Submission: Health Professions Regulatory Advisory Council

SEIU Local's Pharmacy Technicians Concerns

SEIU would like to make the following submission to HPRAC in order to outline the questions and concerns that our Pharmacy Technician members in the Niagara Health System have with regards to the upcoming legislation change to the Pharmacy Act requiring Pharmacy Technicians to become regulated under the Ontario College of Pharmacists.

  • A current concern facing Pharmacy Technicians is the fact that there is no standardization of responsibilities for this job classification and some technicians are being underutilized. To the extent that the Regulation of Pharmacy Technicians has the potential to standardize the field (by providing a stricter job definition) and broaden the scope of the job, technicians may benefit from this legislative change. This can have potential positive consequences such as increasing Pharmacy Technicians' mobility to pick up shifts at other sites to the extent that regulation guarantees a minimum level of training and competence. As well, regulation allows Pharmacy Technicians to work under a professional title, delineating the difference between Registered Pharmacy Technicians and Unregistered Pharmacy Technicians.
  • Many Pharmacy Technicians are already carrying out these new functions and will stand to benefit from regulation if after regulation they are compensated for carrying out such duties. At some hospital sites Pharmacy Technicians have completed an in-house certification and can now be held liable in the event of a mistake. This new responsibility has not been accompanied with an increase in pay. Pharmacy Technicians would expect that if they are now required to become regulated and assume greater responsibility, it is only fair that there is a corresponding increase in pay. Currently, Pharmacy Technicians that work in retail are barley getting minimum wage. If they are required by law to become regulated then they could stand to benefit if this regulation will increase the Pharmacy Technician base wage.
  • It is very important to our members that Registered Pharmacy Technicians be on the Ontario College of Pharmacists' board to ensure that their profession is adequately represented.
  • Thus far, the information provided by the College of Pharmacists has been very vague in regards to the changes of job responsibilities for Pharmacy Technicians. The four scenarios provided by HPRAC do not adequately describe how Pharmacy Technicians can expect their job to change after regulation has taken place. The scope of Registered Pharmacy Technicians compared to Unregistered Pharmacy Technicians responsibilities needs to be clarified. Without this information it is difficult to give HPRAC a true impression of whether or not our members support this legislative change.
  • Will there be dispute mechanisms in place through the Ontario College of Pharmacists to assist Pharmacy Technicians in the event that a complaint is made against them? As well, will there be a disciplinary process through the OCP in the event that a malpractice complaint is filed against a technician.
  • There is confusion amongst our members as to if this regulation will be voluntary or would all technicians currently practicing have to acquire their regulation in order to work in the same facet. Or is the only voluntary component of this change the fact that employers can choose whether or not to employ Registered Pharmacy Technicians? It is the understanding of some Pharmacy Technicians that this is not meant to be a process of across-the-board regulation, but rather, an opportunity for any pharmacy technician that wishes to further expand their scope of practice. Furthermore, will employers have the option of deciding whether or not to employ Regulated Pharmacy Technicians in their expanded role? Can they in fact opt to continue utilizing assistants/technicians in their current unregulated scope of practice?
  • Once this regulation creates a classification of Registered Pharmacy Technicians with an expanded scope, will hospitals still be allowed to use the Delegation of Dispensing with unregulated technicians?
  • Our members still see it as problematic that employers still will not have to use the full scope of Pharmacy Technicians' abilities.
  • What are the costs to acquire this new license and will there by annual fees to renew one's license?
  • What will the time frame be for technicians to acquire this regulation? If they will be required to write an exam, will they automatically lose their job if they do not pass the exam on the first try?
  • What are the prerequisites required to write the exam? Will technicians require a two year diploma before being permitted to write the exam to become regulated or will comparable work experience suffice? Currently our members have different academic backgrounds. Some technicians have obtained a one year college diploma and some have obtained certificates from business schools. Will either one of these be deemed adequate academic background in order to be permitted to take the exam? Furthermore, the one year Pharmacy Technician College Diploma has recently become a two year program with the idea that a one year program was too intensive and the work would be better spread out into two years as well allowing students to opportunity to take more electives. Will it be necessary for all technicians currently working, specifically the technicians with the one year diploma, to go back to school and get this two year diploma before even qualifying for this regulation? Will 20 years of experience be recognized as equivalent to the required academic background?
  • To the extent that employers have the choice of whether or not to employ Regulated Pharmacy Technicians, it is possible that some Regulated technicians could be at risk of losing their jobs should employers opt to employ more unregistered technicians. Employers may be motivated to employ fewer Regulated Pharmacy Technicians as they will become more expensive than their unregulated counterparts. Employers may choose to employ more unregulated technicians to work under the direct supervision of a few Pharmacists. Technicians feel that their jobs should be protected against these potential negative consequences.
  • How will the Ontario College of Pharmacists educate the public about this new regulation?
  • What will the quality assurance requirements be in order for technicians to be able to renew their regulation?