Deregulation of support staff training and unenforceable guidance – risks to patients

The GPhC consulted from 20 July to 11 October 2017 on proposed guidance for pharmacy owners on creating suitable working environments which enable pharmacy staff to operate safely and effectively. The PDA responded to the consultation, expressing its concerns.

Thu 19th October 2017 The PDA

The GPhC consulted from 20 July to 11 October 2017 on proposed guidance for pharmacy owners on creating suitable working environments which enable pharmacy staff to operate safely and effectively.

It is also proposing to cease setting training requirements and assessing and approving training courses for dispensing and medicines counter assistants. It plans instead to provide guidance for employers on what that training might involve.

The PDA is concerned that this is another misstep by the GPhC in its role protecting the public. The GPhC has not only failed to ensure its expectations are enforceable, but has sent a message that it seemingly regards the matters covered in the guidance – which include expectations in relation to staffing levels, protected time for training and raising concerns – as being of insufficient importance to do so.

According to the GPhC’s own figures, over a two year period from 2015 to 2017, it has issued an average of more than sixty sanctions against registrants every month. In contrast, the findings of a Freedom of Information request, submitted to the GPhC during the course of responding to the consultation, were telling of its approach to the regulation of pharmacy premises and pharmacy owners. Though the GPhC was established in 2010, it has never:

  • Fulfilled its legal obligation to set Standards for Registered Pharmacies in rules (which then have to be laid before parliament)
  • Issued an improvement notice to a pharmacy owner*
  • Brought a fitness to practise case against a registrant for a failure to comply with the Standards for Registered Pharmacies. It confirmed that its focus, as far as individual registrants and standards are concerned, is on the Standards for Pharmacy Professionals
  • Established a category in its fitness to practice database for recording allegations which relate to compliance with the Standards for Registered Pharmacies
  • Disqualified, removed, or sought to disqualify or remove, a pharmacy premises from the register (article 14 of the Pharmacy Order 2010)
  • Sought or obtained a conviction against a pharmacy owner under articles 12 or 14 of the Pharmacy Order 2010 (failing to assist or obstructing an inspector, providing false or misleading information to an inspector, failing to produce a document or record to an inspector when requested to do so or failure to comply with an improvement notice)

* The GPhC has the power to issue improvement notices either for:

  • a failure to meet its Standards for Registered Pharmacies OR
  • a failure to meet the conditions of the pharmacy’s registration
    with the GPhC.

We envisage that the proposed changes to training requirements, if enacted, would lead to a chaotic and inconsistent approach throughout Great Britain as to the quality of training that unregistered support staff have and the transferability of their roles from one pharmacy to another.


The PDA’s consultation response can be downloaded below.

thumbnail of PDA response to GPhC Guidance for a Safe and Effective Pharmacy Team consultation



thumbnail of guidance_to_ensure_a_safe_and_effective_pharmacy_team_june_2018

The Pharmacists' Defence Association is a company limited by guarantee. Registered in England; Company No 4746656.

The Pharmacists' Defence Association is an appointed representative in respect of insurance mediation activities only of
The Pharmacy Insurance Agency Limited which is registered in England and Wales under company number 2591975
and is authorised and regulated by the Financial Conduct Authority (Register No 307063)

The PDA Union is recognised by the Certification Officer as an independent trade union.

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