Feedback for Proposed Revisions to By-law No 3 — Fees & Public Register

Pharmacist  ·  Nov. 20, 2015

I wish to applaud the document that you created (Table Summary) in order to make it easier to compare the proposed changes to what is currently in place. My comments below reference the sections of the By-law as they occur in that Table:

10.3.2: (grammatical)...Just preceding the proposed changes, the word "by" appears to be absent from directly in front of "...any two of the Registrar,..." (etc.).

11.4.27: The proposal to allow any language(s) the Member wishes to form part of the Register information has been addressed by other respondents, and I would agree that it is inappropriate to allow self-declared lising of this information on the public Register -- UNLESS the College is going to assess that this is accurate information, to the extent that there can be adequate provision of services to/with patients in that language.

At present, the OCP website is very clear in its position regarding the two official languages of this country: English, & French. (

Members have the right to be "interacted with" in either of these official languages. Will this not mandate that the OCP staff (inspectors) be able to inspect the member in that language? Or, during a practice review, will staff be qualified to "listen in on" and assess the level of care being provided if a language other than English or French is used? This is very dangerous territory and should likely be left OUT OF the statutory and By-law requirements/permissives. If a member wishes to notify their patients they can speak another language, that's another matter. But don't get into "permitting" it in the By-law if you're not going to be able to assess the veracity of that "officially-listed" (per it being in the Register) self-declaration.

11.8.2: Changing the retention period for information to the public at large regarding a member's history, etc. from 6 years to 3 is a change that results in far too short an interval. If a review is made of recidivism by members, one will see that often the interval for repeat offenders is beyond 3 years. In some cases, the probation period alone for "repeat inspections" etc. resulting from Discipline may extend to 3 years.

The six-year period for this vital information is still quite reasonable and should remain; even the CRA requires financial records, etc. be retained for at least six years from the end of the year in question. I would suggest a serious re-visit to this proposal prior to making this change, taking into consideration some of the concerns mentioned above.

Thank you.

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