does not have a role in authorising when pharmacies open, investigating pharmacy closures, or monitoring opening hours. it encouraged the public and pharmacists to report concerns to the nhs. it also said that closures could be reported to the gphc, but given that it also claimed it doesn’t have a role in investigating them, it appears that this would not be a fruitful use of time. the gphc reasoned that some closures may be appropriate if necessary in the interests of patient safety. however, this does not account for the fact that closures are avoidable in almost all circumstances; if the pharmacy owner ensures there are enough staff available to open the pharmacy, no decision to close would be required. between 2010 and 2021 there was a substantial increase in the number of pharmacists relative to the number of registered pharmacies. this holds true when the increased number of pharmacists working in primary care, is taken into account. if the closures cause the pharmacy to fail to meet the gphc’s premises standards, then they are a matter for the gphc. if the gphc’s standards don’t cover such closures, then that in itself would be a regulatory failure. the gphc did not explain how, if pharmacies are expected to provide a safe and effective service, this can be achieved when the pharmacies close unnecessarily when the public reasonably expects them to be open. it is not clear from what source the gphc derives its commitment to inaction in respect of regulating registered pharmacies and pharmacy owners. however, given it’s high-profile, long-standing nature, it is almost certainly sponsored, and is at the least passively accepted, by central government. gphc’s legal powers to set standards relating to pharmacy closures the gphc has a legal function, under article 3 of the pharmacy order 2010, to set and promote standards for the safe and effective practice of pharmacy at registered pharmacies. as regards the contents of the standards, article 7 of the pharmacy order 2010 makes provisions which would allow the gphc to set standards relating to pharmacy closures. the standards can relate, for example, to: pharmacy governance arrangements, including arrangements for managing and monitoring the safe and effective provision of pharmacy services the working environment at and the condition of registered pharmacies; the patient and public experience of pharmacy services provided arrangements for ensuring staff of the retail pharmacy business are properly held accountable for the health, safety and well-being of patients to whom pharmacy services are provided article 7(3) of the pharmacy order 2010 does not limit the contents of the standards that the gphc must set under article 7(1). gphc standards for registered pharmacies the gphc’s standards for registered pharmacies, in the table below, are relevant to pharmacy closures. however, the gphc does not take action against pharmacies or pharmacy owners, in respect of pharmacy closures. gphc premises standard number standard how the standard applies to pharmacy closures 1.1 the risks associated with providing pharmacy services are identified and managed. the risks associated with providing pharmacy services are not being identified and managed effectively if the pharmacy is closed at a time when the public would reasonably expect it to be open. 1.3 pharmacy services are provided by staff with clearly defined roles and clear lines of accountability. when the pharmacy is closed at a time when the public would reasonably expect it to be open, contrary to the public's expectations, the pharmacy services are not being provided at all. 1.4 feedback and concerns about the pharmacy, services and staff can be raised by individuals and organisations, and these are taken into account and action taken where appropriate. there has been a substantial amount of feedback and concern about the adverse impact of the closures on patient safety, withoutany discernible robust action being taken by the gphc. 1.8 children and vulnerable adults are safeguarded. children and vulnerable adults are not being safeguarded when the pharmacy is closed unnecessarily, where they would reasonably expect it to be open. 2.1 there are enough staff, suitably qualified and skilled, for the safe and effective provision of the pharmacy services provided. pharmacy owners are not ensuring that there are enough staff, and the pharmacy services are not being provided safely and effectively, if the pharmacy is closed at a time when the public would reasonably expect it to be open. 2.3 staff can comply with their own professional and legal obligations and are empowered to exercise their professional judgement in the interests of patients and the public. closing the pharmacy unnecessarily (for example, as a result of the failure to plan appropriately) is not in the interests of patients and the public. pharmacy owners' failure to plan appropriately may place pharmacists in the position of having to make choices contrary to the public interest. 2.4 there is a culture of openness, honesty and learning. closures are repeated at the same pharmacies. this may show that the situation is not being learned from adequately. 2.6 incentives or targets do not compromise the health, safety or wellbeing of patients and the public, or the professional judgement of staff. some of the closures are about maintaining profit and inevitably compromise the health, safety and wellbeing of patients and the public. 4.1 the pharmacy services provided are accessible to patients and the public. the services are not provided, and are not accessible to the public, if the pharmacy is closed when the public would reasonably expect it to be open. 4.2 pharmacy services are managed and delivered safely and effectively. this is not the case when there are repeated closures and pharmacists are available. regulation of pharmacists and pharmacy technicians the gphc is responsible for the regulation of 61,137 pharmacists and 24,928 pharmacy technicians as at july 2022. confidence in the gphc in 2016/17, the pharmacists' defence association conducted a survey of its members, in which one of the questions asked was "do you have confidence that the working environments in the pharmacy, set by your main employer, are satisfactorily regulated by the gphc/psni in such a way as to support the safe provision of pharmacy services to patients?". of the 1,492 responses received, 72.7% said "no" or that they were unsure. in 2022, during the parliamentary process of examining the pharmacy (responsible pharmacists, superintendent pharmacists etc.) order 2022, comments from the secondary legislation scrutiny committee were noted which related to professional distrust in the gphc. it was noted that "several proposals were not popular with respondents to the consultation exercise on the grounds that they may reduce patient safety, particularly provisions allowing superintendent pharmacists to cover more than one firm and responsible pharmacists to cover more than one pharmacy or to operate remotely. we also note significant levels of distrust from the profession that the regulator, the general pharmaceutical council … would be able to set standards and rules appropriately. worryingly, the committee goes on to say: “we found the response of the department of health and social care … to these concerns, as set out in the explanatory memorandum, unconvincing.” human rights legal challenge to its professional standards in 2017, the gphc renamed its “standards of conduct, ethics and performance”, which set standards for pharmacists registered with the gphc, to “standards for pharmacy professionals”. at the same time, it changed the standards, and set out for the first time expressly that “the standards need to be met at all times, not only during working hours.” two pharmacists, pitt and tyas, who were employees of the pharmacists’ defence association, initiated judicial review proceedings on the basis that – they alleged - the new standards would infringe their human rights set out in articles 8, 10 and 11 of the european convention on human rights, as given effect in uk law through sch. 1 to the human rights act 1998. the challenge was ultimately not successful, but the judgement has been called into question. the gphc's social media guidance (“demonstrating professionalism online”) – which asks pharmacists not to get involved in “negative, unconstructive discussions”, has not as yet been subject to legal challenge on the grounds of human rights. however, action taken against a pharmacist on the basis that he/she was involved in a negative and/or unconstructive discussion (which ostensibly includes, for example, talking to someone who was complaining about the weather) has the potential to engage human rights issues in relation to freedom of expression. potential cheating/collusion/plagiarism on pharmacy technician training courses in july 2018, the pharmacists’ defence association reported on “potential cheating, collusion or plagiarism among trainee pharmacy technicians”. it stated that, “a small number of online distance learning courses are undertaken by many trainee pharmacy technicians in the uk… since 2011, an extensive set of responses to assessment questions appears to have been developing, all of which are publicly visible and indexed on online search engines. this means that trainee pharmacy technicians completing the distance learning courses can find answers to these questions and could potentially plagiarise them word-for-word to help them pass their assessments, without having conducted their own research or developing their own understanding. some of the suggested responses to exam questions indicate what grading was obtained for that response. communication also appears to occur through private messaging. as at 22 march 2018, the threads identified had been viewed a combined total 61,483 times.” it also stated that “gphc-commissioned research, published in 2014, included comments relating to the potential for cheating, collusion and plagiarism on pharmacy technicians’ initial education and training courses... it is unclear what action the gphc has taken on this matter since that time.” it is not clear whether the gphc took any action to investigate following the pda report. buttercups training responded to the pda report, saying among other things that “cheating is a part of the human condition”. however, it said it has robust systems to detect cheating and will respond swiftly and decisively where it is discovered on its own courses. continuing professional development (cpd) (improperly called "revalidation") pharmacists and pharmacy technicians are required to provide evidence annually to the gphc that they have maintained their fitness to practise. prior to 30 march 2018, the process of ongoing learning – evidence of which had had to be provided to the gphc since its inception in 2010 – had been referred to as "continuing professional development" (cpd). development of the framework for three years from 2014 to 2017, the gphc developed the proposals to change the requirements upon pharmacists and pharmacy technicians as a continuing fitness to practise “cftp” programme. the gphc decided to change the name to “revalidation” around three weeks before the launch of the public "consultation" on the proposed change, whilst the head of continuing fitness to practise was on leave, and after its cftp advisory group - which had advised the gphc during the programme - had been disbanded. the head of cftp, on learning of the change on return from leave, implored the gphc to reconsider, and revert to calling the process "cftp". during the meetings of the cftp advisory group, the head of cftp at the gphc spoke in favour of calling the process, simply, “cpd”. requirements the requirements under the framework include submitting four cpd records each year (two of which must be planned); a reflective account, in which the individual considers his/her own practice; and a peer discussion. this does not amount to revalidation because it does not involve a formal assessment by another person that the registrant is meeting regulatory requirements, in order for the registrant to re-register. such formal assessment is a feature of the gmc and nmc revalidation programmes, which were, at the time the gphc introduced the change, the only two programmes among healthcare regulators regulated by the professional standards authority. definition of revalidation formal assessment by another person was the basis of revalidation as recommended in the shipman report, in which actual revalidation has many of its roots. the shipman report was a landmark report in uk healthcare into a doctor who is estimated to have murdered at least 215 of his patients over a period of 24 years. the distinction between revalidation and cftp is therefore an important one, which should be recognised if healthcare regulators are to be able to claim they have genuinely learned from past events. the gphc’s “revalidation” programme does