Given the complexity of storing some modern medicines; either because of unusual storage requirements, because of the value of the product or simply because of space considerations, what can a pharmacy do?
The simplistic answer would be to suggest they find bigger premises or invest in complex storage solutions, but we obviously live in the real world where margins are tight and such things are never as simple as they sound. Experience shows that sheds, random out buildings or flats above shops are often pressed into service, most of these are far from ideal for the storage of medicines: too hot, too cold, too damp or a combination of all three! Please remember that the Pharmacy Standards, particularly principle 3, applies to all areas or premises where medicines are stored.
If the pharmacy is part of a group, spare space at another site could be utilised or it would be possible to take on an off-site warehouse for use by all group pharmacies, and as long as the storage is only used for pharmacies and stock owned by the same legal entity, this facility wouldn’t need a Wholesale Dealer’s Licence. As above, it would however need to comply with the Pharmacy Standards.
A final option would be to use a third-party storage site; local pharmaceutical wholesalers may be looking for additional revenue streams or there may be companies that specialise in the storage of products requiring special storage conditions. This may sound complicated but as long as it is set up correctly it should be pretty straightforward. The company operating the storage site would need a Wholesale Distribution Authorisation (WDA), that covers the types of products being stored (i.e the relevant legal categories of medicines (POM, P, GSL) and also permission to hold Cold Chain medicines if handling fridge lines and an appropriate Home Office Controlled Drugs licence, in addition to a WDA, if any schedule of CD is being held) but as long as the pharmacy retains legal ownership of the stock whilst it is in storage, the pharmacy wouldn’t need a WDA themselves. This sort of set up would be best established via a written agreement between the two parties, indeed the WDA holder would probably insist on this. This agreement, often describes as quality Technical Agreement (QTA), would establish the status of the stock as ‘consignment stock’, that is it is being stored by one company but fully owned by another, and it would also clearly define the responsibilities of the two parties. Whilst WDA holders will be used to these sorts of agreements, pharmacies are often not, but it is nothing to be scared of. Given the costs of many medicines and the slim margins that pharmacies operate to, it makes sense to invest it appropriate storage.