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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 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

     a)    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

     b)    the clinical pharmacist or courtesy pharmacist ensures that during the absence

             i.    either

                   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.

Role of the intern

Interns (or provisional pharmacists) are not pharmacists and 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 thus requires the attendance and oversight of a pharmacist. Intern skill development is the primary intent of the program, not the accumulation of hours. Interns 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.

Direct supervision

Who requires direct supervision?

  • Pharmacy interns and provisional pharmacy technicians who are completing the SPT program.
  • Pharmacy students.
  • Pharmacy assistants.
  • Additionally, any student or intern 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.

When direct supervision is required, the supervisor must

  • be present when the supervised individual is performing a restricted activity,
  • be able to observe and promptly intervene or stop the actions of the supervised individual, and
  • be authorized to perform the restricted activity being supervised.

Indirect supervision

Who requires indirect supervision?

  • Pharmacy interns or provisional pharmacy technicians who have completed their SPT program 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 registrant. Interns should not be scheduled to work independently without a supervising pharmacist present.

When indirect supervision is required, the supervisor must

  • be readily available for consultation and, if necessary, for providing hands-on assistance to the supervised individual;
  • ensure the supervised individual complies with procedures; and
  • have procedures in place that comply with the standards and ensure the safety and integrity of the dispensing or compounding of drugs by the supervised individual.

The supervising pharmacist is responsible and accountable for the restricted activities performed by the intern. Therefore, clinical decision making by the intern, such as adapting a prescription, should be made in consultation with the supervising pharmacist. Initial access prescribing must only occur if the pharmacist has seen the patient at the time of prescribing or has developed a professional relationship with the patient over time.

Direct supervision is still required for any intern administering drugs by injection. To administer drugs by injection, the intern must have met the requirements to perform this restricted activity and the supervising pharmacist must have authorization to administer drugs by injection.

Pharmacy technicians

The Pharmacists and Pharmacy Technicians Profession Regulation, Section 21(1), authorizes a pharmacy technician under the direction of a clinical pharmacist, to perform certain restricted activities. However, a pharmacist must always be present in the pharmacy to consult with, provide guidance to, and, if necessary, provide assistance to the pharmacy technician. “Under the direction of a pharmacist” does not necessarily require the “directing” pharmacist to be on the same shift as the technician. The pharmacist providing direction must work in the same pharmacy and ensure there are appropriate policies and procedures in place that comply with the Standards of Practice for Pharmacists and Pharmacy Technicians. The pharmacy technician must report to the pharmacist who is responsible for providing direction.