Protection of Conscience Project
Protection of Conscience Project
www.consciencelaws.org
Service, not Servitude

Service, not Servitude

Submission to the Alberta College of Pharmacists
Re: Draft Code of Ethics

Appendix "C"

The Exercise of Freedom of Conscience in Pharmacy

Professional and Regulatory Responses

Details - February, 2009

Only the URL of a document is provided when -

  • the issue of conscientious objection is not addressed by an entity; or
  • the issue of conscientious objection is not addressed, but a policy concerning it can be drawn from another source that is identified as an authority by the entity.

Legend
Full Text
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  • (NA) - Not Addressed
    • The issue of conscientious objection is not addressed.
  • (P) - Provide
    • Conscientious objection is prohibited. The objecting pharmacist is required to provide the controversial drug or service.
  • (PPA) - Provide or Personally Act
    • The objecting pharmacist is required to facilitate or arrange access to the controversial drug or service by referral to a specific person or entity, or by some other act, and to provide the controversial drug or service if this is not possible.
  • (PA) - Personal Action
    • The objecting pharmacist is required to facilitate or arrange access to the controversial drug or service by referral to a specific person or entity, or by some other act.
  • (SC) - Systemic Cooperation
    • The objecting pharmacist is not required to directly assist in the delivery of a drug or service, but is to work cooperatively within a system that allows patients to access controversial drugs and services through other sources.
  • (PA/SC) - Personal Action or Systemic Cooperation
    • An objecting pharmacist may directly assist in the delivery of a drug or service by referral to a specific person or entity, or by some other act, OR work cooperatively within a system that allows patients to access controversial drugs and services through other sources.
  • (ND) - No Duty
    • No duty is imposed upon an objecting pharmacist.
  • (EAS) - Includes consideration of pharmacist involvement in execution
  • (EX) - Includes consideration of pharmacist involvement in euthanasia or assisted suicide
  • * - Required by statute
AUSTRALIA
Pharmaceutical Society of Australia

(Adapted from the Royal Pharmaceutical Society of Great Britain Code of Ethics)

Principle Nine

A pharmacist shall ensure continuity of care for the patient in the event of labour disputes, pharmacy closure or conflict with personal moral beliefs.al beliefs.

Obligations

9.1 A pharmacist shall when required, assist and refer clients to another pharmacist in order to maintain service and care.

(Accessed 2009-02-19)

This document represents the current, official position of the Pharmaceutical Society of Australia (PSA) relating to ethical issues that may arise when a pharmacist declines to supply a therapeutic product or pharmacy service

Background

The Pharmaceutical Society of Australia (PSA) acknowledges that the profession carries a responsibility to provide a timely, accurate and high quality pharmacy service as needed by the Australian community.

Pharmacists approved to supply medicines under the Pharmaceutical Benefits Scheme (PBS) must maintain adequate stock (at their own expense) for the supply of pharmaceutical benefits and may be called upon to provide the Health Insurance Commission with details of the stock held. In addition, they must publicly display a notice of their normal hours of business and are obliged to supply pharmaceutical benefits at other times if the prescription is marked "urgent" and initialled by the prescriber. 1

There is no law that requires a pharmacist owner or employee to dispense any or all non-PBS prescription medicines. However, if a failure to supply is construed as discriminatory or as leading to foreseeable harm to the individual, then there is a risk of liability for the pharmacist (see below).

At common law, a trader may refuse to sell any product to any person. However, this right may be affected by other laws.

Pharmacy owners and their employees are subject to the Trade Practices Act 1974 which deals with issues such as anticompetitive conduct (Part IV), unconscionable conduct (Part IVA) and unfair practices (Part V Division 1).

Intervention by pharmacists which may result in non-supply

Codes of conduct have been issued by the PSA2 and by the Society of Hospital Pharmacists of Australia3 to establish the principles and standards of behaviour expected by the profession of its members. A key principle espoused in these documents for guiding professional practice is that the health and well being of patients and the community should be the primary concern when providing professional services. The PSA code elaborates on this principle by establishing associated obligations. These include obligations to avoid supplying a medicinal product whose quality, safety or efficacy is in doubt; use professional judgement to prevent supply of excessive quantities of medicinal products or those likely to constitute an unacceptable hazard to patients; and ensure that all reasonable care is taken when dispensing medicines.

Though not widely appreciated by consumers or other health professionals, pharmacists are obligated to dispense medicines according to the prescription only to the extent that it is consistent with patient safety. In some jurisdictions this circumstance is recognised in legislation.4 In limited situations, consideration of patient safety may lead to a pharmacist declining to dispense a prescribed medicine.5

The Society supports and encourages pharmacists to play an active role in monitoring and reviewing the medicines taken by patients. The resulting interventions, including those where the pharmacist acts to prevent supply in the interest of patient safety, are integral to achieving safe treatment and optimal therapeutic outcomes for patients. They are a key element to achieving the quality use of medicines.

PSA recognises the right of pharmacists to decline to provide products or services to any individual. However, pharmacists are also reminded that as health service providers they are responsible for considering the health and well being of the individual concerned and the community above any commercial or other personal consideration.

Declining supply on moral grounds

PSA recognises and respects the right of individuals, including health professionals, to hold a moral belief on particular issues. It further recognises that at times these moral beliefs may impact on the roles undertaken by those health professionals.

While not legally binding, the codes of conduct may serve as a point of reference when the appropriateness of the professional conduct of a pharmacist is under consideration. This point is of particular relevance to a further two principles of the PSA Code of Conduct. Principle Two obligates pharmacists to uphold the reputation of the profession and adhere to legislative requirements while Principle Nine obligates pharmacists to ensure continuity of care, including in the event of a "conflict with personal moral beliefs".2

Care must be exercised where the objection to supply is essentially based on personal moral considerations. In the event that a moral belief of a pharmacist leads to the nonsupply of a product or service, PSA reminds pharmacists of the obligations established under the PSA code to accept responsibility for ensuring continuity of care - that is, timely access to the required medicine or service. This may involve the use of initiative to identify another reasonably available source for the required medicine or service, particularly in rural or remote areas or in other situations where access to alternate service providers may be limited.

In 2002, the South Australian Branch of PSA released a statement to pharmacists practising in that state.6 The statement, which was based on legal advice received by the Branch, was that the pharmacist had a right to decline supply of prescription medicines where such supply would be contrary to a moral stance held by the dispensing pharmacist.

PSA recognises there are jurisdictional variations in the regulation of the pharmacy profession. Nevertheless, where a pharmacist's moral belief is likely to impact on the pharmacy services available to patients, pharmacists should consider the following.

Employee pharmacists should reach agreement with their employer about what limitations will apply to their dispensing and other pharmacy activities and have these formally recognised in their terms of employment.

The owner/manager should have processes in place (eg. a sign or leaflet) to clarify to patients/consumers seeking pharmacy services, any limitations applicable to the services provided. The information provided should clearly inform the patient of appropriate alternative sources. The need for this process may be more compelling where the availability of alternate service providers is limited.

A pharmacist might choose a certain course of action based on moral beliefs which may result in the provision of a particular product or service being declined either generally or to particular persons. In such circumstances, the pharmacist should be aware of the following possibilities.

An individual may claim discrimination (eg.based on medical, disability, cultural, religious or other legal grounds) or unconscionable conduct by the pharmacist.

Where there is foreseeable risk of harm to the individual, the pharmacist could be held liable for any consequences that may arise from the decision to not supply.

Therefore pharmacists are strongly advised to obtain independent legal advice where their personal moral beliefs are likely to preclude the provision of a certain product or service in the course of their professional practice either generally or to particular persons.

References
1. Commonwealth Department of Health and Ageing. Schedule of Pharmaceutical Benefits. Canberra: CDHA; 2003 May.
2. Pharmaceutical Society of Australia. Code of Professional Conduct. In: Pharmacy Practice Handbook. Canberra: PSA; 2000.
3. The Society of Hospital Pharmacists of Australia. SHPA Code of Ethics. In: Johnstone JM and Viénet MD, eds. Practice Standards and Definitions. Melbourne: SHPA; 1996.
4. For example the Victorian Pharmacists Regulations 1992 (made under the Victorian Pharmacists Act 1974).
5. Pharmaceutical Society of Australia. Dispensing Practice Guidelines. In: Pharmacy Practice Handbook. Canberra: PSA; 2000.
6. Pharmaceutical Society of Australia. SA Branch Newsletter. Refusal to dispense.

Society of Hospital Pharmacists of Australia
  • Code of Ethics......................................................................NA

(Accessed 2009-02-24)

New South Wales
  • Pharmacy Board of New South Wales
Pharmacy Practice Act.........................................................NA

(Accessed 2009-02-23)

Australian Capital Territory
  • Pharmacy Board of the ACT
Standards ............................................................................NA
Northern Territory
  • Pharmacy Board of the Northern Territory
As per APhS and SHPhA Practice Standards.................PA/SC

(Accessed 2009-02-23)

Queensland
  • Pharmacy Board of Queensland
As per PhSA...................................................................PA/SC

(Accessed 2009-02-23).

Tasmania
  • Pharmacy Board of Tasmania
As per APhS and SHPhA via Pharmacy Code .............. PA/SC

(Accessed 2009-02-24)

Victoria
  • Pharmacy Board of Victoria
As per APhS via Guidelines 2005 ...................................PA/SC

(Accessed 2009-02-24)

CANADA
National Association of Pharmacy Regulatory Authorities (NAPRA)

Approved by Council: November 1999

Developed by: Executive and Inter-Provincial Pharmacy Regulatory Committees

The use of prescribed drugs for emergency contraception and euthanasia is an arising issue that has prompted the pharmacy regulatory authorities to address the balance between the individual rights of pharmacists and professional responsibilities to their patients.

In response to the need for clear and consistent regulatory policy on this matter, NAPRA Council approved a model regulatory position statement on November 14, 1999. This model statement was developed following preliminary review by Council and Pharmacy Registrars in April of this year and external consultation with member Provincial and Territorial Regulatory Authorities, the Canadian Society of Hospital Pharmacists, the Canadian Pharmacists' Association and the Consumers' Association of Canada, throughout the summer months. NAPRA's member Provincial and Territorial Regulatory Authorities will now consider the model statement for adoption or adaptation and implementation.

"Pharmacists shall hold the health and safety of the public to be their first consideration in the practice of their profession. Pharmacists who object, as a matter of conscience, to providing a particular pharmacy product or service must be prepared to explain the basis of their objections. Objecting pharmacists have a responsibility to participate in a system designed to respect a patient's right to receive pharmacy products and services.

The following policy clauses reflect the need to meet a patient's requirements for pharmacy products and services while respecting a pharmacist's right of conscience:

  • A pharmacist is permitted to object to the provision of a certain pharmacy product or service if it appears to conflict with the pharmacist's view of morality or religious beliefs and if the pharmacist believes that his or her conscience will be harmed by providing the product or service. Objections should be conveyed to the pharmacy manager, not to the patient.
  • The individual pharmacist must pre-arrange access to an alternate source, to enable the patient to obtain the service or product that they need. Any alternate means must minimize inconvenience or suffering to the patient or patient's agent."

(Accessed 2009-02-21)

(Accessed 2009-02-20)

Pharmacists' Professional Responsibility

. . . Pharmacists who do not wish to provide EC treatment for personal reasons should maintain objectivity and remain professional in manner when dealing with patients. In this case, patients should be referred to an alternate source, as listed below. More information is found in the "Model Statement Regarding Pharmacists' Refusal to Provide Products or Services for Moral or Religious Reasons", approved by NAPRA Council in November 1999.

The Model Statement suggests that pharmacists not convey their personal objections to the patient. If the patient questions the pharmacist as to why he or she will not personally be providing the product or service, the pharmacist should answer in a manner that does not make the patient feel uncomfortable. Alternate sources for EC noted might include referral to one or more pre-arranged source options such as:

• another pharmacist in the same pharmacy
• another pharmacy in the vicinity
• the prescribing physician
• nearby hospital
• family planning clinic

(Accessed 2009-02-21)

Canadian Pharmacists Association

. . . The physician, the pharmacist, the nurse should have a right to take part or not in assisting a person once he or she has reached a decision to put an end to his or her life. Should they elect not to participate, their duty to their patient requires that they refer them to health professionals who will assist them. . .

(Accessed 2009-02-21)

British Columbia
  • College of Pharmacists of British Columbia
Ethics Advisory Committee
Ethics in Practice: Moral Conflicts in Pharmacy Practice.
Bulletin March/April 2000 Vol. 25, No. 2
.................PPA/EAS/EX

The Code of Ethics adopted by the College of Pharmacists of British Columbia acknowledges that some pharmacists have moral objections to providing certain recognized pharmacy services. . . These pharmacists must refer patients to colleagues who will provide such services, and in the end deliver these services themselves if it is impractical or impossible for patients to otherwise received them. . .

Individual pharmacists may experience conscience problems when requested to provide services to which they have a moral objection. At present these services might include provision of contraceptives, syringes and needles for drug addicts, emergency contraceptives, high doses of narcotics to control intractable pain that might hasten death in the terminally ill, and medications for terminal sedation. In future these services might expand to include preparation of drugs to assist voluntary or involuntary suicide, cloning, genetic manipulation, or even execution. . .

The moral position of an individual pharmacist, if it differs from the ethics of the profession, cannot take precedence over that of the profession as a whole. The public cannot be expected to consider it to be just bad luck if patients are refused recognized pharmacy services because their pharmacists have moral objections to providing them. . .

Code of Ethics ...................................................................PPA

Value 8 - A pharmacist ensures continuity of care in the event of job action, pharmacy closure or conflict with moral beliefs.

Obligations

1. A pharmacist has a duty through coordination and communication to ensure the provision of essential pharmacy care throughout the duration of any job action or pharmacy closure. Patients who require ongoing or emergency pharmacy care are entitled to have those needs satisfied.

2. A pharmacist is not ethically obliged to provide requested pharmacy care when compliance would involve a violation of his or her moral beliefs. When that request falls within recognized forms of pharmacy care, however, there is a professional obligation to refer the patient to a pharmacist who is willing to provide the service. The pharmacist shall provide the requested pharmacy care if there is no other pharmacist within a reasonable distance or available within a reasonable time willing to provide the service.

(Accessed 2009-02-20)

Alberta
  • College of Pharmacists of Alberta
Code of Ethics 2008 .......................................................PA/ SC

Principle V:
A pharmacist endeavours to ensure that the client's right to pharmaceutical service is met.

Guidelines for interpretation:
1. Pharmacists who are unable or are unwilling to provide appropriately prescribed pharmaceutical services (e.g. compounding of sterile products) to clients, must make reasonable efforts to ensure that clients are able to obtain these services from another authorized provider.

2. Pharmacists who are unable or are unwilling to provide certain pharmaceutical services are obligated to arrange the condition of their practice so that the care of the client will not be jeopardized.

3. Pharmacists who are unable or are unwilling to provide a pharmaceutical service shall make it known to their potential employer or employee, whichever the case may be, before entering into a formal relationship. If their convictions change over the course of their career, pharmacists must make it known in their place of work.

(Accessed 2008-02-18)

Draft Code 2009 ...................................................................NA
Saskatchewan
  • Saskatchewan College of Pharmacists
Statement Regarding Pharmacists'
Refusal to Provide Products or Services
for Moral or Religious Reasons
.......................................PA/SC

Pharmacists shall hold the health and safety of the public to be their first consideration in the practice of their profession. Pharmacists who object, as a matter of conscience, to providing a particular pharmacy product or service must be prepared to explain the basis of their objection. Objecting pharmacists cannot abandon their ethical duty of care to the patient, and respect of the patient's right of autonomy to make informed decisions to receive pharmacy products and services based on objective and accurate information. The following policy clauses reflect the need to meet a patient's requirements for pharmacy products and services while respecting a pharmacist's right of conscience:

1. A pharmacist is permitted to object to the provision of a certain pharmacy product or service if it appears to conflict with the pharmacist's view of morality or religious beliefs, and if the pharmacist believes that his or her conscience will be harmed by providing the product or service. The reasons for the objection should be conveyed to the pharmacy manager, and to the patient. It would be improper and unethical conduct if the pharmacist used the opportunity to promote his/her moral or religious convictions, or engage in any actions, which demean the patient.

2. Duty of care includes ensuring that the decisions of the pharmacist do no harm or promote the wellbeing of the patient. This might mean that the individual pharmacist refers the patient to, or pre-arranges access to an alternate source, to enable the patient to obtain the service or product that they need. Any alternate means must minimize inconvenience or suffering to the patient or patient's agent and must maintain patient confidentiality.

(Accessed 2009-02-21)

Nova Scotia
  • Nova Scotia Pharmaceutical Society (Nova Scotia College of Pharmacists)
Code of Ethics 2002 .............................................................SC

(Accessed 2009-02-21)

Code of Ethics 2003 .............................................................SC

(Accessed 2009-02-24)

Code of Ethics 2007 .............................................................SC

Value V
Pharmacists respect the rights of patients to receive pharmacy services and ensure these rights are met.Pharmacists who are unable to provide prescribed medicines or services to their patients shall take reasonable steps to ensure these medicines/services are provided and the patients' care is not jeopardized.

Pharmacists who are unwilling to provide prescribed medicines or services to patients because of moral or religious reasons shall inform pharmacy management of their objections at the onset of employment. Pharmacy management shall provide reasonable accommodation of the pharmacist's right of conscience and develop an alternate means of providing the medicines or services. The alternate means shall be timely and convenient for the patient.

Pharmacists have a duty, through communication and co-ordination, to ensure the continuity of care of patients during pharmacy relocation/closure, job action, natural disasters or situations where continuity of care may be problematic.

Manitoba
  • Manitoba Pharmaceutical Association
Notice to Pharmacy Managers
Emergency Contraception "Controversy"

2 February, 2006....................................................................SC

Over the past couple weeks, there have been many media reports regarding Emergency Contraception medication and the role of the pharmacist. . . .
While the MPhA has not received any reports of misconduct by pharmacists in the provision of Emergency Contraception care, the following information serves as an important reminder . . .

A pharmacist or pharmacy that refuses to sell emergency contraception as a matter of conscience needs to plan a process to enable patients to access the medication. . .

(Accessed 2009-02-21)

MPhA Practice Guideline
Emergency Contraception (EC) Care (Post Coital Contraception)
April, 2005, Updated 13 February, 2006....................................SC

4) Pharmacists, who object to providing Emergency Contraception Care as a matter of conscience, must participate in a system that respects a patient's right to receive that care (MPhA SOP #1 & #5)*. Ensuring the patient's right to receive care could mean referral to a colleague, an emergency room, a clinic, or other health practitioner offering the care. If EC Care is not available in the pharmacy, a sign must be posted in the pharmacy advising patients that EC Care is not available and where the patient care can be obtained (e.g. a sign located in the pharmacy front window and/or at the dispensary). An obligation to provide care is not the same as refusal to supply a product for an individual patient based on professional judgement. When providing care with Schedule 2 or 3 medications, the pharmacist is accountable for that care. At times, a pharmacist may be requested to supply EC Care to a patient's agent. The pharmacist is undertaking a professional decision, and must still keep records including the reasons for the decision to supply care in the absence of the patient.

(Accessed 2009-02-21)

Standards of Practice: Community
June, 2006 ............................................................................SC
D. Pharmacist's Responsibilities in the Refusal to provide Products or Services for Moral or Religious Reasons

1.9. Pharmacists shall hold the health and safety of the public to be their first consideration in the practice of their profession. Pharmacist who object, as a matter of conscience, to providing a particular pharmacy product or service must be prepared to explain the basis of their objections. Objecting pharmacists have a responsibility to participate in a system designed to respect a patient's right to receive pharmacy products and services.

1.10. The following policy reflects the need to meet a patient's requirement for pharmacy products and services while respecting a pharmacist's right of conscience:

1.10.1. A pharmacist is permitted to object to the provision of a certain pharmacy product or service if it appears to conflict with the pharmacist's view of morality or religious beliefs and if the pharmacist believes that his or her conscience will be harmed by providing the product or service. Objections should be conveyed to the pharmacy manager, not the patient.

(Accessed 2009-02-21)

Ontario
Ontario College of Pharmacists
  • Code of Ethics 1996 .............................................................PA

Principle Two
The pharmacist actively promotes the well-being of every patient in a caring, compassionate manner. The patient's well-being is at the centre of the pharmacist's professional and business practices. This principle ensures that no patient shall be deprived of pharmaceutical services because of the personal convictions or religious beliefs of a pharmacist. Where such circumstances occur, the pharmacist refers the patient to another pharmacist who can meet the patient's needs. The pharmacist exercises his or her professional judgement to ensure that patients' needs are met in situations where emergency services or care may be required.

Following is the position statement approved at the March 2001 Council meeting:

Pharmacists shall hold the health and safety of the public to be their first consideration in the practice of their profession. Pharmacists who object, as a matter of conscience, to providing a particular pharmacy product or service must be prepared to explain the basis of their objections.
Objecting pharmacists have a responsibility to participate in a system designed to respect a patient's right to receive pharmacy products and services.

The following clauses, reflect the need to meet a patient's requirements for pharmacy products and services while respecting a pharmacist's right of conscience:

- A pharmacist is permitted to decline providing certain pharmacy products or services if it appears to conflict with the pharmacist's view of morality or religious beliefs and if the pharmacist believes that his or her conscience will be harmed by providing the product or service. Objections should be conveyed to the pharmacy manager not the patient.

- The individual pharmacist must insure an alternate source, to enable the patient to obtain the service or product that they need. Any alternate means must minimize inconvenience or suffering to the patient or patient's agent.

(Accessed 2009-02-18)

  • Code of Ethics, Draft 3
    22 March, 2005 ................................................................NA (?)

Principle Four
The pharmacist and pharmacy technician respects the autonomy, individuality and dignity of each patient and provide care with respect for human rights and without discrimination. No patient shall be deprived of pharmaceutical services because of the personal convictions or religious beliefs of a pharmacist or pharmacy technician.

Principle Four
Each member respects the autonomy, individuality and dignity of each patient and provides care with respect for human rights and without discrimination. No patient shall be deprived of access to pharmaceutical services because of the personal convictions or religious beliefs of a member. Where such circumstances occur, the member refers the patient to a pharmacist who can meet the patient's needs.

(Accessed 2009-02-21)

New Brunswick
New Brunswick Pharmaceutical Society

Approved by Council: November 1999
Developed by: Executive and Inter-Provincial Pharmacy Regulatory Committees

The use of prescribed drugs for emergency contraception and euthanasia is an arising issue that has prompted the pharmacy regulatory authorities to address the balance between the individual rights of pharmacists and professional responsibilities to their patients.

In response to the need for clear and consistent regulatory policy on this matter, NAPRA Council approved a model regulatory position statement on November 14, 1999. This model statement was developed following preliminary review by Council and Pharmacy Registrars in April of this year and external consultation with member Provincial and Territorial Regulatory Authorities, the Canadian Society of Hospital Pharmacists, the Canadian Pharmacists' Association and the Consumers' Association of Canada, throughout the summer months. NAPRA's member Provincial and Territorial Regulatory Authorities will now consider the model statement for adoption or adaptation and implementation.

"Pharmacists shall hold the health and safety of the public to be their first consideration in the practice of their profession. Pharmacists who object, as a matter of conscience, to providing a particular pharmacy product or service must be prepared to explain the basis of their objections. Objecting pharmacists have a responsibility to participate in a system designed to respect a patient's right to receive pharmacy products and services.

The following policy clauses reflect the need to meet a patient's requirements for pharmacy products and services while respecting a pharmacist's right of conscience:

1. A pharmacist is permitted to object to the provision of a certain pharmacy product or service if it appears to conflict with the pharmacist's view of morality or religious beliefs and if the pharmacist believes that his or her conscience will be harmed by providing the product or service. Objections should be conveyed to the pharmacy manager, not to the patient.

2. The individual pharmacist must pre-arrange access to an alternate source, to enable the patient to obtain the service or product that they need. Any alternate means must minimize inconvenience or suffering to the patient or patient's agent."

(Accessed 2009-02-21)

Statement V:
A Pharmacist , Certified dispenser or Registered student shall respect the rights of patients to receive pharmacy products and services and ensure these rights are met.

Guidelines for interpretation
Pharmacists who object, as a matter of conscience, to providing a particular pharmacy product or service must be prepared to explain the basis of their objections to pharmacy management, not the patient.

Pharmacists who object, as a matter of conscience, to providing a particular pharmacy product or service have a responsibility to participate in a system designed to respect a patient's right to receive pharmacy products and services. The system must be pre-arranged to enable the patient to obtain the product or service in a timely and convenient manner, minimizing suffering to the patient.

Pharmacists have a duty, through communication and coordination, to ensure continuity of care of patients during pharmacy relocation or closure, job action, natural disasters or situations where continuity of care may be problematic.

(Accessed 2009-02-21)

Prince Edward Island
Prince Edward Island Pharmacy Board

The use of prescribed drugs for emergency contraception and euthanasia is an arising issue that has prompted the pharmacy regulatory authorities to address the balance between the individual rights of pharmacists and professional responsibilities to their patients.

In response to the need for a clear and consistent regulatory policy on this matter, NAPRA Council approved a model regulatory position statement on November 14, 1999. This model statement was developed following preliminary review by Council and Pharmacy Registrars in April 1999 and external consultation with member Provincial and Territorial Regulatory Authorities, the Canadian Society of Hospital Pharmacists, the Canadian Pharmacists Association and the Consumers' Association of Canada, throughout the summer months.

In June of 2000, the Prince Edward Island Pharmacy Board approved the Statement to provide direction and guidance on this issue to Island pharmacists.

"Pharmacists shall hold the health and safety of the public to be their first consideration in the practice of their profession. Pharmacists who object, as a matter of conscience, to providing a particular pharmacy product or service must be prepared to explain the basis of their objections. Objecting pharmacists have a responsibility to participate in a system designed to respect a patient's right to receive pharmacy products and services.

The following policy clauses reflect the need to meet a patient's requirements for pharmacy products and services while respecting a pharmacist's right of conscience:

1. A pharmacist is permitted to object to the provision of a certain pharmacy product or service if it appears to conflict with the pharmacist's view of morality or religious beliefs and if the pharmacist believes that his or her conscience will be harmed by providing the product or service. Objections should be conveyed to the pharmacy manager, not to the patient.

2. The individual pharmacist must pre-arrange access to an alternate source, to enable the patient to obtain the service or product that they need. Any alternate means must minimize inconvenience or suffering to the patient or patient's agent".

(Accessed 2009-02-21)

Statement V:
Pharmacists respect the rights of patients to receive pharmacy products and services and ensure these rights are met.

Guidelines for interpretation
1. Pharmacists who object, as a matter of conscience, to providing a particular pharmacy product or service must be prepared to explain the basis of their objections to pharmacy management, not the patient.

2. Pharmacists who object, as a matter of conscience, to providing a particular pharmacy product or service have a responsibility to participate in a system designed to respect a patient's right to receive pharmacy products and services. The system must be pre-arranged to enable the patient to obtain the product or service in a timely and convenient manner, minimizing suffering to the patient.

3. Pharmacists have a duty, through communication and coordination, to ensure continuity of care of patients during pharmacy relocation or closure, job action, natural disasters or situations where continuity of care may be problematic.

(Accessed 2009-02-21)

Newfoundland and Labrador
Newfoundland and Labrador Pharmacy Board
  • Code of Ethics
    2001 (4 February) .................................................................SC

Statement V:
Pharmacists respect the rights of patients to receive pharmacy products and services and ensure these rights are met.

Guidelines for interpretation
1. Pharmacists who object to providing a particular pharmacy product or service must be prepared to explain the basis of their objection to pharmacy management.

2. Pharmacists who are unable or unwilling to provide a particular pharmacy product or service have a responsibility to participate in a system designed to respect a patient's right to receive pharmacy products and services. The system must be pre-arranged to enable the patient to obtain the product or service in a timely and convenient manner, minimizing suffering to the patient.

3. Pharmacists have a duty, through communication and co-ordination, to ensure the continuity of care of patients during pharmacy relocation or closure, job action, natural disasters or situations where continuity of care may be problematic.

(Accessed 2009-02-21)

IRELAND
Pharmaceutical Society of Ireland

(Accessed 2009-02-21)

KENYA
Pharmaceutical Society of Kenya
The Code of Ethics and Standards
for Pharmacy Practice in Kenya (2nd Ed)

2004 (26 July) ........................................................................PA

9. The pharmacist ensures continuity of care in the event of labour disputes, pharmacy closure and conflict with personal moral beliefs.

9.1 Obligations:

i. To refer a patient to another pharmacist.

ii. To ensure that when a pharmacy closes, the patients are informed of the pharmacy to which their records, if held, have been transferred.

9.2 StandardsThe pharmacist:
i. Informs patients of the opening and closing hours of his/her pharmacy

ii. On duty should have his/her name displayed.yed.

iii. Establishes a working relationship with a colleague on locum basis to ensure continuity of services subject to patients consent.

(Accessed 2009-02-21)

NEW ZEALAND
Pharmacy Council of New Zealand

Principle 7: Trustworthiness
The pharmacist shall act in a manner that promotes public trust in the knowledge and ability of pharmacists and enhances the reputation of the profession
Specific obligations

7.2 Conscientious objection *
The pharmacist must, in advance, advise any employer, Charge Pharmacist, local general medical practitioners and patients of the pharmacy of any belief or conscientious objection which may influence or impact on their sphere of practice.

Commentary to Principle 7
7.2 Conscientious objection
s. 46 of The Contraception, Sterilisation and Abortion Act 1977 provides for a right of conscientious objection as follows: (1) Notwithstanding anything in any other enactment, or any rule of law, or the terms of any oath or of any contract (whether of employment or otherwise), noregistered medical practitioner, registered nurse, or other person shall be under any obligation

To perform or assist in the performance of an abortion….

…or supply or administer or assist in the supply or administering, of any contraceptive, or to offer to give any advice relating to contraception if he objects to doing so on grounds of conscience.

The obligation in the Code does not in any way impinge on or seek to limit this right, but requires that where a pharmacist does object to supplying contraceptives, or object to giving advice relating to contraception on grounds of conscience, the pharmacist must advise any employer, Charge Pharmacist, local general medical practitioners and patients of the pharmacy of this objection.

(Accessed 2009-02-21)-21)

UNITED KINGDOM
Royal Pharmaceutical Society of Great Britain
1 August, 2007 ......................................................................PA

3.4 Ensure that if your religious or moral beliefs prevent you from providing a particular professional service, the relevant persons or authorities are informed of this and patients are referred to alternative providers for the service they require.

(Accessed 2009-02-20)

UNITED STATES
American Pharmacists Association
  • Code of Ethics ......................................................................NA

(Accessed 2009-02-24).

APhA Position
APhA recognizes the individual pharmacist's right to exercise conscientious refusal and supports the establishment of systems to ensure patient's access to legally prescribed therapy without compromising the pharmacist's right of conscientious refusal. When this policy is implemented correctly, and proactively, it is seamless to the patient, and the patient is not aware that the pharmacist is stepping away from the situation. In sum, APhA supports the ability of the pharmacist to step away, not in the way, and supports the establishment of an alternative system for delivery of patient care.

APhA policy does not support lecturing a patient or taking any action to obstruct patient access to clinically appropriate, legally prescribed therapy. APhA policy does not interject the pharmacist between the patient and the physician.

(Accessed 2009-02-20)

Q: Can I refuse sale of Plan B OTC?

A: APhA supports an individual pharmacist's ability to choose not to dispense a medication for personal, religious and moral reasons and also supports the establishment of systems to ensure patient's access to legally prescribed therapy. Pharmacists with objections to dispensing any medications, including Plan B OTC, should work with their management to develop any systems necessary to accommodate the patient's and pharmacist's needs...

(Accessed 2009-02-21)

. . . it is important to note that the "conscience clause" which allows pharmacists to opt out of offering services that they find morally objectionable is not limited to emergency contraception. It is intended to protect all health professionals from being compelled to violate their beliefs, including dispensing medication for assisted suicide or executions. These are just some of the other activities that pharmacists may choose not to participate in. Well-constructed conscience clauses also support systems to assure patient access to legally prescribed clinically accurate therapy.

(Accessed 2009-02-21)

Arkansas
Arkansas State Board of Pharmacy
  • News - May, 2005
    Conscience Clause.............................................................ND*

The Arkansas State Board of Pharmacy receives several calls each year regarding the conscience clause for pharmacists. While there is a law in Arkansas that addresses a pharmacist's right to refuse filling certain prescriptions, it is actually a public health law that has been in place since 1973.

20-16-304. Public policy - Availability of Procedures, Supplies, and Information -Exceptions.
It shall be the policy and authority of this state that . . .

(4) Nothing in this subchapter shall prohibit a physician, pharmacist, or any other authorized paramedical personnel from refusing to furnish any contraceptive procedures, supplies, or information; and

(5) No private institution or physician, nor any agent or employee of such institution or physician, nor any employee of a public institution acting under directions of a physician, shall be prohibited from refusing to provide contraceptive procedures, supplies, and information when the refusal is based upon religious or conscientious objection. No such institution, employee, agent, or physician shall be held liable for the refusal.

(Accessed 2009-02-21)

California
California Board of Pharmacy
  • California Code of Regulations, Title 16 ..............................PA

(5) Referrals and Supplies: If emergency contraception services are not immediately available at the pharmacy or the pharmacist declines to furnish pursuant to conscience clause, the pharmacist will refer the patient to another emergency contraception provider. The pharmacist shall comply with all state mandatory reporting laws, including sexual abuse laws. . .

Colorado
Colorado Board of Pharmacy

(Accessed 2009-02-20)

Colorado Pharmacists Society (APhA)
  • E-mail to Protection of Conscience Project from Exec. Dir.
    2009-02-10 15:18 ...................................................................SC

The code of ethics used by pharmacists in Colorado is the one developed by the American Pharmacists Association.

Georgia
Georgia State Board of Pharmacy

(n) Refusal to Fill Prescription.
It shall not be considered unprofessional conduct for any pharmacist to refuse to fill any prescription based on his/her professional judgment or ethical or moral beliefs.

(Accessed 2009-02-21)

Iowa
Iowa Pharmacy Association
  • Code of Ethics .....................................................................NA

(Accessed 2009-02-20)

Kansas
Kansas Pharmacists Association
  • Code of Ethics ......................................................................NA

(Accessed 2009-02-20)

Michigan
Michigan Pharmacists Association
  • Code of Ethics .....................................................................NA

(Accessed 2009-02-24)

Nebraska
Nebraska Pharmacy Association (APhA)
E-mail to Protection of Conscience Project
from NPhA Finance & Marketing Manager
2009-02-23 12:30:41...............................................................SC

Nebraska regulations refer to the APhA Code of Ethics.

New York
Pharmacists Society of the State of New York
  • Code of Ethics .....................................................................NA

(Accessed 2009-02-20)

North Carolina
North Carolina Board of Pharmacy (APhA) ............SC

Q: Does North Carolina have a "Conscience Clause" for dispensing emergency contraceptives?

A: The Board has adopted a policy on pharmacists' refusal to dispense prescriptions in certain circumstances: . . .

Compassionate care and conscientious objection are not mutually exclusive.
A pharmacist has the right to avoid being complicit in behavior that is inconsistent with his or her morals or ethics. It is unacceptable, however, for pharmacists to impose their moral or ethical beliefs on the patients they serve. Pharmacists who object to providing a medication for a patient on this basis alone, therefore, should take proactive measures so as not to obstruct a patient's right to obtain such medication.

The Board notes that although pharmacists have a right to avoid moral or ethical conflict, they do not have a right to obstruct otherwise legitimate prescription dispensing or delivery solely on the basis of conscientious objection.

Board of Pharmacy staff interprets this policy to mean that if a pharmacist refuses to fill a prescription for emergency contraception then that pharmacist has an obligation to get the patient and the prescription to a pharmacist who will dispense that prescription in a timely manner.

(Accessed 2009-02-21)

Oregon
Oregon State Board of Pharmacy

. . . Just as other health care professionals and practitioners in Oregon have a choice, so do pharmacists have a choice whether or not to participate in activities they find morally or ethically objectionable. Oregon pharmacists cannot however, interfere with a patient's lawfully and appropriately prescribed drug therapy or request for drugs and devices approved by the U.S. Food and Drug Administration (FDA) for restricted distribution by pharmacies. . .

The Board of Pharmacy expects each Oregon Pharmacist-in-Charge (PIC) to adopt written policies and procedures that address the issues of pharmacists' moral, ethical and professional responsibilities. It is the Board's belief that pharmacy policies and procedures could allow a pharmacist to exercise his or her choice to not participate, and at the same time not interfere with the patient's right to receive appropriate and lawfully prescribed drug therapy or drugs and devices approved by the U.S. FDA for restricted distribution by pharmacies. These may include dispensing of the prescription or drug or device by another pharmacist on site or arranging for the prescription to be dispensed by a pharmacist at another site. The Board also expects Oregon pharmacists to discuss issues of moral, ethical and professional responsibilities with their Pharmacist-In-Charge and to understand and comply with the pharmacy's policies and procedures.

The Board expects that pharmacy policies and procedures will ensure patients in Oregon always receive appropriate and lawfully prescribed medications and information or drugs and devices approved by the U.S. FDA for restricted distribution by pharmacies in a timely and professional manner and that patients are not burdened by the pharmacist's individual beliefs. Interference with a patient's right to receive timely, professional prescription services and information or drugs and devices approved by the U.S. FDA for restricted distribution by pharmacies may be considered unprofessional conduct and could result in disciplinary action by the Board. (See attached "Clarification")

Position Statement History
Originally Adopted September 2005
Revised February 2007

Clarification
For Example, the Board would consider it unprofessional conduct for a pharmacist to lecture a patient about the pharmacist's moral or religious beliefs, to violate the patient's privacy or to destroy, confiscate or otherwise tamper with the patient's prescription.

The written policy should require an objecting pharmacist to inform the PIC in advance so that the PIC can reasonably accommodate that objection before a patient presents a prescription or makes a request for drugs and devices approved by the U.S. FDA for restricted distribution by pharmacies. The accommodation may not include permission to lecture the patient. The policy should also ensure that the patient's prescription or drug and device needs are met either by ordering the drug, if it is not in stock, pursuant to the usual pharmacy policies, by transferring or returning the prescription to the patient if the patient requests, or by referring the patient to another pharmacy nearby where the patient can get the prescription filled or receive drugs and devices approved by the U.S. FDA for restricted distribution by pharmacies. In the event of a referral, the pharmacist is responsible for identifying another pharmacy that has the medication in stock and will dispense the prescription or dispense drugs or devices approved by the U.S. FDA for restricted distribution by pharmacies.

(Accessed 2009-02-20)

Oregon State Pharmacy Association

(Accessed 2009-02-24)

Pennsylvania
Pennsylvania State Board of Pharmacy

The State Board of Pharmacy (Board) by this notice adopts the following statement of policy regarding matters of conscience, to read as set forth in Annex

A. The policy statement sets forth guidelines that should be considered when a pharmacist has a religious, moral or ethical objection to filling a prescription. These guidelines are intended to ensure that patients are not abandoned or neglected and that pharmacists are not forced to engage in activities that conflict with their religious, moral or ethical beliefs.

Background and Purpose
Questions have been raised regarding the professional obligations of licensed pharmacists with respect to providing services to which they may be religiously, morally or ethically opposed. The Board is publishing this policy statement to provide guidance to pharmacists and pharmacies on how to handle the situation when a pharmacist has an issue with filling a prescription due to a religious, moral or ethical objection. This statement of policy is not intended to supersede relevant laws, rules or regulations. The Board also recognizes that professional judgment is often based upon a specific set of facts that requires a particular analysis and not every situation can be addressed with general guidance.

Guidelines
Pharmacists have a professional responsibility to ensure that their patients obtain properly ordered and therapeutically appropriate medications in a timely matter with appropriate counseling from a pharmacist. Pharmacists also have a responsibility to practice competently and to protect against abandoning or neglecting a patient in need of immediate care without making alternate arrangements. When a pharmacist recognizes that the pharmacist's religious, moral or ethical belief, will result in the refusal to fill a prescription that is otherwise available in a pharmacy, the pharmacist has a professional obligation to take steps to avoid the possibility of abandoning or neglecting a patient. When a pharmacist begins practice in a professional setting, the pharmacist should take steps that may include notification to the owner and pharmacist-manager if the pharmacist's beliefs will limit the drug products the pharmacist will dispense.

If a pharmacy employs a pharmacist who has identified circumstances that would preclude the filling of prescriptions for particular products, the owner and pharmacist-manager should devise reasonable accommodations that will respect the pharmacist's choice while assuring delivery of services to patients in need. This may include scheduling of pharmacists to allow a pharmacist who has a religious, moral or ethical objection to practice simultaneously with another pharmacist who will fill the requested prescription, entering into collaborative arrangements with pharmacies in close proximity, or other accommodations designed to protect the public.

In addition, a pharmacist who has a religious, moral or ethical objection to filling a particular prescription should avoid judgmental or confrontational activities with the patient and should not interfere with another pharmacist filling the prescription.
The policy statement set forth in Annex A is effective upon publication in the Pennsylvania Bulletin

(Accessed 2009-02-24)

South Dakota
South Dakota Pharmacists Association
  • Code of Ethics .....................................................................NA

(Accessed 2009-02-20)

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