At their January Council meeting, the General Pharmaceutical Council (GPhC) discussed draft premises standards with the intention that they go out to consultation shortly. This Blog looks at the potential impact of these standards on pre-registration training. These standards can be found at:


We had hoped that this document may have had something to say about standards required for pre-registration training premises and were disappointed to find only one specific mention of pre-registration in Principle 5, which says in its compliance indicators that:
You identify the equipment and facilities needed to provide safe and effective services, taking into account for example the presence of a pre-registration pharmacist.

It would seem there is some work to do around how the premises standards will fit with both the GPhC standards for the initial education and training for pharmacists (http://www.pharmacyregulation.org/initial-training
and the GPhC standards of conduct, ethics and performance (http://www.pharmacyregulation.org/standards) to shape pre-registration training.  

But there is cause for optimism:
  • These standards will go out for consultation;
  • Some of the themes in the document are good and can be adapted for the governance of training.
One of the main messages in the draft premises standards is the development of competent and caring professionals for safe and effective service delivery and this is where the GPhC will target regulation.
 
They see an enhanced role for registrants, but that professionals will work to their own standards.   The “no one size fits all” approach to regulation is a recurrent thought throughout the document.  Professionals should be able to make decisions in the best interests of their patients.  Individuals will make their own judgements, informed by their professionalism and with reference to standards and guidance.

Colleagues and other healthcare professionals also have a role in supporting the individual and offering constructive advice.

Some responsibilities appear to be devolved to business owners and managers and employers, e.g. setting rules and providing investment in buildings and equipment.  This is then expanded to say that management structures should show who has clear responsibilities for which aspects of safe and effective practice.   

The draft standards also state that rules should not get in the way of safe and responsible innovation.
 
It’s about what you do, rather than what (procedures) you write.  This is a change from how premises are currently regulated.  Exactly what sort of evidence an inspector will look at before, during or after an inspection is likely to form one of the consultation questions.

Principle 1 emphasises the need for regular review and monitoring of services and guidance suggests this can in part be achieved through listening to feedback from staff and public.  This can be carried across into the area of pre-registration training. That the GPhC will look at feedback from tutors and trainees about the pre-registration experience is a recurrent theme in the regulator’s other work e.g. in the education and training standards.  The later section in the draft premises standards on securing compliance and enforcement develops this and says that inspectors will focus on such feedback and prioritise the premises they inspect according to where they see risk.  Premises with good reports won’t require or receive much of their attention.

Principle 2 mentions that there should be enough suitably qualified staff for the safe and effective provision of services, that there is a culture of openness, honesty and “no blame” and that staff understand their roles and responsibilities. Standard 2.1 asks that staff are working under the supervision of another person whilst they are in training.  All of these requirements can be applied to pre-registration training and this is expanded in the guidance underpinning Principle 2:
  • Staff have access to the training they need and have any approved training their duties require
  • You identify the essential elements of training for each role and have evidence that staff have done the training 
  • You review the progress and performance of staff, particularly trainees, for example through appraisal, and give honest and constructive feedback 
  • All staff understand that healthcare professionals who provide services for the pharmacy have their own legal and professional obligations 
  • You consider the number of staff and the skill mix that are needed for the safe and effective provision of pharmacy services, communicate this to staff and take reasonable steps to deal with any of their concerns
  • You encourage and consider the feedback or views of staff about the provision of pharmacy services
  • Staff report and record mistakes and near misses and learn from them.
Principle 3 states that the size, design and layout of the premises should be suitable for the services provided and that the volume of work and work flow through the dispensary are considered and then procedures developed to reduce risk. This may be used to replace the requirement that training premises require a specific floor space to accommodate a trainee.

Principle 4 is about medicines management but whilst it focuses on aspects such as obtaining, storing and handling medicines, we feel that there is a gap in that clinical safety and dispensing accuracy are not mentioned specifically.

As discussed, principle 5 specifically mentions pre-registration pharmacists saying that equipment and facilities should reflect their presence.  This requirement is developed with an obligation to obtain feedback from staff on the availability and usefulness of these resources.

In summary, the messages from the draft standards are:
  • All levels of professional (from trainee to business owner) must take more individual responsibility and accountability for their practice and think for themselves.
  • Everyone in the team should be clear about their responsibilities.
  • Feedback is important.
We welcome this approach.  Now to develop the skills to do this!