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Royal Pharmaceutical Society of Great Britain - Student Registration
Consultation: Response
Part 1: Your details
Name:
Dr Robert Dewdney
Address:
Welsh School of Pharmacy, Redwood Building, Cardiff University,
King Edward VII Avenue, Cardiff CF10 3NB
Affiliation:
Secretary to Council of University Heads of Pharmacy (CUHOP)
I am completing this response on behalf of the Council of University
Heads of Pharmacy (CUHOP)
Part 2: Questions and your responses
Q1 On the basis of the risk presented to patients by MPharm pharmacist
students, should they be registered with the Society (or successor
regulatory body)?
Possibly. See response to Q4.
Q2 On the basis of the risk presented to patients by pre-registration
pharmacist students, should they be registered with the Society
(or successor regulatory body)?
Possibly. See response to Q4. Also, the RPSGB or the GPhC needs
to recognise that it has a moral duty to see that pharmacy students
and potential pharmacy students with declared health or conduct
problems can know whether or not they will ultimately be able to
register as a pharmacist.
Q3 On the basis of the risk presented to patients by pharmacy technician
students, should they be registered with the Society (or successor
regulatory body)?
CUHOP has no strong locus in the training of pharmacy technicians
and therefore has no comment to make other than that the same broad
principles might apply to the two groups of pharmacy students; student
pharmacists and student pharmacy technicians.
Q4 What relationship should students have with a future professional
body for pharmacy? (Please respond either about all three categories
of student or particular categories.)
The present situation is unsatisfactory. RPSGB declines to provide
advice to students or schools of pharmacy about the fitness to practise
of students with health or conduct problems. This can leave students
in the position of potentially wasting their time studying or continuing
to study for a qualification that they will not be able to follow
through to professional registration. The present situation also
has the potential for exposing patients and other vulnerable people
to risk. Without student registration or a clear fitness to practise
framework operated by the regulator, a school of pharmacy may choose
or be required by its parent university to admit to or retain a
'problem' student on a pharmacy programme. Pharmacy programmes increasingly
involve contact with patients and the public, in pursuit of the
goal of developing students with the capabilities of rounded practitioners.
It should be added that risk for patients and the public can come
not just from direct contact with students but can also come from
student access to personal information or access to medicinal products
to be used by patients.
We see benefit in the earliest possible national guidance to encourage
or mesh with local arrangements, pending a possible national system
to deal with student fitness to practise issues. CUHOP intends to
produce such guidance at least for schools of pharmacy by January,
2008.
RPSGB (GPhC) may be inclined with respect to undergraduate students
to see responsibility for the exclusion, or restrictions upon, pharmacy
students rest with individual university fitness to practise committees.
RPSGB (GPhC) needs to be aware that there is uncertainty in the
higher education sector as to the legitimate remit and powers of
such committees. Students have significant rights in law and under
university statutes and the balance of these rights against any
move for exclusion on the grounds of potential harm to patients
or the public is we believe uncertain and untested in the courts.
The foregoing is not a prelude to a conclusion that RPSGB (GPhC)
should move to student registration, although that conclusion is
not excluded. A possible way ahead would be for there to be put
in place a national fitness to practise committee for pharmacy students,
with referrals to the committee by schools of pharmacy, pharmacy
employers or preregistration tutors. Schools of pharmacy would be
in a strong position - though still not certain - to be able to
implement the directions of such a 'detached' national committee
within their parent universities. CUHOP would be pleased to work
with RPSGB (GPhC) to bring to fruition such a system or indeed whatever
proportionate system RPSGB (GPhC) decides to bring forward.
It is interesting to note that the General Optical Council with
UK Optometry Schools have introduced student registration, apparently
successfully. The model they have is much as we would envisage if
pharmacy went for student registration; students being required
to register and remain in registration to be able to join and remain
on a programme of undergraduate study leading to an Optometry degree
and also being required to be in registration to progress through
preregistration training.
What to do with this response
Send to the Royal Pharmaceutical Society of Great Britain by 9
November 2007
By email: studentregistrationconsultation@rpsgb.org
By post
John Sloan
Education Projects Policy Manager
Education & Registration
Royal Pharmaceutical Society of Great Britain
1 Lambeth High Street
London SE1 7JN
United Kingdom
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