Feedback for Proposed Changes to the Public Register (By-law No 3)

Pharmacist  ·  Nov. 6, 2014

I support the change of this by-law with one caveat regarding how to make the call if the findings of guilt affect suitability to practice. As the amendment reads now, the findings of guilt will be made public if “the Registrar believes is relevant to the member’s suitability to practice”. This is not sufficient, in my view, to determine the detailed process of assessment of the relevance of the findings of guilt to pharmacy practice. Assessment process should be a collective multi-steps process that ensures the best judgment is made by collective efforts of multiple individuals, rather than a sole effort by one individual. I suggest outlining a detailed process of this assessment, in which the findings of guilt are presented to the council with the register’s recommendation if they should be made public. The council then can make the call, and give the individual pharmacist the right to appeal this decision with supporting evidence. Additionally, this amendment does not highlights if the findings of guilt should be final, or once the verdict is made, even with a lower court, they can be made public. The issue will arise if the found-guilty pharmacist decides to appeal the court’s decision in front of a higher court, while the findings were made public in the mean-time.

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