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Restricted pharmacy titles and related requirements

April 20, 2022
Clarifying legislated requirements regarding roles and supervision in the pharmacy.

All regulated members are required to have specific levels of education, defined skillsets, and clear role understanding. There are corresponding restricted titles set out in Section 15 of the Pharmacists and Pharmacy Technicians Profession Regulation. These restricted titles convey important information to the public, indicating the qualifications of each pharmacy team member and the activities they may be able to perform. Additionally, these roles have corresponding supervision requirements to ensure effective oversight within pharmacy teams.

Recently, it has come to ACP’s attention that individuals may be inadvertently using incorrect role titles when communicating to members of the public, other regulatory bodies, or in informal conversation. For example, unless individuals are registered with ACP as a provisional pharmacist or provisional pharmacy technician, they are unable to use the role title of intern. These titles indicate that the individual has completed their education requirements and is in the process of completing registration exams or the Structured Practical Training (SPT) program. Similarly, student pharmacists must be registered in an approved university program to use either pharmacy student or pharmacist student.

The use of correct titles also supports an effective oversight process, as there are legislated supervisory requirements for regulated members. Provisional pharmacists, provisional pharmacy technicians, and student pharmacists often require direct supervision. When direct supervision is required, the supervisors must have hands-on and eyes-on oversight of the restricted activity and supervised individual. Documentation, such as dispensing audit trails or injection administration forms, must make clear which regulated individual provided this authority. Additionally, any student or provisional pharmacist who has met the requirements to administer drugs by injection must perform this restricted activity under the direct supervision of a pharmacist who has authorization to administer injections. To ensure understanding, all regulated members are encouraged to review the supervision requirements detailed on the ACP website.

Wearing correct name tags and using the correct role title in verbal and written communication are all important measures to support transparency about the capacity and supervisory requirements for each pharmacy team member. Overall, establishing a clear understanding of the scope of each regulated role, ensuring appropriate supervision is in place, and communicating these roles and requirements builds transparency and trust within pharmacy teams, with other healthcare professionals, and with the public.