Petition against board notice 543 of 2024. Criteria for registration as a responsible pharmacist

As pharmacists vested in upholding the integrity and standards of our profession, we hereby express our collective decision to reject the proposed Board Notice 543 of 2024, which pertains to the criteria for registration as a Responsible Pharmacist in South Africa. Our stance is rooted in the following considerations:

(B) Must be registered with Pharmacy Council for three years post pharmacy internship

  • One of biggest challenges that the pharmacy professionals faces currently is a high rate of unemployment due to saturation of job opportunities. If a qualified pharmacist needs to have atleast three years experience to register as a responsible pharmacists this will mean:
    • Newly qualified pharmacists who aspire to open their own pharmacies post community service will not be able to do so because they won't be able to register as a responsible pharmacist, this will then contribute towards the high unemployment rate as they won't be able to create job opportunities for other pharmacy professionals and the youth of south africa as a whole.
    • This will also restrict primary healthcare services, meaning the underserved communities in south africa won't receive the most important basic need which is access to primary healthcare services. This will be as a result of newly qualified pharmacist being unable to operate their own pharmacies after undergoing intensive training at university, during internship and community service.

(C)Must have completed the responsible pharmacist short course or submit proof of registration with accredited providers

  • Recognition of Prior Learning; the restriction against recognizing prior learning poses a significant challenge for pharmacist, potentially necessitating the re-study of content already covered in accredited courses(Bachelor of Pharmacy curriculum). This redundant effort not only consumes valuable time but also undermines the efficiency of professional development within the field.
    • the recommendation that we put forward as pharmacists is introduction of CPDs specifically designed for pharmacists registered as responsible pharmacists, this will help pharmacists that have been identified to lack basic knowledge of what being a responsible pharmacist entails to improve their understanding and background governing the pracrice of pharmacy this includes but not limiting to GPP, Pharmacy Act, GMP etc.
    • If the south african pharmacy council has identified a gap that exists within the profession, the Bachelor of Pharmacy Curriculum needs to be reviewed, all the training hubs needs to be assessed if their exit level outcomes meets the minimum criteria and competency standards because clearly if such a gap exists then the training facilities aren't doing their job right.
  •  Cost Implications; the absence of cost consideration for the proposed course presents a formidable obstacle for many pharmacists. Without clarity on financial implications, individuals may face substantial barrires to participation, thereby impeding access to essential professional development opportunities.
    • this will thus impact on entrepreneurship and leadership; the  imposition of mandatory short courses may inadvertently deter pharmacists from pursuing entrepreneurial endeavors or assuming leadership roles within their professional domains. This reluctance stems from the potential disincentive created by additional educational requirements, thereby compromising the diversity and effectiveness of leadership within the pharmacy workplaces. This will directly affect the provision of primary healthcare services as mentioned above.
  • Alternative pathways for experienced pharmacists; the proposed short course should function as a alternative pathway rather than a mandatory prerequisite for registration as a Responsible Pharmaist, recognition of prior learning, successfully completing internship and community service should be eligable for exemption for this mandatory requirement thereby recognizing and valuing pharmacy professionals practical expertise.

In conclusion, while we acknowledge the intent behind Board Notice 543 of 2024, we contend that its implementation in its current form may undermine the foundational principles of our profession. We remain steadfast in our commitment to promoting patient -centric care and upholding the highest standards of professionalism within the pharmaceutical community.


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