Hereunder please find the views of the Council of University Heads
of Pharmacy (CUHOP) on the draft Order.
The membership of CUHOP comprises the heads of UK schools of pharmacy
which enrol students to read for a Master of Pharmacy (MPharm) degree
with the expectation of registering with the Royal Pharmaceutical
Society of Great Britain (RPSGB) and registering as a pharmacist
in this country. The objectives of CUHOP are, to
CUHOP has evolved from and replaces the former UK Committee of
Heads of Schools of Pharmacy.
With respect to the draft Order, all CUHOP members were provided
with the consultation paper and invited to submit in advance or
bring to a full meeting of CUHOP on 15th June their comments. There
was lengthy discussion of the draft Order and the comments upon
it at the meeting and agreement formally to submit the set of responses
that now follows. The responses are to the 22 consultation questions.
|
Question
|
Response
|
| Q1.
Have you identified any significant elements of the Pharmacy
Act 1954 which are not reflected in the draft Pharmacists and
Pharmacy Technicians Order? |
No. |
| Q2.
Do you think the change of name of the register from the
Register of Pharmaceutical Chemists to the Register of Pharmacists
is helpful? Can you suggest a more suitable name for the register? |
Proposal
supported. |
| Q3.
Do you support the proposal to establish a statutory Register
of Pharmacy Technicians for England and Wales to be maintained
by the Royal Pharmaceutical Society of Great Britain? Can you
suggest a more suitable arrangement for the statutory regulation
of pharmacy technicians? |
Proposal
supported. |
| Q4.
Do you think it is helpful for the Society's registers to be
divided into two parts to distinguish between practising and
non-practising pharmacists or pharmacy technicians? Is there
any further division of the registers which might be appropriate? |
We
feel the proposal to be logical but worry about a certain lack
of clarity with respect to the status of pharmacists not involved
in patient care and more importantly, about no obvious means
of protection of patient safety if/when pharmacists change their
sector of practice, e.g. from industrial to community pharmacy. |
| Q5.
Do you agree that it is desirable that those who are recognised
as practising pharmacists or pharmacy technicians should be
required regularly to demonstrate they are keeping up to date
with developments? Can you suggest other, or more suitable,
continuing obligations for registrants than the ones already
set out in the draft Order? |
We
strongly support this proposal in principle. The lack of clarity
in the definition of 'practising' mentioned in our response
to Q.4 makes for some lack of clarity as to whether pharmacists
in academia and industry are to be included or excluded from
this measure (see also our response to next question).
We
assert that the CPD required of pharmacists should be relevant,
proportionate and should constitute real achievement of learning.
If it is not, then inevitably pharmacists not needing to be
registered as such for their work will quit their membership
of the RPSGB, more than would otherwise be the case.
|
| Q.6
Do you consider the definition of practising contained in
the draft Order adequate? If not, how would you suggest that
the definition might be improved? |
There
is a variety of opinion within CUHOP as to whether the definition
of 'practising' in the draft Order encompasses pharmacists and
technicians in academia and industry and in other sectors or
niches of pharmacy where there is no direct contact with patients
or possibly even with other health professionals. The definition
seems to suggest that the RPSGB has purview over all pharmacists/technicians
that are employed because of their 'professional status' rather
than just those pharmacists who are responsible for the supervision
of the sale and supply of P and POM medicines but this is far
from clear. |
| Q.7
Do you agree that the proposal to endorse registration certificates
with the part of the register on which the registrant is entered
provides an element of added public protection? Bearing in mind
the penalty/sanctions contained in articles 20 (for pharmacists)
and 29 (for pharmacy technicians) of the draft Order, do you
agree that public protection considerations are adequately addressed
and that the administrative convenience and expense arguments
are justified? |
CUHOP
has no strong objections to the proposal in principle but has
serious concerns that this approach might be expensive for no
great benefit and that other approaches - issue of an individualised
annual membership card or referral of enquirers to online Register(s)
- might be just as or more effective at lower cost. |
| Q.8
Do you consider that electronic versions of the pharmacists'
and pharmacy technicians' lists which can be updated continuously
are better than an annually published paper list? Can you suggest
any other more accessible and economic way in which the lists
could be presented? |
Proposal
strongly supported. Online Register(s) are far preferable to
printed versions. As we have indicated in response to Q.7, they
can do away with the need for endorsement of registration certificates. |
| Q.9
Do you support the proposals for the collection of additional
information by the Registrar contained in the draft Order? Do
you think there is any other information which the Registrar
could usefully collect as part of the registration process? |
CUHOP
regards these proposals as reasonable so long as collection
of information is proportionate.
We
have some reservations about the need and processes for record-keeping
about personal indemnity cover of academic and industrial
pharmacists. Personal indemnity insurance is not presently
regarded as necessary for workers in the UK pharmaceutical
industry and higher education sectors. Indemnity cover could
be an unnecessary cost upon these pharmacists and could heighten
the possibility of their leaving the profession.
|
| Q.10
Do you think the link between registration as a pharmacist and
membership of the Society should be removed from the draft Order? |
There
is a case for the separation of registration and membership;
clearly separating the statutory work of the Society from those
of a professional body that maintains the interests and standing
of pharmacy. . It is desirable in this regard to have sight
of and reflect on the outcome of the Foster Review of non-medical
professional regulation before coming to a conclusion.
While
some CUHOP members accept the RPSGB's position that there
should be no change in this regard, a clear majority of CUHOP
members is for the separation of registration and membership.
There appear to be two main reasons for this, first, the combination
of the two always sees regulatory imperatives taking precedence
over professional leadership and advocacy; the RPSGB is not
regarded as dynamic or strongly visible in its lesser role
(this is not good for the profession and in the longer term
not good for patients and the public because the profession
does not develop as it might otherwise). The second reason
is that with membership of RPSGB corresponding with registration,
there is no possibility of taking into membership eminent
pharmaceutical scientists and other health professionals with
a strong involvement in pharmacy, people who could contribute
to the advancement of the profession in the public interest.
|
| Q.11
Do you think an express legislative reference to consideration
of attitudes and behaviours as part of the process of determining
whether an applicant is "appropriately qualified"
would be helpful? How would you consider these attitudes and
behaviours could best be assessed? |
CUHOP
agrees with this proposal in principle. It does though wonder
how well attitudes and behaviours can be defined and particularly
how they can be validly, consistently and fairly assessed, judged
by us to be very difficult for the RPSGB or schools of pharmacy
to do. Furthermore, CUHOP has significant reservations stemming
from worries about possible conflicts with principles (and to
some degree legal rights) of freedom of opinion and expression,
including, for pharmacists in higher education, rights of academic
freedom. |
| Q.12
Do you agree that the emphasis in the draft Order on ensuring
that a registrant's fitness to practise remains unimpaired strengthens
the public protection function of the Society? Can you suggest
a more effective way of fulfilling this objective? |
CUHOP
agrees with this emphasis but with reference back to the response
to Q.11., in respect of the cautions in respect of matters to
do with attitudes and behaviours. |
| Q.13
Do you support the proposal to extend the powers of the Society
to collect information from other people related to the fitness
to practise of its registrants? Are there any further powers
you feel the Society should have in respect of fitness to practise
issues? |
Among
CUHOP members, this proposal was agreed or attracted no comment. |
| Q.14
Do you think that reference to a court in these circumstances
is the most appropriate approach? Do you agree that 14 days
is an appropriate time limit to trigger action? |
Among
CUHOP members, this proposal was agreed or attracted no comment |
| Q.15
Do you support the proposal to extend the powers of the Society
to share information on a registrant's fitness to practise where
they feel it is in the public interest to do so? If not, how
else might public interest and protection considerations be
satisfactorily addressed? |
CUHOP
agrees with this proposal but asserts that sharing of such information
must only be in strictly defined circumstances related directly
to the protection of the public. |
| Q.16
Apart from the criteria proposed in article 48 of the draft
Order, can you suggest any other grounds on which a registrant's
fitness to practise may be adjudged to be impaired? |
CUHOP
has no comment or suggestion |
| Q.17
Do you support the proposal that the Registrar should be
able to refer cases directly to the Health Committee or Disciplinary
Committee and ask the committee to consider the issue of an
interim order where circumstances dictate the need for such
action? |
CUHOP
agrees that in certain cases the Registrar should be able to
so refer. |
| Q.18
Do you support the proposal to replace the current Statutory
Committee with the group of new statutory committees? Do you
think the right titles have been selected for the new committees?
Do you think there is a need for any further statutory committees
and, if so, what are your reasons for thinking this? |
CUHOP
is generally supportive of reform of the longstanding present
system but has major reservations about the proposed number
and complexity of committees. The system is set to be overly
bureaucratic and expensive in operation. If this number and
pattern of committees is to be introduced, clarity of their
roles and responsibilities will be essential. |
| Q.19
Do you support the proposal to make the Education Committee
one of the Society's statutory committees? Do you agree that
this will clarify the previous uncertainty about the precise
derivation of the Society's education powers |
The
Society's education powers should not be permitted to be excessive,
rather CUHOP would welcome the Society as a partner or critical
friend in dealing with pharmacist education in higher education.
The new Education Committee should allow for rapid developments
in the teaching of pharmaceutical science and practice at both
undergraduate and postgraduate levels. The Committee should
draw heavily on the expertise within academia in order to improve
Society strategy and activity in this area.
Relevance
and quality demands upon pharmacy education providers that
are not accredited for the running of an undergraduate programme
should be just as rigorous as demands upon those that are.
|
| Q.20
Do you agree that the functions proposed for the Continuing
Professional Development Committee are appropriate? Can you
suggest any other functions that the CPD Committee might reasonably
fulfil? |
Among
CUHOP members there is a variety of views. Some wonder if there
is a need for a separate statutory committee to deal with CPD;
CPD might be dealt with by a subcommittee of the Education Committee.
At the very least they are looking for clarity in the distinction
of its remit from that of the proposed Education, Disciplinary,
Investigation and Registration Appeals committees. |
| Q.21
Do you think that the proposal to have a Registration Appeals
Committee is sensible? Do you think it will provide a more efficient
route to resolving most appeals or slow down the whole process
of securing a just resolution of outstanding registration issues? |
There
is support for this proposal from within CUHOP but there is
also a worry that herein lies the potential for additional bureaucracy
within the RSPGB and that the Registration Appeals Committee
might develop as another step towards the courts rather than
as a means of avoiding the courts, slowing down the resolution
of cases. |
| Q.22
Is there anything else about the contents of the draft Order
on which you would specifically like to comment? |
The
draft Order brings the possibility, some within CUHOP believe
the probability, that the RPSGB will seek to inspect and accredit
postgraduate degrees. CUHOP would make the point that UK pharmacy
schools have a strong record of working with employers to construct
postgraduate programmes. The managed sector (NHS) has given
considerable thought to how education and training should be
delivered in the future to support both general and advanced
practice. This has led to a programme of educational reform
which places a clear focus on work-based training and individual
competence. Educational governance issues are an integral component
of such approaches and informed by Quality Assurance Agency
procedures. We would recommend that the RPSGB adopts a watching
brief on this process and does not impose an alternative, accreditation
approach.
On
the matter of pharmacy undergraduate education and preregistration
training, possibly the ideal model for students' preparation
for practice would be some integrated form of the two; more
closely intertwined even than in a traditional sandwich programme
(although even that has some significant advantages). Unfortunately,
and this is not a matter that the Order can address, the infrastructure
for this is simply not present within (or across) the higher
education and health sectors. CUHOP will be investigating
this possible model for prequalification education and training
over the coming months and years.
|
If any of the above is unclear or you or colleagues would welcome
expansion on one or more points, please do not hesitate to contact
me or the CUHOP secretary, Dr Robert Dewdney, at the Welsh School
of Pharmacy, Cardiff University.