PSNI consultation on indicative sanctions guidance

The PDA responded to the PSNI (Pharmaceutical Society of Northern Ireland)’s consultation on new Indicative Sanctions Guidance for its Statutory Committee. The Statutory Committee considers and adjudicates on serious Fitness to Practise allegations made against pharmacists in Northern Ireland.

Wed 7th November 2018 The PDA

Commenting on the launch of the public consultation, Mark Neale, PSNI Head of Public Affairs, said: “The Indicative Sanctions Guidance seeks to support consistent, proportionate and fair decision making which reflects current case law and best regulatory practice.”

Overall, we are supportive of the guidance as we feel it takes a generally balanced approach insofar as it relates to indicative sanctions for individual registered pharmacists. However, we submitted a number of recommendations on how the guidance can be improved.

PDA recommendations included:

  • Whilst the document does set out its stated purpose clearly, it should be revised to include an equal amount of information about the approach to be taken to pharmacy owners for breaches of pharmacy premises standards as it contains about individual pharmacist registrants. This should include details of the investigation process, the available sanction(s), the factors for Statutory Committees to take in to account when considering applying them and the process to be followed.
  • The guidance should include a requirement that the PSNI must ensure it has the resources to ensure cases are dealt with both thoroughly and expediently. Expediency is important both to complainants and pharmacists; it limits the potential for adverse effects of being subjected to protracted proceedings with uncertainty of outcome.
  • The list of potential mitigating factors must include poor working environments or poor premises standards in the pharmacy as a result of the actions of an employer, and other factors that are outside the control of the pharmacist.

Download the PDA’s full response document here

thumbnail of PSNI Indicative Sanctions FINAL




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For more information about the draft Indicative Sanctions Guidance, click here.

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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