Pharmacy Forum NI has submitted a response to the Pharmaceutical Society of Northern Ireland’s consultation on its draft guidance for safe staffing levels in registered premises.

The Forum had previously submitted a response to a pre-consultation process during the summer of 2022.

The draft guidance fulfils the Forum’s preference for a principles-based approach, and acts primarily as a collation of relevant clauses of existing documents – primarily the Premises Standards (2018), and the Professional Standards of Conduct, Ethics and Performance for Pharmacists in Northern Ireland (the Code) – into one document.

We have offered some feedback, namely:

  • The Premises Standards (2018) are yet to be commenced, and the Code is currently under review – meaning both the main foundational documents for this guidance may potentially change before or shortly after it comes into effect;
  • There needs to be more clarity around how the duties under this guidance apply both to registered and unregistered staff – and we have recommended a diagram to illustrate who is responsible, who is accountable, who needs to be consulted, and who needs to be informed;
  • How much the patient/general public would be able to understand the current draft of the guidance, and the potential need for an explanatory note to clarify how the guidance protects them;
  • That more clarity and flexibility needs to be built in in order to understand how to evidence good practice – both in general compliance with the guidance, and more specifically regarding the requirement to understand the learning and development needs of all staff.

We look forward to the Society’s response to this consultation process.