Regula+e - General Pharmaceutical Council

March 2012 | Issue 4 

Upholding standards and 

public trust in pharmacy 

Inside 

Under the microscope: 

Consultation on fees 6 

Registration assessment 8 

Fitness to practise update 16 

www.pharmacyregulation.org

Contents 

From the chair 2 

Registrant update 

- falsifying prescriptions 3 

- communicating with us 3 

- update on dispensing errors 4 

- planning for the London 

Olympics 4 

Around Great Britain 

- gathering in Scotland 5 

- modernising regulations 

in Wales 5 

Consultation on renewal fees 6 

This year’s registration 

assessment 8 

Recruiting to the 

accreditation panel 10 

Law Commission 

regulation review 11 

Round up on registered 

pharmacies 12 

Letters 16 

Fitness to Practise update 16 

Fitness to Practise 

- determinations 17 

- learning 18 

Regula+e is the registrant bulletin of the 

General Pharmaceutical Council. 

It is sent to all registrants (at the time of 

posting) and pre-registration trainees. At 

times we may approach external 

organisations or individuals to submit an 

article or opinion on a topical issue. All 

articles and letters commissioned, written 

or submitted are subject to editorial control 

and may not be printed in full or with 

reference back to source. 

If you would like to contact the editor or 

submit a letter or comment to Regula+e 

please contact us at: 

regulate@pharmacyregulation.org 

The Editor, Regula+e 

General Pharmaceutical Council 

129 Lambeth Road | London | SE1 7BT 

General Pharmaceutical Council ©2012 

From the chair 

Our consultation on registered 

pharmacies is well underway and it’s 

been heartening to see high levels of 

engagement with these proposals. We 

are only half-way through the 

consultation and already we have 

received 119 responses. 

The national launch provided us with 

the opportunity to talk to the leaders 

of over 20 national organisations and 

to start fleshing out the benefits and 

challenges which these proposals 

present. Participants recognised that 

the proposals represent a big shift from 

detailed standards to an outcomesfocused 

approach, and this generated 

a lot of comment and questions. Our 

first consultation events in Scotland and 

Wales were also well attended and 

raised a number of issues which we 

will think carefully about as we prepare 

our response to the consultation, 

which will be considered at our June 

council meeting. 

We will be attending a number of 

meetings and events to talk about the 

consultation proposals over the next 

few months, and you would be welcome 

to attend. You can find out more on 

page 14. 

We are also consulting on proposals to 

reduce renewal fees by 10 per cent for 

pharmacists and pharmacy technicians 

from 1 October. That consultation ends 

on 8 May, and a decision on any new 

level of fees will be made at our June 

council meeting. Details about that 

consultation are on page 6. 

And the Law Commission has started 

its consultation on the regulation of 

healthcare professionals. This work is 

important for all the regulators, not just 

a new one like the GPhC. We will be 

responding to the consultation and 

encouraging others to do the same. 

There is more on page 11. 

For those trainees seeking to become 

pharmacists, the June registration 

assessment is not far away. This year we 

have increased the number of venues 

and made some changes to the 

registration assessment process. We will 

be sending our spring pre-registration 

bulletin out in April, but have included 

some key points in this edition of 

Regula+e, to help with preparation 

and planning. 

We are also recruiting for new members 

of our Accreditation and Recognition 

Panel, and for the first time, want to 

include pre-registration trainees on our 

panels. You can read more on page 10. 

This edition of Regula+e has arrived with 

the last of the four guidance documents 

we have developed to expand on our 

standards of conduct, ethics and 

performance. This fourth in the series 

covers confidentiality. 

Thanks to those of you who have been in 

touch to tell us what you think of 

Regula+e. Can I encourage you to 

continue to share your thoughts with us 

at regulate@pharmacyregulation.org 

Bob Nicholls 

Chair 


2 Regula+e: March 2012 | Issue 4


Falsifying 

prescriptions 

Recent complaints raised with the GPhC 

by pharmaceutical manufacturers 

indicate that a number of registrants 

may have passed their pharmacy 

account details to third 

parties/wholesalers. 

It has been alleged that these third 

parties are utilising these account details 

to submit orders for medicines to 

pharmaceutical manufacturers, often 

involving the submission of what are 

believed to be altered or falsified 

prescription forms. 

We are currently investigating these 

concerns. The outcomes of these cases 

have not been decided. 

The GPhC’s view is that such action by 

registrants could be viewed as 

inappropriate and/or misleading. 

Registrants should ensure that their 

account details are kept secure and 

are not passed on inappropriately to 

third parties. 

Standard 2.2 of the standards of 

conduct, ethics and performance, says: 

“Make sure that your 

professional judgement is not 

affected by personal or 

organisational interests, 

incentives, targets, or similar 

measures”. 

Communicating 

with us 

It may be necessary for GPhC staff 

to contact pre-registration trainee 

pharmacists from time to time, 

usually as part of an ongoing issue. 

We do this by phone or email. 

It has come to our attention that 

some pre-registration trainees have 

received phone calls from someone 

stating they are from the GPhC and 

trying to gain contact and 

employment information. It is an 

offence to purport to be from a 

regulator if you are not. 

We will always clearly identify 

ourselves and leave a phone 

number and email address (which 

ends in @pharmacyregulation.org). 

If you are not sure that the person 

who has called is who they say they 

are, please phone us for advice. 

You can call us on 020 3365 3400. 

Our new guidance 

Guidance on confidentiality is included with this edition of Regula+e. This is 

the last in our recent series of four pieces of guidance which expand on key 

areas of our standards of conduct, ethics and performance. The other three 

cover consent, maintaining clear sexual boundaries, and raising concerns. 

You can read more at 

http://www.pharmacyregulation.org/standards/guidance 

Guidance 

on patient 

confidentiality 

February 2012 

Guidance 

on patient 

confidentiality 

February 2012 

Upholding standards and public trust in pharmacy 3


Update on 

dispensing 

errors 

A proposed amendment to the Health 

and Social Care Bill seeking a due diligence 

defence in the event of a dispensing error 

was withdrawn as the Bill made its way 

through the final stages of debate in the 

House of Lords. 

Liberal Democrat peer, Lord Tim Clement- 

Jones, had sought an amendment to the 

effect that anyone at risk of prosecution 

under section 67 of the Medicines Act 

would be able to mount a defence that 

they had exercised all due diligence to 

avoid committing such an offence. 

Speaking in the Lords on the withdrawal 

of this amendment, Health Minister in the 

Lords, Lord Howe, said; 

“The Medicines and Healthcare products 

Regulatory Agency (MHRA) intends to 

carry out a review of sanctions and 

penalties in medicines legislation. This will 

extend well beyond issues that have 

arisen in dispensing errors, but the review 

will look at the respective roles of 

medicines legislation and professional 

regulation in this area. 

“The possible role of a due diligence 

defence will remain on the table for 

consideration in the wider context of this 

review. It is worth stressing this point as 

due diligence defences have a well 

established usage in association with strict 

liability offences in many areas of 

legislation, including medicines legislation. 

“This will be a significant and wideranging 

review, and it is important to 

ensure that it covers the right ground. The 

MHRA would aim to scope the coverage, 

conduct and timetable of the review by 

September 2012.” 

Chief Executive and Registrar, 

Duncan Rudkin, said: 

“Our view remains that single dispensing 

errors, without other significant 

aggravating factors, will not amount to a 

fitness to practise concern.” 

Planning for 

the London 

Olympics 

As part of our planning for the 

London Olympics, we have reviewed 

the logistics of holding our fitness to 

practise hearings In London and at 

other locations. We have decided 

that from 26 July to 7 September, 

our hearings will be held at: 

Maple House (first floor) 

150 Corporation Street 

Birmingham B4 6TB 

We will ensure that registrants, 

witnesses, advocates, and others 

affected by this move are made aware 

of this change of location. 

The London Olympics will bring an 

influx of visitors, staff, and athletes to 

Great Britain. Resources to assist with 

planning and business continuity 

include the Royal Pharmaceutical 

Society’s dedicated webpage at 

http://www.rpharms.com/ 

your-day-to-day-practice/pharmacyand-the-olympics.asp 


Around Great Britain 

Gathering in 

Scotland 

We took our consultation on draft 

standards for registered pharmacies to 

one of the largest third sector events in 

the UK – The Gathering held in Glasgow. 

This annual event is in its eighth year 

and attracts 3,000 delegates. 

Our Director for Scotland, Lynsey 

Cleland, and a team from the GPhC, 

took the opportunity to speak with 

people from a broad range of local 

community groups and national 

organisations in Scotland. 

Many of the delegates represent or 

are involved in caring for patients 

who frequently use pharmacy services. 

We encouraged delegates to take 

information about the consultation back 

to their organisations. 

Lynsey said, “Delegates were also very 

interested in finding out more about the 

GPhC and the work we do, and to better 

understand how our work relates to 

their local health communities. In 

particular, about what we are doing, as 

the regulator for Great Britain, to take 

account of the health delivery structure 

and health policies in Scotland. 

“This was also an excellent opportunity 

for us to find out more about the work 

of third sector organisations in Scotland 

and identify ways that we can more 

effectively engage and work with them 

in the future.” 

If you want to discuss this consultation 

or other issues relevant to the GPhC in 

Scotland, you can contact 

lynsey.cleland@pharmacyregulation.org 

Modernising regulations 

in Wales 

The Welsh Government is consulting on changes to the regulations which 

govern the provision of NHS pharmaceutical services in Wales. The consultation 

sets out proposals to amend the process by which applications to provide NHS 

pharmaceutical services are determined. 

Currently, the NHS (Pharmaceutical Services) Regulations 1992 apply. These 

regulations had also applied in England but were revoked and replaced. 

In Wales, a Task and Finish Group reviewed the regulations and made a series 

of recommendations, which form the basis of this consultation. 

The consultation is proposing that the regulations be revoked and replaced in 

Wales with new regulations that consolidate the piecemeal amendments and 

additions that have been made over the years, and ensure consistent use of 

language, definitions and interpretations. 

The consultation also proposes new additions to the regulations, including 

simplifying the process of relocating community pharmacies over short 

distances and introducing procedures for assessing and managing the fitness to 

practices of applicants to the pharmaceutical list, and of existing contractors. 

The deadline for responding to the consultation is 27 April. 

If you want to contact Darren Hughes, the GPhC’s Director for Wales, about 

these Welsh Government proposals or to discuss other issues relevant to the 

GPhC in Wales, contact darren.hughes@pharmacyregulation.org 


Fees 

Consultation 

on reducing 

renewal fees 

The GPhC is proposing a ten per cent reduction in renewal fees for pharmacists and 

pharmacy technicians from 1 October - a reduction of £27 for pharmacists, to £240; 

and of £12 for pharmacy technicians, to £108. 

This proposal is part of a 12-week consultation on fees which ends on 8 May. 

Chief Executive and Registrar, Duncan Rudkin said: 

“As an organisation, we are seeking to work as 

efficiently and effectively as we can while ensuring we 

can fulfil our remit to protect the health and safety of 

patients and the public. 

“We have delivered efficiency gains over the past year 

and have a higher number of registrants than forecast. 

These are some of the factors that have created the 

conditions for a reduction in renewal fees for 

pharmacists and pharmacy technicians.” 


Revalidation 

Other proposals in the fees consultation 

include: 

• the fee for pharmacy premises 

remaining unchanged at £221. This is 

because we are still developing our 

approach to regulating registered 

pharmacies and are not yet in a 

position to establish the future costs 

of this work. 

• continuing to charge a 2 per cent fee 

for credit card payments. That 2 per 

cent represents the typical cost levied 

on us by credit card companies for 

processing these payments. 

In the main renewals period at the 

end of 2012, we paid charges of 

around £74,000 for transactions by 

credit card and recovered around 

£47,000 through the 2 per cent 

charge. Before the introduction of 

that credit card charge, those costs 

were shared across all registrants and 

pharmacy owners, including those 

paying by debit card or annual direct 

debit, or by BACS for premises fees. 

• where a pharmacy professional has 

been removed from the Royal 

Pharmaceutical Society’s register 

following a disciplinary committee 

decision, charge an application fee 

of £413 for a pharmacist or £283 for 

a pharmacy technician to join the 

GPhC register. 

These applications require detailed 

consideration. Last year we 

introduced a higher initial registration 

fee but now want to introduce a 

higher application fee, to reflect the 

additional work involved in processing 

these applications. The total fee for 

joining the register (application fee 

plus registration fee) would be 

unchanged, which means it would 

remain equal to the total payable by a 

registrant who is removed from the 

GPhC’s register following an FtP 

committee decision and who later 

applies to join the register. 

• adjusting the fees for application for 

restoration and restoration itself. 

We currently have a flat fee for 

applications for restoration to the 

register. The restoration fee varies 

according to the original reason for 

removal from the register, and 

whether it applies to a pharmacist, 

pharmacy technician or premises. 

We believe it would be more logical 

to have different application fees 

rather than different restoration 

feeds, as the additional work to 

process certain types of application 

has to be done, whatever the 

outcome. 

The total payable for restoration to 

the register (application fee plus 

restoration fee) would remain 

unchanged. 

For the full list of proposed fees for 

applications for restoration and 

restoration itself, go to: 

http://www.pharmacyregulation.org/ 

sites/default/files/Fees%20rules%20con 

sultation%202012.pdf and look at 

pages 11 to 15. 

The GPhC’s governing council will 

consider the outcomes of the 

consultation at its June meeting and 

make a final decision then on any new 

level of fees. 

We will publicise that decision on our 

website, in the June edition of our 

stakeholder e-bulletin, Upda+e, in our 

July edition of Regula+e, and through 

the pharmacy press. 

Any changes to the level of fees would 

come into force from October 2012. 

To find out more, download the consultation paper or 

fill in the online questionnaire, go to 

www.pharmacyregulation.org/fees-consultation-2012 

If you want to print off and fill in the questionnaire, you can 

send your completed form to: 

Email: 

Address: 

consultations@pharmacyregulation.org 

with the subject “Fees consultation” 

Draft 2012 Fees Rule Consultation Response 

Governance Team, GPhC 

129 Lambeth Road 

London SE1 7BT 

If your answers take up more than the alloted space, 

you can attach extra pages if you wish. 

The deadline for responses is close of business on 

Tuesday 8 May. 


Registration assessment 

June and 

September 

registration 

assessments 

The spring pre-registration bulletin will 

be sent to all pre-registration trainee 

pharmacists in April, setting out details 

of preparing for and sitting the June and 

September assessments. Here are some 

key points. 

June assessment - Friday 29 June 

Deadline for applications to sit that 

assessment is Friday 18 May. 

September assessment - 

Friday 28 September 

Deadline for applications is 

Friday 17 August. 

London Olympic Games 

For anyone taking the assessment in 

London, please take account of the 

Olympic Games, particularly if you are 

arranging travel and/or accommodation. 

While the sittings are either side of the 

Olympic Games, you may need to book 

your travel earlier than originally 

planned or even stay overnight, and 

accommodation may be more heavily 

booked than usual. 

Reference sources 

These two reference sources are 

permitted in the assessment hall for the 

afternoon open book paper only: 

1. British National Formulary, Edition 62 

(September 2011) 

2. GPhC standards of conduct, ethics 

and performance (September 2010) 

What you can bring 

into a venue 

You can store most of your belongings in 

the cloakrooms provided. Once you 

enter the assessment hall, you can only 

bring in the following items. We have 

compiled this list in co operation with 

the British Pharmaceutical Students’ 

Association (BPSA): 

• water and non-fizzy drinks 

• sweets, if you have a cough 

• medications or other items, if you 

have a medical condition 

As well as these, you can have on 

your desk: 

• HB pencil (or softer shade) 

• pencil sharpener 

• pencil eraser 

• specific reference sources – open 

book only 

You cannot bring in anything else, and 

that includes sweets, fruit and fizzy drinks. 

Results 

An online pass-list will be available on 

the GPhC website on: 

Friday 27 July 2012, for the June 2012 

assessment 

Friday 26 October, for the September 

2012 assessment 

Registration assessment results will not 

be given by telephone or email. 

Venues 

There are eight venues for the June 2012 

assessment and two for the September 

resit (see table). 


Registration assessment 

June 2012 

City 

London 

London 

Manchester 

Birmingham 

Cardiff 

Edinburgh 

Leeds/Bradford 

Sunderland 

Venue 

London Hilton Metropole Hotel. This venue 

includes an adjustments room. 

Bishopsgate Institute 

Armitage Centre. 

This venue includes an adjustments room. 

Birmingham Hilton Metropole Hotel 

Motorpoint Arena 

Edinburgh Corn Exchange 

Abundant Life Conference Centre (ALCC), 

Bradford 

CitySpace, University of Sunderland 

How to get there 

Edgware Road tube (2 minute walk) and 

Paddington train station (10 minute walk) 

Liverpool Street tube and train station 

(2 minute walk) 

University of Manchester Armitage site. 

Bus/taxi from centre of Manchester. 

Birmingham International train station and the 

National Exhibition Centre (10 minute walk) 

Cardiff Central train station (5 minute walk) 

Slateford train station on the Edinburgh-Glasgow 

train line (3 minute walk) or bus from the centre 

of Edinburgh 

Bradford Forster Square train station 


‘University’ stop on Newcastle Metro 


September 2012 

City 

London 

Edinburgh 

Venue 

London Hilton Metropole Hotel. This venue 

includes an adjustments room. 

Edinburgh Corn Exchange 

How to get there 

Edgware Road tube (2 minute walk) and 

Paddington train station (10 minute walk) 

Slateford train station on the Edinburgh-Glasgow 

line (3 minute walk) or bus from the centre of 

Edinburgh

Education and accreditation 

We want you! 

During April and May, we will be 

recruiting new members to join our 

Accreditation and Recognition Panel. 

We will advertise these posts in the 

national press. 

We are seeking new accreditors to 

refresh the panel and broaden the 

base of expertise we use. 

We are particularly interested in 

recruiting people from universities who 

work on MPharm degrees and people 

who are involved in pre-registration 

training who also work at universities. 

We want to cover both community and 

hospital pharmacy. 

The GPhC accredits and recognises 

pharmacy courses leading to registration 

and annotation. These are: 

• Master of Pharmacy (MPharm) 

degrees leading to pre-registration 

and then pharmacist registration 

• Overseas Pharmacists' Assessment 

Programmes (OSPAPs) leading to 

pre-registration and then pharmacist 

registration 

• prescribing courses leading to 

pharmacist annotation 

• competency and knowledge-based 

qualifications leading to pharmacy 

technician registration 

The GPhC also accredits pharmacy, 

dispensing and medicines counter 

assistants courses. These are: 

• dispensing or pharmacy assistants 

level 2 courses 

• medicines counter assistant courses 

The accreditation process involves peer 

review, site visits, provider self 

assessment and public reports. 

Recognition relates to national 

qualifications delivered across Great 

Britain. We recognise the quality 

assurance of the awarding bodies, while 

not directly accrediting the specific 

providers. 

For further details contact Joanne 

Martin, Quality Assurance Manager 

(Education) at 

joanne.martin@pharmacyregulation.org 

Pre-registration 

trainees to join 

accreditation 

panel 

We plan to further enhance our 

accreditation process by recruiting preregistration 

trainee pharmacists to join 

the Accreditation and Recognition Panel 

as newly qualified pharmacists. We will 

be advertising shortly, with the aim of 

starting to train these recruits in June. 

Chief Executive and Registrar, Duncan 

Rudkin, said: 

“We are keen to have pre-registration 

trainees involved in our work in this way 

and hope there will be plenty of interest 

in this opportunity. 

“It is important for us to capture, as part 

of our accreditation process, the views 

of people who have recently studied at 

university and been pre-registration 

trainees.” 

We plan to recruit up to six trainees to 

start panel training in June. They will be 

able to start panel work when they 

register with the GPhC and begin work 

as pharmacists. This will require an 

annual commitment of approximately six 

days, including preparation work. 

All accreditors are paid for the work they 

do for us. 

For further details or an informal chat, 

please contact Joanne Martin, Quality 

Assurance Manager (Education) at 

joanne.martin@pharmacyregulation.org 


Being proportionate 

Law 

Commission’s 

review of 

regulation 

Tim Spencer-Lane of 

the Law Commission 

explains 

The Law Commission has recently 

launched a consultation on the 

regulation of health care professionals in 

the UK and social workers in England. 

The consultation runs to 31 May. Tim 

Spencer-Lane from the Law Commission 

provides a brief outline of the key 

proposals. 

The regulatory bodies covered by the 

review include the General 

Pharmaceutical Council, General Medical 

Council, General Dental Council, and 

Nursing and Midwifery Council. The 

project is the first trilateral joint project 

between the Law Commission, Scottish 

Law Commission and Northern Ireland 

Law Commission. 

The regulators operate within a wide 

variety of legal frameworks which have 

been agreed and amended by 

Parliament in different ways and at 

different times over the past 150 years. 

A complex legislative landscape has 

evolved on a piecemeal basis resulting in 

a wide range of idiosyncrasies and 

inconsistency in the powers, duties and 

responsibilities of each of the regulators. 

Our proposed structure would consist of 

a single Act of Parliament to provide the 

legal framework for the regulators (as 

well as the Council for Healthcare 

Regulatory Excellence). In effect, all the 

existing governing statutes and orders 

would be repealed. 

The broad aim of the proposals is to 

enhance the autonomy of the 

professional regulators in the exercise of 

their statutory responsibilities and 

enable the regulators to adopt their own 

approaches to professional regulation in 

the light of their circumstances and 

resources. 

This would be achieved largely by 

reducing the regulators’ dependence on 

the Privy Council (and through it, the 

Department of Health). The regulators 

would be given broad powers to make or 

amend rules concerning the exercise of 

their functions and governance without 

any direct oversight by Parliament or 

Government. 

However, these broad powers would be 

subject to certain safeguards, such as a 

duty to consult widely, and 

accountability hearings before the 

House of Commons Health Committee 

and the devolved assemblies. The 

Government would also be given default 

powers to intervene where a regulator 

has failed or is likely to fail to perform 

any of its functions. 

The consultation extends to all the main 

functions of the professional regulators 

including establishing and maintaining a 

register, and approving and setting 

standards for education, conduct and 

ongoing practice, and the investigation 

and adjudication of fitness to practise 

cases. It also extends to business 

regulation and the powers and duties of 

some of the regulators to register bodies 

corporate or regulate businesses, such 

as the General Pharmaceutical Council. 

The consultation period will last for 

three months (the closing date for 

responses is 31 May 2012), and the final 

report and draft Bill are expected to be 

published in 2014. 

We emphasise that the proposals in our 

consultation paper represent our initial 

view about how the law should be 

reformed. We will review our proposals 

on the basis of the responses received 

during the consultation period. We 

encourage all readers to respond. 

The consultation paper and summary 

are available to download from the Law 

Commission’s website at: 

www.lawcommission.justice.gov.uk/ 

Tim Spencer-Lane 


Registered pharmacies 

National launch 

of registered 

pharmacies 

consultation 

Mike Holden, of the National Pharmacy 

Association, with Priya Warner, the GPhC’s Head of 

Standards and Fitness to Practise Policy. 

Leaders from more than 20 national 

organisations came together at the 

national launch of our consultation on 

registered pharmacies in London on 

8 February. 

Leaders from the key pharmacy 

representative bodies, patient 

organisations including National Voices, 

other health regulators, the Department 

of Health, and Kevin Barron MP, Chair of 

the All Party Parliamentary Group on 

Pharmacy, looked at the main proposals 

in the consultation document. 

They worked through the proposals in 

small groups and discussed what some 

of those proposals might mean in 

practice for pharmacies, pharmacy 

owners and superintendents, pharmacy 

staff, patients and the public. 

A question and answer session with the 

GPhC team ran for nearly an hour and 

raised some useful issues about the 

proposed draft standards for registered 

pharmacies. 

For instance, Martin Astbury, the 

President of the Royal Pharmaceutical 

Society (RPS), raised the issue of the selfselection 

of pharmacy medicines and 

whether the consultation proposals 

might cause risks to patient safety if they 

were implemented. 

Mike Holden, Chief Executive of the 

National Pharmacy Association (NPA), 

asked for more details on how the 

inspection model might change, and 

what a risk-based approach to 

inspection would mean for pharmacies. 

There were also a number of detailed 

questions on specific areas, including the 

supply of veterinary medicines and 

registration for temporary premises in 

the event of disruption of services 

caused by natural disasters. 

Questions and comments made 

at events and meetings over the 

consultation period are being 

collected and analysed, and will 

be taken into account in 

developing our response. 

A report setting out our response 

will go to the June meeting of the 

GPhC council and will be available 

on our website 

Bob Nicholls, GPhC Chair, with Mark Koziol, from the Pharmacists’ Defence Association. 



In Scotland 

In Wales 

At the first of our consultation events 

in Wales, members of Community 

Health Boards from across Wales came 

to explore what the consultation 

proposals might mean for the patients 

they represent. The GPhC’s Council 

member for Wales, Lesley Morgan MBE, 

introduced the event. 

Professor Roger Walker, the Chief 

Pharmaceutical Officer for Wales, and 

leaders from Scotland’s professional and 

representative bodies for pharmacy, had 

the opportunity to ask questions of a 

panel of GPhC staff, including Director 

for Wales, Darren Hughes. 

Many of the questions scrutinised how 

the proposals would fit with increasingly 

diverging healthcare delivery structures 

in Wales. 

Representatives from pharmacy 

professional and industry bodies, the 

NHS and patient organisations came 

together at the first of our consultation 

events in Scotland. Attendees travelled 

from as far as Shetland and Inverness to 

attend the event and share their views. 

The GPhC’s Council member for 

Scotland, Gordon Dykes, introduced 

the event. 

The question and answer session with 

GPhC staff focused on how the new 

standards could work with pharmacy 

care and services in Scotland. Panellists 

included our Director for Scotland, 

Lynsey Cleland. 

Top: Alex MacKinnon, Royal Pharmaceutical 

Society, Dr James Johnson, Strathclyde Institute 

of Pharmacy, and Dr Jean Turner, Scottish 

Patients Association 

Bottom: Dr Hamish Wilson and Duncan Rudkin, 

the GPhC’s Chief Executive, with Professor 

Bill Scott, and Lynsey Cleland, the GPhC’s 

Director for Scotland 

Paul Worthington, from Cwn Taf 

Community Health Council, talked 

about the inspections carried out by 

Community Health Councils and asked 

whether and how the GPhC and 

Community Health Councils could 

coordinate their inspections to make 

sure they did not overlap. 

Mair Davis, Chairman of the Welsh 

Pharmacy Board of the RPS, asked 

how the GPhC would ensure there was 

consistency in how inspectors interpreted 

the outcomes-focused standards. 

Top: Chief Pharmaceutical Officer for Wales, 

Professor Roger Walker 

Bottom: Catherine O’Brien from WCPPE with 

Darren Hughes, the GPhC’s Director for Wales 

Dr Hamish Wilson, who is leading the 

national review of NHS Pharmaceutical 

Care of Patients in the Community, said 

that while he thought the proposals 

fitted well with what was happening 

in Scotland, the final version could do 

even more to reflect the different 

perspectives in pharmacy across 

Scotland, England and Wales. 

A key theme that emerged was how 

to achieve the best outcomes for 

patients using pharmacy services in 

Scotland. Professor Bill Scott, the Chief 

Pharmaceutical Officer for Scotland, 

asked how the GPhC had worked with 

patients and the public in developing 

the proposals. 

Dr Jean Turner, from the Scottish 

Patients Association, asked if the 

standards have a role to play in 

encouraging pharmacists to keep good 

records, which could be useful, 

especially when treating patients with 

complex conditions. 



How you can 

get involved 

We are attending a number of Local Pharmacy 

Forum (LPF), Local Pharmaceutical Committee 

(LPC) and other organisations’ meetings and 

events. You may want to attend. You can check 

details of dates, times and venues at 

www.registeredpharmacies.org/events 

Some of these meetings and events include: 

England 

16 April GPhC (supported by LPC) meeting - Greater Manchester 

20/21 April Clinical Pharmacy Congress - ExCel, London 

1 May GPhC meeting for superintendent pharmacists and registrants - 

East London 

Scotland 

10 April LPF meeting - Aberdeen 

18 April GPhC meeting with registrants and pharmacy owners - Glasgow 

19 April LPF meeting - Edinburgh 

Wales 

16 April LPF meeting - Abergele, North Wales 

23 April LPF meeting - Swansea 

24 April LPF meeting - Cardiff 

You can find our calendar of consultation events at www.registeredpharmacies.org/events 

or you can contact us at consultations@pharmacyregulation.org for more information. 

You can respond to the consultation online by visiting 

www.registeredpharmacies.org. 

If you would like a hard copy of the consultation document 

and/or questionnaire, you can: 

phone : 0203 365 3506 

email: consultations@pharmacyregulation.org 

Write to: 

Registered Pharmacy Consultation 

c/o Communications Department 


129 Lambeth Road 

London SE1 7BT 

Other formats 

There is a Welsh Language version of 

this consultation document available at 

www.registeredpharmacies.org 

You can request an alternative format 

by emailing us at 

consultations@pharmacyregulation.org 

or calling us on 020 3365 3506. 


Letters 

Dear Sir/Madam, 

I must say I love reading regula+e as the 

content is informative and thorough. I 

especially enjoy the fitness to practise - 

learning. I find this useful as I am a 

newly qualified Pharmacy Technician 

and want to fully understand all aspects 

of pharmacy and best practise. 

I would, however, like to see more 

information about, and support, on CPD 

- possibly including example entries. 

Thanks 

Richard Lee 

Dear Richard 

Thank you for your feedback. We are 

really pleased to read your comments 

about Regula+e. We will have a look at 

your suggestion. We will be launching a 

new online learning tool soon and will 

update you about that in the next 

edition of Regula+e. That item will 

include some information about CPD. 

In the meantime, you might want to 

look at the learning points at the back 

of this edition and let us know what 

you think about how we have done 

them this time. 

Editor 


Fitness to Practise update 

New policy on 

underlying 

health issues 

The GPhC can now routinely request a 

medical examination and report in fitness 

to practise cases that are drug or alcoholrelated. 

This is part of a new policy, 

‘Identifying Underlying Health Issues’, 

which was agreed in March, and also 

applies to registrants making an 

application for registration. 

The medical examination is carried out by 

an independent practitioner nominated by 

the GPhC, who examines the registrant 

and provides a written report, including 

any relevant test results. 


Rudkin, said: 

“As a result of their working environment, 

registrants have access to drugs that are 

liable to abuse or misuse. This is a 

potential area of risk that needs further 

examination. 

“As part of implementing this new policy, 

we will gather evidence to assess whether 

carrying out routine medical examinations 

helps to identify risks in terms of 

protecting the public. We will review this 

policy in six months time to assess what 

evidence has emerged.” 

This policy applies to all cases received on 

or after 13 February 2012, as well as all 

applications for registration received on or 

after that date. 

The GPhC will request a medical report 

where applications for registration contain 

a specific or related drugs or alcohol 

caution or conviction. Whether a medical 

report is required will depend on the 

specific facts and circumstances in each 

case. Applicants who are asked to submit a 

medical report will be required to pay the 

cost of that report themselves. 

The policy will be reviewed in August to 

assess its effectiveness in indentifying 

underlying health issues which, if not 

addressed, might increase risks to patients 

and the public. 

Keeping in 

touch 

Not long after we send out Regula+e, 

the returned copies arrive. Can we 

encourage you to keep us updated if 

you change your home address. You 

can do this by visiting MyGPhC.org 

and entering your new home 

address. It only takes a few minutes. 

We have seen an increasing number 

of returned copies of Regula+e with 

handwritten forwarding addresses on 

the outside packaging. We have 

assumed that these have been filled 

in by new occupants at the old 

address. This does not constitute 

notifying us of a change of address. 

It is a requirement of your 

registration that you provide us with 

your current home address. Failing to 

update your address may result in 

you failing to respond as required to 

correspondence from the GPhC, 

which may ultimately lead to your 

removal from the register. 

It may also be a factor in a fitness to 

practice matter too. If we don’t have 

your latest home address, have made 

appropriate efforts to contact you at 

the address you have provided, and 

you haven’t responded or attended a 

scheduled hearing, then the 

committee may conclude that you 

have decided not to attend. We 

would like to avoid the disruption and 

distress that can be caused when this 

happens. A simple change of address 

is all that is needed to ensure this 

won’t happen. 

Please contact our customer service 

team if the process of notifying us of 

a change of address is still not clear. 

You can call us on 020 3365 3400. 

And if you have a colleague who has 

not received their copy of Regula+e, 

please ask them to check their details 

on MyGPhC.org or call us on 020 

3365 3400. 


Fitness to Practise - determinations 

Fitness to 

Practise – 

determinations 

Should a fitness to practise committee 

determine that a registrant’s fitness to 

practise is impaired, the committee may 

impose a sanction that is proportionate to 

the conduct that has been found proven. 

This may include, for example, issuing a 

warning, placing conditions on the 

individual’s registration, suspension of 

registration or, in the most serious cases, 

erasing the individual from the register so 

that they can no longer practice. 

The matters listed here include the 

registrant’s registration number, date of 

determination and the sanction. 

Determinations of the facts and additional 

information about the hearings can be 

found on our website at 

www.pharmacyregulation.org/search/ 

search_decisions 

Gulamhusein, Charlotte, 2052358 

Determination date 16 January 2012 

Suspension for one month 

Emohare, Jude Isibor, 2066515 


Conditions placed on registration for six 

months, to be reviewed before the end 

of the six month period 

Aujla, Sukhjinder Singh, 2059794 


Suspension for two months 

Akram, Shahnawaz, 2045100 



Morsy, Ramsey Sobhy, 2042254 


Suspension for 12 months 

Peploe Williams, Anthony, 2026041 


Suspension for 12 months, to be 

reviewed before the end of the 12 month 

period 

O’Sullivan, Simon Patrick Joseph, 

2040785 

Determination date 3 February 2012 

Suspension for six months 

Shekoni, Mufutau Olawale Alade, 

2021866 


Review hearing in respect of a six month 

suspension previously imposed on 

registration. Direction that on the expiry 

of the current period of suspension, 

registration will be conditional on 

compliance with conditions which must 

be completed within 12 months 

Taylor, Stacey, 5001370 


Review hearing in respect of a 12 month 

suspension previously imposed on 

registration. Further suspension of 12 

months with a review before the end of 

that period 

Thomas, Lisa Ellen, 5001076 


Suspension for six months, with a review 

before the end of the suspension period 

Mistry, Vijay, 2032315 


Suspension for 12 months, with a review 


Ivanov, Emil 

Determination date 6 March 2012 

Conditional registration for 12 months 

Bal, Narinderpal 



Lal, Roshan 


Suspension for 12 months, with a review 


You can find out more about the role of the investigating committee at: 

http://www.pharmacyregulation.org/raising-concerns/hearings/committees/investigating-committee 

And about the fitness to practise committee at 

http://www.pharmacyregulation.org/raising-concerns/hearings/committees/fitness-practise-committee 

Our threshold criteria can be found at: http://www.pharmacyregulation.org/sites/default/files/The%20threshold%20criteria.pdf 


Fitness to practise – learning 

Fitness to 

practise – 

learning 

We receive concerns about 

pharmacy professionals from 

a wide variety of sources. 

Some of the concerns fall 

below our threshold criteria 

and so do not get referred on 

to our investigating 

committee or fitness to 

practise committee. Cases 

are only referred to these 

committees where there is 

reason to believe that the 

registrant’s fitness to 

practise may be impaired. 

We are keen to share 

learning from a variety of 

cases to improve practice 

and for registrants to better 

understand how we deal 

with these matters. 

Sometimes we have cases where the 

circumstances seem similar but the 

outcomes quite different. Here we look 

at two sets of examples. The first 

involves practising while not registered; 

and the second, making false claims for 

Medicine Use Review (MURs). 

First prosecution for 

practising while not 

registered 

The GPhC has successfully brought its 

first prosecution against a pharmacist 

for practising while suspended from 

the register. 

Mark Robert Taylor (registration number 

2039228) was convicted of an offence 

under S38(4) of the Pharmacy Order 2010 

at Tower Bridge Magistrates Court on 9 

January 2012 and fined £1,750 plus costs. 

Our fitness to practise committee had 

suspended Mr Taylor’s registration on 9 

June 2011 for six months, after a 

number of allegations were found 

proved during a hearing. These 

allegations included accessing the 

controlled drugs cabinet when not on 

duty and without authorisation, and 

demonstrating unprofessional and 

threatening behaviour to a colleague. 

A GPhC Inspector conducting a routine 

inspection of a pharmacy on 14 July 

2011 found that Mr Taylor had 

unlawfully been working there during his 

period of suspension. 


Rudkin, said: 

“This conviction sends a clear message 

that there are serious consequences if 

someone tries to work as a pharmacist 

when they are not registered to practise. 

“Patients and the public can have 

confidence that we will take decisive 

action to prevent anyone from practising 

as a pharmacist if they do not meet the 

high standards of conduct, ethics and 

performance necessary to hold 

registration.” 

Practising while not 

registered 

The fitness to practise committee heard 

that a pharmacist who had been 

removed from the register for failing to 

renew his registration had worked as a 

locum on 43 occasions between 8 April 

and 18 June 2009. 

He had not told his employers that he 

had been removed from the Register. As 

far as he was aware, the companies he 

worked for believed he was a registered 

pharmacist. 

The committee heard that at the time of 

the offences, he had felt overwhelmed 

by debt. His motivation had been to try 

and get his financial affairs into a 

manageable state. 

He accepted that his behaviour had 

been both inappropriate and dishonest. 

The committee took into account that 

while the misconduct had occurred over 

a two-month period, it had to be seen in 

the context of an otherwise 

unblemished record. He had cooperated 

fully with the GPhC’s investigation and 

had made open and frank admissions. 

He had apologised for his misconduct 

and shown genuine remorse. 

A two-month suspension was imposed, 

which the committee said adequately 

reflected the aggravating and mitigating 

features of the case. 

Learning points 

• You cannot call yourself a 

pharmacist, practise as a 

pharmacist or hold yourself out to 

be a pharmacist unless you are 

registered with the GPhC 

• It is your responsibility to renew 

your registration annually before 

the deadline 

• The owner or superintendent 

pharmacist must carry out 

relevant checks on all staff that 

they employ. The registration 

status of a pharmacist or 

pharmacy technician can be 

checked on our live register on 

our website. Go to 

http://www.pharmacyregulation. 

org/registration 

• Our register also shows details of 

any fitness to practise decisions 

relating to a registrant. 


Fitness to practise – learning 

Making false claims for 

MURs: Case one 


allegations that a pharmacist had made 

false claims for Medicine Use Reviews 

(MURs) that had resulted in an 

overpayment of £22,000 to the pharmacy 

and a personal bonus to the pharmacist of 

£800. The false claims had occurred over a 

two-year period and his employer had 

been obliged to pay back the £22,000. 

The pharmacist had claimed for eight 

MURs per week, whether or not he had 

done them. 

The committee said the pharmacist’s 

evidence on how many MURs he had 

carried out was unclear and at times, 

contradictory. On the balance of 

probabilities, they said that approximately 

20 per cent had not been carried out at 

the time a claim was made. 

The pharmacist had also made no record 

on his employer’s computer system, as 

required by his employer. 

The committee said the pharmacist had 

treated the dishonest reporting and 

claiming of MURs as an insignificant matter 

and had denied his dishonesty up to a very 

late stage in the investigation, and it was 

“extremely concerned” about his apparent 

lack of insight into his misconduct. 

The committee accepted that the 

pharmacist had felt under pressure to 

achieve a target of 400 MURs a year, and 

that he had experienced some personal 

and family problems. There was also no 

evidence of any direct risk to patient safety. 

However, accuracy and honesty in recordkeeping 

was crucial to a pharmacist’s duty. 

The committee concluded that his 

conduct was not fundamentally 

incompatible with registration as a 

pharmacist but that a clear message 

needed to be sent out about the 

unacceptability of his behaviour. 

The pharmacist was suspended for 12 

months, with a review of the suspension 

by another panel of the fitness to practise 

committee before the end of that period. 

Making false claims for 

MURs: Case two 


allegations that a pharmacist had 

submitted 308 claims for Medicines Use 

Reviews (MURs) over a four-month period 

which had not been carried out, and as a 

result of these claims, had received a 

personal bonus of £800. 

Over a four-month period, the pharmacist 

had claimed that she had completed a 

total of 400 MURS, but when asked by the 

company pharmacy manager to produce 

the documentary evidence, was unable to 

do so. There was no evidence she had 

done more than 92 MURs. 

The pharmacist had initially helped with 

the search for evidence that she had 

completed the MURs, then had admitted 

she had submitted inflated claims, and 

repaid the £800. 

The committee said the pharmacist 

had found herself out of her depth in 

fulfilling her responsibilities in her first 

non-locum role, and that she particularly 

wanted to impress her employers in the 

hope of being offered a permanent post. 

One way she had decided to do that was 

by completing a high number of MURs. 

She had accepted that she had acted in a 

dishonest manner and had breached the 

standards of conduct, ethics and 

performance which require pharmacists 

to make sure their professional 

judgement is not impaired by personal 

or commercial interest, incentives, 

targets or similar measures. 

In deciding on the outcome, the 

committee took into account the early 

repayment of the £800; that the events 

had taken place over a short period; that 

the pharmacist was not motivated by 

personal financial gain; and that there 

was no actual harm to patients or to the 

public. The pharmacist had shown 

insight by accepting her wrongdoing and 

showing remorse. She had no record of 

previous wrongdoings, and testimonials 

considered by the committee spoke 

highly of her care, kindness and 

professionalism. 

The committee said a lengthy 

suspension would be a disproportionate 

interruption to her career, and due to 

the insight shown, imposed a onemonth 

suspension. 

Learning points 

• You must always act with honesty 

and integrity 

• You must cooperate with 

investigations, acknowledge when 

your practice is inappropriate and 

reflect on how your practice 

should be improved or changed 

• You must not make claims for 

services that you have not carried 

out, even if you intend to carry 

them out in the near future 

• You must make necessary records, 

to show a clear audit trail of the 

services that you have carried out, 

and to comply with any 

requirements that may apply 

under your NHS contract 

• You must make sure that your 

professional judgement is not 

affected by having to achieve 

targets set in the course of your 

employment 

• If you feel under undue pressure 

to meet certain targets that have 

been set for you, you should raise 

this with your manager or 

superintendent pharmacist 


Check that a pharmacy professional is registered: 

http://www.pharmacyregulation.org/ 

theregister/index.aspx 

Copies of Regula+e are available to download from 

our website www.pharmacyregulation.org/publications 

We welcome feedback and comments on 

this publication which can be sent to 



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Telephone: 020 3365 3400 

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