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  • Not a board response but

    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:
    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

  • #2
    Re: Not a board response but part 2

    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.
    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


    • #3
      Re: Not a board response but

      Thanks to admin for the email. Looks great to me

      Comment


      • #4
        Re: Not a board response but

        Originally posted by Web Ferret View Post
        Thanks to admin for the email. Looks great to me
        Would be even better if he'd included the tag line at the end about opinions.

        I'll however be making my own response.

        Jeff

        Comment


        • #5
          Re: Not a board response but

          Was going to ask what you meant Jeff, then the penny dropped!
          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: Not a board response but

            Having had a presentation by Steve Lutener I have added an intro paragraph stating that discussing the RP without knowing how the Supervision consultation is going to go is very difficult as we do not know what the RP will be responsible for.

            Have added that not being able to give out Rxs that have been checked while the pharmacist is absent is ludicrous

            And following discussion with an ex pres of the RPSGB I have cut and paste the paragraphs to fit the questions in the consultation.


            I have 61 people signed up at the mo. This is more than I expected but not as many as I had hoped.

            If you feel you can get behind my response please let me know ASAP.


            TIA

            (Thanks in aniticipation - I'm not having a stroke!)
            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


            • #7
              Re: Not a board response but

              Absolutely fab response
              DO you need my full name and registration number ?
              If so pls istruct as to what to do , if no details are required please count me in

              Thanks for all the hard work Linear...it couldn't have been easy....pat on the back...well done!
              Kemzo the pharmacist forumly known as kemzero

              Comment


              • #8
                Re: Not a board response but

                Thanks Kem!

                It was a slog but I feel that it has been worth it. I've got 63 names up to now plus several people that were stirred up by my response to write their own.
                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


                • #9
                  Re: Not a board response but

                  me too.
                  johnep

                  Comment

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