The recent tragic case of Alison Stamps is another example of the wider issue of workplace morale and stress in the Pharmacy profession, which is a safety issue both for pharmacists and their patients. It was one of my disappointments, as a member of the Royal Pharmaceutical Society’s English National Board, to see a failure of all pharmacy organisations to effectively grapple with this issue in a meaningful way. Meetings were held, platitudes were spoken, but no substantial action was taken. Sometimes concerns about target culture were dismissed as pharmacists who did not wish to engage with changing professional roles, rather than as substantial concerns about the way metrics could be mis-used by poor management structures.
It is pleasing to see that concern has reached Parliament about this issue. We must do better.
This is the sort of book they were selling (several were for sale).
Pharmacies in the UK are regulated by the General Pharmaceutical Council (GPhC), they exist to ‘protect, promote and maintain the health, safety and wellbeing of members of the public by upholding standards and public trust in pharmacy.’ The GPhC has stated in 2011 that they would continue to monitor the situation in one pharmacy after the selling of homeopathic malaria prevention treatments: ‘the information gathered as part of the (recent Newsnight) investigation including the original complaint may be taken into account if we receive any further complaints about the pharmacy professional in the future.’
I was therefore hopeful that action, or at the very least an investigation, might happen when I complained to the GPhC about the two registered pharmacy premises who were selling the books, and additionally I noted that a homeopathic preparation (pertussin homeopathic remedy) that could be used as a homeopathic vaccine was being sold by one.
Despite being pretty much an absolutist on free speech, I feel this is appropriate. That is, I do not have a problem with the publication or selling of anti-vaccine literature from bookshops, my only concern is that registered healthcare professionals are supplying this material from registered premises.
I have received a prompt response from the GPhC this morning to my complaint. They have not investigated my complaint, but have looked at whether it sits in their area of jurisdiction.
The response raises a number of issues for me since it dropped through the postbox this morning:
1. How can someone be fit to practice as a pharmacist (which includes knowledge) and knowingly sell an anti-vaccination book?
2. Is selling an anti-vaccine book from a pharmacy purely a commercial matter? I might agree if I had complained about hair dryers or cameras. Does the pharmacy regulator not have a role in public health? Remember they exist to ‘protect, promote and maintain the health, safety and wellbeing of members of the public’. Does this mean anything if pharmacists can sell anti-vaccine books? Can they sell cigarettes on this basis too?
3. There is a hole in regulation. Selling anti-vaccine books, and selling homeopathic remedies that are suggested in those books is tantamount to putting an indication on the remedy.
4. There is no evidence that a registrant is acting outside of their competency. Isn’t a pharmacist in control of a registered premises? If so, isn’t the fact the book is on sale evidence they are dangerously ill-informed, and a threat to public health?
5. There is no evidence they holding themselves to be anti-vaccine specialists. I am not sure that is important. I was not making the accusation they are anti-vaccine specialists in my complaint, but implying their are vaccine ignorant. Selling anti-vaccine books shows a startling lack of knowledge of immunity, the science of vaccination and public health. How is that compatible with professional registration as a pharmacist?
I’m not a fundamentalist on homeopathy, I can see how differing health beliefs of patients might lead them to use such products, despite the lack of plausible mechanisms, and evidence for their effectiveness. I also have some issues on how pharmacists are targeted as suppliers of homeopathy by skeptics, when they may well be employees with little to no control over stock in their store (unlike their superintendent pharmacists). However, in this case it seems clear-cut to me that products dangerous to public health are on sale from a registered pharmacy, which is under the control of a pharmacist.
And there is apparently nothing to be done about it.
NOTE: A big thanks to eagle-eyed Rob who spotted this material in the first place
Ainsworths homeopathic pharmacy (purveyors of blank pills by royal appointment) stocks some… *interesting* books http://t.co/J636tipLkJ
The GPhC have noticed this post and treated it as a complaint, and combined it with a review of my initial complaint. A Fitness to Practise investigation into these concerns has been initiated, an apology was issued about the initial letter’s inaccuracies, and the GPhC are identifying improvements that can be made to the initial assessment of concerns. They have promised to keep me updated about progress on the investigation. This is reassuring news.
No drug is safer without regulation and that includes nicotine. Licensed e-cigarettes used as part of pharmacists’ smoking cessation role would be a step forward. Concern at the meeting that e-cigarettes were becoming an “easy fix” was supported by suggestions that smoking cessation services were not being renewed on the basis that e-cigarettes had solved the problem. Pharmacists need to defend the added value of those services and ensure e-cigarettes are an option when we have a licensed product.
In the meantime, we cannot support the sale of unlicensed e-cigarettes in pharmacies. This places pharmacists in a difficult position of selling an essentially recreational product with no licensed medicinal claim. There is potential for variation in dosing with unlicensed e-cigarettes, without the regulatory oversight of quality and safety the MHRA provides.
The risks to patients from unregulated herbal preparations means a scheme that reduces the risk of adulteration carries a public health benefit, even in the absence of known efficacy. Differing licensing requirements for prescribed drugs and herbal products do not reflect dual standards of evidence; a herbal product licence is an admission that the product has no proved efficacy.
The surge in the use of ecigs has taken the health sector, including professional bodies, the pharmaceutical industry and regulators, by surprise. It’s a fascinating rise of a novel new delivery system, which has happened outside of the normal regulatory process.
This post isn’t about the evidence as to whether ecigs are harmful, whether they are a gateway to smoking, or whether they are an effective form of smoking cessation therapy (in future, they may have a role, but that should be after normal scientific evaluation and regulatory processes), but about the issues of professional autonomy they raise for pharmacists, and whether they are a good test case for exerting that autonomy.
Health, safety and well-being of patients must be the first concern of pharmacy owners and superintendent pharmacists (as it is for pharmacy staff)
Pharmacy staff should be empowered to exercise their professional judgement in the best interest of patients and public
They point out ecigs are unlicensed and have limited scientific evidence
They say they do not support their use as smoking cessation aids and that they should not be presented as having any therapeutic value
The response from companies who have decided to stock ecigs is interesting. Boots have agreed with concerns, suggesting that their decision to spend two years developing a ecig offering with a company is a responsible way forward. They hope to be the first to get a licensed preparation. Before that happens, Boots seem happy to sell an unlicenced product with no proven therapeutic value. Lloyds has said it is not selling ecigs as nicotine replacement therapy. Which begs the question what are they selling them for? None of this counters the concerns of chief pharmacists about the suitability for ecigs as a product pharmacy sells. At best, it is mitigation for a wrong decision to stock an unlicensed ecig in the first place.
Individual pharmacists are faced with the fact that their companies, and their superintendent pharmacists, are happy to stock a product that is:
They should ask themselves if they are equally happy about this (and some may be).
They could of course, just ignore the ecigs and follow the advice that they tell patients they are not a smoking cessation aid. That still leaves them in the position of supplying a product they might not have personally stocked in the first place.
It is arguable that if acting as the responsible pharmacist within a pharmacy you could make a good case for removing any ecigs from display within the registered pharmacy premises on the grounds of maintaining the health, safety and well-being of patients. Certainly, you have the GPhC, the RPS, the MHRA, and all the Chief Pharmacists to support your stance. The fact that the superintendent of the company has a different opinion, does not invalidate your own professional judgement. In reality, it isn’t that simple. There may be local pressure from non-pharmacist managers who do not feel it is the place of pharmacists to make this decision – after all they have material from head office saying this is a perfectly OK product. The pharmacist may be putting themselves in a difficult position in terms of future performance reviews. It would be nice if superintendent pharmacists actually issued a statement that such action would be permissible, that the professional autonomy of individual pharmacists on stocking such products was key and that no detriment would come to pharmacists who made this professional judgment.
“What we have to ask ourselves is whether, when there are pressures [and] mistakes, as inevitably there will be, can we have confidence that the registrant might be able to stand up and not ‘buckle’?”
Should it always be down to individual pharmacists having to exert their professional independence in a battle of wills? Is that the best we can do? Hope people don’t “buckle” when they are under immense work pressures? Is it time for regulators to regulate the industry in a manner that reduces the toxicity of this commercial environment, and help create a more supportive environment for individual acts of professionalism? Of course individuals need to take responsibility, but it is naive to think that the environment they practice in has no influence. Recent NHS scandals note both the role of individuals and the culture of organisations. Could the GPhC exert more control over superintendents? Could they make it clear that employee pharmacists should have the professional autonomy as individual pharmacy owners to remove items from sale they feel are incompatible with the best interests of patients and the public? Ecigs make a great test case for what actual control pharmacists over the materials they provide to the public, just as GPs have control over what they prescribe to the public.
And from there we might make some other steps forward on OTC medicines and homeopathy….