Feedback for Seeking Feedback on Proposed Implementation Timeline for NAPRA's Sterile Compounding Standards

Pharmacist  ·  May 19, 2016

I think while 2 years is a good goal for everyone to strive for in that we need to work quickly to standardize the processes and facilities to protect the public, it is not a reasonable deadline by which everyone must meet.
Things to consider; - this is likely not the only goal most hospital pharmacies are working to in order to protect the public. There may be others that actually pose a greater risk. I believe there to be at my hospital. While this is one that currently has the public/media spotlight and OCP must answer to, as professionals we have a responsibility also to focus on the greatest risk. It will take more time to get the both goals completed. - For those that did not manage to put in a capital submission in January 2016 or it was not approved, it leaves only a year to complete the project (assuming approval) when submitted in Jan 2017. - Once the capital project is approved (April 2017), priorities must be set within the approvals and then funding must be sought. Often this takes months if not years. - Once funding is obtained, one needs external subject experts to help prepare plans, vendors to provide estimates (RFP process), and training programs to be available. With potentially even half of the 240 hospitals needing renovations and many staff needing training and certification, where will the external subject matter experts, vendors, trainers come from to complete even a small portion of this work in likely the last 6 months? Given that most of the hospitals are smaller and remote, will they be able to get the experts, vendors, etc to come to them when there is more work than they can handle in the larger centres? - If there are 5 technicians making the IV's and needing training/finger-tip certification, one must consider how many can go off for 3 days to training at a time and then if the sessions are offered monthly how long even that step takes. - Currently it is not easy to find who the vendors even are. There needs to be an electronic bulletin board, not endorsed by any organization, where potential vendors can post their services and references, that helps hospitals identify potential places to start.
- While there is a CSHP / OPA training program it is expensive and said to be quite basic. Is an advanced one being planned? When will it be available? - If there is a big push for the vendor services in the last 6 months of an impossible timeline, will the price charged drastically go up (what the market will bear) costing the system (tax payer) more than it's worth? - I believe this will require a lot more supportive coordination by groups such as CSHP (guidelines are very high level; web-in-airs are getting there but still don't hit the mark) to provide the advanced training for the workers and day long workshops for the directors/managers in design, policy and procedures, etc.
Only when these supports are in place, should we be talking about a timeline for completion. That timeline should take into account how much work is required to be done across the province and the extent to which the resources available can meet the demand.

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