GPhC correspondence Feb 2016 – April 2016

Related posts to this page:


Registered Homeopathic Pharmacies Can Sell Anti-vaccine Books (initial concerns)

Pharmacies can sell anti-vaccine books (initial GPhC response).

What Sort of Anti-vaccine Books do Homeopathic Pharmacies Sell? (a look at one of the books after the second GPhC response)

Letter to GPhC after my initial complaint was not taken further February 2016

I am writing to express my dismay at the decision not to refer the complaints about homeopathic pharmacies selling anti-vaccine books to the investigating committee (your refs G-CM1509-028 and G-CM1509-029).

My central concern is that the letter refers to 3 clearly written professional standards. These are:

4.3 Explain the options available to patients and the public, including the risks and benefits, to help them make informed decisions. Make sure the information you give is impartial, relevant and up to date

6.2 Not abuse your professional position or exploit the vulnerability or lack of knowledge of others

6.4 Be accurate and impartial when you teach and when you provide or publish information. Do not mislead or make claims that you have no evidence for or cannot justify

The anti-vaccine books concerned are not up-to-date, impartial, or relevant to modern healthcare practice (4.3), they are openly sold on a registered pharmacy’s website which gives them credibility (6.2 – exploiting vulnerability or lack of knowledge of others), and they are misleading about the harms and benefits of vaccines (6.4).

Selling this information from a pharmacy is equivalent to endorsement of them in the context of a pharmacy premises. A bookseller may be able shelter behind the principle of free speech (quite rightly), but a pharmacist’s professional standards mean that selling material that is misleading, inaccurate, and which presents an impartial view, is clearly wrong.

The decision shows startling lack of insight into the dangers that anti-vaccine views pose to children in the UK. After the MMR vaccination hoax started by Andrew Wakefield and propagated by the media, vaccination levels have failed to hit herd immunity levels, leading to outbreaks of disease. Pharmacists have a clear public health duty not to propagate misleading and false information about vaccines in this context.

Here are the four points you put in your letter.

GPhC points

To take your points in order.

  1. The assumption that a potential customer has consented to having misleading information sold to them is merely an assumption, and does not bear any relation to the professional standards referred to previously in this letter. The onus is on the pharmacist to act professionally in all circumstances, there are no caveats in the standards suggesting that pharmacists may breach the standards on the basis of an assumed consent (based on clicks on a webpage!) to supply misleading biased information.
  2. The customer profile is irrelevant to the fact that the pharmacist continues to sell material in breech of the professional standards. There is no qualifier in standard 6.4. Presumably providing misleading information about a normal prescription drug to a fellow professional would also be a concern about fitness to practice. Further to that, homeopathic practitioners are known to be vaccine skeptical, and that is a public health danger. For qualified pharmacists to sell books that would re-enforce this dangerous activity by homeopathic practitioners is unprofessional. What you present as an excuse is actually further evidence that pharmacists should not breech your own professional standard.
  3. Point 3 is irrelevant. The pharmacist is still selling misleading biased information. The fact they do so provides no confidence that any advice given to members of the public or training is any better than their decision to sell these books.
  4. Again irrelevant. The GPhC presumably takes a pro-active stance on inspecting pharmacies if they find unsafe ways of working, even if no patient harm has occurred. In this case, the harm may be hard to ascertain, as the pharmacist is removed from the poor practice of homeopathic practitioners who take the books’ advice to heart. The professional standards are not based on outcomes, but behavior. And the sale of these books (an outcome in of itself one could argue) is clear evidence that the standards have been breeched, regardless of whether complaints have been received. Of course, I find it bizarre that my complaint is being discounted on the basis of no complaints being received from members of the public. Although I am a pharmacist, this should not negate my complaint, since I am also a “member of the public”.

I would ask that you review this decision.

Instead of focusing on the key issue of whether these texts offered for sale are suitable for sale by a registered pharmacy, decision makers have instead focused on reasons, or excuses, which allow the pharmacies concerned to “pass the buck” onto the customer or homeopathic practitioner.

This suggests that the GPhC feel that the pharmacies and pharmacists concerned can abrogate their clear professional responsibilities set out in the GPhC’s professional standards to provide truthful accurate information. This is a disappointment.

Does the GPhC feel that the sale of misleading inaccurate anti-vaccine books to the general public is ‘Upholding standards and public trust in pharmacy’? That is the central question to be answered.

If the GPhC feels it cannot act to regulate the sale of such materials from registered pharmacy premises, I will seek to take this this further.

Response from GPhC 7th of April.

GPhC Response Part 1 April 2016

GPhC Response Part 2 April 2016