By David J
The misnamed PSI, our beloved regulator has called for submissions on mail order pharmacy in Ireland. See here for details. They have given this the innocent sounding name of “Public Consultation on draft Guidance on the Delivery of Prescription-only Medicines from a Retail Pharmacy Business (Pharmacy)” but make no mistake this is all about mail order pharmacy. And be under no illusion if this is permitted then it will be a game changer in Irish pharmacy.
The Regulation of Retail Pharmacy Business Regulations 2008 (S.I. No. 488 of 2008) specifically makes mail order pharmacy illegal for many good reasons. But it now seems that some in the PSI, for whatever motivation would like to drive a coach and four through these regulations. I doubt that any of the community pharmacists (past, present or recently resigned) on the Council would be among those who seek to do so. To go further I have heard whispers that those pharmacists have been threatened with the Competition Authority when they sought to put a halt to this coach and four.
It’s is a sad day when some of those charged with enforcing the law are threatened with the Competition Authority when they seek to do just that.
I intend to make a submission and to publish it here when I do so. When this process is complete all of the submissions made will be subject to Freedom of Information. But I will publish your submissions here if any wish to send them to me. Submissions should be sent by snail mail to the PSI or by email to
As I said above if this is allowed then community pharmacy in Ireland will be decimated. Aside from all the patient centred reasons why this is a bad move it will also undermine the economic basis for community pharmacy. If you are an employee this will drive down salaries even further. There will be costs for the state as well. Large amounts of medicines will lead to overdoses, either intentional or otherwise. Lack of contact with a pharmacist will cause poor patient outcomes.
I intend to ask that my and other submissions should be circulated to all members of Council and not just the PPD Committee who will be drafting a report to the full Council. To me it is that important that they should hear all the facts and not just a distilled down and sanitized version. I don’t expect that the Registrar will agree to this. At the very least I will ask that members of Council be circulated with my request and the reasons for it.
Don’t leave it to others. And don’t just copy & paste other submissions. This is the surest way to have them ignored. Your professional and financial future is at stake. It’s time to get up off your arse.
By David J
Last week I heard rumours that there had been two pharmacist resignations from the PSI Council. I emailed the PSI asking them to confirm or deny and to date I have not had any reply on this matter. I recognize that they might well have confidentiality issues and that they couldn’t possibly comment.
So today I decided to attend the public session of the PSI Council meeting. As soon as the meeting started I quickly confirmed in my own mind who the two resigning members were. Apologies were made for those not present and all the other members had name tags in front of their seats. There was no mention nor any name tags for the presumably now ex-members of the Council.
Towards the end of the meeting there was a very bland sounding item on the agenda. “Policy and Procedure for the use of Executive Sessions.” From the discussion on this I got a very negative feeling about relations between the executive and some of the Council. My overall impression was that all was not well in this house of cards.
Then this evening I heard more rumours of another pharmacist resigning from the Council. I must stress that all these are rumours. There has been no comment, official or otherwise from the PSI and neither has there been any comment that I’m aware from from the pharmacists concerned. And therein lies part of the problem.
If the rumours are untrue I think that the PSI should issue a statement removing any doubt. If they are true then we need to know what the hell is going on. The PSI have introduced many guidelines and directives. They have taken a lot of money in fees from pharmacists and pharmacies to fund their enforcement. We need to know how it is being spent. They have reserves of nearly €11 million and it is difficult to see what they need such a large reserve for. They are accountable to the Minister for Health but I don’t see him doing very much for now.
Today I prepared an article for June’s edition of Irish Pharmacist but events of the past few hours have rendered it out of date already. This is always an issue when dealing with publication dates so far in advance. I had titled the article “Strange days Indeed.” Little did I realise how strange today would turn out.
By David J
This is already happening in the US. There is no reason why it can’t happen here. We’re accessible and able to do it. This would help take some of the strain off GP’s and hospital out patients departments. All it takes is somebody to pay for it.
Thanks Ultan for the link.
By David J
Here’s a copy of a letter I sent to Dr. Reilly in relation to the extortionate fees being charged by the regulator. They currently are running a surplus of just short of €2 million per year. That means they could charge each community pharmacy €1,250 per year instead of €2,250 per year and still be generating a surplus. I intend to circulate this to every member of the council as well. So that the next time that they decide to do nothing they cannot say that “nobody told us.”
I would urge you all to do likewise.
Dear Minister Reilly,
I am writing to ask you to reduce the annual registration fees payable to the Pharmacy Regulator, the Pharmaceutical Society of Ireland (PSI). As you can see from the table below the registration fees for premises and individuals are far higher in Ireland than those payable in both the UK and Northern Ireland. I feel that the fees payable to the PSI should be reduced to rates similar to those paid by pharmacists in other EU countries.
Premises Ireland €2250 UK(1) £221 (€265) Northern Ireland(2) £155 (€185.89)
Pharmacist Ireland €400 UK(1) £240 (€287.82) Northern Ireland(2) £372 (€446.12)
(Exchange rate – 21/11/13)
On June 26 2013, the Health and Social Professionals Council (CORU) reduced the annual registration fee by 3€195 and set it at €100 for the next 3 years and agreed to refund any members who had paid the annual fee of €295. I would appreciate if you could instruct the PSI to implement a similar reduction for both the individual pharmacists and pharmacy premises as soon as possible.
I would also appreciate if you could instruct the PSI to implement a system allowing for payment in instalments to ease the cash flow burden imposed on pharmacists due to the implementation of a once-off annual payment system.
In light of the current economic climate, the fact that the PSI reported an annual excess of €1,944,324 (4) for the year ending 31/12/12 and the recent reductions in fees paid to pharmacists, I would ask that you give serious consideration to my application and ask the Pharmacy regulator to implement an appropriate deduction in fees payable as soon as possible.
I look forward to hearing from you.
(1)Ref – General Pharmaceutical Council
ees (cited 21/11/13)
(2)Ref – PSNI
-2013141.pdf (cited 21/11/13)
(3)Ref – CORU
(4)Ref – PSI http://www.thepsi.ie/tns/publications/core-publications.aspx (21/11/13)
By David J
By David J
Here it is.
It has been edited a little in the published version, but that’s what editors are for!
By David J
As you know I follow a couple of pharmacy related blogs mostly from the USA. One which I haven’t listed to date (soon to be corrected ) is Jim Plagakis. Over the weekend he posted a report of what caused a PIC (Pharmacist in Charge) to walk out and close the pharmacy that they were working in. He followed it up with the pharmacist’s own story.
While the conditions that allowed this to occur do not exist yet in Ireland to me it gives a good example of what can happen when the pharmacy chains are dominant. It might be a good idea for the employee committee of the IPU to prepare an S.O.P. for how they might deal with this type of situation and one for employee pharmacists on how they should react.
Maybe for a bit of fun we could ask the PSI for their advice should such a scenario arise.
By David J
It’s not often that I agree with the PSI. In fact this will probably be the first in a long time. Their latest email is that first.
It is a position paper on electronic cigarettes. I don’t think they would mind too much if I reproduce it here.
I will do my best to promise that this will be a first and last time and I will try not to make a habit of this.
“PSI position on electronic cigarettes
The PSI has recently received a number of inquiries regarding the appropriateness of electronic cigarettes (e-cigarettes) being offered for sale or supply in retail pharmacy businesses, as these products are not currently regulated under either the medicinal products or medical devices legislation.
In addition, the supply of these products in pharmacies requires consideration under the PSI Code of Conduct, as pharmacists should ensure that products supplied do not pose a hazard to a patient’s health or well-being.
Electronic cigarette products are typically presented in two parts, one of which is a device and the other a fill or refill consisting of a solution of various compositions containing Nicotine. These products are not currently being regulated under the medicinal products legislation, medical devices legislation or tobacco legislation. It should be noted that they do come within the scope of the Waste Electrical and Electronic Equipment (WEEE) Directive.
Agreement has not yet been reached as to the legal classification of these products, i.e. whether they are medicinal products that would require appropriate marketing authorisation, or whether they are medical devices, in which case an appropriate notification to an EU competent body would be required, including appropriate labelling, before being placed on the market.
The PSI understands that the EU Commission has recently commenced a public consultation with respect to the possible revision of the Tobacco Products Directive 2001/37/EC, and that one of the issues being considered is the extension of the scope of that Directive to cover electronic nicotine delivery systems where such products are presented as alternatives to cigarettes. It has also been noted that these kinds of products have the potential of undermining smoking cessation policies, since they keep the smoking addiction (EC Orientation Note on Electronic Cigarettes, May 2008*).
This EC Orientation Note also gave consideration to whether or not these products can be characterised as human medicines and thereby requiring regulation as authorised medicinal ”