ACP has received concerns recently from members of the public who have noticed minors (individuals under 18 years of age) working as employees or volunteers in community pharmacies.
While there is no minimum age requirement for those who may have access to the dispensary, pharmacy licensees are responsible for ensuring employees or volunteers must be of a sufficient age to understand and appreciate the dangers and responsibilities of working with drugs and health information. Licensees must also ensure that they only employ (including volunteers) appropriate staff, and that they have been properly trained and are being appropriately supervised.
If a pharmacy has minors as employees or volunteers with access to the dispensary, or other areas of the pharmacy where patients receive professional services, there are several important points to consider.
Drug safety
Minors may not be able to appreciate the potential harms associated with drug therapy or the role of the pharmacy team in ensuring drug safety—for themselves, others present in the dispensary, or members of the public.
Protection of personal information
Licensees are responsible for ensuring all unregulated employees understand privacy and confidentiality and the consequences of a privacy breach. Minors who have access to personal or health information may not appreciate the potential consequences of a privacy breach. This includes accessing or sharing someone’s personal or health information without permission. Some minors may not fully identify the risks associated with accessing and disclosing personal information. Any unregulated employee who cannot understand the significance of this information must not be allowed access to an environment where this information is present.
Responsibilities of the licensee
Licensees who choose to employ minors must ensure they, along with any unregulated staff, receive the appropriate training to ensure drug safety and the protection of personal information. In addition, licensees must monitor these employees to ensure compliance with the pharmacy’s policies and procedures covered within their training.
When employing minors, licensees should be prepared to address any concerns from the public. These may be about a minor employee having access to their personal health information or being involved in a professional service. Proactively addressing these concerns will ensure a professional environment where drug safety and the protection of personal information is assured.
