What Went Wrong: Practicing Without Registration or Required Certification
College Registration as a “Registrant”
In order to practice as a pharmacist or a pharmacy technician in BC, a person must be registered as a registrant of the College of Pharmacists of BC:
- Section 1 of the Health Professions Act defines “registrant” to mean, in respect of a designated health profession, a person who is granted registration as a member of its college.
- Section 3 of the Pharmacists Regulation under the Health Professions Act states that only a registrant may practise the health profession of the practice of pharmacy.
- “Pharmacist” is defined in section 25.8 of the Health Professions Act to mean a person who is currently registered under section 20 of the Health Professions Act as a member of the College.
- “Pharmacy Technician” is defined in section 1 of the Bylaws to the Health Professions Act as a member of the college who is registered in the class of registrants established in section 41(e) of the Bylaws to the Health Professions Act.
Additionally, all registrants are required, under s. 51 of the Bylaws to the Health Professions Act, to renew their registration on an annual basis in order to remain a registrant of the College.
The College’s Inquiry Committee has reviewed recurrent situations whereby registrants failed to renew their registration prior to their renewal date. While most of these cases were inadvertent oversights, these individuals had all practiced within the scope of a pharmacist or pharmacy technician for a period of time without being a College registrant.
In the above cases, the registrants’ actions were equivalent to unauthorized practice, which even in the absence of bad faith is serious in nature. In both cases, the Inquiry Committee requested the registrants consent to specific formal undertakings that included a Letter of Reprimand placed on the College register.
All College registrants receive a “reminder” email approximately six weeks before their registration renewal date. However, ultimately it is the registrant’s responsibility to ensure that renewal requirements such as Continuing Education submissions, payment, and statutory declarations are all received by the College prior to their renewal date. Names of pharmacists and pharmacy technicians who are registrants of the College are listed in the Find a Pharmacy or Registrant section on the College’s website.
Pharmacist registrants must also note that PharmaNet only permits the registration numbers of current registrants to process prescriptions. If a pharmacist’s registration is not renewed on time, their access to PharmaNet will be denied.
Certification for Drug Administration
Pharmacists may administer drugs by injection or intranasal route only if officially certified by the College:
- Section 43(1) of the Bylaws to the Health Professions Act states that a practising pharmacist may apply to the registrar under this section for certification that the practising pharmacist is qualified and competent to perform a restricted activity under section 4(1) (c.1) of the Pharmacists Regulation (administering injections).
- Section 4.1(1)(c) of the Pharmacists Regulation under the Health Professions Act states that a registrant may perform an activity described in section 4(1)(c.1) (administering injections) only if the registrant has successfully completed a certification program established, required or approved under the bylaws to ensure registrants are qualified and competent to perform the activity.
After completing the necessary courses, pharmacists must submit the “Application for Certification – Drug Administration by Injection and Intranasal Route” to the College. Pharmacists are not officially certified for drug administration until the College processes this application. All pharmacists authorized for drug administration are listed in the Registrant Directory on the College’s website.
The Inquiry Committee has also reviewed recurrent situations whereby pharmacists completed the necessary courses, but failed to submit an application to the College for official certification.
In this case, even though the pharmacist had the necessary training, the pharmacist did not have official certification to administer injections. This is analogous to having a pharmacy degree but not being registered with the College as a pharmacist registrant. The Inquiry Committee found that the pharmacist should have known about the requirements to submit an application to the College, as these requirements are clearly stated on the College’s website and are also made known to registrants during the injection courses. Given the seriousness of this matter, the Inquiry Committee requested this pharmacist consent to specific formal undertakings that included a Letter of Reprimand placed on the College register.