PDA slams ‘incomprehensible’ draft GPhC guidance on EDI risk assessments
The PDA has branded aspects of the GPhC’s draft equality guidance for pharmacies “incomprehensible” and stressed that pharmacy owners “must” conduct separate risk assessments for each pharmacy premises to prevent poor practice.
The draft equality, diversity and inclusion (EDI) proposals – which the General Pharmaceutical Council (GPhC) consulted on from March 31 to May 26 – suggest that pharmacy owners with multiple sites “do not have to carry out a specific, separate, risk assessment at every pharmacy”, but that they should still consider “the circumstances of each individual pharmacy”.
The Pharmacists' Defence Association (PDA) used its response to the consultation to argue that pharmacy owners should instead carry out specific risk assessments at each of their branches, and suggested that the GPhC amends its wording to reflect this.
What does the GPhC mean by "risk assessments"?
In a document outlining its draft proposals, the GPhC said that pharmacy owners should conduct targeted risk assessments to identify if anything in their pharmacy “could prevent patients from accessing pharmacy services or prevent staff from providing services”.
If risks are identified, pharmacy owners should “provide clear recommendations” on how they should be addressed and “timescales” for carrying them out.
The GPhC gave the example of a pharmacy owner who acknowledged “that people from black, Asian and minority ethnic backgrounds, as well as some other groups, are being disproportionately affected by COVID-19” and took measures to protect both staff and patients. For example, they arranged to deliver medication to the homes of exceptionally vulnerable patients “so that they didn’t have to come into the pharmacy”.
“We find the suggestion made in the proposal that there is no need for each premises to have undertaken a risk assessment incomprehensible,” the PDA stated in its response, published last week (July 1).
Some pharmacy chains own more than 1,000 branches across Great Britain, it pointed out, which prompted the PDA to question how “a generic risk assessment” could be suitable to different realities.
In its current state, “the guidance [would be] exceptionally easy to apply for large corporate pharmacy owners”, the PDA added.
C+D has approached the GPhC for comment.
Current guidance “likely to lead to poor practice”
The PDA claimed it was “simply unrealistic” that “large corporate owners” would take the GPhC equalities guidance “seriously […] without an obligation being imposed for a specific risk assessment at each individual premises”.
Were the above proposal to come into force as it is, it would have a negative impact on patients, the public and pharmacy staff, the PDA claimed, as well as individuals or groups with protected characteristics, as it “is likely to lead to poor practice and pose a risk to patients”.
While pharmacy owners might initially welcome the GPhC’s suggestion that they do not need to assess premises individually, they might “expose themselves to risk of prosecution by other agencies”, the PDA warned.
Additional suggestions
The EDI proposals “will allow the same inequalities to persist as the proposals are inadequate unless some significant changes are made”, the PDA summarised.
The PDA further suggested that the GPhC explicitly link its EDI guidance to its inspection framework and that each inspection report should contain a subsection in the “summary findings”, specifying whether a premises had applied the GPhC equalities guidance.
Inspectors should also “be trained to a consistent standard” so they can “include EDI considerations as part of the overall premises inspection”, it added.
“Failure by the premises owner to demonstrate how the equalities guidance has been applied in that particular premises for each individual principle should automatically lead to a ‘standard not met’ outcome for that principle and an overall ‘standard not met’,” the PDA said.
