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 pharmacy services.
According to the Pharmacy and Drug Regulation, Section 17:
A licensed pharmacy may be without a clinical pharmacist or a courtesy pharmacist for a very short period of time during the hours of operation if
- 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
- 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 are secure from unauthorized access.
Role of the provisional pharmacist and pharmacy technician
Provisional pharmacists (or interns) and provisional pharmacy technicians are recognized on the provisional register for training. The objective of the SPT program is to develop competence and confidence in applying the skills required to be a pharmacist and pharmacy technician, and thus requires the attendance and oversight of a supervising regulated member. Skill development and evaluation is the primary intent of the program, not the accumulation of hours.
Provisional pharmacists should not be scheduled to work independently without a supervising pharmacist present. A pharmacy site that is providing pharmacy services must have a pharmacist on site.
Who requires direct supervision?
- Provisional pharmacists (or interns) who are completing the SPT program or are between levels.
- Provisional pharmacists who are administering drugs by injection
- Provisional pharmacy technicians who are completing SPT Level 1
- Provisional pharmacy technicians who are completing SPT Level 2 or 3 and have not yet successfully completed the Ethics and Jurisprudence Exam
- Pharmacy students
- Any unregulated individuals who are working in the dispensary (e.g., pharmacy assistants.
When direct supervision is required, the supervisor must
- be present and observing the supervised individual performing a restricted activity
- be able to recognize when there is need for support, correction or intervention
- be able to promptly intervene or stop the actions of the supervised individual, and
- be authorized to perform the restricted activity being supervised.
Who can practice under indirect supervision?
- Provisional pharmacists (i.e., interns), after completing all three levels of the SPT program, can perform restricted activities under direct or indirect supervision, at the discretion of the supervising pharmacist. The level of supervision must be agreed upon by both the supervising pharmacist and the provisional pharmacist. Provisional pharmacists must not be scheduled to work independently without a supervising pharmacist present.
- Provisional pharmacy technicians who have successfully completed SPT Level 1 and the Ethics and Jurisprudence exam can perform restricted activities under direct or indirect supervision, at the discretion of the supervising regulated member. The level of supervision must be agreed upon by both the supervising regulated member and the provisional pharmacy technician.
When indirect supervision is appropriate, the supervisor must
- be readily available for consultation and, if necessary, for providing hands-on assistance to the provisional registrant;
- ensure the provisional registrant understands and complies with pharmacy policies and procedures; and
- ensure the safety and integrity of the dispensing or compounding of drugs by the provisional registrant.
Any pharmacy student or provisional pharmacist, who has met the requirements to administer drugs by injection must perform this restricted activity under direct, “eyes-on” supervision of a pharmacist who has authorization to administer injections. Furthermore, clinical decision making by the intern, such as adapting a prescription, should be made in consultation with the supervising pharmacist before the pharmacy service is provided to the patient. Initial access prescribing must only occur if the supervising pharmacist themselves has established a professional relationship with the patient at the time of prescribing.
Supervision of Pharmacy Practice Outside of SPT
A pharmacy student, provisional pharmacist, or provisional pharmacy technician who works in a pharmacy must always be supervised and must also have a supervising regulated member assigned. If a pharmacy student, provisional pharmacist, or provisional pharmacy technician is working in an institutional setting, like a hospital, or a community pharmacy outside of the SPT program or an educational rotation, they must submit a pharmacy student/provisional pharmacist or provisional pharmacy technician Work Experience Notification form. This notification form identifies the supervising regulated member who will accept responsibility for the practice of the student, provisional pharmacist, or provisional pharmacy technician.
It is important to note that even if these individuals are not participating in a structured learning environment, their presence still requires continual support and monitoring. All pharmacy team members should be aware of the student or provisional registrant’s roles, limitations of practice, and the level of supervision required.