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8/12/2019 pharmacyguildwatch (2)
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RISKMANAGEMENT
G U I L D W A T C H
FOR PHARMACY
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CONTENTS
SECTION 1 2
GUIDE TO GO ODDISPENSING
SECTION 2 10
SECURITY& LO SS
SECTION 3 18
PUBLICLIABILITY
SECTION 4 24
HEALTH& SAFETY
SECTION 5 32
PRIVACYCONTROLS
SSECTION 6 34
INCIDENTS& CLAIM S
SECTION 7 36
RISKHORIZONS
Guild Risk Services, a Division of Guild
Insurance Limited, has produced this
GuildWatch Risk Management Guide for
Pharmacy. It provides preventative
measures from both an insurance and a
professional standards perspective to
minimise risk. It is a proactive guide to
assist you in reducing the likelihood ofloss in your pharmacy.
The new revised text is divided into
sections each with a series of challenges;
together with a question-and-answer, risk
and quality snapshot to help you assess
your pharmacys level of risk.
We hope you enjoy the new GuildWatch.
David Roddis
Group Risk Man ager
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INTRODUCTIONGuildWatch, Risk Management for Pharmacy, has been
produced in c onsultation w ith the Pharmacy Guild of Australia,
Pharmaceut ical Defence Limited, Pharmacy Board of Victoria
and the Pharmaceutical Society of Australia. We thank these
bodies for their valuable insights and advice in preparing th is
document.
1
Guild Insurance Limited works closely with the profession and its representatives. The
Risk Management Committee (which comprises members of Pharmaceutical DefenceLimited, the Pharmacy Board, the Pharmaceutical Society of Australia, the Pharmacy
Guild of Australia and members of Guild Insurance) meet to review claim trends on a
regular basis. This has assisted in producing a Guide that reflects the issues that impact
upon your pharmacy. By way of illustration you will find real case studies throughout the
document which are indicative of those commonly received and managed by Guild
Insurance.
Reducing dispensing error, and managing the process if any error occurs, is one of the
main themes in this document. However, there are many other incidents that may result
in litigation, not the least of which are possible breaches of the Privacy Act and Trade
Practices Act. We hope you find the advice timely and practical. The aim is to add value
to your business by helping to identify the risks that surround your everyday activities.
In addition to this printed document, Guild Risk Services has an on-line self assessment
risk management tool, RiskMASTER.
RiskMASTER provides an anonymous online survey system which, through a series of
questions and answers, assists you to assess your risk profile and your management of
risk. Surveys on a range of topics are provided and the resulting report includes advice
on steps to take to improve your risk profile or reduce risk. These reports can be used
in the professional development for your team.
We value your feedback
A reader survey form has been included in this publication and we ask that you
complete this and return it to Guild Risk Services. We appreciate your feedback.
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GUIDE TO GOODDISPENSING
SECTION 1
Every year millions of prescriptions are filled by Australian pharmacies. AsAustralia has become more l it igious, and as the range and complexity of
medications has increased, the need for a highly vigilant approach to
cont roll ing risk in dispensing has never been great er.
Challenges 3
Question-and-answer Risk and Quality Snapshot 4
Errors & solutions 5
Common sound-alike and look-alike drugs 7
Risk control steps in dispensing (flow diagram) 8
2
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CHALLENGES
Evaluating dispensing processes, equipment and proceduresto minimise risk of error.
Use of layout and technology to minimise error.
Organising storage and product placement so that risk ofincorrect drug selection is reduced.
Group drugs to avoid similar name and similar strength errors.
Use of scanners to enhance the dispensing process.
Standardising use of abbreviations and the labelling protocolsused by all personnel.
Communicate with prescribing doctors where doubt exists inregard to the prescription.
Managing workflow and ergonomics for maximum comfortand minimal distraction.
Agreeing on communication protocols among allpharmacy personnel in the event of a dispensing error.
3
Dispensary design and procedural c ontrols are the keys to
eliminating or reduc ing dispensing errors. Here is a l ist of
your main challenges.
G U I L D WATC H
GUIDE TO GOOD DISPENSING
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4
DISPENSARY LAYOUT Yes Could improve No
Are phones redirected away from the dispensary?
Is the dispensary area removed from distracting sounds?
Is lighting high grade and free from glare?
Are work stations self contained with their own printer?
Are work stations ergonomic in their design?
TECHNOLOGY
Are database technologies used effectively?
Is data entry appropriately quality assured?
Are scanners used to provide additional checking support?
Is equipment standardised at each work station?
STORAGE AND STOCK ROTATION
Is grouping by manufacturer not practised?
Are strengths of the same drug separated?
Are look-alikes and sound-alikes separated?
Are unusual or dangerous drugs subject to special protocols?
Are drugs restocked so as to rotate stock and avoid expiry?
WORKFLOW
Is workflow directional to avoid double handling & confusion?
Is the pharmacist involved at the beginning and end of thedispensing process?
Are dispensary technicians fully utilised to free up the pharmacist?
Are interruptions kept to a reasonable minimum?
INFORMATION ISSUES
Are suspicious scripts checked with the clinician?
Are strengths and dosage queried when unclear?
Are patient histories used to cross check interactions?
Are additional checks in place where multiple clinicians prescribe?
Does a protocol exist in the event an error occurs or is suspected?
CAUTIONARY AND ADVISORY LABELS
Are suitable cautions attached to packaged drugs?
Are labels attached so that manufacturer advice is still visible?
Are CMIs provided where required?
Work t hrough the following t o assess
how your pharmacy is placed to
mitigate dispensing risks. QA&
Ques tion-a nd-a nswer Risk a nd Qua lity S na pshot
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The volume and variety of drugs handled by a
pharmacist requires that care be taken instoring and providing access to them. Here
are some of the main ways to reduce error:
USE OF INFORMATION TECHNOLOGY
The variety and volume of drugs on offer
makes the use of database-driven dispensing
programs essential. But like all such
technologies, they are only as good as the
way in which they are handled. Basics
include:
checking of data entered because an error
can be multiplied
control of access and administrator rights
avoidance of double entry of data
entry of consistent and decipherable
abbreviations and notations
update of data on a regular cycle.
USE OF SCANNERS
Scanners are strongly recommended by
Pharmaceutical Defence Limited and G uild
Insurance.
Where they are used properly, they have been
shown to reduce error by providing an
additional layer of checking. To review their
use in the dispensing process, please refer to
the chart on pages 8 and 9.
MANUFACTURER GROUPING
It may be quicker and easier to replenish
stocks if they are kept according to
manufacturer. H owever, the similarity in
packaging style between different drugs from
the same manufacturer immediately increases
the risk of an incorrect selection. If this
practice is followed in your pharmacy,
consider implementing a new system.
SEPARATION OF STRENGTHS
Dispensing the incorrect strength of a drug
(for example Wafarin) can be as dangerous as
dispensing the wrong drug! In fact, it is amore likely error; for this reason, strengths
should be separated on the shelf, even
though the drug is the same and from the
same manufacturer.
SEPARATION OF SIMILAR NAMES
Similar names are a fact of life in the industry
and an issue further complicated by the
emergence of generics. Solutions include:
use of scanners
absolute separation of similar names and
avoidance of a purely alphabetical
organisational system
prominent display of an up-to-date list of
similar names to encourage recognition
among the pharmacy team (see table p.7)
reorganisation of stock when a new similar
name appears.
ROTATION OF STOCK
Systems for restocking must be designed so
that stock rotation is achieved. This will
reduce the risk of dispensing expired goods.
SPECIALIST DRUGS AND HIGH VOLUMES
It is recommended that drugs with a greater
risk profile (eg, special usage requirements
and/or high risk of interaction) are stored
separately to the more commonly prescribed
drugs.
DIRECTIONAL WORKFLOW
Directional workflow is recommended to help
reduce double handling or possible
confusion. Each dispensing station should be
self contained to avoid risks that may arise
from sharing of resources such as label and
repeat printers.
Systems and controls
ERRORS & SOLUTIONSBecause dispensing involves human interact ion and judgement
(and includes information provided by patients and doct ors)
errors cannot be totally eliminated. However, they can be
minimised both in frequency and severity.
Very few professionals
operate in such high-stresssettings where distractions
are not easy to eliminate
and where conflicting
demands on the
professionals time are
made throughout the day.
It is therefore very impor-
tant to review and manage
workflow, physical layout
and interaction protocols.
5
CLAIM SNAPSHOT
A locum pharmacist
made a selection error
leading to a customer
being dispensed anti
depressant medication
on a prescriptionfor
gout medication. The
names and the pack-
aging of the two
(generic) medications
involved were very
similar. The customer
has alleged that he
has sustained signifi-
cant medical and hos-
pital expenses as a
result of the error and
made a substantial
claim.
G U I L D WATC H
GUIDE TO GOOD DISPENSING
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6
ERRORS & SOLUTIONS (continued)
Managing strengths, sound-
alikes and look-alikes must
be the rationale for any
organisational system.
A purely alphabetical sys-
tem will not provide suffi-
cient protection from error.
Physical separation and
clear labelling are bothessential.
CLAIM SNAPSHOT
As a result of difficulty
reading a prescription
sent by facsimile, the
pharmacist dispensed
an excessive dose of
opioid analgesic. This
led to the elderly
patient becoming
drowsy causing her to
fall and sustain signif-
icant injuries. Her
family claimed sub-
stantial compensation.
CLAIM SNAPSHOT
A pharmacist dis-
pensed Wart-Off to a
customer as he did
not stock Wartec.
Wartec is designed for
use in the treatment ofwarts around the
genital region whereas
Wart-Off is contra indi-
cated. The client
sustained chemical
burns, leading to a
claim being made.
FORWARD PHARMACY
Irrespective of the pharmacys specific
operating arrangements, the pharmacist must
be involved at the beginning of the process
and at its conclusion.
Perhaps the greatest distraction for the
professional pharmacist is that generated by
the commercial activities of the pharmacy. Very
few professionals are required to provide their
skills and knowledge in such an open,
potentially noisy, and high traffic environment.
This may lead to stress and reduces the ability
to concentrate for long periods. Therefore,
physically engineering your work place so that
you can work with minimal interference is
essential for your well-being and it is also
essential for error control.
G ood design of the dispensary will allow the
pharmacist to interact with patients for
counselling but will also provide privacy andquiet to improve concentration.
Basics include:
redirection of all incoming phone calls to
the service counter and space separation
between dispensing and commercial
functions in the pharmacy
use of sloping drawers, caroussels and
other devices to systematise, and reduce
inconvenience
properly designed work stations including
sufficient room, dedicated label and repeat
printers, adjustable heights for benches
and fittings
excellent ergonomics including noise
control and ergonomic workflow
management (eg, avoiding double
handling, stretching and bending)
high levels of illumination appropriate to the
environment
staff training as to when and how to interact
with the pharmacist.
At all times it must be remembered that patient
counselling and consultation are the primary
roles of the pharmacist. D ont let other
distractions get in your way.
The practice of pharmacy requires excellent
management of information from distinct
sources: pharmaceutical knowledge,
prescriptions from clinicians, and information
provided by the patient or their care giver. The
variety and multitude of sources of information
can cause problems. Here is a list of the
common causes of error:
RIGHT DRUG WRONG STRENGTH
Similarities between packages can cause a
dispensing error (again, scanning technologies
will assist with capturing such errors). O ther
causes include:
doctor error in dosage prescription
inconsistent use of abbreviations
transposition of quantity, strength and /or
frequency
Well set up patient histories can assist in quality
assuring dosage and strength.
PRESCRIPTION QUALITY
Pharmacists must rely upon the information
supplied to them. However, a critical approach
is required to deal with the following key issues:
unclear handwriting or instructions
obviously incorrect scripts.
Where information is doubtful, the pharmacist
should always check with the prescriber.
INTERACTIONS
Because the pharmacist is a central point of
contact in a patients care, the pharmacist
should routinely check the patients history forinteractions or other warning signs. Pharmacists
should be alert to interactions when processing
scripts provided to one patient by a variety of
clinicians. O bviously, the doctors should
likewise be checking; however, where your
records show a likelihood of adverse
interactions your dispensing practices may be
called into question in an adverse event.
HUMAN ERROR AND FATIGUE
There are obvious limits on the capacity of any
individual to work in an error-free manner over
long stretches of time. A planned work day
with some element of job rotation and breaks
is therefore prudent.
Information-related problems
Reduc ing distrac tions
G U I L D WATC H
GUIDE TO GOOD DISPENSING
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7
ERRORS & SOLUTIONS (continued)
It is acknowledged that as the number of
scripts increases the likelihood of an incident
arising from a dispensing error also
increases. O bviously, the nature of the script
dispensed has an influence on the time
taken. As an example, for a person to dispense
160 scripts per day at an average of three
minutes per script equates to 480 minutes or
eight hours. This does not include any time for
breaks or other issues. O n an ongoing basis this
is a cause for concern, as the potential for a claim
may increase depending on the script dispensed.
EXTEMPORANEOUS
DISPENSING/COMPOUNDING
Particular care should be exercised by
pharmacists who are requested to dispense
medicines extemporaneously for which there
are no precedents in the standard references
or who are requested to, or choose to make
alterations to proprietary medicines. Refer to
State and Territory Pharmacy Board G uidelines
and PSAs Professional Practice Standards.
CORRECT USE OF CMIS
CM Is are not a substitute for patient
counselling as patients often require and
expect some explanation and reassurance.
Refer to the PSA s guidelines on C onsumer
M edicine Information and the Pharmacist.
PRESCRIPTION REPEATS
Where repeats are provided by the clinician,it is inadvisable to dispense them all at once.
This type of practice is discouraged as it puts
people at risk. These risks include:
large quantities of a drug in a persons
household
prescribed medication may change but
patients may continue taking old medication.
Adalat Aldomet
Akamin Aclin
Aldactone Aldazine
Aldactone Aldomet
Aldomet Alodorm
Alphapress Alphapril
Alprim Solprin
Amantadine C imetidine
Amaryl Amoxil
Amaryl Reminyl
Amfamox Alphamox
Amitriptyline Aminophylline
Amoldipine Amiloride
Amohexal Atohexal
Amorolfine AminophyllineAmoxycillin Ampicillan
Anaprox Aprinox
Apomine Avomine
Aratac Aropax
Arima Arimidex
Aropax Aratac
Arthrex Aururix
Atacand Atacand Plus
Atrop Azopt
Augmentin Augmentin Forte
Aurorix Aropax
Auspril Auscap
Avandia Avanza
Avanza Avandia
Avapro Avapro-HCT
Beclomethasome Betamethasone
Beconase Becotide
Betaloc Becotide
Burnetanide Budesonide
Capoten G opten
Carafate Caltrate
Carbimazole Carbamazepine
Cardizem Cardiprin
C ipromil C iproxin
C isplatin Carboplatin
C lomid Atromid
C lomipramine C lomiphene
Clomipramine Chlorpramazine
Cortisone Cordarone
Daonil DeserilDeptran Ditropan
Deptran Endep
Deptran Ditropan
Desferal Deseril
Diaformin Diamicron
D iamicron D iamicron-M R
Dicloxacillin Flucloxacillin
Didronel Didrocal
Difflam Differin
Dimeryl Reminyl
D ithiazide D itropan
Dothiepin Doxepin
Doxepin Dothiepin
Efexor Efexor-SR
Endep Deptran
Ergotamine Ergometrine
Fluoxetine Paroxetine
Gemfibrozi l Gabapentin
G lipizide G licazide
Hydroxyzine Hydralazine
Imdur Imuran
Imdur Ibilex
Imipramine C lomipramine
Imipramine Trimipramine
Ketotifen Ketoprofen
K alma K aluril
Lamictal Largactil
Lamictal Lamisil
Lamisil Lamictal
Lanivudine LamotrigineLasix Lasix-M
Lasix Losec
Lasix Lescol
Levlen Logynon
Lipex Lipitor
Lipidil Lipazil
Losec Prozac
Lovan Luvos
M axolon M oxacin
M icardis M icardis-P lus
M iloride Amizide
M obilis M ovalis
M ogadon M axolon
M onoplus M obilis
M onopril M onoplus
Norfloxacin Ciprofloxacin
Norimin Norinyl
Norvasc Normison
Panadeine FortePrednefrin Forte
Panafcort Panafcortelone
Paroven Proven
Paxam Paxtine
Pethidine Prothiaden
Pramin Pressin
Prednisolone Prednisone
Prednisolone Risperidone
Q uinine Quinidine
R ocaltrol R oacutane
Rosig Zomig
Seretide SereventSerevent Seretide
Seroquel Serzone
Tenoxicam Tamoxifen
Thioridazine Thyroxine
Tramal Tramal-SR
Trimipramine Trimeprazine
Vasocardol Veracaps
Xalatan Xalacom
Zantac Zyrtec
Zestril Zyrtec
Zinvit Zinnat
Zocor Zestril
Zocor Zoton
Zoloft Zocor
Zyprexa Zyrtec
COMMON SOUND-ALIKE/LOOK-ALIKE DRUGS
The chart above is an alphabetical list of common drugs which look-alike or sound-alike. Source: PDL 2006 annual report, with permission.
CLAIM SNAPSHOT
A pharmacist dis-
pensed generic long
acting insulin rather
than short acting. The
patient did not realise
until away on holiday
in a remote place
where he used it andsignificantly compro-
mised his health. The
customer claimed the
cost of the ruined
holiday.
G U I L D WATC H
GUIDE TO GOOD DISPENSING
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8
RISK CONTROL The script is received and regis-tered on the system. Its legality is established andcontact details and key personal data is confirmed.
STAGE I RECEIVAL
ACTIVITY
Patient deta ils
Name
Address
Phone number
Mobile number
Concessional entitlements
Medicare Number
Allergies
Child's age
Weight
(remote/rural: where will be next stop)
Presc ription de tails
Date
Doctor's signature
S4 requirements
S8 requirements
HIC Authority Approval
RISK CONTROL The computer record is checked forabuse, interactions and information needs (CMIs).The label is attached and scanned for a doublecheck. The screen is checked during the scan.
ACTIVITY
Che ck s a gainst patient history
Enter script into computer checking for:
Change of dosage
Interactions
Evidence of misuse
Selec tion a gainst script
Drug
Strength
Quantity
Labelling
Che ck directions on labe l against those
on the original sc ript
Expiry date
Drug, strength and quantity
Attach label to product leaving bar code
exposed
Scanning and screen double check
Sca n barcode and re-chec k sc reen for :
Patient name and address, and date
Drug
Strength
STAGE 2 PROCESSING
G U I L D WATC H
RISK CO NTRO L STEPS IN DISPENSING
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9
RISK CONTROL The near-f inished i tems arecollated and additional warnings affixed.
ACTIVITY
Packaging and warnings
Attach appropriate cautionary and advisory
labels
Place in container which leaves all items
visible, with relevant paperwork
RISK CONTROL The finished items are presentedfor col lection. Counselling, i f necessary, provided.
ACTIVITY
Communication
Determine level of counselling required
Provide CMI if required
Maintain privacy and confidentiality
Consider special needs of patient
Double checks
Verify drug against script
Verify recipient
The steps advised above are based on the Quality Care Pharmacy Program. They are aimed at reducing or
eliminating dispensing error including: wrong drug, wrong strength, interactions, misinformation and
patient medication abuse.
STAGE 3 AS SEMBLY
STAGE 4 COMMUNICATION
G U I L D WATC H
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SECURITY& LOSS
SECTION 2
Dispensing best practice must be matched by management of security,premises and goods as pharmacies operate for long hours and thereforehave specific risks to control in these areas.
Challenges 11
Question-and-answer Risk and Quality Snapshot 12
Cash & negotiables 13
Security systems 14
Theft; fraud 15
Stock; agencies 16
10
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CHALLENGES
Handling cash securely by using both a time delay safe andclearing registers during the trading day.
Daily banking. Cash held overnight should be moved to acash-rated safe.
Displaying prominent signage that communicates the use ofsecurity and surveillance systems.
Training all staff on how to respond safely in the event of anarmed robbery.
Ensuring physical barriers to all forms of unauthorised entryare in place and adequate.
Securing all access points (eg, skylights), not only windowsand doors.
Installing closed circuit television (CCTV) to deter shop-liftingand malicious damage and create a record for investigation.
Installing good quality burglary and smoke alarmsthat are monitored to Grade 1 standard.
Managing stock losses including theft, and spoilage;securing high-value stock.
Training on fraud, and the use and abuse of credit cards,cheques and concessions.
11
Secur i t y sys tems reduce loss and pro tec t your va luab le
bus iness assets . How do you c ur rent l y measure up
agains t these key c ha l lenges?
NOTE:
A store refit or extension
can create security blind
spots. At the time of any
such renovations, ensure
that security systems are
not compromised. It is
often wise to have a
security audit carried out tocheck that security remains
adequate.
G U I L D WATC H
SECURITY & LOSS
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12
CASH AND NEGOTIABLE INSTRUMENTS Yes Could improve No
Are registers anchored and cash drawers locked?
Are registers left empty and open after closing?
Is minimal cash held in registers in accordance with QCPP?
Is cash cleared directly to a time delay safe?
Is banking completed daily so overnight cash is minimal?
Is the cash drop safe on a time delay and anchored to the wall/floor?
If on a keypad system, is the code regularly changed?
Do you display signs stating that time delay safes are used?
Do you train new staff on safe response to robbery?
SECURITY SYSTEMS
Are all windows and doors reinforced and secure?
Are all access points (such as skylights) secured?
Is illumination at night sufficient to discourage thieves?
Is the rear entry well lit and secured?
Are glass break sensors and reed switches installed?
Are deadlocks used on all windows and doors?
Is CCTVinstalled, especially in high risk areas?
Is your alarm monitored by a Grade 1 monitoring company?
Does the alarm have a back up system in place?
Are smoke detectors linked to the monitored alarm?
THEFT; FRAUD
Are blind spots avoided with mirrors and CCTV?Are cash registers and other high value areas covered by CCTV?
Is a master keying or pin code system used?
Is the use of CCTVprominently advertised?
Are staff trained in how to respond to shoplifters?
Is an employee anti theft policy in place?
Are controls such as audits used to control supplier theft?
Is fraud training carried out and are internal controls used?
STOCK; AGENCIES
Is responsibility for cash collection clearly understood/contracted?
Is the ATM the total responsibility of the supplier?
Work through the follow ing chec klist toassess how your pharm acy rates. QA&
Ques tion-a nd-a nswer Risk a nd Qua lity S na pshot
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CASH & NEGOTIABLES
Large amounts of cash held in the cash
register will increase the risk of robbery andof employee fraud.
THE CASH REGISTER
Your cash register should be anchored and
hold minimal cash. M ore importantly, minimal
cash holding should be communicated with
signage so that the incentive to conduct an
armed hold-up (or break & enter) is reduced.
TIME DELAY SAFES: A DETERRENT
A time delay safe should be used to store
cash taken from the register throughout the
day. Note that such a safe will still allow later
access, but on a time delay. A standard, quick-to-access safe may place staff under extra risk
during a hold-up if they are asked to open it.
The majority of thefts are conducted in just a
few minutes.
Time delay safes cannot be opened on
request. They can also be linked to remote
monitoring which will activate an alarm and
notify of a crime in progress when access is
attempted in a certain way. Such safes are
therefore a deterrent. P rominently displaying
that they are used strengthens the deterrent.
DAILY BANKING
It is preferable to bank the days takings daily.
Vary your banking routine so that the pattern is
not predictable. O wners must consider who is
accountable for banking and ensure that the
staff member is provided with basic training on
their personal safety when carrying out this
duty. Professional cash carriers will minimise
risk to staff. R econciliation of cash from the
register should be done throughout the day so
that no staff member is required to count a
large sum of cash at one time. C ounting of
cash should be done in a secure area out ofpublic view. If cash is held overnight, a time
delay and security-rated safe is desirable.
New staff should be given training on the
appropriate way to respond in the event of anarmed hold-up. These events are stressful and
the aim is always to protect life first and
foremost. In the event of an armed hold-up:
keep calm and never argue
never try to talk a robber out of it
never argue, criticise or stare
inform of possible surprises such as a staff
member in a back room
make no quick movements
be honest about all available money
never chase a robber.
Your actions after a robbery are vital:
the pharmacist should take control
call 000 and ask for police; tell them We
have had a hold-up
lock the pharmacy; ask witnesses to
stay until police arrive
the scene, particularly any surfaces
touched by the robbers, should be
preserved until police arrive
do not discuss the event; rather askwitnesses to jot down independent notes.
C omparing stories will weaken evidential
value
do not discuss the event with the media
call Guild Insurance for assistance.
Regaining control of the pharmacy is vital. It is
recommended that those involved receive
trauma counselling because no matter how
they feel on the day, an extraordinary and
frightening event can produce a delayed
reaction. C ounselling will assist in
managing this potential reaction.
Responding after the event
Responding to a robbery in progressMana ging ca sh se curely
Theft is a crime of opportunity; reducing the opportunit ies
to gain access to cash is therefore the driver of managing
cash and other negot iable instruments in a w ay that w i l l
lessen the l ikel ihood of robbery.
13
G U I L D WATC H
SECURITY & LOSS
CLAIM SNAPSHOT
A Victorian pharmacist
took a call from thealarm monitoring com-
pany at 3.00am. A
number of the alarm
sensors had been trig-
gered. The alarm com-
pany contacted police;
however the pharma-
cist himself attended
at the pharmacy. As he
shone his headlights
through the shop win-
dow, two heads
bobbed down behind
the dispensary. The
pharmacist blocked
the front entrance to
the pharmacy with his
four wheel drive and
had an anxious wait
until police arrived.
Unbeknown to the
pharmacist the offend-
er/s had chiselled outthe concrete around
the bricks of the neigh-
bouring premises and
gained entry at that
point. More than
$10,000 worth of per-
fume was stolen.
NOTE: Please r emember at
all times the monitoring
company or police should
attend the pharmacy onsuspicion of a break-in. A
Pharmacist should never
attend a break-in by them-
selves.
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14
SECURITY SYSTEMS
There is a range of measures that can be taken
to dramatically lower the risk of a break andentry crime at your pharmacy.
ALL ENTRY POINTS
It is important to secure all entry points (not just
the main doors and windows). In particular, sky
lights, maintenance access, rear entry points
and toilet windows should be fully protected.
ILLUMINATION
After hours and late night trading are vulnerable
times with darkness providing concealment
opportunities. A well lit premises (including rear
entrances) will discourage opportunistic crimes
and acts of damage. If motion sensors areused they should be of good quality.
SECURITY PATROLS AND ALARMS
Patrols provide a visible presence but must
be used with monitored alarms.
PHYSICAL DETERRENTS AND SENSORS
Well developed solutions include:
shutters and grilles are highly effective, but
may not be appropriate in some locations
reed switches on doors and windows, and
vibration/glass break sensors, sound an
alarm when a break-in is attempted
reinforced glass with break detectors
makes entry more difficult
bollards where there is a reasonable risk
of a car ram-style entry
deadlock-style locks on all windows and
doors and a security door on rear access.
ADJOINING PREMISES
Sometimes an adjoining premises can pose a
risk. This is difficult to control. A
neighbourhood watch-style committee can
be formed to encourage awareness and
consistent practices between traders.
Internal security measures reduce risk during
open hours, and damage from burglary.PROCEDURAL
O pening and closing procedures should be in
place and staff trained in them; otherwise,
security systems may not be properly used.
KEY SYSTEMS
The key system for the premises should be a
master system or an electronic keypad system.
These enable proper control of staff access
and accommodate staff turnover.
INTERNAL SECURE AREAS
Areas that store high value items (stock,
specialist drugs, records or info-tech) shouldhave additional security measures.
CCTV
Digital computer-driven video monitoring has
become far more affordable. Its use is known
to discourage theft from all sources.
MONITORED ALARMS
A monitored alarm with a back up system is
preferred. The monitoring company should be
G rade 1 under the Australian standard. If a
dialler system is used, check that a G SM or
other back up system is in place. Also, where a
dialler system is used, compare the cost-benefitof this including the phone costs as it may not
be the most economical system.
A good monitored alarm includes:
response provided by the supplier, and
alert to owner, guards and local police
attendance of third party (not staff) at a call-
out (lower personal safety risk)
careful placing of detectors and checking
of their effectiveness (especially if store
layout changes)
awareness that false alarms indicate faulty
design of the system
linking of smoke detectors to the monitored
alarm.
Internal se curityExternal sec urity
The aim is to make it very hard to gain acc ess; and if access
is achieved, encourage t he offender to leave without further
damaging t he property.
CCTV and signs advertisingyour security investment act
as deterrents.
Glass break/ i mpact sen-
sors, reed switches and
strong locks help discour-
age an entry prior to it
being attempted.
Monitored alarms provoke a
response. The supplier
should provide a Grade 1
standard of monitoringwhere the owner, security
guards and police
or emergency services will
receive the appropriate
alert from the monitoring
station.
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THEFT; FRAUD
While it is very upsetting to have your trust
abused, to avoid unpleasant legal disputes
you must be careful how such thefts are
handled.
Loss prevention has a clear cost benefit with
estimates suggesting possible losses from
theft as high as 3% to 5% of turnover.
SHOPLIFTING
Signs must be displayed indicating that
customer bags will be searched when leaving.
Signs advising the use of CC TV (video
surveillance) in operation are also required
under law. O ther signs include the use of time
delay safes for cash, premises monitored 24hours, etc. All signage is a good deterrent to
theft.
ELIMINATING BLIND SPOTS
Store layout should make it difficult to
conceal theft. Appropriately placed convex
mirrors are a useful measure for revealing
blind spots. Video monitoring should also be
used to ensure there are no areas obscured
from view. R emember i f you cant see it
then it can be stolen!
ACCESS CONTROLS
Access to high value stock shouldbe controlled. Items of higher value such as
perfume should be close to staffed areas, and
should also be locked behind glass.
ELECTRONIC STOCK TAGS
When considering the amount of stock to be
tagged weekly, also take time to consider the
cost-benefit of this control method. A response
plan is also necessary as staff should not be
encouraged to pursue an offender.
GREETING CUSTOMERS
Just the act of greeting customers reduces
risk of loss because visitors become aware ofthe staff presence and that their presence has
been identified/acknowledged by staff.
Fraud carried out by customers will include
the following:
illegal scripts for harder drugs
returns and refunds
passing off identity
price switching
cheque fraud
credit cards
CONTROL CONCEPTS
These include:
carefully checking scripts, especially
suspicious notations
observing a pattern of repeated script
presentation
requiring receipts for returns and
displaying a returns policy
checking prices which seem incorrect
seeking ID for all cheques or having
regular customers register for use of
cheques
checking signatures and file records
automated card processing so that over
limits can be identified.Staff should be trained to spot fraud and
should be encouraged to adhere to
procedure if a customer is trying to hurry them
or confuse them.
This is an unpleasant occurrence and requires
a culture of vigilance. Aspects of effective
control include:
employment contract clauses stating clear
consequences for acts of theft
a policy on minimising theft
character references (verbal) and detailed
reference and job history checking
Employee theft
Customer fraudIntroduction
Theft and fraud by shoppers, employees or suppliers must
be handled c arefully as there are a num ber of potential legal
issues in making such an accusation.
Internal theft does happen
and needs to be managed.
A culture of control includ-
ing written policies will
reduce incidence as it wi ll
suggest that the behaviour
will not be tolerated.
Shoplifting can account for
inventory loss by between
3% and 5%. For this reason,
CCTV, mirrors, entry buzzersand the like are sound
investments.
Supplier theft must be con-
sidered, and the receipt of
goods should be a for-
malised process.
15
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STOCK; AGENCIES
16
use of C C TV where valuables are handled
double checking and counter signatures for
purchases and requisitions
some form of policy on incidental stock
which can be pilfered (eg, consumables)
stock reconciliation
staff discounts on products.
A combination of these practices will limit the
temptation to steal and to pilfer.
Fraud carried out by staff is often incremental
and difficult to detect in the early stages.
Skimming of stock or receipts, failure to ring
up sales and discounting for known
acquaintances are some of the ways in which
this can occur.
CONTROL CONCEPTS
Losses may be incremental or a large one-off
loss. Either way, the impact is unpleasant so it
is desirable to put controls in place which
discourage fraud related behaviour.
two signatures for requisitions and cheques
small sums in petty cash
rotation of jobs, especially checking and
audit roles
separation of roles and accountabilities
locked access to areas where cheques and
other negotiable instruments are held.
Pharmacies have a wide range of suppliers,
and suppliers come and go. Aspects of
effective management controls include:
check goods received and match to
invoices; demonstrate vigilance by carrying
out random in-depth audits; check before
signing for deliveries
try to avoid suppliers stocking shelves
have a staff member involved in receipt of
goods and take special care with new
suppliers
carry out mini stocktakes before and after
shelves have been restocked
keep accurate sales records so that any
discrepancies can be spotted. contractual clauses may be needed to
eliminate doubt and suspicion where high
value goods might have gone missing.
Supplier theft
Employee fraud
THEFT; FRAUD (contd)
Stock control is a big part of managing apharmacy. There is a wide variety and large
volume of goods, and often limited space in
which to handle and store them. This raises
various issues relating to loss control, including
those arising from safety considerations and
those arising from spoilage and asset
protection.
SAFETY ISSUES
The safety issues include:
manual handling considerations, especially
strains and repetitive movements
safe access and trip and fall hazards
using knives and cutters to open
packaging.
Space is often at a premium; however, stock
should not be stacked so high that it may
cause injury if it falls or risk of injury when
retrieving it.
THE KEY ISSUES OF LOSS ARE AS FOLLOWS:
stock rotation and ordering regimes which
avoid stock shortages and lost sales, but
also avoid surplus stock
damage of goods when unpacking and
confusion as to liability
spoilage and contamination
the treatment of goods requiring
temperature control
the receipt of high value (as opposed to
bulk) goods; especially who takes receipt
and where they are stored and under what
security conditions.
Introduction
Employee fraud does hap-
pen; and it occurs when
trust is not supported by
adequate checks and bal-
ances to control processes
and sign offs. Note that
good systems also
protect staff from that
uncomfortable feeling
when something goesmissing (for example a
sum of cash) and there is
no audit trail.
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17
Loss control for stock
includes proper rotation
and inward goods receipt.
High value chilled goods
must be carefully protect-
ed, and temperature sen-
sitive goods maintained at
their recommended tem-
perature.
Protocols, including internal sign offs, may be
needed to eliminate doubt and suspicionwhere high value goods might have gone
missing.
Not all losses are a result of theft. The storage
of items requiring refrigeration has increased
over recent years.
Inappropriately rotated and poorly stored
refrigerated stock is increasingly resulting in
losses, and increases the potential for
customer harm.
Refrigerators used traditionally for vaccine
storage have become the store space for a
number of additional items. Issues include:
C apacity of the refrigerator used. Does it
provide sufficient physical space to store
and keep its entire contents at the ideal
temperature? O ver loading can impact
cooling capacity. A larger unit of greater
capacity will operate more efficiently than a
small overburdened unit.
Is refrigerated stock being rotated to
ensure ageing stock is selected first? Are refrigeration temperatures monitored
and logged regularly to identify any failures
or temperature variations beyond
tolerance?
Is the temperature displayed?
Is the equipment regularly maintained,
cleaned and serviced?
Is protection in the form of surge arrest
provided to these items to protect from
damage?
The refrigeration unit used should be ofhigh quality, and high reliability and
dedicated to the storage of pharmaceutical
and medical substances only.
Is there a back up in the event of power
outage?
If a pharmacy takes on a banking agency or
AT M , the following should be in place:
excellent external, physical, access control
monitored alarms, reed switches and
vibration sensors, silent duress alarms
(used in the event of a hold-up)
C C TV throughout the pharmacy
time delay drop safe for cash storage
during the day
cash rated overnight cash safe
use of professional money carriers forbanking (note that some will not insure
cash and if this is the case you will have an
exposure).
The best ATM solution is where the bank
installs and maintains the device and is
completely responsible. When considering an
AT M , check the following:
who is responsible for the cash
who is responsible for maintenance
quality and cash rating of the ATM s safe
(some are not rated so you may be
exposed after a break-in)
operation of the ATM (some require new
notes)
hidden costs in the proposed benefit.
Banking agencies
Refrigeration
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PUBLICLIABILITY
SECTION 3
The key to mi t ig at ing l iab i l i ty inc id ents in the pharmacy is to takea common sense look at the envi ronment and procedura l contro lsand ident i fy (and then contro l ) t he foreseeable r isks .
Challenges 19
Question-and-answer Risk and Quality Snapshot 20
Legal concepts; access 21
Layout and services 22
18
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CHALLENGES
Understanding core legal principles, and defining the limitsof your duty of care.
Controlling the immediate environment of the pharmacy andnotifying risks to property owners.
Providing safe access and egress. Reducing risks of slips,trips and falls.
Marking large glass expanses so they are easily identified,reducing the risk of people walking into them.
Designing fixtures and fittings so that they are safer and lessprone to cause injury.
Ensuring that boxes and goods are stored securely so asnot to create a hazard to staff or customers.
Thinking child safe and user friendly in laying out aislesand displays.
Cleaning the premises without creating an additional hazard.
19
The d uty o f care i s a c ore lega l pr inc ip le . Address ing the
fo l low ing c ha l lenges w i l l ass is t you in comp ly ing w i th
th is du ty.
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20
UNDERSTANDING, TRAINING, RISK MANAGEMENT Yes Could improve No
Is basic knowledge of legal liability included in staff induction?
Is a proactive approach taken to risk control?
Are regular reviews of the premises and operations carried out?
Are records kept of actions taken and advice given to staff?
Is written notice given to landlords about possible risks?
Are temporary signs just that temporary?
ACCESS, SURFACES, ILLUMINATION, AISLES
Is glass marked to avoid mishap?
Are paths and steps free of obstructions?
Are floor surfaces even and free of trip hazards?
Is the car park, if available, properly marked out?
Is illumination both at night and in the pharmacy adequate?
Are aisles able to accommodate prams, frames, wheelchairs?
DISPLAYS
Are displays secured so that they cannot fall on people?
Are signs hanging from the ceiling well secured?
Are the corners of shelves rounded, or covered with rubber?
Are sharp spikes and hooks stoppered with rubber?
Are goods stored in a safe way (ie, not too high, hard to retrieve)?
Are walkways free from electrical leads?
Is restocking carried out safely at quiet times or after hours?
Is stock presented safely so it cannot fall on people or obstruct?CLEANING
Is cleaning carried out after hours?
Are spills cordoned off, cleaned and warning signs displayed?
ANCILLARY SERVICES
Is customer privacy considered and acted upon?
Is consent considered where health services are provided?
Is health and safety procedure (for services) adequate?
Are stringent hygiene practices adopted?
Is the safety of equipment regularly checked?
Is access to equipment limited?
The following questions wil l help you
to identify some of the basic st eps in
meeting your dut y of care. QA&
Question-and-answer Risk a nd Qua lity S na pshot
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LEGAL CONCEPTS;ACCESS
To avoid being negligent, the law requires you
to exercise your duty of care to the public at
large. You must eliminate or control dangers
which may give rise to personal injury or property
damage, including properly managing business
activities that may give rise to a risk of injury.
PROACTIVE APPROACHES
To avoid liability for negligence, you must meet
your duty of care to others. You must take
reasonable care to avoid acts or omissions
which you can reasonably foresee would be
likely to cause injury or property damage. In
the case of your business, this would include
those at your business premises, visitors andneighbours.
It can be seen that those to whom you owe a
duty of care is broad. You must therefore be
proactive in your business to reduce risks to
the public in pharmacies, due to the long
hour/high traffic environment, the risks to the
public are real and can be substantial in the
event of an accident.
CONTRIBUTORY NEGLIGENCE
Sometimes a customer might do things that are
dangerous (especially young children). This can
contribute to the cause of an accident, but the
law tends to take the view that an occupier
should manage for worst cases so these
contributions are acknowledged but
discounted. In practice, this means that you
must look at risks very conservatively.
NOT MY PROBLEM
Where you lease your business premises,
it pays to be vigilant in reporting risks in the
vicinity (in writing) to those responsible for the
area (whether landlord or council). Because you
are operating the business and inviting
customers, you must demonstrate that you took
your duty of care seriously. Your lease may infact make you directly accountable for entry
areas in a shopping mall, or for parking and
other spaces even if they fall outside the
boundary of your premises.
TEMPORARY SIGNS ARETEMPORARY
M ounting a temporary sign where a problem is
identified is a prudent step to lower risk and
show care. However, relying indefinitely on such
a sign will have the opposite effect, if you could
reasonably remove a hazard. Permanent signs
should only be used where they encourage
cautious behavior in what is an otherwise safe
environment.
Access to and from the pharmacy is one of the
major sources of liability risk.
GLASS
G lass is a great design feature, but it must be
marked so that those entering the pharmacy do
not mistake it for a doorway and injure
themselves. Signs and markings should be
used to distinguish glass from an open door.
PATHS AND STEPS
Paths should be free from obstructions or
protrusions such as overhanging branches,
or changes in surface (for example pavement
which has dropped). Steps are not advisable;.
If they are present, they should be sound and,
if more than one or two rises, a secure handrail
should be considered.
CAR PARKSWhere you offer parking you must manage the
space. Basics include:
excellent lines of sight for access (eg,
trimmed shrubbery and no visual
obstructions)
marked parking bays and traffic flow (arrows
and entry/exit signs)
no pot holes or uneven surfaces
excellent illumination for low visibility times
(dusk, dawn and bad weather).
Where you are party to a communal parking
lot, provide written notice to those managing
the space of any concerns you may have.
Safe ac ce ss to your premises
What is liability?
Whether you are an owner or oc cupier o f a pharmac y
premises, you w i l l be l i ab le for acc idents w hich oc cur in
the spac e wh ich you manage; somet imes, your l i ab i l it y
may ex tend beyond the borders o f the lease or t i t l e .
The courts tend to interpret
duty of care ver y broadly.
You must be able to demon-
strate that you acted appro-
priately and with due regard
to safety. Management
records will play a signifi-
cant part when defending
any action. It is advisable
to keep a simple file on the
various steps you have
taken to review operationsand to advise staff of
actions to be taken to miti-
gate risk.
21
CLAIM SNAPSHOT
A lady walking through a
laneway at the back of a
pharmacy put her foot into
a deep hole which was noteasily visible. She fell, sus-
taining a number of frac-
tures. The hole was locat-
ed at the rear of the phar-
macys premises and it
was alleged that it had
been caused by water
running from the
pharmacy. The injured lady
threatened to sue for
substantial damages.
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22
LAYOUT AND SERVICES
Trips, slips and falls are a large source of
claims, some legitimate and others not. To
protect your customers and your business,
the following principles apply:
where there is a change in surface or
height mount a sign
purchase industrial grade coverings and
mats with non-slip backing
replace frayed or torn mats
replace or repair torn, ripped or creased
carpets
replace cracked, and secure loose tiles
warn of potential slips in wet weather (witha sign) or, better still, use non-slip tread.
Where a spill occurs, do not leave it unattended,
and use a portable sign warning of the danger
and cordon off the affected area.
G ood quality illumination will reduce risk of
accident and prevent concealment of offenders
who may enter the premises after hours.
Pharmacies offer a wide range of products andhave permanent, mobile and temporary displays
of various kinds. All have potential risks.
DISPLAYS
Displays pose a special risk as they tend to
change regularly and may be supplied by third
parties. The basics include:
where mobile displays are used at the
entrance, ensure that wheels are pointing
inwards to avoid a trip
where cardboard displays are used and
goods mounted on temporary devices,
ensure the display cannot collapse andcause harm, especially if it contains
glassware, pottery, or other sharp or
weighty objects
ensure that covers pinned to display tables
will not catch feet or prams, wheelchairsand the like
secure all objects so that they cannot come
loose and fall on a customer (examples
include signs hanging from the ceiling, video
display terminals running in store promotions
and shelves and racks).
SHELVING
Shelves, hooks and spikes are a potential
danger as they may contain sharp ends which
can cause injury if customers fall against them.
The corners on low-level shelves are a
particular risk to children. Steps to be taken toreduce risk of injury include:
rubber stoppers on the ends of hooks and
spikes, and the positioning of hooks and
spikes so that risk of a mishap is low
bevelled edges and rounded corners on all
shelves; or rubber stops/plastic caps
retrofitted to pre-existing shelves with sharp
corners.
While space must be used to maximise
commercial results, consideration must be
given to access and egress. Aisles should be
wide enough to accommodate prams,
pushers, wheelchairs and walking frames.
This way, stock will not be pushed from
shelves with the risk of damage to stock or
personal injury.
ELECTRICAL LEADS
It is inadvisable to run leads in public areas, as
they can cause a trip or fall. N ote that even
taping a lead down still poses a risk. If
suppliers wish to provide back-lit displays, they
need to be positioned so that that leads do not
give rise to mishap.
Aisle width and obstructionsFixtures a nd fittings
Illumination
Floor surface s
How you organise the internal environment of the pharmacy
w il l inf luence i ts r isk profi le. Likewise, th e services you offer
wi l l carry certain r isks.
Trips, slips and falls are of
particular concern to phar-
macies because of the high
number of elderly, and inca-
pacitated people among the
customer base. For this rea-
son pharmacies must pay
extra attention to floor sur-
faces, steps, uneven sur-
faces and so on.
CLAIM SNAPSHOT
An elderly lady exiting the
pharmacy fell heavily sus-
taining serious injury
necessitating hospitalisa-
tion. The lady alleged that
she had fallen as result of
movement of a m at under
her and threatened to sue.
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LAYOUT AND SERVICES (continued)
Pharmacies are high traffic businesses so
it is not always easy to restock without
causing inconvenience to customers. Staff can
often get called away during the process,
leaving boxes on the floor which
can (and have) cause trips and falls.
It is therefore advisable to train staff on the
risks posed to customers by restocking
activity, and to try to carry out restocking at
quieter times or cordon off the area.
STABILITY OF STOCK
Boxes do not provide strong support, so
storing stock on boxes can be a risk,
especially to young children and particularly
if stock is stacked too high. Ensure that stock
is well secured.
C leaning is a routine pharmacy task but it has
inherent risks for both staff and customers. If
possible, routine cleaning should be
conducted after hours. C laims have arisen
where customers have tripped on vacuum
cleaner leads and hoses.
SPILLAGE
When a spillage occurs, the area should be
cordoned off with a sign advising of the
potential danger. Spillages should be attended
to promptly.
R isks associated with ancillary services will
include:
expertise to deliver the service
registration or qualifications required
privacy
consent
occupational health and safety.
These issues arise in the provision of the
following common services:
ear or body piercing
audiometric tests
beauty treatments
glucose or cholesterol testing.
Expertise and qualifications can be an issue if
a claim arises, and the pharmacy must
comply with all legislative requirements and
regulations.
Privacy is an important issue and addressed
in Section 5 of this G uide. Some services will
require a private room for their delivery.
When providing ancillary services it will be
necessary to obtain written consent from thecustomer, particularly when carrying out
procedures on minors, such as ear piercing.
AGENCY AND NON MEDICAL
Risks associated with agency and non-
medical services will include those related to
contract and product/service standards.
Photofinishing includes possible risk of liability
where images do not develop correctly, safety
issues with respect to chemicals and staff
training. The advent of digital photography is
lessening these concerns. A particular issue is
what to do if illicit images or films such aschild pornography are asked to be processed.
In general, agencies should be entered into
with care, and the contract of service should
be reviewed by your lawyer prior to entering
into it to identify contingent liabilities that it
may entail.
REVIEWS AND ACTION
As a matter of routine, the pharmacy should
carry out an operations review (say monthly or
quarterly), record issues at variance with
standards, and record action taken. Action is
vital where a problem is identified.
Ancillary services; agencies
Cleaning
Handling stock
Liability relating to the
provision of health servic-es should be carefully con-
sidered. Risks include those
relating to handling biohaz-
ardous substances, consent
and patient confidentiality.
23
CLAIM SNAPSHOT
The third party asked the
insured to transfer a video
tape of their children grow-
ing up onto DVD format. As
this type of work is con-
tracted out to another com-
pany, the insured arranged
for the video tape to be
couriered. The video tape
was subsequently lost in
transit. The third party
threatened legal action
unless the tape wasreturned. The pharmacist
had no agreement with the
contractor and could there-
fore be found liable for the
resultant loss.
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CHALLENGES
Establishing a system for identifying, assessing and
actioning potential risks.
Applying the most effective measures to minimise risk.
Managing work practices and the environment to minimiseinjury and incidents.
Training in correct manual handling.
Training to minimise the risk and effects of armed hold-up.
Training in infection control; correct disposal of biohazards;protective equipment use.
Offering immunisation to those at risk of contracting HepA,HepB or Influenza.
Sound housekeeping practice to reduce the risk of
accident, especially in non-retail areas.
Tagging programs for all electrical equipment on an annualbasis.
Checking all equipment on a regular basis, especially stepsand ladders.
Management of staff to reduce stress and improve
communications; sound OHS management.
25
Heal th and safe ty management i s an in tegra l par t o f
the e f fec t i ve operat ion o f a pharmac y. The long hours
in whic h pharmac ies operate and the nature o f the
serv ices provided inf luence the r isk prof i le .
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26
SAFETY SYSTEMS Yes Could improve No
Is a system used to identify hazards, assess and manage risk?
Is action taken when risks are identified?
Are basic management records of such actions kept?
Is staff consultation formalised?
ERGONOMICS; MANUAL HANDLING
Are tasks assessed for their ergonomic impacts?
Are work stations designed to reduce strain, stretching etc?
Can seating and computer equipment be adjusted?
Is lighting adequate in the dispensary and in non-retail areas?
Is manual handling included in training for induction?
INFECTION CONTROL
Does infection control form part of induction training?
Are gloves and goggles used when handling blood?
Are sharps and lancets strictly single use?
Is appropriate biohazard disposal used?
Are staff immunised against influenza and HepA and HepB?
WORKPLACE STRESS
Are work breaks scheduled to reduce fatigue?
Is communication kept open and non-discriminatory?
Is training provided on armed hold-up and response?
Are anti-discrimination and anti-harassment policies in place?
Are tasks allocated on an equitable basis?Are incidents and grievances documented and followed up?
ELECTRICAL
Are all electrical goods checked and tagged annually?
Are Residual Current Devices (safety switches) in place?
Is care taken to separate liquids and electrics?
Are computers well ventilated and switched off after hours?
Is powerboard use avoided; overloading avoided?
HOUSEKEEPING
Are non-retail areas (stores, kitchen, office) well organised?
Are staff amenity areas adequate (space etc)?
Are premises reviewed regularly for issues requiring action?
Is ventilation and space adequate for assembling packs?
Work through the following c heck list to
assess how your pharmac y is handling
its health and safety. QA&
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SYSTEMS & ERGONOMICS
HAZARD IDENTIFICATION
Unless you are aware of a hazard it is not likely
to be managed. Identifying hazards requires a
routine and formal review of all aspects of the
pharmacys operations.
RISK ASSESSMENT
M easuring the risk associated with a hazard.
This is an evaluation of the likelihood, the
severity, and the consequence of an incident,
in view of the current controls in place.
RISK CONTROL
By far the most important stage in the cycle is
to apply the most appropriate and effectivecontrols to minimise any identified risks.
REVIEW OF CONTROL SYSTEM
The review process determines the
effectiveness, relevancy and currency of the
controls put into place to manage risk.
MORE THAN MEETS THE EYE!
Pharmacies would consider themselves to be
low risk work environments, but on closer
examination it can be seen that there are
various risks associated with the nature of the
business. Low risk doesnt mean no risk, and
the purpose of ergonomics is to isolate those
work systems and equipment that pose a risk
to employees.
RISKS
The risks associated with poor work design
include the loss of productivity and risk of injury
or error where employees experience fatigue or
become uncomfortable in the dispensary,
treatment areas, stores and in any other work
areas such as an agency desk, the cash
register and the non-retail office areas.
The dispensing process requires a large
number of repetitive movements which can
cause physical injury. The following are some
of the factors that need to be considered:
reach distances to pharmaceuticals, other
stock etc. (shelf height and so on)
space to carry out tasks
height of work stations
lighting levels and glare, shadow and
reflection factors
positioning of keyboard, screen and mouse
script positioning for reading
posture when standing or sitting
work pace and breaks
table and bench heights
task duration and repetition
bending and twisting
adjustability of seating, fittings, equipment
stock placement (too high for example).
MANUAL HANDLING
M anual handling is a common source of injury.
For this reason, it is subject to its own
regulation. M anual handling risk needs to be
assessed, factors include load weight and
bulk, task repetition, task duration, posturesadopted and employee fitness for the task.
The work place and work tasks should be
designed so that the frequency and intensity
of manual handling tasks are minimised.
Ergonomics
Systems
The need from bot h a legislative and moral perspect ive to
manage t he health, safety and well being of staff is not new.
Pharmacies need to be able to evidence t heir management of
this risk with clear policies and close consultation. Some of
the basic elements follow.
A health and safety policysets a standard, makes
safety a shared concern
and demonstrates to staff
and to authorities that you
have taken your responsibil-
ities seriously.
Formal consultation with
staff means that a consul-
tation mechanism is i n
place that ensures comm u-nication on health and
safety occurs. This may
necessitate the nomination
of health and safety repre-
sentatives, establishing
designated work groups
or an OHS committee.
Fitting the tasks to humans,
not the other way around is
the essence of good work
design. The many repetitive
tasks in a pharmacy, war-
rant a detailed examination
of workflow and the physi-
cal environment.
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G U I L D WATC H
HEALTH & SAFETY
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INFECTION CONTROL
Exposure to a bloodborne disease and
airborne contagion is a potential risk to staff.
These diseases include HIV, hepatitis (HBV and
HCV) , and influenza. Stringent controls are
required wherever there are activities that expose
staff to this foreseeable risk.
BIOLOGICAL HAZARD ISOLATION
Standard precautions include the following:
exclusion from treatments and tests if staff
have a cut or abrasion which is not
completely sealed by a waterproof dressing
use of single use surgical gloves, and eye
goggles, as standard personal protectiveequipment when carrying out any
procedure where blood may be involved
use of single use devices to prick skin and
draw blood
non-recapping of any device and direct
disposal into a biohazard sharps container
appropriate disposal of any biohazardous
waste and washing of hands.
The transfer process must be designed to
minimise risk of blood splatter. C ontrols
include:
test strips placed flat on a hard surface to
minimise risk of their flicking up and
spraying blood
direct application of blood to test strips.
PERSONAL HYGIENE
Regular hand washing by those exposed to
any contagion can reduce their risk of
contamination. Exposure to airborne viruses
(eg, those working in a pharmacy at the height
of flu and cold season) can be assisted
through immunisation in addition to regular
hand washing.
IMMUNISATION
All staff exposed to either airborne or blood
borne contagion in the course of their work
should be offered a course of immunisation;
flu vaccination is advisable given the high
exposure to the public and the ill.
SINGLE USE CUPS
If the pharmacy is involved in a methadone
program, single use cups should be used and
rinsed before disposal in general waste.
DISINFECTION
Where blood or other fluids are spilled, the
area should be wiped (gloves and goggles
used) and disinfected with 100% strength of
a certified disinfectant.WRITTEN PROCEDURE
There should be written and known procedures
to follow for substance isolation with training
provided during induction.
POST EXPOSURE CONTROL
There should be a protocol in place and readily
accessible. If an incident occurs (such as a
sharps, or used lancet puncture or blood
splatter in the eye), a specific post exposure
procedure should be followed:
the area of puncture or access should be
thoroughly washed with antiseptic
the sharp or source should be placed in a
rigid container such as a capped jar
the source of the blood should be
approached to have a voluntary test
the staff member should attend a doctor
and supply the suspect source for testing
tests should be offered; and counselling
too.
The entire incident should be recorded and
efforts made to reduce the anxiety that the
event may have given rise to.
Blood: the sma llest a mount counts
In fec t ion f rom body substan ces, main ly b lood, is a
potent ia l r i sk w here a pharm acy o f fers anc i l l a ry serv ices
such as p ierc ing, b lood g lucose and c ho les tero l tes t ing.
The community has a
good level of awareness
about blood borne disease,
and the use of gloves and
goggles is understood to be
a normal practice in a
healthcare services
environment, and high stan-
dards in this regard would
be expected of pharmacy.
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G U I L D WATC H
HEALTH & SAFETY
WORKPLACE STRESS
M anaging morale and wellbeing can be acomplex area as work may not be the main
cause of a persons level of stress. The main
issues revolve around induction, work load
and organisation, communication, incident
management and policy and procedure.
INDUCTION
A prepared induction makes it easier for
employees to settle in, and reduces anxiety.
It should equip them with the information,
training and instruction that allows them to
conduct their tasks competently and safely.
WORK ORGANISATIONTasks should be distributed equitably, with
appropriate work breaks taken by all staff to
minimise fatigue. A management plan should
be in place for staff working late. Provide the
appropriate controls to maximise staff safety
during late hours, and avoid, if possible, staff
working alone.
Avoid placing staff in positions of risk,
particularly carrying cash.
COMMUNICATION
Establish a culture and supporting systems
for open communication to avoid claims ofvictimisation or discrimination. Ensure that a
health and safety representative or a health
and safety committee is in place to address
health and safety concerns.
CRITICAL INCIDENT MANAGEMENT
Extraordinary incidents such as an armed
hold-up should receive a professional
response in the form of counselling.
For this obvious area of exposure the
pharmacy should have training in place, and
set procedures to follow in the event of
armed hold-up.
Incident preparation and post incident
management is vital for exposed staff whose
recovery and response to such an event can
be significantly influenced by its
management. To do otherwise, when armed
hold-up is a foreseeable risk in pharmacy is
neglecting your duty of care.
POLICY AND PROCEDURE
It may seem like overkill for a small team,
but failure to have specific policies on
discrimination harassment
reasonable work load
staff breaks
may lead to claims. As an employer, you
must make it clear what standards of
behaviour are not tolerated. The best place
and time to do this is during a formal
induction, but should also be reinforced at
appropriate intervals.
Manageme nt of work place s tre ss
Workplace s t ress can be a sourc e o f c la ims aga ins t
employers and a pharmacy m ust th erefore organ ise it s
work and ac t i v i t i es to reduce s t ress and show th at care
was t aken in the area o f employee wel lbe ing.
Claims relating to stress are
rising, so pharmacies must
adopt human resource
practices which will reduce
the causes of stress and
demonstrate m anagement
care, especially in the area
of discrim ination, harass-
ment and response to inci-
dents and grievance.
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30
G U I L D WATC H
HEALTH & SAFETY
HOUSEKEEPING
In a busy pharmacy serving the customer
takes priority. The result can be a retail area,a store room, office or tea room that can at
times become untidy and cluttered, creating
a risk to work place health and safety.
SLIPS, TRIPS AND FALLS
Because of the high level of traffic and long
hours which pharmacies experience, slips,
trips and falls are a common source of claims.
A messy work environment creates a
foreseeable injury risk and with regard to
public liability, dilutes defensibility should any
incident occur .
EVERYTHING IN ITS PLACEEnsuring that the environment is well
organised reduces the risk of mishap
especially for new, unfamiliar staff. The non-
retail areas should be as organised a space
as the dispensary; and the same care used in
the pharmacy regarding security and safety
should also apply.
STAFF AMENITIES
Staff amenities must be of a standard which
will not give rise to grievance on the part of a
disgruntled employee. Space is at a premium
in most pharmacies, but room must be madefor staff amenity. N ote too that upkeep is
important: a spill on a hard surface in a tea
room is as great a risk for a claim as a spill in
the pharmacy entrance.
SECURITY AND SURVEILLANCE
Because pharmacies are open for long hours
and have both permanent, part time and
locum staff, some thought needs to be given
to security and surveillance in non-public
areas.
KEYS TO GOOD HOUSEKEEPING
develop checklists (which are actioned and
then filed) for monitoring the pharmacys
housekeeping
incorporate specific tidying up tasks in job
descriptions
devise a specific regime for dealing with
waste and ensure that any biohazard
waste is disposed of correctly inspect all equipment regularly, including
equipment not in public use or view
ensure that care is exercised in organising
store rooms.
Poor housekeeping can be responsible for
injuries, errors, or fires.
MANAGEMENT OF ELECTRICAL GOODS
Pharmacies have a large power load and
operate a range of electrical equipment
Risks include:
electrocution fire, especially out of hours
damage to equipment
flash burns.
Reducing opportunity for mishap
Good housekeeping makes the work p lace more com for tab le
and produc t i ve , and he lps w i t h reduc ing r i sk . A s t i t c h in
t ime l i tera l ly saves nine in these areas.
Electrical hazards arise inseveral places throughout
the pharmacy and require
management consistent
with legislation. Because of
the severity of a mishap
with electrici ty, extra cau-
tion is required in this area.
CLAIM SNAPSHOT
An employer was fined in a
landmark OHS case
concerning occupational
overuse injuries. Following
the court ruling the
employer was fined
approximately $16,000 for
a breach in their duty of
care to provide a work
environment that was safe
and posed
minimal r isk to the health
of employees.
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HOUSEKEEPING (continued)
TAGGING
All electrical equipment should be checked and
tagged by a qualified electrical tradesperson at
least every 12 months. This program will reduce
the risk of fire from electrical faults,
as well as the risk of personal injury.
COMPUTERS
C omputers can cause electrical fires if left on
and unattended. The risk rises if ventilation
around a computer is poor.
RESIDUAL CURRENT DEVICES (RCD)
All outlets and equipment should be protected
by RC Ds (safety switch) which will respond to
earth leakage.
The switchboard should also have protection
from electrical surges which, although
infrequent, can destroy vital equipment such
as vaccine refrigeration and computers.
THERMOGRAPHIC SCAN
Having an electrician conduct a
thermographic scan of your switchboard is an
effective means of identifying heat build up
and may possibly prevent an electrical
problem which could result in fire.
G U I L D WATC H
HEALTH & SAFETY
YES NO YES NO
R esolve (or remove) any obstructions/protrusions N on-slip floor surface
Stable fittings/fixtures G ood ventilation and heating
Sharp edges on fixtures First Aid kit present/well stocked
M erchandise stacked/stored safely C lean staff facilities
Sturdy/safe customer seating Emergency contact number displayed
Sturdy ladder/steps Safety switch protection on power points
Internal areas always well lit Appliance cords in good condition
External area well lit after dark Emergency exits accessible and visible
Floor even and in good condition Fire extinguishers present/serviced
PUBLIC LIABILITY AND OHS CHECKLIST
Reference: Q uality Care Pharmacy Planning, 2nd edition
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PRIVACYCONTROLSA g o o d m e a s u r e o f t h e e f f e c t i v e n es s o f y o u r p r i v a c y c o n t r o l sa n d t h e p h a r m a c y s s e n s i t i v i t y t o p r i v a c y i s t o a s k t h eq u e s t i o n o f a n y a c t i o n : w o u l d I p e r s o n a l l y b e h a p p y i f t h i sh a p p e n ed t o m e ?
32
Privacy check Yes Could improve No
Does the pharmacy have a policy on privacy?Does the pharmacy train new staff on privacy?
Is consent sought before information is divulged to third parties?
SECTION5
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LITIGATION RISKS
The main principles concern the sharing of
information with third parties where the patient
has not provided consent for you to do so.
This is not easy to manage because in many
instances family members and partners
provide care or run errands.
A great deal will depend upon judgement but
there are obvious actions that should be
avoided.
PUBLIC AREAS
Private information should be kept out of view
of public areas.
PHONESDiscussions about patients on speaker phone
are risky as the communication may be
overheard by third parties.
MESSAGES
M essages about scripts ready for collection, or
issues associated with the script should not be
left with friends or relatives. The patient may
not have wanted to share information about a
condition.
OTHER CLINICIANS
Where advice and information is to be shared,
it is appropriate to seek the patients consent
before discussing the medication with another
clinician.
PUBLIC COMMUNICATIONS
All staff should be trained at induction on the
inadvisability of discussing patients with other
staff, particularly in public areas, or worse still,
outside the pharmacy environment.
Sending health and medical records via
facsimile (for example HM Rs) could place a
patients information in view of others.
Pharmacies should consider the adoption of
the Public Key Infrastructure, ( PK I) a
combination of procedures and technology
providing security and confidentiality for
electronic business. The PK I is the framework
adopted by the Australian G overnment and
health sector to provide authentication and
confidentiality for online transactions. It is a
secure and confidential method using digital
certificates and authentication before data is
released.
It is being used to transfer information
between G Ps and Specialists, practitioners
and hospitals. Pharmacy could adopt this as
a means of further minimising the risk of
confidential / sensitive information being read
or accessed by those, other than for whom
the information is intended.
( ref : www.hesa.com.au )
CONCLUSION
Privacy issues are centre stage and require
careful judgement and skill. As a general rule,
always ask a patient before divulging
information to a third party and, if possible,
note their response on the file. Try to counsel
patients away from others, in an area
providing relative privacy. Train staff,
especially new staff, on the importance of
customer privacy and set clear limits on what
is to be said at the counter in relation to any
patient. A clear policy in regard to
confidentiality should be developed. Each
staff member should sign an undertaking in
relation to confidentiality.
Electronic communicationsMain principles
Pr ivacy has bec ome a large soc ia l i ssue w i th the pass ing
of leg isla t ion guarantee ing r ight s to p r i vacy and
consequent c onsumer awareness o f pr ivacy r ights .
Note that people often
maintain some secrecy
about their ailments an