In its response to the draft Pharmacy Order 2009 consultation the NPA's major concerns relate to:

- regulation of pharmacy premises
- membership of the Council
- use of post-nominals
- temporary registration in emergencies
- proposals for differential fees.

Membership of the Council

The NPA considers that at least two places should be reserved on the General Pharmaceutical Council for community pharmacists, with one reserved for a hospital pharmacist.

Given the General Pharmaceutical Council's role in setting standards for the education and training necessary for registration, it would also be appropriate for a reserved place for a pharmacist with expertise in this field.

We also note that the reserved places for England, Scotland and Wales may be held by lay members of the Council, and are concerned that the Council may therefore lack insight into the changing practices of pharmacy across the UK.

The Inspectorate

By effectively regulating the practitioners, the GPhC will be able to maintain high quality practice without the need to regulate the pharmacy premises. We believe that regulation of pharmacy practice, coupled with incentives within service level agreements between PCTs and contractors, and ultimately patient choice, engender an upwards dynamic of quality. Minimum standards, on the other hand, can have the effect of maintaining standards at a minimum level. Consequently we do not support the introduction of standards for premises, noting that many of the areas for standards outlined in the order are for issues already considered by PCTs as part of their contract monitoring.

The General Pharmaceutical Council's role in relation to premises, therefore, can be restricted to the keeping of a register, detailing where persons may lawfully carry on a retail pharmacy business and sell or supply medicines not on the general sales list.

The NPA is also concerned that there should be clear separation between the roles of regulators and contracting bodies. The role of the contracting body (eg, PCT in England) is to secure services and monitor the delivery of contractual obligations. The role of the regulator is to verify that minimum standards of practice are met. These are clearly distinct roles, and there should not be duplication between the activities of the regulator and the local contracting body.

Post-nominals

The NPA proposes that, in the interests of public safety, registered pharmacists should be able to identify themselves to the public and other health care professionals by the use of a set of post-nominals. These post-nominals should be awarded by the General Pharmaceutical Council to its registrants.

Temporary registration with regard to emergencies

Whilst the NPA accepts that the registrar should be able to register very recently retired pharmacists, some non-practising pharmacists and some pre-registration trainees nearing the end of their training on the practising register, we do not agree that the registrar should have the power to register other groups as pharmacists.

Statutory committees

The NPA does express concern at the loss of the health committee. A caring profession should ensure that, whilst ensuring public protection, practitioners whose performance is impaired through ill health receive support and understanding, rather than being subject to the full weight of the disciplinary mechanisms. A non-statutory committee would be an acceptable alternative.

Improvement notices, fees and superintendents

The NPA believes that minimum periods for complying with an improvement notice should be increased. The proposal for differential fees for inspection needs careful consideration, it would be completely unacceptable if those who offer clinical services are penalised for their innovation. We do not believe that there is any justification for imposing additional requirements on superintendent pharmacists

The NPA has, in addition, signed up to a joint response with other community pharmacy bodies submitted separately, covering in greater detail concerns about GPhC powers in relation to pharmacy premises.

National Pharmacy Association