If you are the only pharmacist working with a pharmacy technician (i.e., a regulated health professional who has met all the conditions required for that restricted title), can you step out for coffee for 15 minutes? What about going to a meeting for an hour?
Pharmacy technicians alone in the dispensary?
Stepping out for coffee is OK; going to a meeting for an hour is not. Let’s look at the three reasons why.
1. Section 11.1 of the Pharmacy and Drug Act specifies that unless the regulations authorize otherwise, a licensee must ensure that there is always a clinical or courtesy pharmacist present and supervising the practice of pharmacy at the pharmacy when the public has access to the pharmacy.
2. Section 17 of the Pharmacy and Drug Regulation specifies that a licensed pharmacy may be without a clinical or courtesy pharmacist for a very short period of time during the hours of operation if:
a) the clinical or courtesy pharmacist who is temporarily absent is accessible in person or by phone and can return to the pharmacy immediately, and
b) the clinical pharmacist or courtesy pharmacist ensures that during the absence
A) no restricted activities are performed, or
B) restricted activities are performed only by individuals authorized to perform them and that they are performed in accordance with the authorization,
ii) the practice of pharmacy and safety of the public are not compromised, and
iii) all drugs are secure from unauthorized access.
With a regulated technician, you could be sure the drug supply is secure and if you had already counseled patients and assessed appropriateness of prescriptions, the technician could give out the medication. However, the Standards require that the technician indicate to the patient that a pharmacist is available to speak to them (Standard 8.2(b)).Therefore, being absent for an hour would not allow you to fulfill your obligation to the patients.
3. Schedule 19 of the Health Professions Act states that pharmacy technicians must practice under the direction of a pharmacist. What does “under the direction of” mean?
“Under the direction of” means that the clinical or courtesy pharmacist who is providing the direction* must:
a) practice at the same pharmacy as the pharmacy technician, unless otherwise authorized in writing by the Registrar,
b) ensure there is a system in place in the pharmacy that complies with the Standards of Practice under which
i. a pharmacist is available to consult with, provide guidance to and, if necessary, provide assistance to the pharmacy technician,
ii. the involvement of the pharmacy technician in the restricted activities can be monitored and assessed,
iii. the pharmacy technician reports to the pharmacist who is responsible for providing direction to the pharmacy technician; and
c) be authorized to perform the restricted activities for which the pharmacist is providing direction to the pharmacy technician.
*Note the difference between direction and supervision.
Supervision is provided by the pharmacist on shift that day and that pharmacist must be available to provide hands-on assistance, either immediately or within a reasonable period of time.
Direction is provided by a pharmacist who works in the same pharmacy, but not necessarily on the same shift as the technician. That pharmacist is responsible for ensuring that there are appropriate policies and procedures in place to maintain the integrity of the dispensing and compounding processes and for making sure that a pharmacist is available to work with the technician as required in the regulations and the standards.
So, if you, the only pharmacist, can return to the pharmacy quickly to consult with, provide guidance to and, if necessary, provide assistance to the pharmacy technician, stepping out for coffee may be reasonable.
Also remember that non-regulated staff such as pharmacy assistants or provisional pharmacy technicians must work under supervision. This makes it even more important that you be absent for only a “very short period of time.”
Originally published in the July 24, 2012 issue of The Link