Feedback for Proposed Changes to the Pharmacy Act (Administration of Vaccines by Pharmacists)

Pharmacist  ·  May 29, 2016

I agree that we should also be able to PRESCRIBE these vaccines especially if we are going to be responsible for: 1. Vaccinating the patient (if we're not prescribing, then how is this so different from getting a medical directive for such a vaccine) 2. Informing the primary physician/general practitioner that the patient received the vaccine (and "details" surrounding this vaccine) - this sounds like a lot added to the workflow.

I think it's also important to recognize that because we will be responsible for injecting this, we will have to educate ourselves MUCH more closely of the Canadian Immunization Guide (especially when it comes to some of the considerations surrounding our immunosuppressed patient populations, and especially when it comes to patients who we do not know very well). It will be so important for us to know what medications these patients are on. I really think pharmacists should be providing these services to patients that we have at least a 3 month relationship with.

I think the language around TRAINING (" The member must possess sufficient knowledge, skill and judgment respecting the substance to be administered, and sufficient understanding of the condition of the patient, to be able to administer the substance safely.") needs to be strengthened. While I believe a 4th year pharmacy student on their APPE or final Co-Op rotations or an intern would probably be well-equipped to provide these services, I do NOT believe a 1st, 2nd or even 3rd year pharmacy student would be a sufficiently trained provider of these services.

Training requirements must also be strengthened, because it will be important in the course of injection training courses approved by OCP that pharmacists are educated ON these vaccines that we will have to provide, because I'm quite certain that if you were to ask someone what the precautions, warning, common dosing, etc. surrounding a vaccine such as the Japanese encephalitis vaccine, very few pharmacists would be able to give you a sufficient answer.

It's not just sticking a needle into a patient, we are being tasked with a lot of serious responsibility here. And it is important that the OCP support members to fully rise to the occasion.

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