RXA response to ACP

4.3.2 – It is unclear if this statement means the regulated member shouldn’t be doing these activities or should not say they are a pharmacist when they are doing them – or should not do them in a pharmacy?  Further, we feel that instead of restricting this activity in its entirety, the college should instead consider establishing the criteria, knowledge and skills within which a pharmacist would need to demonstrate their safe effective care when providing these types of services and using medications.  It is our understanding that many pharmacists have pursued competency learning and training to enable themselves to confidently provide these services and if they could demonstrate having met the ACP criteria, then they should be able to continue.  If the pharmacist is the best trained individual providing this service, then that should be the person providing the care.  Instead, you are asking them to transfer care to someone who potentially has lesser qualifications – which is not person focused nor in the best interest of the patient.  Other healthcare professionals are not restricted in this way.  Eg. Dentists are able to provide botox injections for aesthetic reasons using their knowledge and skill – https://www.cdsab.ca/?s=botox . 

7.7.3 a) i) – Keeping with the person-centeredness of these standards, helping a patient’s mental health through improving body image by administering a product to improve aesthetic appearance should be accommodated for pharmacist practice.  There are “health” elements for mental health where these services might be appropriate and not called “aesthetic” – so how are these differentiated?  It seems unreasonable to restrict aesthetic injection in its entirety, §  rather we feel that appropriate competencies should be defined for when a pharmacist chooses to engage in providing this type of care, and that they satisfy these before providing.  The college could identify what these competencies would be which would give a pharmacist an opportunity to continue providing this care while also meeting the College criteria for safe provision.