It looks likely that the current DOH consultation on control of entry will conclude that all exemptions except distance selling pharmacies will be removed. The closing date for comments and observations to be made on the consultation is 25th January 2012, after which the rules can be changed.
What is not yet so clear is what the transitional arrangements will be joining the end of the 2005 regulations with the beginning of the new PNA based control of entry regulations.
Those who have or applying whilst the current regulations are still fully in force, will probably feel that their application should be processed under the current regulations, regardless of how long the relevant PCT may delay processing the application. Whilst this seems a reasonable and fair aspiration, it is perhaps just one of the several options open to the regulators.
It could for example be that only those applicants whose applications have been finally decided before the PNA basis comes into force, will be allowed to proceed with opening.
Whilst I would in no way seek to encourage anyone to open a 100 hours pharmacy lightly, as profit margins in 2012 will undoubtedly be worse than in 2011, there look to be potential risks for those whose applications are submitted late and may therefore not be processed before the new legislation is decided.