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Note: this webpage has been updated to reflect requirements in the new standards, which come into effect on February 1, 2025.

Supervising students and provisional registrants

Pharmacist presence

According to the Pharmacy and Drug Act, section 11.1:

“A licensee must ensure that there is always a pharmacist who is registered in either the clinical register category or the courtesy register category of the college’s regulated members register present and supervising the practice of pharmacy at the licensed pharmacy when the public has access to the licensed pharmacy.”

In other words, there must be a pharmacist (from the clinical or courtesy register) on duty, supervising the pharmacy team when the pharmacy is providing professional services.

According to the Pharmacy and Drug Regulation, section 17:

A licensed pharmacy may be without a clinical pharmacist or a courtesy pharmacist during the hours of operation if:

  • the total amount of time the pharmacy is without a clinical pharmacist or courtesy pharmacist during the hours of operation does not exceed one hour;
  • the clinical pharmacist or courtesy pharmacist who is temporarily absent is accessible in person or by phone and can return to the pharmacy immediately; and
  • the clinical pharmacist or courtesy pharmacist ensures that during the absence
    • either
      • no restricted activities are performed, or
      • restricted activities are performed only by individuals authorized to perform them and that they are performed in accordance with the authorization;
    • the practice of pharmacy and safety of the public are not compromised; and
    • all drugs and patient records are secure from unauthorized access.

According to the Standards for the Operation of Licensed Pharmacies, a licensee must

  • ensure that any regulated member who is employed in a licensed pharmacy and who will engage in a restricted activity, or who will supervise a restricted activity in the licensed pharmacy, is authorized to engage in that restricted activity;
  • ensure that no restricted activities occur in the licensed pharmacy at any time unless a regulated member who is authorized to perform the restricted activity is present to conduct or supervise the restricted activity;
  • ensure that each regulated member who will practise in a licensed pharmacy and each unregulated employee who will work in a licensed pharmacy receives
    • an orientation that includes a review of
      • the pharmacy’s operational policies and procedures,
      • the plan required by Standard 3.10, and
      • all professional services provided from the pharmacy; and
    • a suitable period of supervision, training, observation, and assessment of skills and knowledge.

The licensee must inform ACP of the names of the regulated members who are employed at the pharmacy via myACP. Regulated members must also ensure their employment information in myACP is up to date.

Supervising pharmacy students, provisional pharmacists, and provisional pharmacy technicians

Pharmacy students, provisional pharmacists, and provisional pharmacy technicians are recognized on the student and provisional registers for training and thus requires the presence and oversight of a supervising regulated member. A pharmacy student or provisional registrant must be supervised in accordance with the rules of the Structured Practical Training programs and the Standards of Practice for Pharmacists and Pharmacy Technicians (SPPPT). According to the SPPPT,

A regulated member providing supervision must

  • be authorized to perform and supervise the professional services being supervised, and
  • be satisfied that the individual being supervised is authorized to perform the professional services.

The supervising regulated member must

Pharmacy students and provisional registrants must not be scheduled to work independently without a supervising regulated member present. A pharmacy site that is providing professional services must always have a pharmacist who is present, onsite, and available to support the actions of the pharmacy student or provisional registrant.

Per the SPPPT, the supervising regulated member must provide the level of supervision they consider appropriate to ensure the safe and effective performance of the professional services. Initially, the supervising regulated member must begin with direct supervision to assess the competence of the pharmacy student or provisional registrant. Direct supervision requires the supervising regulated member to be directly present to observe, guide, monitor, and promptly intervene as the pharmacy student or provisional registrant performs a restricted activity. Restricted activities are defined in the Health Professions Restricted Activities Regulation.

As the supervising regulated member establishes confidence that the pharmacy student or provisional registrant can perform a restricted activity safely and effectively, at the supervisor’s discretion and based on their assessment of the pharmacy student or provisional registrant, they may decrease the level of supervision, allowing the student or provisional registrant to practise with less oversight and guidance. However, the supervisor must always be present, onsite, and available to monitor and support the actions of the pharmacy student or provisional registrant as the supervisor remains responsible and accountable for the actions of the pharmacy student or provisional registrant.

Restricted activities that always require additional oversight

A pharmacy student or provisional pharmacist who has completed the Council requirements for the administration of injections and has valid and current CPR and first aid certifications may administer drugs by injection under direct supervision by a supervising pharmacist who has the appropriate authorization and training. Direct supervision is always required when a pharmacy student or provisional pharmacist is administering a drug by injection. In other words, the supervising pharmacist must be directly present to observe, guide, monitor, and promptly intervene.

Clinical decisions made by a pharmacy student or provisional pharmacist, such as adapting a prescription, should be made in consultation with the supervising pharmacist. Any prescribing decisions must be approved by the supervising pharmacist and under their signature. Prescribing at initial access, managing ongoing therapy, or deprescribing must only occur if the supervising pharmacist themselves has additional prescribing authorization and has established a professional relationship with the patient at the time of prescribing.