Professional Autonomy and Patient Safety Before Corporate Profit

The Pharmacist Cooperative is a collective of practising pharmacists across UK who are committed to defending the professional autonomy and clinical independence of pharmacists. We represent pharmacists working in community, hospital, primary care and independent settings.

Our founding principle is that professional autonomy and patient safety must take precedence over corporate profit motives and government cost-cutting measures. We believe that pharmacists are clinical professionals first and foremost, and that any regulatory framework must recognise and protect that status.

We welcome the opportunity to respond to this consultation on the draft rules and standards for Responsible Pharmacists and the draft standards for Superintendent Pharmacists. We have analysed all four parts of the consultation document  and the accompanying draft statutory instrument in detail.

The Pharmacist Cooperative broadly supports the GPhC's objectives of strengthening pharmacy governance, clarifying accountability and improving patient safety. We agree that the Pharmacy (Responsible Pharmacists, Superintendent Pharmacists etc.) Order 2022 provides a necessary legislative framework.

However, we have serious concerns about several aspects of the draft proposals, and we are putting them on record here.

First, the proposed standards place considerable regulatory burden on individual pharmacists, particularly Responsible Pharmacists, without adequately addressing the structural conditions that prevent them from meeting those standards. A pharmacist who is understaffed, under-resourced and working under commercial pressure from a corporate employer cannot simply be told to "prioritise patient safety" unless the system around them enables that. The standards must be paired with enforceable obligations on pharmacy owners.

Second, the authorisation framework introduced by the Human Medicines (Authorisation by Pharmacists and Supervision by Pharmacy Technicians) Order 2025 is presented as "enabling" legislation, but in practice it transfers workload and liability without transferring authority or resources. Pharmacists will be held accountable for authorisation decisions they make under commercial pressure, in settings where staffing is determined by non-pharmacist business managers. That is a recipe for patient harm, not patient safety.

Third, the two-hour absence rule for Responsible Pharmacists is unfit for a profession that now provides clinical services including vaccinations, blood pressure checks, Pharmacy First consultations and independent prescribing. A pharmacist conducting a 40-minute clinical consultation is technically "absent" from the dispensary. The rule needs rethinking.

Fourth, the consultation says very little about what happens when a pharmacist identifies a safety concern but is overruled by commercial management. The standards speak of "professional judgement" but do not create any meaningful protection for pharmacists who exercise it against their employer's commercial interests. Without whistleblower protections embedded in the standards themselves, the entire framework is hollow.

We set out our detailed responses to each consultation question below.

Section 1: Standards for Superintendent Pharmacists

Question 1: Do you think we should set additional minimum requirements for a pharmacist to become a Superintendent Pharmacist?

The Pharmacist Cooperative response: Yes

The role of Superintendent Pharmacist carries significant legal and professional responsibility. Allowing any registered pharmacist, regardless of post-qualification experience, to take on this role is inadequate for the protection of both patients and the profession.

We recommend a minimum of five years' post-registration experience, with at least two of those years in a senior or management role within pharmacy. The SP should also be required to demonstrate continuing professional development in governance, leadership and regulatory compliance.

It is well established in other healthcare professions that senior regulatory roles carry experience requirements. A newly qualified pharmacist should not be overseeing the governance of a multi-site corporate pharmacy chain. That is common sense, and the current lack of requirements on this point is a gap the GPhC should close.

We would also ask the GPhC to consider requiring the SP to hold independent prescriber status, given that the SP sets clinical governance frameworks for pharmacies increasingly involved in clinical services.

Question 2: When a Superintendent Pharmacist leaves their role or is unable to perform their responsibilities due to an extended period of absence, do you think it is reasonable for the GPhC to require pharmacy owners to appoint a new permanent or interim Superintendent immediately?

The Pharmacist Cooperative response: Yes

Patient safety cannot have a gap. If a pharmacy business operates without a qualified SP in post, governance collapses. 

The requirement for immediate replacement should be strict. We would define "immediately" as within 72 hours. If a pharmacy business cannot identify a replacement SP within that timeframe, it should be required to notify the GPhC and demonstrate what interim governance arrangements are in place.

We note that the GPhC proposes succession planning requirements within the SP standards. That is welcome. But succession planning on paper is meaningless if corporate owners do not invest in developing pharmacists for senior roles. The GPhC should require evidence of active succession planning during inspections, not just a policy document gathering dust in a shared drive.

Question 3a: In the interests of patient and staff safety, do you think the standards will strengthen the safe and effective running of a pharmacy business?

The Pharmacist Cooperative response: Yes, with reservations

The five proposed SP standards are reasonable on paper. Strategic leadership, workforce development, responsible delegation, governance and premises safety are all areas that need strengthening.

Our reservation is that these standards are only as strong as the GPhC's willingness to enforce them against powerful corporate pharmacy owners. Boots, Well and other large chains have historically treated SP roles as a compliance checkbox rather than a genuine clinical leadership position. The SP is frequently a remote figurehead with no real authority over local staffing, budgets or operational decisions.

If the GPhC is serious about these standards, it must be prepared to take enforcement action against pharmacy owners who undermine the SP's ability to meet them. Standard 1 says the SP must "have a clear vision and strategy to deliver safe and effective pharmacy services." That is meaningless if the SP's employer gives them no budget, no staff and no authority to implement that vision.

We therefore support the standards, but only if the GPhC simultaneously strengthens its enforcement against corporate owners who create the conditions in which SPs cannot realistically meet the standards.

Question 3b: Do you think the standards will clarify the role of the Superintendent Pharmacist, making their accountabilities and responsibilities clear?

The Pharmacist Cooperative response: Yes, with reservations

The draft standards do a better job than the current arrangements of setting out what an SP should be doing. The inclusion of examples is helpful.

However, the standards still do not adequately address the fundamental power imbalance. An SP employed by a corporate owner is accountable to the GPhC for governance, but answerable to their employer for their job. When the employer's commercial interests conflict with patient safety, which master does the SP serve? The standards assume this tension does not exist, or that it can be resolved through professional judgement alone.

We recommend the standards explicitly require pharmacy owners to provide SPs with the authority, resources and contractual protections necessary to fulfil their regulatory role. The SP's employment contract should be required to include a clause confirming their professional independence in matters of patient safety. The GPhC should inspect for this.

Question 4: Are there any other standards you think should be included for Superintendent Pharmacists?

The Pharmacist Cooperative response: Yes

We recommend the addition of a standard requiring SPs to maintain a minimum level of direct patient-facing practice. An SP who has not dispensed a prescription, counselled a patient or conducted a clinical service in years is poorly placed to set clinical governance standards.

We also recommend a standard requiring SPs to engage meaningfully with pharmacy staff at all levels. Too many SPs in corporate settings have never visited the majority of the pharmacies they oversee. The standard should require documented evidence of regular engagement with frontline pharmacy teams.

Finally, we recommend a standard on transparency. The SP should be required to publish, or make available to the GPhC on request, data on staffing levels, dispensing volumes, error rates and patient complaints across the pharmacies they oversee. Without data, accountability is impossible.

Question 5: Is there anything else related to the standards for Superintendent Pharmacists that you would like to raise?

The Pharmacist Cooperative response: Yes, we have additional comments

The standards say nothing about the SP's obligation to resist commercial pressure from pharmacy owners. In practice, many SPs are employed on terms that make them subordinate to non-pharmacist commercial directors. They can be overruled on staffing decisions, service provision and even clinical governance by people who are not registered professionals and owe no duty to patients.

The GPhC must use these standards to create a regulatory expectation that the SP's professional judgement on patient safety matters is final within the organisation. If an SP raises a safety concern and is overruled by commercial management, that should be treated as a potential regulatory breach by the pharmacy owner, not a failure by the SP.

Section 2: Standards for Responsible Pharmacists

Question 6: Do you think we should set minimum requirements for a pharmacist to become a Responsible Pharmacist?

The Pharmacist Cooperative response: Yes

Every registered pharmacy in Great Britain must have an RP present and signed in. The RP is personally responsible for the day-to-day safe and effective running of that pharmacy. This is a significant responsibility that should carry minimum requirements.

We recommend a minimum of one year's post-registration experience before a pharmacist can take on the RP role. During that first year, a pharmacist should work under the supervision and mentorship of an experienced RP.

The reality is that newly qualified pharmacists are routinely placed as sole RP in community pharmacies on their first day of practice. They are expected to manage dispensing, clinical services, staff supervision, controlled drugs, error reporting and patient consultations with no support. This is not safe, and it is not fair on those pharmacists.

We recognise this creates a workforce planning challenge. But the answer to the non-existant pharmacist shortage is not to lower the bar for the RP role. The answer is to improve working conditions, pay and professional recognition so that more pharmacists want to work in community pharmacy.

Question 7: What records do you think are the responsibility of the Responsible Pharmacist?

The Pharmacist Cooperative response: 

  The pharmacy record (Rule 4 - RP name, registration, sign-in/out, absences) 

  Dispensing intervention records (clinical checks, dose queries, refusals) 

  Clinical consultation records (Pharmacy First, NMS, prescribing clinics) 

  Controlled drugs register entries 

  Patient safety incident and near-miss reports

  Authorisation records under the 2025 supervision legislation 

  Staff on duty logs 

  Complaints received and initial actions 

  Equipment/IT/premises failure logs

Question 8a: In the interests of patient and staff safety, do you think the standards will strengthen the day-to-day running of the pharmacy?

The Pharmacist Cooperative response: Yes, with reservations

The four proposed RP standards address the right topics: patient safety, leadership and management, authorisation responsibility and governance.

Our concern is the gap between the standard on paper and the reality on the ground. Standard 2 says the RP must "provide the leadership and management needed to ensure the safe and effective operation of the pharmacy." In many community pharmacies, the RP is a sole pharmacist working a 12-hour shift with inadequate support staff, no breaks and no cover. They cannot provide leadership because they are drowning in prescriptions.

The standards need to be accompanied by an explicit recognition that the RP can only meet them if the pharmacy owner provides adequate staffing, resources and working conditions. Without that, the standards become a stick to beat individual pharmacists with, while corporate owners escape accountability.

Question 8b: Do you think the standards will clarify the role of the Responsible Pharmacist, making their accountabilities and responsibilities clear?

The Pharmacist Cooperative response: Yes

The standards are clearer than the current arrangements in setting out what an RP should be doing. The relationship between the RP, SP and pharmacy owner is better defined.

We particularly welcome the explicit statement that the RP shares responsibility with the pharmacy owner and SP for the safe running of the pharmacy. This shared accountability is important. Too often the RP has been treated as the sole fall person when things go wrong, while the corporate owner who created the unsafe conditions escapes scrutiny.

Question 9: Are there any other standards you think should be in place for the Responsible Pharmacist?

The Pharmacist Cooperative response: Yes

We recommend a standard on working conditions. The RP should have a right, enshrined in the standards, to refuse to operate the pharmacy if staffing falls below safe levels. At present, pharmacists who refuse to open the pharmacy when understaffed face disciplinary action from their employer. The GPhC should make clear that an RP who closes or restricts services on safety grounds is meeting their professional obligations, not failing them.

We also recommend a standard on protected time for clinical services. With Pharmacy First and the expansion of independent prescribing, RPs are expected to provide complex clinical consultations. They cannot do this while simultaneously supervising dispensing. The standards should require that adequate arrangements are in place to cover the dispensary when the RP is providing clinical services.

Additionally, we recommend a standard on the RP's right to report safety concerns without retaliation. The standards mention whistleblowing policy, but they should go further. An RP who escalates a safety concern to the GPhC should be explicitly protected by the standards.

Question 10: Is there anything else related to the standards for Responsible Pharmacists that you would like to raise?

The Pharmacist Cooperative response: Yes, we have additional comments

The standards do not address the growing issue of remote and distance-selling pharmacies. RPs working in these settings face different challenges: they may never see the patient, they rely on technology platforms controlled by their employer and they may be expected to clinically check prescriptions at unsustainable rates.

The standards should include specific provisions for RPs in distance-selling pharmacies, including maximum prescription-checking volumes per hour and mandatory breaks.

We are also concerned about the increasing use of locum pharmacists as RPs. Locum pharmacists often arrive at a pharmacy they have never visited, with no induction, no knowledge of  SOPs and no relationship with the staff team. The standards should require that every locum RP receives a minimum documented induction before signing in as RP.

Section 3: Rules for Responsible Pharmacists

Question 11: Do you agree with our proposal to continue with the present 'one pharmacy' rule?

The Pharmacist Cooperative response: Yes

The one-pharmacy rule is a fundamental protection for patient safety. An RP can only be responsible for one premises at a time because they need to be physically present, available and engaged with the pharmacy they are overseeing.

We are concerned that some corporate owners have attempted to circumvent this rule by pressuring pharmacists to "cover" neighbouring pharmacies informally. The rule must be strictly enforced, and the GPhC should make clear that any arrangement where a pharmacist has practical responsibility for more than one premises at a time is a breach of the rules, regardless of where they are formally signed in.

We also note that the rule states the RP cannot perform the role from any location other than the pharmacy where they are signed in. This is right. Remote RP roles are not appropriate for community pharmacy.

Question 12: Do you agree with our proposal to continue with the current two-hour absence rule?

The Pharmacist Cooperative response: No

No - the two-hour absence rule should be abolished entirely

The Pharmacist Cooperative opposes any permitted absence rule. We believe no absence from the pharmacy should be allowed during opening hours, with the sole exception of a lunch break.

Our position is based on what we have witnessed in practice. The two-hour absence rule has been systematically abused by large corporate chains, most notably Boots, to operate pharmacies without a pharmacist physically present. The way this works is straightforward: the pharmacist is asked to sign in as RP up to two hours before they actually arrive at the pharmacy, or to remain signed in for up to two hours after they have left. This allows unregistered staff to continue working, dispensing and serving patients without a pharmacist on the premises. The two-hour rule was never intended to enable this, but that is exactly how it is being used.

This practice is dangerous. During those two hours, there is no pharmacist available to carry out clinical checks, intervene in dispensing errors, answer patient queries about medication, manage controlled drugs or respond to clinical emergencies. Patients entering the pharmacy have no way of knowing that the person whose name is on the RP notice is not actually in the building.

The GPhC knows this is happening. Yet enforcement has been inconsistent. By retaining the rule, the GPhC is giving corporate employers a regulatory loophole to reduce pharmacist staffing costs at the expense of patient safety.

We accept that a pharmacist may need to take a lunch break during a long shift. That is a basic employment right. But a lunch break is a planned, short absence, typically 30 minutes, during which the pharmacy can either close or restrict services. That is very different from a systematic arrangement where the pharmacy operates for two hours each day without a pharmacist.

The GPhC's own consultation document states that a pharmacy cannot operate without a Responsible Pharmacist being signed in and in charge. If the RP is not physically present, they are not "in charge" in any meaningful sense. The two-hour rule contradicts the very principle it sits alongside.

We recommend the following. First, the two-hour absence rule should be removed entirely. Second, the only permitted absence should be for a meal break of up to 30 minutes, during which the pharmacy must either close to dispensing or have another pharmacist cover. Third, if a pharmacist is providing clinical services elsewhere on the premises (for example in a consultation room), this should not count as an absence, because the pharmacist is still present in the building and available if needed. Fourth, the GPhC should investigate and take enforcement action against pharmacy owners who have been using the two-hour rule to operate without a pharmacist present.

Question 13: Is there anything else related to the rules for Responsible Pharmacists that you would like to raise?

The Pharmacist Cooperative response: Yes, we have additional comments

We also note that Rule 5 on authorisations is new and reflects the supervision legislation changes. We have concerns about the practical implementation of this rule. The RP must be "aware of" all authorisations, but in a busy pharmacy with multiple pharmacists and pharmacy technicians, this is operationally difficult. The rule should require the pharmacy owner to provide systems that make this information readily accessible to the RP, rather than placing the burden on the individual pharmacist to seek it out.

Section 4: Standards for registered pharmacies

Question 14: Do you agree with the inclusion of 'any other product intended for supply or administration' under Principle 4 of the standards?

The Pharmacist Cooperative response: Yes

This is a sensible and necessary update. Pharmacies now supply a wide range of products beyond traditional medicines, including medical devices, point-of-care diagnostic tests, food supplements marketed with health claims and products used in clinical services. The current restriction to medicines and medical devices leaves a regulatory gap.

However, we would ask the GPhC to clarify what "any other product intended for supply or administration" covers. The wording is broad and could potentially capture products like sun cream, cosmetics or food items sold in a pharmacy. Some definition or guidance would help RPs and SPs understand the scope of this change.

Question 15: Do you agree with the inclusion of a specific standard around consent?

The Pharmacist Cooperative response: Yes

This is overdue. Pharmacies are increasingly providing clinical services that involve physical examination, diagnosis and treatment. Informed consent is a basic requirement for any clinical interaction.

The consent standard should require that consent is obtained, documented and specific to the service being provided. It should also address the capacity to consent, including provisions for patients who lack capacity under the Mental Capacity Act 2005.

We would also urge the GPhC to ensure that the consent standard covers commercially motivated services such as private testing and screening services. There is a growing market in pharmacy-based health screening that is sometimes driven more by revenue than clinical need. Patients must be able to give informed consent to these services, including understanding the limitations of the tests being offered.

Question 16: Is there anything else you think could put patient safety at risk and should be changed or added to the standards for registered pharmacies before the full review?

The Pharmacist Cooperative response: Yes - several issues require urgent attention before the full review

1. Minimum staffing levels. The single biggest threat to patient safety in community pharmacy is inadequate staffing. Pharmacists working alone, without adequate support staff, make more dispensing errors and provide lower-quality clinical care. The GPhC should set minimum staffing ratios linked to dispensing volume and service provision. At a minimum, any pharmacy dispensing more than 2,000 items per month should have at least one pharmacist and one registered pharmacy technician present at all times during opening hours. Pharmacies providing clinical services under Pharmacy First or independent prescribing should have additional staffing to cover the dispensary while the pharmacist is consulting.

2. Maximum working hours without breaks. Pharmacists routinely work shifts of 10 to 13 hours without a proper break. This is unsafe. Tired pharmacists make mistakes. The standards should require pharmacy owners to provide a minimum 30-minute uninterrupted break for any shift exceeding 6 hours, and a minimum 60-minute break for shifts exceeding 10 hours. This is a basic employment right that the pharmacy sector has ignored for decades, and it has a direct bearing on patient safety.

3. Safe dispensing volumes. There is no maximum on the number of prescriptions a single pharmacist can be expected to clinically check in one day. In some high-volume pharmacies, pharmacists are checking 300 to 400 items per day while simultaneously running clinical services, managing staff and answering patient queries. The GPhC should commission research into safe dispensing volumes and set guidance on maximum items per pharmacist per day.

4. Pharmacy closures and service reductions. When a pharmacy cannot be safely staffed, the RP should have an explicit right under the standards to close the pharmacy or restrict services without facing disciplinary action from the employer. At present, pharmacists who close pharmacies on safety grounds are frequently disciplined or dismissed. The standards should protect them.

5. Accountability of pharmacy owners. The current standards for registered pharmacies place obligations on the pharmacy but not directly on the owner. Where a pharmacy owner's decisions on staffing, investment or service provision create unsafe conditions, the GPhC should be able to take enforcement action against the owner directly, not just against the pharmacy premises or the individual pharmacist.

Question 17: Is there anything you would like to raise now for us to consider when we carry out the full review of the standards for registered pharmacies?

The Pharmacist Cooperative response: Yes - the full review should address the following

1. Pharmacy ownership models and patient safety. The GPhC should examine whether certain ownership models pose greater risks to patient safety than others. There is growing evidence that pharmacies owned by private equity-backed companies, large corporate chains and vertically integrated businesses (where the pharmacy owner also owns the prescribing service or the wholesale supply) face particular commercial pressures that affect staffing, investment and clinical independence. The standards should require pharmacy owners to demonstrate that their business model and corporate structure do not compromise patient safety or the professional autonomy of their pharmacists.

2. Technology and digital platform standards. PMR systems, prescription tracking software, robotic dispensing equipment, remote consultation platforms and electronic CD registers all need to meet minimum standards for reliability, accuracy, interoperability and data security. Some pharmacies are still running PMR systems that are decades old and no longer fit for purpose. The GPhC should set minimum technology standards for registered pharmacies and require pharmacy owners to invest in systems that support safe practice.

3. Physical accessibility. Many community pharmacies operate from premises that are not fully accessible to people with physical disabilities, wheelchair users, people with pushchairs or people with sensory impairments. Consultation rooms are frequently too small to accommodate a wheelchair. This is both a patient safety issue and an equality issue. The full review should introduce minimum accessibility requirements for pharmacy premises.

4. Environmental standards. Pharmacies increasingly provide clinical services including vaccinations, blood tests and physical examinations. The premises standards should be updated to reflect the clinical environment needed for these services, including appropriate hand-washing facilities, clinical waste disposal, infection control measures and adequate consultation room size.

5. The full review should consider the impact of pharmacy closures on patient access to services. Between 2015 and 2025, over 1,200 pharmacies closed in England alone. Many of these were in deprived or rural areas where the pharmacy was the only easily accessible healthcare provider. The standards should address the GPhC's role in monitoring and responding to reductions in pharmacy access.

6. The relationship between the standards for registered pharmacies and the new SP and RP standards. There is a risk of overlap, confusion and gaps between the three sets of standards. The full review should ensure they work together as a coherent framework rather than three separate documents that may contradict or duplicate each other.

Section 5: Standards for pharmacy professionals

Question 18: Do you agree with our proposal to publish an annex to the standards for pharmacy professionals to cover authorisation?

The Pharmacist Cooperative response: Yes, with reservations

We agree that an annex is needed to clarify the authorisation framework. The supervision legislation changes are significant and pharmacy professionals need clear guidance on what is expected of them.

Our reservation is that the annex, as drafted in Part D, places the weight of responsibility on individual pharmacists while saying very little about the obligations of pharmacy owners and employers to create the conditions in which authorisation can be used safely.

Authorisation is presented as an "enabling" change. In reality, it will be used by corporate employers to reduce pharmacist staffing. If a pharmacy technician can be authorised to dispense medicines, the commercial incentive is to replace pharmacist hours with pharmacy technician hours. This is cheaper for the employer but transfers risk to the authorising pharmacist, who remains professionally accountable for every authorisation they give.

The annex should explicitly state that authorisation must not be used as a substitute for adequate pharmacist staffing. The authorising pharmacist must have sufficient time and capacity to properly assess whether authorisation is appropriate in each case, to monitor the quality of work done under authorisation and to be available for advice and intervention.

Question 19: Is there anything else you think could put patient safety at risk and should be changed or added to the standards for pharmacy professionals before the full review?

The Pharmacist Cooperative response: Yes - several issues need addressing before the full review

1. Commercial pressure on professional judgement. This is the most urgent patient safety risk in pharmacy today that the standards do not adequately address. Pharmacists working in corporate settings are routinely set targets for dispensing volumes, service provision numbers, hypertension case finding and NMS completions, and product sales. These targets are tied to performance reviews, bonuses and in some cases continued employment. When a pharmacist is told they must complete eight Pharmacy First consultations per day alongside dispensing 250 items, something has to give. The standards should explicitly state that a pharmacy professional must never allow commercial targets set by their employer to override their clinical judgement. The GPhC should treat an employer who disciplines a pharmacist for failing to meet commercial targets where patient safety was the reason as a potential fitness-to-practise concern against the pharmacy owner.

2. Adequate rest and safe working conditions. Pharmacy professionals cannot provide safe care when they are exhausted, hungry or working without breaks. The standards currently say nothing about this. They should. A pharmacist who has been working for ten hours without a break is a risk to patients, however competent and well-intentioned they may be. The standards should require employers to provide working conditions compatible with safe practice, including adequate breaks, manageable workloads and reasonable shift patterns. The Working Time Regulations 1998 already provide for rest breaks, but they are routinely ignored in community pharmacy. The GPhC should make compliance with basic employment law a professional standards issue.

3. Protection for raising concerns. The standards for pharmacy professionals include a duty of candour and a duty to raise concerns. But they say nothing about what happens when a pharmacist raises a concern and faces retaliation from their employer. We have members who have been disciplined, moved to less desirable locations, had their hours cut or been dismissed after raising safety concerns with the GPhC or with their employer. The standards should explicitly protect pharmacy professionals who raise legitimate safety concerns, and the GPhC should treat employer retaliation against a whistleblowing pharmacist as a serious regulatory matter.

4. The authorisation framework and its impact on pharmacy technicians. The new supervision legislation allows pharmacists to authorise pharmacy technicians to carry out dispensing tasks. The standards should address the pressure that pharmacy technicians may face to accept authorisations they are not comfortable with. In corporate settings, pharmacy technicians may feel unable to say no to an authorisation if it means the pharmacy cannot function. The standards should reinforce that pharmacy technicians have an absolute right to refuse an authorisation without facing any adverse consequences.

5. Locum pharmacists and continuity of care. The standards should address the particular challenges faced by locum pharmacists. A locum may work in a different pharmacy every day. They arrive with no knowledge of the local team, the patient population, the SOPs or the particular risks of that premises. The standards should require that every pharmacy has a documented induction process for locum pharmacists and that no locum is expected to sign in as RP without first receiving that induction.

Question 20: Is there anything you would like to raise now for us to consider when we carry out the full review of the standards for pharmacy professionals?

The Pharmacist Cooperative response: Yes - the full review should address the following issues

1. Recognition of different practice settings. The current standards for pharmacy professionals were written primarily with community pharmacy in mind. The profession has changed. Pharmacists now work as independent prescribers in GP surgeries, in urgent care centres, in care homes, in prisons, in specialist hospital roles, in public health and in distance-selling pharmacies. The full review should adapt the standards to recognise these different settings and the different challenges they present. A one-size-fits-all approach no longer works.

2. Mental health and wellbeing. There is growing evidence of burnout and psychological harm among pharmacy professionals. The Pharmacists' Defence Association has reported year-on-year increases in pharmacists seeking support for work-related stress. The GPhC registrant survey showed declining job satisfaction. The standards should require employers to actively support the mental health and wellbeing of their pharmacy professional staff, including access to occupational health services, employee assistance programmes and reasonable workloads. This is not a "nice to have." A pharmacist in psychological distress is a patient safety risk.

3. Protected learning time and funded CPD. Every pharmacy professional should have access to regular, funded continuing professional development time during working hours. At present, most pharmacists complete their CPD in their own unpaid time, often late at night after a long shift. This is unacceptable for a profession that the GPhC expects to maintain high standards of clinical competence. The standards should require employers to provide a minimum number of paid CPD hours per year. Other healthcare professions have protected learning time built into their contracts. Pharmacy should be no different.

4. Independent prescribing and scope of practice. As more pharmacists qualify as independent prescribers, the standards need to address prescribing practice. This includes requirements for clinical supervision, peer review, access to patient records, continuing prescribing competence and the governance framework within which prescribing takes place. The current standards say very little about prescribing specifically.

5. Multi-disciplinary working. Pharmacists increasingly work alongside GPs, nurses, paramedics and other healthcare professionals. The standards should reflect this and set clear expectations about collaborative practice, information sharing, referral pathways and professional boundaries.

6. The impact of artificial intelligence and automation. Pharmacy is beginning to adopt AI-assisted dispensing checks, robotic dispensing, automated stock management and AI-driven clinical decision support. The standards should address the professional responsibilities of pharmacy professionals when using these technologies, including the requirement to maintain professional oversight and not blindly defer to automated systems, AI developers taking responsibility for mistakes made by their product. 

7. Fair and proportionate regulation. We ask the GPhC to use the full review to examine whether its regulatory approach is proportionate and fair. There is a widespread perception among pharmacists that the GPhC is quicker to take enforcement action against individual pharmacists than against corporate pharmacy owners. If the standards are to command the respect and compliance of the profession, they must be seen to apply equally to everyone, including the large corporate employers who set the conditions in which pharmacists work.

Impact of the proposals

Question 21: Do you think our proposals will have a positive or negative impact on individuals or groups who share any of the protected characteristics?

The Pharmacist Cooperative response: Positive and negative impact

Age: Positive and negative. The standards should benefit older patients who rely heavily on pharmacy services. However, older pharmacists who are approaching retirement may find the additional regulatory burden disproportionate. Younger pharmacists will be most affected by any minimum experience requirements for the RP and SP roles.

Disability: Positive impact. The inclusion of consent standards and the requirement for accessible premises will benefit people with disabilities. However, the GPhC should ensure that the standards explicitly address reasonable adjustments for patients with communication difficulties, learning disabilities and sensory impairments.

Sex: Negative impact potential. Women make up the majority of the pharmacy workforce. Many work part-time. The increased accountability and governance requirements may disproportionately affect part-time pharmacists who have less control over the pharmacy environment.

Race: The GPhC should monitor whether enforcement of the new standards disproportionately affects pharmacists from ethnic minority backgrounds, as there is evidence of disparity in fitness-to-practise proceedings across healthcare regulators.

Pregnancy and maternity: The succession planning requirements for SP and RP roles should explicitly address maternity leave and ensure that pregnant pharmacists are not disadvantaged.

For all other protected characteristics, we consider the impact to be neutral or positive.

Question 22: Do you think our proposals will have a positive or negative impact on any of the listed groups?

The Pharmacist Cooperative response: Positive and negative impact

Patients and the public: Positive impact, provided the standards are enforced. Patients will benefit from clearer accountability, better governance and explicit consent requirements. However, if the standards drive up costs for pharmacy owners without corresponding funding, some pharmacies may close, reducing access to pharmacy services in deprived or rural areas.

Responsible Pharmacists: Positive and negative impact. The clearer role definition is welcome. The increased accountability, without corresponding improvements in working conditions, is a concern. RPs already carry significant personal liability. Adding further expectations without addressing staffing, workload and working conditions may drive more pharmacists away from community pharmacy.

Superintendent Pharmacists: Positive and negative impact. The standards give SPs a clearer framework to work within. However, SPs employed by corporate owners may find the gap between what the standards require and what their employer allows them to do is unbridgeable.

Pharmacy owners/employers: Positive and negative impact. Good employers will find the standards consistent with their existing practice. Employers who have relied on minimal governance and low staffing to maximise profit will find the standards challenging, as they should.

Pharmacy staff: Positive impact. The emphasis on workforce development, training, wellbeing and a culture of safety should benefit all pharmacy staff.

Other healthcare professionals: Positive impact. Clearer pharmacy governance should improve multi-disciplinary working.

Students and trainees: Positive impact. The emphasis on mentoring, supervision and competency development is welcome.

The Pharmacist Cooperative appreciates the opportunity to contribute to this consultation. The GPhC's proposals, if implemented with proper enforcement and adequate support for frontline pharmacists, have the potential to improve pharmacy governance and patient safety.

We urge the GPhC to remember that standards on paper are worth nothing if the structural conditions prevent pharmacists from meeting them. Corporate pharmacy owners must be held to the same level of accountability as individual pharmacists. It is not acceptable for a regulator to set high expectations of professionals while allowing their employers to create the conditions that make failure inevitable.

Professional autonomy is not a luxury. It is the foundation of safe pharmacy practice. When a pharmacist's professional judgement is overridden by commercial targets, it is the patient who suffers. The GPhC must use these standards, rules and enforcement powers to protect professional autonomy alongside patient safety.

We are happy to discuss any aspect of this response in more detail and to work with the GPhC as these proposals are finalised.