The CCA has responded to the GPhC’s consultation on draft rules and standards for Responsible Pharmacists, and draft standards for Superintendent Pharmacists.
The Company Chemists’ Association (CCA) supports the overall intent of the General Pharmaceutical Council’s proposals to clarify accountability in community pharmacy, including how new legislation relating to pharmacy supervision is implemented.
However, the draft rules and standards require further refinement to ensure they are proportionate, practicable. The proposed rules and standards are not aligned with how pharmacy services are currently delivered, particularly across businesses operating multiple pharmacy premises. They need to better maintain clear separation between the strategic governance role of Superintendent Pharmacists and the operational accountability of Responsible Pharmacists, while avoiding unnecessary bureaucracy that does not demonstrably improve patient safety.
The additional bureaucracy and restrictions proposed in these rules and standards risks disrupting service continuity. The GPhC should consider how existing practice, which utilises advances in technology, established governance frameworks and professional judgement, can continue to evolve whilst maintaining safe pharmacy services.
We are also concerned that aspects of the proposed authorisation annex and premises standards risk duplicating existing professional obligations, blurring accountability, and undermining the enabling intent of the legislation. We look forward to working closely with the GPhC and the Royal Pharmaceutical Society to further develop these proposals.