Annex F: Consultation response form
Health Care and Associated Professions: Setting standards – proposals for
consultation
Please fill in and/or tick the appropriate response. Completed forms should be sent to
info@chre.org.uk
Name East Sussex Local Pharmaceutical Committee
Contact address 2 Nevill Ave, Hampden Park, Eastbourne
Postcode BN22 9PT
Contact telephone 07770 430186
Email vanessam.taylor@btopenworld.com
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Scotland
X England
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If you are responding as a health or social care professional, please supply the
following details:
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East Sussex Local Pharmaceutical Committee represents all pharmacy
contractors in three PCTs – Hastings and Roher, East Sussex Downs and
Weald and Brighton and Hove City.
Consultation questions
DRAFT STANDARDS – GENERAL PRINCIPLES
Question 1
Do you agree that overall the standards adequately reflect an outcome and
patient focussed, broad and flexible approach?
X Agree
Disagree
Unsure
Comments: It is important that the GPhC works in tandem with other bodies
that have an inspectorate role, to reduce the regulatory burden on
pharmacists and pharmacies.
Following the consultation process and agreement of the Standards it will be
very important that the standards are clearly communicated to all
stakeholders and pharmacists
Question 2
Do you agree with the use and definition of the term ‘patients and public’?
Agree
Disagree
X Unsure
Comments The South East Forum is confused between the terms “patient”
which refers to “a person receiving care or treatment from a health
professional.” We feel that the term health professional should be more clearly
defined. “Patients and public” seems to relate specifically to pharmacist and
pharmacy technicians, this seems anomalous.
Question 3
The GPhC is committed to embedding Equality and Diversity at the heart of
everything it does. Do you think that the draft standards support this
commitment?
Agree
Disagree
X Unsure
Comments With regards to equality and diversity we feel that this should be
taken in to account when dealing with individual pharmacists as well as
patients and the public
ANNEX A - DRAFT STANDARDS - OWNERS AND SUPERINTENDENT
PHARMACISTS
Question 4
Do you think that the draft standards for owners of pharmacies and
superintendent pharmacists are proportionate to the benefit they bring and
the risk they are guarding against?
Agree
X Disagree
Unsure
Comments The SE Forum is unclear as to what relevance standards on both
record keeping and waste management have as far as the GPhC is
concerned.
Question 5
Should there be specific standards for the systems in place within
registered pharmacies to control and prevent healthcare related infections?
Agree
X Disagree
Unsure
Comments Patients and he public use community pharmacies as the first port
of call, in great numbers and not just for pharmacy services and products. We
appreciate the importance of infection control but feel that in a pharmacy the
risks are outweighed by the benefits of not imposing an infection control
regime on community pharmacies. We also do not understand how infection
control measures could sensibly be applied.
Question 6
There is no explicit prohibition on owners of pharmacies and
superintendent pharmacists offering pharmacy medicines for self –
selection. Instead there is a general requirement that ‘systems are in place
to ensure the safe supply of medicines to patients and the public, in a
manner that promotes their safe and effective use and appropriateness’.
Do you agree with this approach?
X Agree
Disagree
Unsure
Comments Although we agree with this it should not mean abdication of
responsibility by owners, pharmacy superintendents or pharmacists. We
would respectfully suggest that the paragraph is misleading. Pharmacists are
indeed responsible and a requirement should be made to ensure that a
pharmacist is on the registered premises at all times to discharge their
responsibilities.
ANNEX B - DRAFT STANDARDS - CONDUCT, ETHICS and
PERFORMANCE
Question 7
Do you think that the draft code of conduct, ethics and performance
adequately applies to registered pharmacists and pharmacy technicians in all
sectors of practice?
Agree
X Disagree
Unsure
Comments We are concerned that Conduct and ethics do not have any
outcome measures, however performance certainly does have outcomes.
This needs to be explained fully in the guidance.
Question 8
Do you agree that there should be provision within the Code which allows
personal beliefs of registrants to prevent them from providing a particular
professional service? (subject to ensuring that patients and the public are
referred to alternative providers of the service they require)?
Agree
X Disagree
Unsure
Comments If a registered pharmacist or pharmacy technician agrees to work
in registered premises when services are provided then they should provide
the services. Of course individuals should have a choice, but that choice
should be not to work where the service is provided that goes against their
personal beliefs
ANNEX C - DRAFT STANDARDS – PROFICIENCY
Question 9
Do you think that the proficiency standards for pharmacists and pharmacy
technicians are sufficient to ensure that they are able to practise safely,
lawfully and effectively?
Agree
Disagree
X Unsure
Comments The question should include the word “registered” before
pharmacists and pharmacy technicians. We agree with the statement as of
today – for the future this may change. We are a little unsure as to why there
is a job description for the role of the pharmacy technician.
Question 10
Do you agree that the standards of proficiency for pharmacy technicians
should require a broader range of knowledge and understanding?
Agree
X Disagree
Unsure
Comments The question should include the word “registered” before
pharmacists and pharmacy technicians. Pharmacy technicians are trained to
be accurate dispensers of medicines. Critical analysis and ethical
considerations are the domain of the pharmacist.
Question 11
Do you agree with the distinctions between the proficiencies of pharmacists
and pharmacy technicians?
Agree
Disagree
X Unsure
Comments The question should include the word “registered” before
pharmacists and pharmacy technicians. We feel this should be defined more
specifically.
ANNEX D - DRAFT STANDARDS - EDUCATION AND TRAINING
Question 12
Do you agree that knowledge programmes for pharmacy technicians
may continue to be delivered outside national frameworks provided that
they have been accredited by the GPhC as delivering equivalent
outcomes?
Agree
X Disagree
Unsure
Comments The question should include the word “registered” pharmacy
technicians. If technicians are to be registered and treated in the same
manner as pharmacists, then logic would dictate that their knowledge
programmes should be delivered within a national framework.
Question 13
Do you agree that pharmacy technicians must be able to apply a general
knowledge of clinical and pharmaceutical science?
Agree
X Disagree
Unsure
Comments The question should include the word “registered” pharmacy
technicians. The clinical and pharmaceutical science knowledge should be
that needed as far as the dispensing process is concerned and should not be
patient facing. Clear guidelines need to be developed to explain this concept.
Question 14
Do you agree that undergraduate education and pre-registration should
be integrated?
X Agree
Disagree
Unsure
Comments This approach is the ideal, however the funding and practicalities
may be stumbling blocks.
Question 15
Do you agree that the standards should be based on an increased
clinical role for pharmacists?
Agree
Disagree
X Unsure
Comments Unless funding is assured for developing the clinical role for
pharmacy the need to have standards that reflect this may be premature
Question 16
Do you agree that delivering these standards will require changes to
assessment at undergraduate level?
Agree
Disagree
X Unsure
Comments Any changes made should be in discussion and should be to meet
the needs of the profession and not the standards
ANNEX E - DRAFT STANDARDS - CONTINUING PROFESSIONAL
DEVELOPMENT
Question 17
Do you agree that together, the standards and framework provide a
comprehensive approach to CPD, in line with the draft Pharmacy Order
requirements?
Agree
X Disagree
Unsure
Comments We agree that CPD standards and a framework need to be put in
place, however we have not reached that stage yet. We would respectfully
suggest that CPD entries should be relevant to the registered pharmacists
and technicians field of practice.
Question 18
Do you agree that registrants, regardless of their scope of practice,
should record some CPD that relates to their ability to practise
according to the GPhC standards of conduct, ethics and
performance?
Agree
X Disagree
Unsure
Comments Scope of practice should be the determining factor with regards to
which CPD to record.
Question 19
Do you agree that there should be a return to practice requirement after
two years out of practice?
X Agree
Disagree
Unsure
Comments We would suggest that consideration should be given to the need
to have continuous but reduced annual practice e.g. to equate to 6hr/month.
Question 20
Do you agree with the proposed return to practice and updating
requirements?
Agree
X Disagree
Unsure
Comments We would suggest that return to practice should be tailored to
meet each returnee’s individual requirements.
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consultation documents then please complete the box below:
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