Sometimes I do arithmetic in my head or on paper. Sometimes, I use a calculator. Sometimes I write notes with a pen. Sometimes, I touch-type, as I am doing now.
Those thoughts went through my head when I read the General Pharmaceutical Council’s draft Standards for Superintendent Pharmacists and draft Standards for Responsible Pharmacists.
It launched a consultation on the draft Standards last December, but the consultation seems to have received surprisingly little attention, despite the potentially far-reaching effect of the proposed Standards.
If the Standards are adopted in their draft form, they will not only distinguish between the respective roles of Superintendents and Responsible Pharmacists, but they will introduce a considerable level of detail into how those roles should be carried out.
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For me, the draft Standards strike a particularly jarring note when it comes to the use of technology. The proposed Standard 1 for Superintendent Pharmacists is: “Provide strategic and professional leadership”. This seems unobjectionable. However, to meet this Standard, the draft says that Superintendents must (amongst other things):
“Make use of research, technology and innovation to enhance safety and improve services, taking into account the needs and available resources of the pharmacy.”
When it comes to technology, what does this requirement mean? In particular:
- Why “must”?
- What “technology”?
- How are “available resources” to be assessed?
The draft Standards go on to give examples of how to meet Standard 1, but do not answer any of these questions.
I do not see why Superintendents cannot use their judgement in deciding whether and when to use a calculator rather than doing simple arithmetic on a notepad or in their heads.
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Is the GPhC proposing that Superintendents must use AI? If so, what programme and for what purpose(s)? If a Superintendent decides that the needs and resources of a pharmacy do not justify installing a dispensing robot or an automated prescription collection locker, is the GPhC entitled to second-guess that decision?
Elasticated ethics
I raise these questions because the draft Standards for Responsible Pharmacists treat the use of technology completely differently.
Standard 1 of the draft Standards for Responsible Pharmacists is: “Prioritise patient safety”. No one could argue with that.
This is followed by five bullet points, listing things that Responsible Pharmacists must do. Using available technology is not among them. This is followed by examples of how Responsible Pharmacists can meet Standard 1. Among the examples, you will find:
“Embrace research, technology and innovation to enhance safety and improve services.”
So Superintendent Pharmacists must use technology, but Responsible Pharmacists are not required to. They can embrace if they want to in order to meet Standard 1. Why is there a difference?
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Unlike the draft Standards for Superintendent Pharmacists, the draft Standards for Responsible Pharmacists even include an example of the technology they can use. Among the examples of things Responsible Pharmacists can do to meet Standard 1, the draft Standards suggest:
“Use interventions such as … barcode scanning technology to ensure medication safety.”
Before the General Pharmaceutical Council was created in 2010, the pharmacy regulator had been the Royal Pharmaceutical Society of Great Britain which published a Code of Ethics.
This went into considerable detail about how pharmacies should be run and what pharmacists could and could not do. I remember someone saying (I wish it had been me) that the Code of Ethics was only elastic in the sense that it kept getting longer.
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When the General Pharmaceutical Council succeeded the Royal Pharmaceutical Society as the regulator, I remember its approach was that it would set the standards for pharmacy practice, but it would leave pharmacies and pharmacists to decide for themselves how to meet those standards. Sixteen years later, it seems to me that the approach of the General Pharmaceutical Council is becoming more prescriptive.
I can’t pretend that the General Pharmaceutical Council’s consultation paper with the draft Standards is a light read, but it is an important document that all pharmacy owners, Superintendents and would-be Superintendents and Responsible Pharmacists should read and consider responding to.
The consultation is open until 25 March 2026. I hope that when responses to the consultation are considered, the General Pharmaceutical Council will review and clarify what the Standards say about the use of technology.
David Reissner is chair of the Pharmacy Law & Ethics Association