GPhC

General Pharmaceutical Council's Consultation

on Religion, Personal Values and Beliefs

- a submission on behalf of Affinity, February 2007.

All the relevant documentation can be read on the GPhC's website at:
https://www.pharmacyregulation.org/sites/default/files/consultation_on_religion_personal_values_and_beliefs_december_2016-ii.pdf

Please provide a brief description of what your organisation does and what your organisation's interest is in this particular consultation:

Affinity is a partnership of churches, evangelical agencies and individual Christians committed to working together to advance the Gospel in the UK, Ireland and around the world. With more than 1,200 UK churches in fellowship, we are one of the largest groups of evangelical churches in the country. Further details can be found on our website: www.affinity.org.uk Among Affinity's specialist teams is one that deals with social issues, such as education, the law, families, politics and bioethics. Among our thousands of constituents are pharmacy users, patients, as well as pharmacists.

Collated consultation questions:

1. Do you agree with the proposed changes to the wording of the examples under standard 1 – about religion, personal values and beliefs?
No.

1a. Please explain your reasons for this.
Conscientious objection, and its personal expression, are key freedoms of any civilised society. They ensure that we are at liberty to express ourselves without fear or favour. Of course, they also mean that not all people will agree on all issues – that is part of what makes us individuals and so encourages and preserves our social diversity. Affinity is concerned that these freedoms are currently under threat in the UK by means of subtle pressures under the guise of political correctness and equality legislation. We fear that the proposals of this Consultation from the General Pharmaceutical Council (GPhC) are part of that curtailment of conscientious objection.

We think that the proposed changes to both the Standards and the Guidance, in particular the removal of the right to refer, are too coercive and will seriously impinge upon the rights and freedoms of pharmacists and pharmacy technicians, as well as those of the general public.

We are especially concerned that the Consultation is based upon the ‘religion, personal values and beliefs’ of pharmacy professionals, as if Christian, Muslim, Zoroastrian and such-like pharmacists deserve specifically targeting and restraining. This thinking needs to be challenged. As the Consultation rightly states (p. 15), ‘… religion means any religion, including a lack of religion. Belief means any religious or philosophical belief, and includes a lack of belief.’ In other words, everyone, including the agnostic and the atheist, has his or her worldview shaped by ‘religion, personal values and beliefs’. To pretend otherwise, as if people are able to live some sort of morally-neutral lives, is absurd. To that end, it is entirely feasible, and morally unobjectionable, that an atheist pharmacist might oppose dispensing emergency ’contraception’ just as a Christian pharmacist might contest the selling of homeopathic ‘medicines’. In other words, it is not just Christians who might be troublesome, it is the entire pharmaceutical workforce, simply because all have been moulded by ‘religion, personal values and beliefs’. We understand why the GPhC might wish to impose some sort of uniformity upon its professionals, but we question its rationale, ethicality and usefulness.

Moreover, the proposals are unnecessarily severe. They will have at least two adverse effects on the profession. First, they will marginalise, even result in the dismissal, of some of the most competent and caring pharmacy professionals. Second, they will deter many ‘morally sensitive’ young people from seeking to enter the profession. Neither will engender ‘patient-centred care’.

We understand that some practical aspects of affirming and upholding conscientious objection may be complex, but they are not unachievable and they are entirely laudable. Indeed, such a position is contained in guidance issued by the General Medical Council, and is protected by conscience clauses in the 1967 Abortion Act (s. 4) and the 1990 Human Fertilisation and Embryology Act (s. 37). If other branches of the healthcare enterprise can respect and maintain such a stance, surely the GPhC also could, and should.

2. Does the revised guidance adequately cover the broad range of situations that pharmacy professionals may find themselves in?
No.

3. Is there anything else, not covered in the guidance, that you would find useful? Please give details.
Doubtless all of Affinity's constituents are consumers/users of pharmacy services. We are concerned that the GPhC proposals would not only mitigate against those of us who are pharmacy professionals, but that all of us would feel compromised conducting business with pharmacies that practise workforce discrimination. To force pharmacists either to act against their consciences, or leave the profession, is a step too far. Similarly, to suggest that such pharmacists can work only in a few large dispensaries, where at least two professionals are on duty, is to discriminate against and unduly constrain the careers of too many.

4. Will our proposed approach to the standards and guidance have an impact on pharmacy professionals?
Yes.

5. Will that impact be: Mostly negative.

5a. Please explain and give examples.
Several explanations and examples have already been outlined above. In effect, the GPhC proposals will result in those pharmacy professionals, who have a religious or moral opposition to dispensing certain pharmaceuticals and providing equivocal medical advice, being presented with a two-fold dilemma. They will either have to abrogate their consciences or leave the profession. That is too punitive. Moreover it may also be in contravention of the 2010 Equality Act whereby ‘freedom of religion and belief’ is protected as well as by Article 9(1) of the European Convention on Human Rights, which safeguards ‘freedom of thought, conscience and religion’.

The solution is relatively simple. It consists of ‘reasonable accommodation’. The current system of Standards and Guidance has proved to be satisfactory for many years. There is no evidence of widespread unworkability or complaints from pharmacists or the general public. Therefore, leave as is! Or another possibility would be to adopt an opt-out scheme similar to that of paragraph 8 in the GMC’s Personal beliefs and medical practice (2013).

6. Will our proposed approach to the standards and guidance have an impact on employers?
Yes.

7. Will that impact be: Mostly negative.

7a. Please explain and give examples.
As outlined above, the proposals will have a negative effect upon staff recruitment and retention, as well as patient-pharmacist/pharmacy relationships.

8. Will our proposed approach to the standards and guidance have an impact on people using pharmacy services?
Yes.

9. Will that impact be: Mostly negative.

9a. Please explain and give examples.
We are concerned that the proposals will undermine the consumer-pharmacist relationship of respect and trust. Consumers want to deal freely with honest, uninhibited professionals. When we ask for advice and/or a professional opinion, we expect genuine answers, not those manipulated by some socio-political regime. This is not the way to ensure ‘patient-centred care’.

10. Do you have any other comments?
The Social Issues Team of Affinity is grateful for the opportunity to make this submission to the GPhC’s Consultation. Much within the Consultation is sensible and commendable. However, we have fundamental disagreements with other aspects, as outlined above. While our response to the Consultation is primarily from a Christian perspective, our concerns and remit are far more comprehensive and therefore applicable to all men, women and children.

In summary, we are opposed to the proposed changes. We consider them to be discriminatory, unethical and unnecessary. As already stated, the solution is relatively simple. It consists of ‘reasonable accommodation’. The GPhC's current system of Standards and Guidance has proved to be satisfactory for many years. There is no evidence of widespread unworkability or complaints from pharmacists or from the general public. To ensure ‘reasonable accommodation’ the present Guidance should be retained, or changed to an opt-out scheme similar to that of paragraph 8 in the GMC’s Personal beliefs and medical practice (2013). Whichever, we ask the GPhC to think again and withdraw its current proposals.

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