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To represent and preserve the interests of our members including their right “to work, to free choice of employment, to just and
favourable conditions of work and to protection against unemployment”
(Article 23’ United Nations Universal Declaration of Human Rights, 1984)

To support qualified pharmaceutical assistants, work in partnership with pharmacy bodies to deliver professional excellence, ensuring the delivery of safe and professional service to the public.

To liaise with regulatory bodies on behalf of our members.

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Submission no 91:
“The real world outcomes of these changes will be the deemed redundancy of the original qualification and the literal redundancy of hundreds of PAs who, through no act of negligence, will be virtually unemployable.”

As a concerned member of the public I submit the following for consideration with regard to the draft PHARMACEUTICAL SOCIETY OF IRELAND (REGULATION OF TEMPORARY ABSENCE COVER BY PHARMACEUTICAL ASSISTANTS) RULES 2016
Rules 1 – 5: Understood as read
Rule 6: 6 (a) the period of temporary absence does not exceed 12 hours in any one week
This arbitrary number of 12 hours is profoundly unfair on pharmaceutical assistants (PA) who have been working, fully qualified and competent, in the role for decades. The choice of such a low number of hours can only be aimed at ensuring that the position of the PA is economically unviable for both the PA and pharmacists who employ them. The imposition of a limit at so few hours is to all intents and purposes a mass dismissal of the 393 PAs currently working in the country.
Furthermore, I fail to see how a person, qualified for at least 30 years in a position, can lose the ability to carry out their duties once an arbitrary time limit has elapsed each week. This is a nonsense.
The practical application of the rules will inevitably lead to any number of absurd situations whereby a PA would be in breach of the rules and unable to perform their duties – for example: a PA may be in the process of carrying out their duties of dispensing prescribed medication to a customer and the clock ticks over the 12 hours per week limit – the PA would not be able to complete the dispensing and the customer would be turned away and asked to return on another day despite the almost completed transaction. A ludicrous situation and a situation that absolutely undermines the PA and the public’s confidence in their qualification and ability to carry out the dispensing of prescribed medicines.
Rule 7: Before the imposition of these rules it is essential that Rule 7 is clarified. I have interpreted this rule to have several different practical implications and its opacity leaves me in no doubt that there is potential for differing interpretations of this rule being challenged in a court of law. Please clarify the practical application of this rule either through re-writing or issuing guidance. An extension to the current period of public consultation will be required for adequate consideration of Rule 7. Please also clarify the practical interaction of Rule 7 with Rule 9.
Rule 8: Understood as read.
Rule 9: Please clarify the practical interaction of Rule 9 with Rule 7. Is it the objective of these rules to bring into effect a defined period of ‘observation’ for PAs? Is it the intention that PAs are observed and assessed each and every month? Is the intention that the reading of Rule 7 and Rule 9 together brings about a situation whereby PAs are ‘observed’ by a pharmacist/superintendent for 12 hours each and every month? If so, what research and justification is there for such an onerous period of observation? Is there such distrust in the abilities of PAs that such strict periods of observation must be imposed? This also raises the question of the validity/quality of the PSI and its conferral of qualifications that have operated for decades with the holders of these qualifications now deemed to pose such a threat to public health that constant surveillance is required.
I would suggest that it is within the capacity of the PSI to propose a more practical approach to ensure that pharmacists are satisfied that the PAs in their employ retain the skills to carry out the role the PSI has itself deemed them qualified for.
Rule 10 & 11: Understood as read.

Consideration of the rule changes:

The real world outcomes of these changes will be the deemed redundancy of the original qualification and the literal redundancy of hundreds of PAs who, through no act of negligence, will be virtually unemployable. The changes appear to be a vindictive attack on people who have given, at the very least, 30 years of their lives to the profession. Hundreds of people will now be facing uncertainty in the twilight of their professional careers and likewise their retirement. Many are so close to retirement that retraining is not an option as the time and cost would leave them unable to recoup these costs in the short years remaining before retirement. Moreover, the changes will leave the PAs hugely handicapped in a jobs market that will inevitably look to the employment of younger professionals not expected to retire in the immediate future.
The raison d’être of the PSI is to protect the health, safety and wellbeing of the public by regulating the practice of pharmacy and the operation of pharmacies. I cannot see how betraying the very graduates upon whom the PSI has conferred their qualification can in anyway lead to achieving the PSI’s stated aims.
There are two very real and very predictable outcomes the proposed changes will bring about with regard to the PSI. First; the PSI will wantonly discard a vast pool of knowledge and experience. A pool of at least 12,000 years’ experience! (assuming 393 PAs having a minimum of 30 years’ experience) This loss will be compounded by the natural attrition of retiring qualified pharmacists and those leaving the profession for other reasons. I cannot fathom why the PSI would wish to deprive itself of such valuable experience. It smacks of chronic myopia. Furthermore, I expect the U-turn by the PSI on its view of its own conferred qualifications will lead to a wider uncertainty in the profession and very real concern of potential future changes that would similarly degrade or dismiss other PSI qualifications.
Likewise, the proposed changes will (at the very least) pose a threat to smaller pharmacies, especially those serving rural communities. The additional cost in terms of increased workload and increased expense in maintaining operating hours will inevitably have a detrimental effect on the service provided. There will undoubtedly be situations where a pharmacist, through unforeseen personal or medical emergencies, will have to leave the pharmacy. Given the restrictions on PAs this will result in stark choices for the pharmacist – close and deprive those in need of medicines or break the law by allowing an, up until now completely qualified and legal, PA to dispense in their absence.
It is my opinion that in its current form the draft rules are an attempt by the PSI to mitigate a situation that has been in effect for 126 years and that will itself be non-existent in a very short number of years – perhaps a shorter number of years than would be required for a resolution to a legal challenge to the proposed changes/rules should it be deemed necessary. I would imagine the cost and reputational damage the PSI and those heading the regulatory body would accrue over the lifespan of any legal challenge would ensure that any victory, should its position be deemed lawful, would itself be pyrrhic.
The proposed changes are simply a dismissal of pharmaceutical assistants and will result in a service provided to the public that is shorn of their vast experience – in short, a lesser service, and a result completely at odds with the goals of the PSI.


Pharmacy Regulations 798. Deputy Bríd Smith asked the Minister for Health Simon Harris to ensure there will be no changes to the definition of temporary absence of a pharmacist in view of the fact that some proposed changes could have dramatic effects on the working arrangements of pharmaceutical assistants who have experience and skill at their jobs; and if he will make a statement on the matter. [46756/17]

Minister of State at the Department of Health (Deputy Catherine Byrne): Pharmaceutical Assistants (PAs) are registered with the pharmacy regulator, the Pharmaceutical Society of Ireland (PSI). Under section 30(1) of the Pharmacy Act 2007 (the Act) PAs may perform the same functions as a pharmacist, in the temporary absence of a pharmacist, with the exception of functions that are restricted to pharmacists under specific medicines legislation, such as vaccination services. Since 1994, the provisions of “temporary absence” have been understood with reference to a Code of Practice agreed that year between the PSI and the Pharmaceutical Assistants’ Association (PAA).

Section 30(2) of the Pharmacy Act 2007 provides that the PSI Council may make Rules, with the consent of the Minister, to provide further as to what constitutes the temporary absence of a registered pharmacist and what may or may not be done by a PA when acting on behalf of a pharmacist. In 2013, the PSI Council directed that a policy position be developed to enable and facilitate the drafting of rules relating to the circumstances in which a registered PA may act in the temporary absence of a registered pharmacist in line with the requirements of Section 30(2) of the Act. The PSI Registration and Qualification Recognition Committee (RQR) was assigned responsibility to progress this work. A Pharmaceutical Assistant was sought to join this Committee and was appointed by the PSI Council in March 2014. The PSI developed the draft Pharmaceutical Society of Ireland (Regulation of Temporary Absence Cover by Pharmaceutical Assistants) Rules 2016 following debate and engagement with interested parties including the Pharmaceutical Assistants Association (PAA). The draft Rules were issued for public consultation on 8 February 2016. Following discussion at the PSI Council meeting of 23 March 2017, and taking account of the responses received through the consultation process, the Council decided not to submit the draft Rules to me for approval. The Council instead directed that the matter be re-examined by the PSI Executive with further consideration to be given to what could be covered within the scope of the Rules. In making its decision at this meeting the Council confirmed that the current approach to regulating temporary absence by PSI inspection staff under the 1994 Code of Practice would continue to apply pending the future adoption of statutory Rules. A working group consisting of 6 persons (two Council members, two PSI staff members, and two external participants – a Pharmaceutical Assistant and a person with regulatory and risk expertise) was then established to provide expertise, advice and input to assist in developing policy options and drafting rules. To date this group has met three times, and I understand the group will recommend a position to the Council in the coming months.


First Qualified Assistant invited to address council in 126 years!

“As Registrar,President and Council members you will go down in history as a group who brought about the demise of a group of elderly mainly women graduates of your own formulated, validated and examined qualification. We are not seeking anymore than
the terms we qualified under on the day we qualified.
I hope I have done some justice to all my fellow colleagues, a fantastic, committed, loyal, dependable ,professional group . What a loss you would all be to the Profession of Pharmacy.”

PAA Presentation to PSI Council March 2017

Please click on above link to view full text of presentation

Next PSI Council Meeting : 22nd March 2018

Council meetings take place in public at the PSI office, which is located at PSI House, 15-19 Fenian St, Dublin 2. Meeting agendas are normally published one week in advance of the meeting.
Should you wish to attend please contact Éanna Ó Lochlainn (eanna.olochlainn@psi.ie) at least one working day in advance of the meeting, stating any particular access requirements you may have.

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