PDA respond to DHSC’s dispensing errors and organisational governance consultation

The DHSC consulted from 19 June 2018 until 11 September 2018 on changes to the way registered pharmacies operate.

Wed 19th September 2018 The PDA

Examples include permitting the GPhC and PSNI to bring about:

  • Remote pharmacist responsibility for pharmacies (leading to remote supervision)
  • Pharmacists being the Responsible Pharmacist for more than one pharmacy
  • Making pharmacists responsible for following SOPs set by a superintendent, removing their power to write, set and maintain SOPs themselves

At the same time, the DHSC were consulting on extending the legal defences to prosecutions for inadvertent dispensing errors under section 63 or 64 of the Medicines Act 1968, to hospital pharmacists and pharmacists working in other areas of practice such as in care homes.

In its response, the PDA stated its opposition to remote supervision. The PDA also opposed any changes which would allow the pharmacy regulators to bring about remote pharmacist responsibility for pharmacies. See previous news item here.

Below are a few recommendations highlighted in the PDA’s response document:

  • Standard setting should be driven by professional leadership bodies, in pharmacy’s case the Royal Pharmaceutical Society and the Pharmacy Forum of Northern Ireland.
  • The rebalancing board’s approach should be changed to make it representative of the pharmacy profession, by ensuring organisations such as the PDA (the largest pharmacist membership organisation in the UK), and the NPA – the independent contractor’s organisation – are represented on the board.
  • The rebalancing board ought to seek the introduction of guidance for state prosecutors, prompting local police forces to work to a programme where any offences related to inadvertent dispensing errors where gross negligence manslaughter has been excluded are referred to the regulator and are not subjected to criminal prosecution. At the same time, the board should conduct a broader review of medicines legislation with a view to removing the threat of criminal sanction for inadvertent dispensing errors as far as possible [GL1] as per the DHSC policy objective. It is fully understood that the prospect of gross negligence manslaughter prosecutions, and prosecution for crimes against the person (e.g. where harm occurs) cannot be removed.

Download the PDA’s complete response document here

thumbnail of DHSC Pharmacy Errors Organisational Governance FINAL 11-09-2018



thumbnail of consultation-document thumbnail of 19 June 2018 – Q&A for S60 Orders Consultation – Dispensing Errors and RPSP



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thumbnail of draft-order-2-responsible-pharmacist-superintendent-pharmacist thumbnail of draft-order-1-preparation-and-dispensing-errors

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The Pharmacists' Defence Association is an appointed representative in respect of insurance mediation activities only of
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and is authorised and regulated by the Financial Conduct Authority (Register No 307063)

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