This story is from an experienced proprietor in their own words. The purpose is to share this pharmacist’s perspective of the regulatory journey. designed to prepare students for successful careers in the pharmaceutical industry, healthcare, or academia.
My experience with a regulatory notification was both deeply stressful and profoundly disappointing. Like most pharmacists, I had assumed that the regulator existed to protect the public and uphold the integrity of the profession by identifying genuine cases of unsafe or unethical practice.
What I discovered instead was an adversarial, poorly informed system that appeared far more interested in manufacturing allegations than in establishing facts. It was a sobering lesson — and one I believe every pharmacist should understand.
The regulator arrived at my pharmacy without notice and demanded access to a broad range of records. Beyond listing what they wanted, they provided no explanation as to what they were investigating or why.
In hindsight, it is obvious to me that the sole purpose of their questions was to generate further allegations and to use anything I said against me. They had no interest in explanations. There was no point engaging with them: they had arrived on a mission. This was not an investigation — it was a prosecution.
There had been no complaint from a patient, prescriber, or colleague. There was no triggering incident, no context, and no stated concern — simply an unannounced inspection with no transparency and no apparent basis.
I have no objection to genuine oversight. What followed, however, was neither fair nor transparent.
Following the visit, the regulator invited me to attend an interview. On the advice of solicitors appointed through PDL, I declined — advice that proved to be excellent.
For anyone who finds themselves in a similar position, my strongest recommendation is this: limit your interactions with the regulator to what is strictly necessary. Comply with lawful requests, but provide nothing beyond what you are legally required to provide.
Doing so will almost certainly provoke the regulator into generating additional allegations — whether out of spite or simple incompetence is unclear. These extra allegations are time-consuming and irritating to refute, but they are also typically amateurish, poorly reasoned, and unsupported by evidence, making them ultimately easy — though exhausting — to dismantle.
Although the regulators are pharmacists, they appear to have little current practical experience and, frankly, to hold pharmacists — particularly proprietors — in open contempt. The underlying assumption seems to be that we are greedy, unethical, and deserving of punishment.
In my experience, the regulator is not seeking understanding, balance, or accuracy. Their approach is to generate as many allegations as possible, interpret every fact in the least favourable light, and see what survives.
When the regulator eventually particularised their allegations, the list was extraordinary. It was riddled with factual errors, incorrect assumptions, miscalculations, and conclusions that simply did not follow from the data.
It became immediately clear that the investigators’ understanding of pharmacy practice was superficial at best, and that their analytical processes were careless and unchecked. They were not trying to establish the truth — they were trying to claim a scalp. There was no concern for accuracy, proportionality, or the fact that there was a human being at the other end of the process. It was a game, and I was the target.
After nearly 300 days of correspondence, stress, and wasted effort, no orders were made against me and no further action was taken. The episode consumed hundreds of hours, significant public resources, and thousands of dollars in legal fees (thankfully covered by PDL).
The allegations were so weak and internally inconsistent that I can only assume those responsible were quietly embarrassed by the outcome.
The matter was ultimately reviewed by both the Pharmacy Council and the HCCC. Neither made any findings or orders against me, and the case was closed. I am acutely aware that my experience as an owner, my access to competent legal advice, and my resources were protective factors. For a younger, less experienced, or less confident pharmacist, this process could have been professionally and psychologically devastating.
You can need it even when you have done absolutely nothing wrong.
It will not prevent false or misguided allegations, but it gives you the only effective means of defence.
In my case, officers demonstrated limited understanding of pharmacy practice and, at times, basic arithmetic.
The pharmacists involved at the Pharmacy Council were not specialists in the area under investigation, but they were open-minded, asked mostly sensible questions, and ultimately accepted my explanations.
The HCCC’s role, by contrast, was baffling. After being investigated by the regulator and reviewed by the Council, you are required submit your story again — often months later — only for the HCCC to confirm what has already been decided. It appears that their role is often just to drag things out and torture you a little more.
The process is slow, one-sided, and error-prone: you must respond within days, while they take as long as they like and routinely issue documents containing mistakes, with little apology or accountability.
To add insult to injury, every letter arrives decorated with cheerful “wellbeing” messaging — a hollow gesture from agencies whose processes are responsible for much of the distress they claim to acknowledge. This tells you a lot about the culture of this organisation – it is all about do as I say not do as I do and holding the person being investigated to very different and higher standards to the standards they hold themselves to.
Do not expect fairness, good faith, or due process. Transparency and cooperation will not protect you; they will simply provide more material to be misinterpreted.
The regulator is free to interpret legislation however it wishes and is under no obligation to disclose those interpretations until it decides to deploy them against you.
You will be given a hearing, but you must be impeccably prepared. Facts and documentation are your only real allies.
Each committee member may pursue their own tangential agenda, often unrelated to the original allegations. The process feels less like an examination of specific conduct and more like a generalised inquisition into your character and practice.
I have real sympathy for inexperienced, anxious, or slower-thinking pharmacists. If you stumble, the consequences can be severe.
Even exemplary practice can be distorted into something sinister. Assume it is a matter of when, not if, you will need to justify your conduct.
I once believed that “where there’s smoke there’s fire.” I no longer believe that to be true.
The best possible outcome is to endure nine to thirteen months of stress, disruption, and expense, only to emerge without sanction but with a “black mark” against you name despite the outcome that will have to be justified if you ever come to the attention of a regulator again (that’s right – you can never actually be completely cleared from anything, it stays on your record forever).
Regulators face no consequences for reckless or unfounded allegations. Challenging them further would require years of litigation, at enormous cost, with little practical reward. There are no apologies. No acknowledgements. No lessons learned. They don’t have to account for what they put you through or for the massive waste of public resources – there is no judge to chastise them for wasting everyone’s time or resources as there would be if they were the Police. They can be as amateurish, spiteful and incompetent as they like with no consequences whatsoever – it is a disgraceful situation and it also makes me think that if you were actually a “bad apple” there is no guarantee they would be capable of catching you.
This experience demonstrated how regulatory power, when paired with minimal accountability, breeds carelessness and arrogance. The regulator’s investigation achieved nothing of public value, yet consumed extraordinary time, money, and energy.
What is more troubling is that it exposed a system in which fairness depends less on principle than on who happens to be conducting the investigation.
If sharing this experience helps even one pharmacist prepare, protect themselves, or feel less blindsided when that unannounced visit inevitably occurs, then perhaps some good will come from an otherwise pointless and infuriating ordeal.
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