More responses please
From Miss P. R. Sejpal, MRPharmS
The close of two current consultations that the Royal Pharmaceutical Society is running is fast approaching and I urge all pharmacists to take part and voice their opinions (PJ, 17 January 2009, pS1).
We are currently seeking their views on the responsible pharmacist (RP) standards and the changes to the positions of authority standards. Although a number of pharmacists have responded concerning the RP standards, we have not received as many responses about the positions of authority standards.
Those who work in registered premises and are the appointed RP will have to comply with the RP standards: we need to know if this strikes the right balance. If RPs were absent from the pharmacy, should they have to record their reason for absence?
Also, those who own a pharmacy, are superintendents, are area managers or who will be RPs with managerial responsibilities should tell us whether we have made the right changes to our positions of authority standards.
Both consultations close on 6 March 2009 and are available online
Priya Sejpal
Head of Professional Ethics
Royal Pharmaceutical Society
Opportunity to reduce pharmacy costs
From Dr T. P. Learoyd, MRPharmS
In response to the Pharmacists’ Defence Association’s stance on the repercussions of the responsible pharmacist agenda, I would like to support the assumption that Mark Koziol has made regarding how large retail pharmacy chains see new supervisory legislation (PJ, 7 March 2009, p239).
In my opinion, large retail pharmacy chains will indeed see the flexibility in remote supervisory legislation as an opportunity to reduce pharmacy costs rather than an opportunity to increase turnover by employing pharmacists as clinicians.
Recent research focusing on enhanced pharmaceutical services at my institution has shown the inability of pharmacies to contract from primary care organisations.
How is the absence of a pharmacist from a pharmacy — not solely from dispensing activities — going to improve our dreadful record in this area? How can we expect a bright clinical future for pharmacy if we are to reduce the availability of pharmacists at the frontline of primary care?
If the Royal Pharmaceutical Society is to achieve the clinical vision it has set the profession, I suggest that it does more to protect the profession it represents from legislation that will loosen its position at the public health interface.
Tristan Learoyd
Council Election Candidate
Locum’s responsibilities
From Mr H. S. Badwal, MRPharmS
Under the new Department of Health guidance on the Medicines (Pharmacies) (Responsible Pharmacist) Regulations, a locum pharmacist would be responsible for ensuring the “safe and effective running of a business”.
I can see why this stance benefits multiple chains. Already, pharmacists do not require rest breaks, time to eat and the support of adequately trained staff.
Some superintendent pharmacists might be reading this thinking that they should not have to take the flack if a locum or employed pharmacist is non-compliant, but in a profession where increasingly big companies are the owners, it feels like they are abandoning their duty to make sure their pharmacies are complying with the rules.
It is not fair that someone who has no say in the running of a business can take the blame if things go bad without it being the responsible pharmacist’s (RP) fault. I cannot see the justification of having superintendent pharmacists if the RP is accountable. It is contradictory and this lack of clarity will be dangerous.
If locums started shutting pharmacies that did not live up to their high expectations, they would find themselves out of favour with managers who might not understand professional requirements since only those responsible tend to care about such matters.
Perhaps, if we learn one thing from the bankers it is that we need the people at the top to be accountable and that regulation is the key to ensuring things do not go wrong in the first place.
Hopefully, the new regulatory body will inspect more pharmacies and ensure they are suitable and compliant before it starts removing locum pharmacists from the Register for not bringing a qualified dispenser with them to work.
I would urge all employed pharmacists, especially those working for supermarkets, to invest in their own private insurance because it seems the next time a pharmacist gets to work and has someone from “home and leisure” as his or her healthcare assistant, he or she is the responsible pharmacist and is ultimately responsible for the safe and effective running of the business.
It certainly will not be the duty manager, who just wants to see that the name badge on your uniform is straight.
Hardeep Badwal
Derby
Ill-considered piece of legislation
From Mr P. Gornall, MRPharmS
I write to voice my concerns at the new responsible pharmacist regulations. In my view, the legislation will simply give some companies a licence to abdicate their professional responsibilities. It is to be the individual employee or locum pharmacist who will be under the obligation to ensure the “safe and effective running of the pharmacy” when he or she is on duty.
The company’s superintendent pharmacist is rather nebulously charged with the duty to be professionally accountable for the pharmaceutical aspects of the business and to have responsibility to set overarching standards and policies. A duty, I think, so vague as to be practically meaningless when set against the precise and demanding obligations placed on the individual pharmacist.
The Royal Pharmaceutical Society’s “Responsible pharmacist toolkit” (PJ, 2 May 2009, p519) sets out a scenario that will be all too familiar to many pharmacists: “On arrival, you find the pharmacy in chaos and a number of pharmacy staff have phoned in sick … the situation is of such concern your first decision may be whether to open the pharmacy or not”. This places the pharmacist in an unenviable and unfair position.
How is the risk to be quantified? Perhaps the locum has never worked in the pharmacy before. If he or she is brave enough to close for the sake of public safety, it is likely that there will be severe criticism from the public he or she is trying to protect.
Also, it is likely that he or she will come under fire from the store or area manager. Is the pharmacist going to be paid to turn up and make such a decision? What is the likelihood of securing any future bookings?
I would suggest that those who are brave enough to make such a decision are soon going to find themselves out of work.
I imagine that the vast majority of pharmacists faced with assessing such a situation will make the reluctant decision to “soldier on”. What now when an error occurs? The company will simply point the finger and say “it’s the pharmacist’s fault. The pharmacy shouldn’t have been opened if it wasn’t safe”.
In my many years as a pharmacist and also as a clinical negligence lawyer, I have not come across a piece of legislation so ill-considered, so impractical and so likely to be ineffective.
This legislation will simply put the burden of responsibility for operational matters firmly on the shoulders of the individual pharmacist while, at the same time, absolving the company from any sort of liability whether it is criminal, civil or professional. It is a retrograde step both in terms of public safety and in corporate responsibility.
Therefore, I repeat my call in an earlier letter (PJ, 25 April 2009, p480) for legally enforceable regulations to ensure adequate staffing levels dependent on prescription volume and other services provided, adequate breaks for all pharmacists and staff, and sensible maximum working shifts.
The above list should be a legal requirement and failure to meet these standards to be punishable with a fine for the company involved.
Let us place responsibility where power lies and protect the public from those who see pharmacy as a cash cow to be milked for maximum profit, regardless of safety.
Paul Gornall
Locum Pharmacist
Preston
Funding allowance for a second pharmacist
From Mr N. Shah, MRPharmS
One of the aims of the responsible pharmacist regulations is to provide pharmacists more freedom to carry out an increasing range of services.
However, I believe the regulations may undermine the safe and effective running of the pharmacy even with staff training and robust pharmacy procedures. Therefore, a second pharmacist is necessary because he or she can ensure that the day-to-day running of the pharmacy is not compromised.
I think the Pharmaceutical Services Negotiating Committee and the National Pharmacy Association should lobby the Department of Health for an allowance for funding a second pharmacist, perhaps based on the level of services provided.
Nitin Shah
Fulham Pharmacy Ltd
London
Standard English?
From Mr R. R. Benington, MRPharmS
My “Responsible pharmacist toolkit” fell open to reveal a glossy colour notice declaring me by name (singular) to be the responsible pharmacist and the additional information that “Their (plural) registration number is …”.
What is wrong with the tried-and-tested non-gender-specific “Registration number …”?
I think most pharmacists are robust enough to accept this slightly less cuddly form, particularly since it has the advantage of not proclaiming a collective inability to express ourselves in standard English.
R. R. Benington
Nottingham
Grammatical error
From Mr F. T. Segal, MRPharmS
On receiving my “Responsible pharmacist toolkit”, I saw that the personalised notice, which I am obliged to display to the public whenever I find myself in that position, contains a grammatical error.
In my case, it says “The responsible pharmacist is Mr Frederick Toby Segal. Their registration number is: 52797”.
I was taught at elementary school that the word “their” is a plural possessive pronoun. I am just one person, so its use is incorrect.
Perhaps the erroneous pronoun be omitted altogether or the word “their” could be substituted with the word “the”.
I believe the cards should be reprinted correctly, or do I have to use Tippex to cover the last two letters of the word “their”?
Frederick Segal
London
An earlier and higher authority
From Mr A. Kershaw
In response to two of your correspondents (PJ, 16 May 2009, p584) who object to the use of the word “their” as a non-gender possessive pronoun in the responsible pharmacist notice, which came with the “Responsible pharmacist toolkit”, I would like to point out that the grammatical conventions they cling to were set (by male grammarians) in the 18th century.
I prefer an earlier — and higher — authority: if William Shakespeare found it acceptable to write “God grant everyone their heart’s desire”, then the word is fine by me and certainly far better than the clumsy “his or her”.
Also, do not tell me that the word “everyone” is, in effect, plural because it is always used with a singular verb.
We can agree to differ, of course. However, if that is the worst fault anyone can find with the “Responsible pharmacist toolkit”, then its authors must have done a pretty good job.
Alan Kershaw
Lay Member of Council
Royal Pharmaceutical Society
Unworkable RP regs for Locums
It is alright for Alan Kershaw to pontificate on the RP sign, as a lay member of council, he does not have to make the whole concept work! Who on earth allowed this unworkable nonsense to become law? How am I to be responsible for things that are beyond my control such as staffing and staff competence? surely this is the responsibility of the contractor?
I have done the Society feedback on the RP package and have asked, as a locum, when do I do all of the 'trolly dolly' flight checks, when all locums know, most staff arrive at 5 minutes before opening and there will already be people waiting in the doorway with prescriptions?
If I am a locum at a 'new to me' pharmacy as the locum for that day, and I have never worked there before, can he please tell me, how he and other council members expect me to sign on as RP and do the little check list? Do I keep people waiting while I plough through all the SOPs and checklist? Who in council put this to the Department of Health to allow it to be passed into law? It is unworkable nonsense that is not in the least bit practical. I have asked the society for support and guidance on this issue, I am still waiting. Not the attitude I would expect from a group that wishes me to join them with my own money (as a self-employed locum) they want to offer me professional support and leadership they say!, well I have asked for this, over a week ago! so where is it?!
Astounded by Member of Council
Ownership without responsibility
From Mr N. M. Cameron, MRPharmS
The responsible pharmacist regulations are pointless from the perspective of a locum. Having worked for large companies, I have seen what ineptly run businesses can be like. The staff levels are usually too low and there are persistent problems with staff being transferred to other branches.
Until the minimum number of trained staff that are required to dispense a given number of prescriptions in a given period is stipulated, the responsible pharmacist is in a difficult position.
For example, the position of a locum arriving at a pharmacy and waiting outside with the drug addicts for the staff to arrive with the key is not good. Then, the dispenser turns out to have only worked in the branch for three days, two weeks before and the shop assistant does not arrive for work until late morning.
Many large multiple pharmacies are run solely by locums so it is not appropriate for the area manager to transfer experienced staff to a different branch or to leave the locum alone in the pharmacy while a shop assistant comes by bus from a branch that can spare him or her.
I believe that the concept of pharmacies run by locum pharmacists with variable, random staff shared over several branches has rather large implications for patient care. These proposed regulations will only encourage this.
Ownership without responsibility is a flawed concept.
Neville Cameron
Coromandel, New Zealand