A recent hearing tribunal issued its written decision on the merit and orders regarding the conduct of a pharmacist who admitted to administering medications by injection to several patients, over an extended period of time, without having the required training, current CPR and First Aid certification, or the authorization to do so. Additionally, the pharmacist failed to create or maintain the required records of care associated with the injections. Although none of the patients reported any harm resulting from the injections, the hearing tribunal found that in providing injections without the proper training and required authorization, the pharmacist placed the patients at risk, failed to meet the ethical obligations of a pharmacist, and harmed the integrity of the profession.
In their decision, the tribunal stated:
[The pharmacist] had an ethical obligation to his patients and the public to obtain and maintain the required authorization prior to injecting any patient, and [the pharmacist] failed to do so. It is clear in the Standards of Practice that when a pharmacist provides a treatment, and particularly when the pharmacist is actively administering a treatment, it is mandatory to maintain records. Records are important for the reason if there is an emergency that arises, but they are also a very important aspect of being able to monitor compliance. In this case the College does not know precisely how many times, and there are no records. It is as if those injections never happened. This behavior has potentially placed patients at risk.
[The pharmacist] practiced outside his authorized scope of practice and failed to create or maintain the required records of care, and by doing so he has called into question the trust placed in him as a member of a self-regulating profession Any self-regulating profession has its obligation to regulate its members, but it can’t be standing over its members. Each member has to take the responsibility to uphold this principle and govern oneself accordingly to the statute, regulations, standards of practice and code of ethics.
[The pharmacist] showed a serious disregard of his duties as a pharmacist to his patients, the Alberta College of Pharmacists, and to the public which relies upon the integrity and competence of pharmacists as members of a selfregulating profession. This behavior undermines the integrity of the profession.
Pharmacists and Pharmacy Technicians: Ensure you practice only in areas in which you are competent and authorized to do so Incorporate these lessons into your practice:
1. Review your professional responsibilities and ethical duties. Principles 1, 5, 9 and 10 of the Code of Ethics will provide you with valuable guidance in this respect. Also, review your responsibilities with regards to administering injections (see Standards 16 & 17 of the Standards of Practice for Pharmacists and Pharmacy Technicians (“SPPPT”)) and creating and maintaining proper records (see Standard 18 and Appendix A of the SPPPT).
2. Ensure that you are properly trained, competent and authorized to provide all restricted activities that you provide, such as administering injections. Review your practice together with Sections 16 to 23 of the Pharmacists and Pharmacy Technicians Profession Regulation (Restricted Activities).
3. Set up your practice to ensure that all pharmacy services customarily needed by your patients can be provided safely, responsibly, and in accordance with all the applicable legislative requirements. If you are unable or not authorized to provide a pharmacy service, ensure that you can assist those patients in seamlessly obtaining the service from another health care provider. Know your limits and know when to refer.
4. Create and maintain proper records for your pharmacy, such as those for the administration of medications by injection.