Regulatory approach in challenging circumstances - GPhC and PSNI joint statement

The first concern of registered pharmacy professionals is the care of their patients and people who use health and social care services. It is important they use their professional judgement to assess any risk to the delivery of safe care, informed by any relevant guidance and the values and principles set out in our professional standards.

We recognise that in highly challenging circumstances, professionals may need to depart from established procedures in order to care for patients and their families. Our regulatory standards are designed to be flexible and to provide a framework for decision-making in a wide range of situations.

They support professionals by highlighting the key principles which should be followed, including the need to work cooperatively with colleagues to keep people safe, to practise in line with the best available evidence, to recognise and work within the limits of their competence, and to have appropriate indemnity arrangements relevant to their practice.

Even during highly challenging circumstances professionals quite rightly want to meet the legal requirements that apply. This includes the duty on the responsible pharmacist to secure the safe and effective running of the pharmacy in relation to the retail sale and supply of all medicines. We recognise there may be situations where the responsible pharmacist unavoidably has to leave the pharmacy at short notice part-way through the day, (e.g. if they are unwell and need to self-isolate).

Where no locum cover can be secured at the pharmacy, and recognising the potential effects of the current pandemic, it would be in the patient’s best interest for medicines already dispensed to be supplied from the pharmacy rather than not supplied at all, even though this may not be in strict accordance with the law as normally understood.

The pharmacy regulators will support pharmacy professionals in the front line making this judgement in patients’ best interests. In such circumstances we would expect there to be access to a pharmacist by phone or video link to provide direction for the remaining staff in the pharmacy. 

Such an approach should only be adopted for a short time period, where other options have been exhausted. Except in such exceptional circumstances, even in the current pandemic situation, arrangements must be made for a pharmacist to be at the pharmacy, including to undertake the responsible pharmacist role and supervise the sale and supply of POM and P medicines.

We will continue to regulate by taking into account the context of the individual pharmacy and any relevant information about resource, guidelines or protocols in place at the time, including those relating to pandemics.

Duncan Rudkin
Chief Executive and Registrar
General Pharmaceutical Council  

Trevor Patterson
Chief Executive
Pharmaceutical Society of Northern Ireland