type, for instance named a ‘Dispensing Association’, where a pharmacist may be absent. ‘Pharmacy’ suggests a pharmacist is involved, which isn’t appropriate when a pharmacist is absent. The patient can then ‘choose’ to have their medicines to be dispensed in the guaranteed presence of a pharmacist in a ‘Pharmacy’, allowing for competition, choice and maintaining the integrity of the pharmacist.


    The proposal is the regulations specify the responsible pharmacist must be able to return to the pharmacy with reasonable promptness.

    Q. Do you agree? If not, what do you propose and what are your reasons for this?
    The proposal is the regulations require the responsible pharmacist to be readily contactable by pharmacy staff during any period of absence but do not specify the arrangements to be made

    A : How can a pharmacist guarantee a return with reasonable promptness? An ambulance has a siren and flashing blue lights. Yet it often arrives too late to emergency situations to save lives. Is it enough for a pharmacist to ‘attempt’ to return with reasonable promptness? Surely not. If a pharmacist becomes stuck in traffic for instance, they will only be wasting the time that they were freed to utilise in the first place. The circumstances for return haven’t even been suggested.

    Q. If you do not agree, what do you propose and what are your reasons for this?
    The proposal is that the responsible pharmacist is required to arrange for another pharmacist to be available to provide advice when s/he is absent from the pharmacy and is unable to be contacted by pharmacy staff.

    A: As previously stated, I do not agree with the pharmacist being absent from the pharmacy. What about emergency situations within the pharmacy that require a pharmacist to administer medicines or first aid that they were trained to carry out? A satellite pharmacist cannot give this kind of treatment, but you can be sure they will be liable in court.

    Q. Do you think that the regulations should require the responsible pharmacist to arrange for another pharmacist to provide advice where s/he is unable to maintain contact with the pharmacy? If so, should the other pharmacist also be a responsible pharmacist or eligible to take on this role?

    A : This may be un-feasible. If another pharmacist can be present at the pharmacy in body, the situation is acceptable for reasons discussed in other answers. If a pharmacist cannot be present at the pharmacy, the pharmacy service should be closed as occurs at present.

    Q. If you do not agree, you propose and why?

    A : This will add potential for errors in advice if consultations are done via telephone etc. Another barrier of communication is added with use of a phone/video link. No visual aid can be given ie demonstrations of how to use medication etc.

  • #2
    Responsible Pharmacist response part 2

    ONE PHARMACY/ONE RESPONSIBLE PHARMACIST: Chapter 7
    The consultation paper sets out two examples of possible exceptional circumstances that might support allowing a pharmacist to be responsible for more than one pharmacy at the same time.

    Q. What are your views on the examples given?

    A: There should be one responsible pharmacist to one pharmacy. There is no justification for removing the pharmacist as the sole medically trained member of staff within the pharmacy. The likelihood is that rather than wait for contact to be made with the pharmacist, the patient will leave the premises without advice that they require. Patients who visit the pharmacy purely for advice and medical or professional opinion (which is saving GP time at present) will revert to visiting the GP if a pharmacist is not present in person. If the step is taken to allow a pharmacist to supervise more than one pharmacy, an advertising campaign must be produced to make the public aware that a pharmacist may not be present in person. If a campaign is not undertaken, then the government is taking advantage of the public’s obedience and naivity. The only member of staff in a pharmacy who can give medical advice is the pharmacist. The only member of staff who is trained to understand medicine is the pharmacist.

    Q. Are there any other exceptional circumstances that you think should be considered?

    A: A festival does not make sense. The main feature of a pharmacy occurring within a festival would be to provide emergency medical or first aid treatment. Anybody in an emergency situation will blatantly head towards the pharmacy. If the pharmacist is not present, then this could produce a dire health and safety situation.

    To permit a pharmacist to be responsible for more than one pharmacy at the same time, there will need to be compliance with exceptional circumstances and certain specified conditions.


    Q. Do you think the regulations should specify all or only some of the proposed conditions? What are your reasons for putting these forward?

    A :The regulations should not specify what situation, only that the situation must be an emergency answerable to the regulators. Situations in community pharmacy cannot be categorised.

    SUPERVISION BY THE RESPONSIBLE PHARMACIST IN A PHARMACY WHERE S/HE IS NOT THE RESPONSIBLE PHARMACIST: Chapter 8

    The Government is seeking views on possible conditions supporting a responsible pharmacist’s ability to supervising activities in another pharmacy where s/he is not the responsible pharmacist. Eg, such conditions (in addition to conditions set for the pharmacist’s absence) might include that one or both pharmacies should employ certain staff (eg a registered pharmacy technician) and that both pharmacies have the same owner

    Q. What are your views on conditions supporting supervision by a responsible pharmacist in a pharmacy where s/he is not the responsible pharmacist and the possible conditions set out in chapter 8?

    A : A registered pharmacy technician does not differ in capability to a non-registered pharmacy technician. Technicians do not undertake pre-registration training. Technicians do not undertake examinations. Technicians cannot give medical advice as they are not medically trained. A pharmacist cannot supervise a pharmacy if they are not in a position to intervene. In the current state, technicians may or may not volunteer the pharmacist an opportunity to intervene when the pharmacist is on the premises. If the pharmacist is not on the premises, this will create a dire health and safety issue. The pharmacist must be able to intervene at their own will, not when prompted. Otherwise supervision will also have to be re-defined. Technicians may be in a situation where they feel obliged to give medical advice. This should not be encouraged as technicians do not have medical training.

    Q. Are there other conditions that you feel need to be specified in the regulations?

    A : The pharmacist should be on the pharmacy premises to supervise where they are not the responsible pharmacist.

    Q. If you do not agree this approach, what do you propose instead?

    A: I propose that a pharmacist can only supervise if on the premises.
    The Responsible Pharmacist

    Comment


    • #3
      Re: Responsible Pharmacist response part 1

      Nice response Wooly.

      I assume that with the work that you've put in you'll be submitting this and good on ya!

      I would love more pharmacists to follow your example

      All the best
      Linnear MRPharmS

      Foetal Alcohol Spectrum Disorder: The biggest cause of brain damage and 100% preventable.

      In pregnancy: 1 fag is not safe, 1 x-ray is not safe and 1 drink is not safe.



      For handy pharmacy links try
      pharmacistance.co.uk

      If you like my posts or letters in the journal try my books!
      eloquent-e-tales

      Comment


      • #4
        Re: Responsible Pharmacist response part 1

        cheers mate, forgot to add that if an rp must return with reasonable promptness, this discriminates against the many physically disabled pharmacists. Hows about that for a spanner in the works!

        Comment


        • #5
          Re: Responsible Pharmacist response part 1

          I like it!
          Linnear MRPharmS

          Foetal Alcohol Spectrum Disorder: The biggest cause of brain damage and 100% preventable.

          In pregnancy: 1 fag is not safe, 1 x-ray is not safe and 1 drink is not safe.



          For handy pharmacy links try
          pharmacistance.co.uk

          If you like my posts or letters in the journal try my books!
          eloquent-e-tales

          Comment


          • #6
            Re: Responsible Pharmacist response part 1

            i think this is an excellent response. and all pharmacists should take a few pointers from here and spit them out to their area managers/societies/MPs etc when the need arises...

            also be sure to PETITION against these proposals on the official petition vs the prime minister on the following link:

            Petition to: stop any legislation allowing a responsible pharmacist to be absent from the pharmacy, or to be responsible for more than one pharmacy in any circumstance.

            Comment


            • #7
              Re: Responsible Pharmacist response part 1

              What's the update on this responsible pharmacist issue?

              I read in a PJ a while ago that the time a pharmacist can be absent isn't indefinite. A time limit will be imposed - is this true?

              Comment


              • #8
                Re: Responsible Pharmacist response part 1

                At the mo we're still waiting on the fallout from the consultation.

                As for time the pharmacist can be away, that's down to the decision makers before/after* they've read all the responses.

                *Please delete as you see fit with regard to how the DH works
                Linnear MRPharmS

                Foetal Alcohol Spectrum Disorder: The biggest cause of brain damage and 100% preventable.

                In pregnancy: 1 fag is not safe, 1 x-ray is not safe and 1 drink is not safe.



                For handy pharmacy links try
                pharmacistance.co.uk

                If you like my posts or letters in the journal try my books!
                eloquent-e-tales

                Comment

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