GPhC Consultation on Responsible & Superintendent Pharmacists
Published: 17th February 2026
GPhC Consultation On Draft Rules And Standards For Responsible Pharmacists And Draft Standards For Superintendent Pharmacists
Introduction
The Pharmacy (Responsible Pharmacists, Superintendent Pharmacists etc.) Order 2022 came into force in December 2022. This Order made several changes, including giving the GPhC legal powers to set rules and describe the roles and responsibilities of Responsible Pharmacists (RPs) and Superintendent Pharmacists (SPs) in a much more flexible and agile manner than the mechanism of setting rules in primary legislation which immediately preceded it. It should be noted that the role of the RP and a description of the related responsibilities still remain enshrined in legislation and are unlikely to change at this point.
The GPhC are now consulting on their draft standards for both RPs and SPs as well as draft rules for RPs. The consultation also seeks to gather views on standards for registered premises and pharmacy professionals. In the main, this is to inform future consultations on these topics – but there are some specific changes that the GPhC are proposing to put into effect earlier, such as standards for authorisation as will be permitted from December this year onwards.
Separately but linked to the detail above, the Department of Health and Social Care carried out a 2023 consultation on potential changes to Supervision rules. CPS’ response to this consultation can be found here. This is relevant to this current consultation as it outlines our extant position on some of the issues that are now being discussed in more detail. The CPS Board and Council agreed that:
The core principle of one RP to one pharmacy premises should remain
Handout of prescriptions should require an RP to be signed in but not necessarily present (achieved indirectly via “bagged and checked authorisation” changes)
Assembly of prescriptions should not need to be supervised or have an RP signed in
RP absence rules should be determined locally
The GPhC consultation is presented in five sections:
1. The standards for Superintendent Pharmacists
This sets out the criteria a Pharmacist must meet if they are to perform the role of an SP, and describes the knowledge, conduct and performance expected of them to support an organisation and its staff to deliver safe and effective care/operations.
2. The standards for Responsible Pharmacists
These standards describe the role and responsibilities of the RP as well as the standards of conduct, ethics and performance they must meet to support the pharmacy and its staff to deliver safe and effective pharmacy services.
3. The rules for Responsible Pharmacists
These proposed rules are specific requirements relating to the duty of the RP which must be followed to ensure the safe and effective running of a pharmacy business at the premises from which it is carried on.
For example, they cover
The maximum period of absence for the RP during business hours
Arrangements for when the RP is absent
4. The standards for registered pharmacies
These aim to ensure the right environment (organisational and physical) for the safe and effective practice of pharmacy.
There are two areas of the current standards that the GPhC believe must be updated as soon as possible:
Widening the application of the standards beyond medicines and medical devices.
Addressing the absence of any standards relating to consent for procedures to be carried out.
5. The standards for pharmacy professionals
As with section 5, there is a specific requirement to issue standards to cover the incoming enablement of authorisation.
The full consultation document can be accessed here, and our draft response is included below for review.
Section 1 - The standards for Superintendent Pharmacists
The criteria for the role of the Superintendent Pharmacist are set out in legislation. The criteria must be met in full. A Superintendent Pharmacist must:
Be a pharmacist who maintains their registration with the GPhC, and
Be a senior manager of the retail pharmacy business who has the authority to make decisions affecting the running of the retail pharmacy business in connection with the retail sale and supply of medicinal products. This includes having a significant role in:
making decisions about how the whole or a substantial part of the activities of a retail pharmacy business are managed or organised, or
the actual managing or organising of the whole or a substantial part of the activities of a retail pharmacy business, and
notifying the GPhC in writing, confirming their name and that they are the Superintendent Pharmacist for the retail pharmacy business. This notice provided to the GPhC must be signed by the Superintendent Pharmacist and signed on behalf of the retail pharmacy business
-
No.
If the standards are set appropriately, then it is whether a prospective SP could reliably meet them that should help an employer determine a person’s (or their own) suitability for the role. Experience measured in years does not necessarily indicate suitability for the role, and there are no recognised qualifications or defined experience that would be fair or reasonable to insist upon as a minimum requirement. The pool of suitable candidates would be unnecessarily shrunk, making it more challenging for businesses to ensure that the periods of operation without an active SP are minimised.
It would, however, be reasonable to expect those undertaking the SP role to perhaps have a different CPD structure and focus, and be expected to seek out development in relation to their role specifics.
-
No.
Maintaining clear governance and leadership is crucial for patient and staff safety. We agree that there should be succession planning in place and significant periods without an active SP in place should be avoided at all costs. It is in the pharmacy owner’s best interests to fill any gaps in a timely manner. However, “immediate” appointment is not achievable and potentially unwise in practice if the wrong person is selected in order to satisfy this requirement. There is a need for proportionality and a recognition of just how challenging this would be to achieve for some of our members. Those in remote and rural areas may struggle to appoint immediately, and even for those in more populous areas the availability of pharmacists with the requisite skills and experience to perform the role of an SP is not guaranteed. A reasonable, risk-based approach must be taken - adopted – taking into account the stability of the business, the systems and procedures already in place and the people supporting the role of the SP.
We suggest that, although the ideal of having no vacancies can be described in the standards, each case must be assessed on its own merit and guidance provided for pharmacy owners for interim arrangements to minimise risk (e.g. avoid major change projects).
We have proposed five standards for Superintendent Pharmacists. These are:
a. Provide strategic and professional leadership
b. Develop a workforce with the right skills, knowledge and experience
c. Delegate responsibly and make sure there are clear lines of accountability
d. Maintain and strengthen governance to ensure safe and effective delivery of pharmacy services
e. Make sure the pharmacy environment and premises safeguard the health, safety and wellbeing of patients and the public
-
No.
The proposed SP standards provide a focussed and clear governance framework, emphasising leadership, culture, workforce capability, risk management and continuous improvement. These align well with the development of community pharmacy services into more complex clinical areas, taking into account the requirement to utilise team members and technology in new and different ways.
However, whilst we cannot disagree with the sentiment behind how Standard 5 is worded, we would caution against the continued use of the term “wellbeing” alongside “health” and “safety” in the context of a regulatory minimum standard – and extend this comment to its current and possible future use in the standards for pharmacy premises. Whilst it may be reasonably straightforward to interpret the latter two terms and therefore make a judgement on whether an SP has met the standards, this is not the case for “wellbeing”. Wellbeing does encompass physical, mental, emotional and social health but it also includes how people feel about themselves, their ability to function and their satisfaction with life. Any assessment of whether wellbeing has been safeguarded and to what extent a perceived failure has caused harm is therefore subjective from the off. We would recommend that this term is removed from the standard, instead moving the reference to wellbeing into the examples of how an SP might meet or indeed exceed Standard 5.
-
No.
Language and contextualisation are of critical importance when writing standards, as although they are primarily intended to be used by those undertaking the role of the SP, they are also used by employers to understand the scope of the role and by the rest of the profession and beyond to assess performance and better understand the role in relation to others.Whilst there is a specific standard around delegation which indirectly recognises that an individual may not be able to carry out all of the example duties personally (especially in larger organisations), we believe that this should be better explained for a broad audience in the introduction to the standards. As an example, it is the SP’s responsibility to ensure that the business has an agreed, well understood and up to date approach to business continuity planning. However, it may be appropriate for them to delegate the completion and upkeep of the fine detail to the RP or manager at each site, or an area operations lead.
The term “make sure” is used throughout the standards in relation to the duties of the SP. We can understand why, as it makes clear that safety is of the utmost importance – merely trying is not acceptable. However, we have some concern that this terminology leaves absolutely no room to recognise that an individual cannot, even through effective delegation, make sure that employees or those engaged to carry out work for the business behave consistently. The standards are what would be used in both fitness to practice and civil cases to ascertain whether the role was carried out to the expected standard, so once again the language used is important. We would suggest that there is a review of the draft standards through this lens, modifying the wording used where necessary. In many cases, it would be more appropriate that the SP ensures that there are systems, procedures and effective monitoring in place to help them meet and maintain standards.
-
No.
Although there are relatively few SP standards in the draft, the detail under each is sufficient. We must remember that SPs are also required meet the standards for pharmacy professionals and for premises, which provide clear expectations that should guide the SP where these new standards are perhaps silent on specific matters. Duplication and fine detail should be avoided across the various sets of standards wherever possible.
-
No.
Section 2 - Standards for Responsible Pharmacists
The Medicines (Pharmacies) (Responsible Pharmacist) Regulations 2008 introduced the role of the Responsible Pharmacist. The owner of a retail pharmacy business must appoint a Responsible Pharmacist, who is a registered pharmacist, to be in charge of the registered pharmacy. The Responsible Pharmacist is responsible for the day-to-day running of the pharmacy. They are also responsible for securing the safe and effective operation of the pharmacy, so far as concerns the retail sale of medicinal products and the supply of medicinal products in circumstances corresponding to retail sale.
Please note, there is new legislation on pharmacy supervision which will allow pharmacists to authorise registered pharmacy technicians to carry out, or supervise others carrying out, the preparation, assembly, dispensing, sale and supply of medicines. Questions about this legislation are outside the scope of this consultation.
A Responsible Pharmacist can only be responsible for one pharmacy premises at a time.
-
No.
Fundamentally, if there is a gap between the standards met to join the register and those required to perform the role of the RP then this must be addressed as a matter of urgency via initial education and training standards and the FTY year. Evidence supporting the need to introduce requirements beyond qualification has not been provided and would need to be compelling for the sector to support this.
Setting minimum experience requirements would undermine workforce flexibility and disadvantage newly qualified pharmacists, as well as putting service stability and therefore patient care at risk.
Instead, employer-led induction processes and risk assessments that take into account specific sites and individuals are what safeguard early years pharmacists and patients. Mentoring and support for post-registration development are also measures that our members invest in, notably with the Scottish contract providing funding for a structured programme and credentialling.
Each pharmacist must also take an active role in assessing their capability to take on certain work – if they do not feel able to fulfil the role of RP, then they should seek to develop towards this whilst undertaking other positions in the meantime.
The Superintendent Pharmacist is responsible for organisational oversight of the management and operation of the pharmacy business. This includes keeping and maintaining records in relation to this (if there is not a requirement for a Superintendent Pharmacist to be appointed, this responsibility is the pharmacy owner’s). The Responsible Pharmacist is responsible for keeping and maintaining records for the safe and effective day-to-day running of the pharmacy.
-
This question is challenging to answer definitively – as services develop, the records that are created and kept in the pharmacy setting have changed, as has the way in which they are handled (e.g. digitally). The SP standards make clear that the SP has ultimate accountability for all governance matters, but should delegate appropriately and put in place systems and procedures to meet the standards. In a general sense, the upkeep of any and all records that are specific to day-to-day operations should be the responsibility of the RP, as is the following of any procedures that the SP has put in place. The RP log, authorisations made, safety incidents, clinical notes, audit completion and training logs would all fall into this category. However, an individual business may agree to delegate more to RPs who are capable of taking on additional responsibilities.
We have proposed four standards for Responsible Pharmacists. These are:
a. Prioritise patient safety
b. Provide the leadership and management needed to ensure the safe and effective operation of the pharmacy
c. Make sure, if using authorisation, to authorise responsibly and make clear the lines of accountability
d. Maintain and strengthen governance to ensure safe and effective delivery of pharmacy services
-
No.
Overall, the standards are clear and sensible, without excessive overlap with the standards for all pharmacy professionals. However, there are some elements which we do not believe will strengthen the day-to-day running of the pharmacy:
Under Standard 1, it is unclear from the wording what the requirement for the RP to “be clear and share with the team the vision and strategy needed to safeguard the health, safety and wellbeing of patients and the public…” means in practical terms. This being described as a “must do” for all RPs on every day of operation is inappropriate, particularly for RPs who are not in a permanent post leading a team. We would suggest that this is simplified or removed.
Under Standard 2, the requirement for the RP to “work collaboratively with the SP, pharmacy owner and team to contribute to…objectives, governance meetings and third-party meetings” will not be achievable for all, particularly in much larger organisations. This also seems a very specific standard, whereas a more generalised standard covering collaborative working and taking the opportunity to “step up” beyond the confines of the premises that the RP works in would be more appropriate. Workforce structure at any given time will dictate whether or not standards like this make sense for an RP or not, so cannot be applied indiscriminately. For example, an owner or SP’s degree of control over a locum engaged to fulfil the role of RP for short periods of time is more limited than thewir influence over employee job roles and descriptions.
Standard 3 is largely appropriate for the RP role, however the content could just as easily belong under Standard 2’s “leadership and management” banner. We understand that authorisation is a new concept and there may be a desire to address it overtly through a specific standard, but it will quickly become a business as usual tool where businesses choose to use it. The proposed interim annex to the standards for pharmacy professionals makes clear to all the expectations.
-
No.
Standard 2 places specific duties on the RP with respect to equality, diversity and inclusion which are near identical to that placed on the SP. We believe that whilst there is justification to include this detail in the SP standards and the standards for all pharmacy professionals, this is less the case for the specific role of the RP.
The model of authorisation that will be enabled is fragile (too dependent on individuals rather than systems) and will no doubt raise many issues that have not yet been anticipated. We understand that it is beyond the scope of this consultation to propose any changes but would caution against the standard that requires the RP to “make sure that authorisation is used appropriately” when it is possible for a non-RP authorising pharmacist to leave notification to the RP to the end of the day as one example.
-
No.
As per our answer to question 4, these standards for RPs are sufficient given that they are in addition to the standards that all pharmacy professionals must meet.
-
No.
Section 3 - Rules for Responsible Pharmacists
Under the law, there must be a Responsible Pharmacist in every registered pharmacy. We are proposing to continue with the present rule where a Responsible Pharmacist:
can only be responsible for one pharmacy premises at any given time, and
is not able to perform their role anywhere other than the pharmacy where they are signed in
-
CPS agrees that one RP should only be responsible for one pharmacy premises at any given time.
However, we believe that the opportunity should be taken now to directly tackle the issue of ‘remote’ supervision. Not doing so is short-sighted, and not providing advice and a framework for the rare occasion that this is appropriate could cause more harm than good. To be clear, we do not support routine remote supervision.
It is in every pharmacy owner, pharmacy team and community’s best interest to have an RP on site wherever possible – and this will always be the aim. However, there will always be unplanned adverse events that prevent this from being the case – particularly in remote, rural and island communities. The definite negative impact of leaving already-underserved patients without access to prescriptions or pharmaceutical care services for days (e.g. in the event of a ferry crossing being suspended) far outweighs the risk of allowing pharmacy owners and SPs to build continuity plans which include the RP dialling in remotely and carrying out the critical functions that can be delivered safely.
We will also take the opportunity to flag that this rule, whilst we agree with it, is not necessarily future-proofed for the inevitability of premises that are completely automated assembly hubs. It may still be necessary to have an RP on site to allow operations to proceed, but they would then be unavailable to carry out RP roles elsewhere. It may be that the answer lies between a more flexible 2-hour absence rule, contemporaneous sign-in options or indeed remote arrangements as described above. The time should be taken now to consider these fringe cases to avoid needlessly restrictive operating models in the future.
We propose to continue with the present rule that allows the Responsible Pharmacist to be absent from the pharmacy for up to two hours. If there is more than one Responsible Pharmacist scheduled during the pharmacy's business hours, the two-hour limit applies to the total time when any of them is absent.
-
No.
This rule is and always has been arbitrary in nature. The determination of how long the RP can be absent for should be risk-based and local in nature. This might mean that under certain circumstances, the SP and RP might decide together that there should be far less than 2 hours’ absence permitted (e.g. new team/premises/adverse events). However, in other circumstances and with robust systems, training, governance, processes and technology in place the RP should be able to exercise greater flexibility. The delivery of modern healthcare and the building of true multidisciplinary teams in the community requires it.
Once again, it is generally in the best interests of all parties that there is an RP present in a community pharmacy most of the time – but to retain the 2-hour absence rule and limit the possibilities for models of care in doing so is short sighted. It is well established that with the correct systems, training, controls and procedures in place, assembly activities can safely be carried out without an RP being physically present – for example before or after a community pharmacy’s normal opening hours. The legislation still insists upon an RP being signed in to permit this activity, but the rules should allow greater flexibility in pharmacy operations by handing the decision on – and accountability for - periods of absence to the RP.
-
No.
Section 4 - Standards For Registered Pharmacies
When we have agreed and published the standards for Superintendent Pharmacists and the rules and standards for Responsible Pharmacists, we will be carrying out a full review of and consultation on the standards for registered pharmacies. When developing the standards for Superintendent Pharmacists we found there are two areas in the standards for registered pharmacies that need updating now, to provide clarity and maintain patient safety. These are:
a. The present standards specifically relate to medicines and medical devices. This limits our ability to take enforcement action against poor practice arising from other services, or from unregulated products provided from pharmacies. We therefore propose to include ‘any other product intended for supply or administration’ under Principle 4 of the standards.
b. Although our standards for pharmacy professionals cover consent, the present standards for registered pharmacies do not. As pharmacies are offering clinical services more and more − such as examinations, diagnosis, and hands-on treatment − it is important to include a specific standard around consent.
-
Yes.
-
Yes.
-
No.
-
No.
Standards For Pharmacy Professionals
When we have agreed and published the standards for Superintendent Pharmacists and the rules and standards for Responsible Pharmacists, we will be carrying out a full review of, and consultation on, the standards for pharmacy professionals. Ahead of the review, and in light of upcoming legislation on supervision and authorisation, we will be producing an annex to the standards for pharmacy professionals. This will be published alongside the standards for Responsible Pharmacists. The annex will set out what is expected of pharmacists and pharmacy technicians if a pharmacy decides to use authorisation.
Please note: The Royal Pharmaceutical Society (RPS) will also be providing guidance covering authorisation.
-
Yes.
This will be necessary to ensure consistency and visibility across the professions – as otherwise non-RP Pharmacists and Pharmacy Technicians would have to be familiar with standards and guidance that is not primarily written for them.
However, our observation is that the proposed administration and day-by-day nature of the authorisation processes being put forward are not conducive to the mechanism being put into practice. We believe that the meaning and importance of these agreements will actually be diluted by turning them into a rote task to be completed each day rather than an overarching agreement between authoriser and authorised team members which could still be reviewed regularly if not every day.
-
No.
-
No.
Disclosure Scotland has published its June 2026 newsletter, covering two important updates for PVG scheme members and customers.