Dear Alberta College of Pharmacy,
I hope this email finds you well.
I write to you with the utmost respect for your role as a regulatory body, aiming to uphold high standards of practice to ensure public safety. However, I would like to bring to your attention a concern regarding your current interpretation of the Health Professions Act (HPA), specifically Schedule 19 pertaining to the practice of pharmacists. In yesterday’s publication dated June 14th, 2023 it is stated “The draft standards propose a requirement that regulated members not hold themselves out as a regulated member when providing services that fall under the Personal Health Services regulation. Schedule 19 section 3(1) or 3(2) of the Health Professions Act (HPA) defines the roles of pharmacists or pharmacy technicians in their practices, and the provision of restricted activities outside of these defined practices is not appropriate. This means that the administration of injections for aesthetic purposes is not enabled. Authorized restricted activities for regulated members and their use must be interpreted and applied in context and conjunction with these sections of the HPA. Within Canada, six provinces specifically do not authorize pharmacists to provide injections for aesthetic purposes, and the remaining provinces have not enabled the practice.”
HPA: Your interpretation suggesting that pharmacists should not administer injections for aesthetic purposes seems narrow and rigid and potentially inhibits the evolution of pharmacists’ roles in healthcare. This interpretation seems to overlook some aspects of Schedule 19, which outlines that pharmacists are equipped with the skills, knowledge, and competencies to promote health, prevent diseases, and provide advice and education, not just dispense medications.
When comparing the roles and responsibilities as outlined in HPA Schedule 19 (Pharmacists and Pharmacy Technicians), Schedule 21 (Physicians, Surgeons, Osteopaths, and Physician Assistants), and Schedule 24 (Registered Nurses), it becomes clear that all three professions share common ground in health promotion, research involvement, provision of treatment and intervention, and education. Yet, the current interpretation of the HPA seems to limit pharmacists’ roles to a far more traditional scope than these other health professionals.
I firmly believe that pharmacists, with proper training and continuous professional development, are more than capable of expanding their skillset to include aesthetic procedures.
As healthcare continues to evolve, I implore you to reconsider this interpretation of the HPA in light of the potential benefits expanded pharmacist services could bring to our communities, both from a health promotion and accessibility standpoint. This reconsideration could pave the way for a more collaborative and comprehensive approach to healthcare in Alberta, maximizing the capabilities of each health profession.
Thank you for your time and consideration. I look forward to a constructive and open dialogue on this matter. I have attached the pdf file that have schedule 19, 21, and 24 side-by-side for your reference.