PODSA Modernization: Bylaw Amendments Coming Soon
Amendments to modernize the College’s bylaws under the Pharmacy Operations and Drug Scheduling Act come into effect on January 16, 2020.
The College Board approved these amendments at its November 2019 meeting, as part of the Legislative Standards & Modernization Goal within the College’s 2017/18 – 2019/20 Strategic Plan.
As a regulator, the College aims to be forward-thinking and anticipate change to support good pharmacy practice. Existing standards may need to change to enable innovation and advancements that improve patient care, while new requirements may be needed to ensure the public is protected through the provision of pharmacy services in new ways.
As a part of its Strategic Plan, the College conducted a comprehensive review and reform of legislative requirements under the Pharmacy Operations and Drug Scheduling Act (PODSA), including the bylaws and policies made under that Act. Throughout all the amendments, the College worked to ensure:
- Bylaws are clearer and duplication in bylaws and policies is addressed,
- Professional Practice Policies (PPP) are standardized and transitioned to bylaw where needed, and
- Bylaws and PPPs have consistent writing style and structure.
These changes support the College in its efforts to follow best practices for regulation, such as the concept of Right Touch Regulation. Right Touch Regulation means always asking what risk we are trying to regulate, being proportionate and targeted in regulating that risk or finding ways other than regulation to promote good practice and high-quality healthcare.
Key PODSA Bylaw Modernization Areas
Operation of a community pharmacy without a pharmacist and pharmacy security
Updates to better reflect modern pharmacy practice and pharmacy security, including clearly setting out the conditions that must be met, the activities that can be performed, and who can perform them. This also includes clearly permitting pharmacy technicians to perform duties when pharmacists are not present.
Responsibilities of pharmacy managers and owners
Updates to better reflect public safety risks, use more principle-based language in how requirements are expressed and better reflect modern pharmacy practice. This includes updates related to day-to-day management of a pharmacy, public identification of registrants, as well as changes to the reporting of pharmacy manager absences and resignations, and reporting of changes in registrant staffing.
Storage of drugs and confidential health information (including offsite storage)
Updates to better reflect public safety risks, improve clarity and consistency of storage requirements throughout College bylaws, and reflect the transition many pharmacies are making to electronic record-keeping.
Temporary Pharmacy Closures
Updates to transition temporary pharmacy closure requirements from policy (PPP-46) into bylaws, including differentiating between requirements for temporary closure due to unanticipated versus anticipated closures. This also includes updates to the notification procedures and changes to clarify expectations of closure due to suspension.
Updates to reflect the transition of administration of PharmaNet functions to the Ministry of Health, as well as changes to better reflect modern pharmacy practice.
Updates to broaden the definition of patient representative to better reflect the range of individuals who may take on that role.
Pharmacy Licensure Improvements
Updates to the College’s pharmacy licensure requirements to improve the licensure process, including allowing pharmacy’s the option to provide their BC Annual report or BC Company Summary only for their pharmacy licence renewal application (if the direct owner is a corporation); and replacing the requirement for Certificate of Incorporation and Notice of Articles with a BC Company Summary for a New Pharmacy Licence application. These updates also include modernizing requirements for pharmacy diagrams and physical requirements of a pharmacy. The name on the external signage of a pharmacy will no longer required to be exactly the same as the operating name (business name) of a pharmacy.
AMENDED BYLAWS and Policies
The following amended bylaws and policies are being provided for reference only and will come into effect on January 16, 2020.
PODSA Modernization Bylaw Amendments
Professional Practice Policy Amendments
Changes to Professional Practice Policies (PPP)
The Board also approved changes to a number of the College’s Professional Practice Policies (PPP) to come into effect at the same time that the previously mentioned PODSA Modernization Bylaw Amendments come into force.
Repealing PPP-25 Disaster Preparedness
- The intent of this policy will instead be reflected through College Bylaws as part of the PODSA Modernization approved amendments and through amendments to other related policies (such as PPP-31 Emergency Prescription Refills).
- The College is also working on developing guidance related to emergency preparedness and will be updating the resource page at bcpharmacists.org/emergency.
Updates to PPP-31 Emergency Prescription Refills
- Updates related to providing an emergency supply of drugs (previously included in PPP-25) were appended to PPP-31, where appropriate. To align with this change, the title of the policy was updated to “PPP-31 Emergency Supply for Continuity of Care”.
Updates to PPP-46 Temporary Pharmacy Closures
- Updates related to the bylaw amendments for temporary pharmacy closures to set out additional notification procedures for both anticipated and unanticipated pharmacy closures.
Updates to PPP-54 Identifying Patients for PharmaNet Purposes
- Updates to clarify that PPP-54 applies not only to patients, but patient’s representatives as well, in both community pharmacy and telepharmacy settings. To reflect this change, the title of the policy was updated to “PPP-54 Identifying Patients and Patient Representatives in Community and Telepharmacy Settings”.
Updates to PPP-59 Pharmacy Equipment
- Updates to modernize pharmacy equipment requirements based on current technologies available and to ensure the requirements are in line with what is necessary to ensure patient safety.
Updates to PPP-65 Narcotic Counts and Reconciliations
- Updates to align with Health Canada’s updated policy on loss or theft reporting, and guidance document on inventory reconciliation. Additionally, changes were made to improve clarity on existing PPP-65 requirements, consistency with proposed PODSA Bylaws amendments, and alignment with current pharmacy practices.
Updates to PPP-73 Validate Identification and College Registration Status for New Pharmacy Hires
- Updates include clarifying that confirmation of an employee’s identity and registration status are to be done at the start of employment, but not during the application process. Stemming from the amended bylaws, which require pharmacy managers to ensure all individuals working in the pharmacy who represent themselves as registrants are registered with the College, a provision was added to the policy, which requires pharmacy managers to confirm the registration status of all staff registrants from time to time, at least annually. To reflect these changes the title of the policy was updated to “PPP-73 Validate Identification and Verify College Registration Status for New and Existing Registrant Staff”.
There were also consequential amendments to made to
- PPP-3 Pharmacy References,
- PPP-74 Community Pharmacy and Telepharmacy Security, and
- PPP-76 Criminal Record History Vendor.
If you have any questions about the new requirements, please email Legislation@bcpharmacists.org.