Ask a C+D Senator: Clearing up RP confusion

With regards to David Reissner’s advice: "My advice would be to get a member of staff to put the RP's name in the RP record, as there is no requirement for the RP to fill in the register personally." In my opinion, this is plain wrong. The latest edition of the MEP (July 2011, page 88) states specifically from the GPhC guidance for the responsible pharmacist "3.2 Personally make the entries in the pharmacy record". Although this is not specifically mentioned in the Responsible Pharmacist Regulations, the fact that it is from the GPhC's own interpretation and has been republished in a document generally accepted as being a compendium of good practice should indicate that any deviation should be made only in exceptional circumstances, should be fully justified and should not be a matter of normal practice.

Hi Tariq,

I put your concerns to Mr Reissner, and he has offered this clarification:

"The GPhC's view is, of course, entitled to respect but, as Appendix 6 of the MEP makes clear, the document does not give legal advice. In my view, the GPhC's guidance goes too far. The word "personally" does not appear in the Medicines Act and the courts have held in relation to other sections in the Medicines Act that when someone is required to act in a particular way, they can use an agent to act on their behalf.
"Perhaps this is something to be considered when the Royal Pharmaceutical Society conducts its review of the RP law. Unless the Medicines Act is changed, the question may one day have to be resolved by the courts. "

Jennifer Richardson, C+D Deputy & Features Editor