The operation of a retail pharmacy business is governed by the Pharmacy Act
2007 and the Regulation of Retail Pharmacy Businesses Regulations 2008 (S.I.
488 of 2008). These particular draft guidelines seek to facilitate compliance with Regulation 4(3).

‘The pharmacy owner shall provide a separate and designated area conveniently located within the pharmacy premises so that a pharmacist may review and discuss in private with the person for whom a prescription has been issued, or with the carer of such a person, such matters relating to the medicine therapy as either of the said persons may request or as the pharmacist, in the exercise of his or her professional judgement, may deem necessary.'

The key factors for consideration in the consultation area are;

1. Privacy

The area must be constructed so as to ensure a reasonable level of privacy for the patient, at all times, i.e. any discussion between the pharmacist and the patient, when speaking at a normal volume, should not be overheard by others.

In addition, the visual privacy of the patient should be considered and the pharmacist should be in a position to demonstrate medicinal products and/or medical devices to the patient without being overseen.

Visual and sound barriers can be used to ensure the above criteria are met.
However, it is not always necessary to create an enclosed room to achieve an
appropriate level of privacy.

2. Separate and Designated Area

The patient consultation area should be a designated area and therefore used
solely by the pharmacist for the purpose of patient consultation and counselling.
The area should not be used for other purposes, e.g. the storage of medicines or excess stock.The area should not be an access route to other areas of the pharmacy, e.g. a store-room, bathroom or the dispensary.

There should be a sign in place which informs patients that the facility exists and is available for their use, should they wish to request the professional input of the pharmacist. Each retail pharmacy business should also have written policy and procedures, which encourage and train staff to direct patients to the consultation area and inform them of their entitlement to such a facility.

3. Conveniently Located

The area should be conveniently located and easily accessible to the patient and
the pharmacist and therefore should be close/ adjacent to the dispensary and non-prescription medicines area. There should be direct access for the patient from the public area of the pharmacy.

A convenient location will help to ensure that the consultation area is availed of more frequently and will allow patient-pharmacist interactions to take place in an environment that respects a patient's dignity and privacy and enhances the professional role of the pharmacist.

4. Size

The area must have sufficient space and facilities to allow the pharmacist, the
patient and/or their carer or guardian to be seated. The area must be accessible to all patient profiles and therefore must be wheelchair accessible.
 

5 Fixtures and Fittings

The area should be fit for purpose. It should be professionally finished and furnished to a high standard to reflect the professional nature of the area. The equipment available should allow for counselling and demonstration on the correct and safe use of specific medicinal products and medical devices, as required, i.e. there should be a table or worktop in the room to facilitate such demonstrations, the writing of notes by patients or their carers, etc.

6. Supervision

The pharmacy layout must be appropriate, and adequate pharmacist personnel must be in place to allow for the required supervision of any preparation, dispensing, compounding, sale or supply of medicinal products. This should be considered when planning and constructing the area. The superintendent and supervising pharmacists should consider the availability of other pharmacists to fulfil these and other requirements as envisaged under the legislation.

7. Security

The security and safety of the patient and the pharmacist is paramount. The consultation area should not be used when, by entering the area, there is deemed to be a potential risk to the personal safety of a patient, pharmacist or
another staff member.

The use of security features such as CCTV cameras or panic buttons can be considered in the area. Patients must be informed of the presence of these devices in the consultation area.

8. Additional or Extended Pharmacy Services 

Consultation area use, and therefore requirements, will vary depending on the services provided by the pharmacy. The regulatory requirement is that, at a minimum, the area allows for private discussions between the pharmacist and the patient on medication and health issues. If a pharmacy currently provides additional services such as health screening and monitoring services, or may consider providing such services in the future, there will be additional requirements for an area that can facilitate these services. This includes the degree of privacy required, the size of the area and the equipment requirements.

Comments are welcome in writing to consultation@pharmaceuticalsociety.ie or by post to Public Consultation, PSI, 18 Shrewsbury Road, Ballsbridge, Dublin 4, and by 5.00pm on Tuesday 06 April 2010.