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London Region Pharmaceutical Services Regulations Committee 20 July 2017 Part 2, London Area agenda item number 2A– Decision report on an application for inclusion in a pharmaceutical list: no significant change relocation application within a HWB's area

Havering HWBB

Name of applicant

Day Lewis PLC

Fitness to practise Not applicable, already included in respect of other premises.

Address of current premises

52 Collier Row Lane, Romford, Essex, RM5 3BB

Address of Proposed premises

Brooks Rattan Garden Furniture Store 268-272North St, Romford, Essex, RM1 4QN

Status of location Non-controlled locality.

Relevant regulations and guidance

Regulations 24 – relocations that do not result in significant change to pharmaceutical services provision. Regulation 31 – refusal: same or adjacent premises. [Regulation 65 – core opening hours conditions1.] [Regulation 66 – conditions relating to providing directed services2.] DH market entry guidance chapter 10.

Consider impact of decision on those with protected characteristics under the Equalities Act 2010 and is this in accordance with NHS England's Public Sector Equality Duty Consider impact of decision on NHS England's duty on health inequality

The information provided has potential impact on patients with protected characteristics. The distance involved and crossing the busy A12, would have an impact on patients within these groups.

1 To be considered if the applicant is undertaking to provide more than 30 or 40 core opening hours a

week.

2 To be considered if the applicant is undertaking to provide directed services.

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Interested parties notified of the application3

Wh Burdess Chemist Ltd 178 Mawney Road, RM7 8BU

Representations submitted

Rowlands Pharmacy 3 Fairview Parade, RM7 7HH

Representations submitted

Boots HO for branches at:

12 The Liberty, RM1 3RL

47 Market Pl, RM1 3AB

7 The Brewery, RM1 1AU

21/23 Clockhouse Lane, RM5 3PH

Representations submitted

Lloyds Pharmacy HO for branches at:

Inside Sainsburys, 1-15 The Brewery, RM1 1AU

12 Chase Cross Road, RM5 3PR

Representations submitted

Mim Pharmacy Ltd 118 North Street, RM1 1DL

Representations submitted

Rise Park Pharmacy 173 Eastern Ave East, RM1 4NT

Representations not submitted

Clockhouse Pharmacy 5 Clockhouse Lane, RM5 3PH

Representations not submitted

Britcrown Pharmacy 5 Balgores Lane, RM2 5JR

Representations not submitted

Park Lane Pharmacy, 1 Park Lane, RM11 1BB

Representations not submitted

North East London LPC Representations not submitted

Londonwide LMC Representations not submitted

Havering HWBB Representations not submitted

Havering Healthwatch Representations not submitted

The PSRC have determined that there is enough information within the papers to decide the

application without an oral hearing.

Regulation 31

The proposed pharmacy is not on the same site or adjacent to any other pharmacy, therefore

this regulation is not engaged.

Regulation 32

There are currently no LPS designations in this area therefore regulation 32 is not engaged.

Regulation 24(1) criteria a) for the patient groups that are accustomed to accessing pharmaceutical services at the

existing premises, the location of the new premises is not significantly less accessible;

Applicants Information

3 List all interested persons who were notified of the application and indicate whether they submitted

representations.

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The existing pharmacy serves a large residential area which comprises a mixture of local/ex local authority and private housing. It is located on the corner of Collier Row Lane/Wainfleet Avenue and forms part of a small parade of shops, none of which are used on a day to day basis by local residents. There is no parking directly outside this parade due to double yellow lines and a controlled traffic crossing so patients have to find parking on one of the busy residential streets. Opposite the pharmacy is another parade of shops with more day to day premises, however there are no reasonable sized convenience stores to cater for everyday needs, therefore these would be catered for elsewhere. Again parking is difficult although there are a number of pay and display places available. In view of the lack of everyday facilities we believe that many local residents are likely to travel south towards Romford town centre which is the major shopping destination. Those travelling from close to the existing pharmacy are likely to travel along Collier Row Lane and then North Street where the proposed premises are located and then to the town centre shops. The proposed premises are a long established family business, currently trading as a furniture shop and are located on the corner of North Street and Parkside Avenue. They are directly adjacent to North Street Medical Practice and enjoy free customer parking to both the front and rear of the premises. We define the patient groups as follows:

1. Patients receiving a delivery service 2. Patients living within the vicinity of the pharmacy who use it because it is close to home. 3. Patients working within the vicinity of the pharmacy who use it because it is close to work. 4. Patients attending North Street Medical Centre and subsequently seeking pharmaceutical

services. 5. Patients attending other surgeries and subsequently seeking pharmaceutical services. 6. Patients attending the pharmacy who do not live within the immediate area and who have

not attended a medical centre before visiting pharmacy. 7. Patients who wish to access advanced or locally commissioned services from the

pharmacy 8. Patients who share protected characteristics.

For each of the patient groups we have considered the implications of the proposed relocation. These comments apply whether people from these patient groups are attending a pharmacy to receive a prescription, access another pharmaceutical service or to purchase “over the counter” medicines. Patients receiving a delivery service Around 25% of the prescriptions are handled through the delivery service, this includes patients whose prescriptions are collected and those whose prescriptions are through EPS. For those patients the service will remain the same. It is clear that for this patient group the services will remain as accessible following relocation. Patients living within the vicinity of the pharmacy who use it because it is close to home. As this is a densely populated area, we believe that many of those residents are used to travelling from their home on a regular basis to cater for their everyday needs as facilities close at hand are limited. It is likely that they travel by car, public transport or on foot.

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Those traveling by car would not find the new premises any less accessible than the current one. They are only approx. 625m apart and there is free parking available at the proposed premises, whereas there are none at the current site. The journey does involve crossing the junction with the A12 but this is simplified by traffic lights. For those on foot some would find the journey slightly longer and some considerably shorter depending on where they live and start their journey from. The walk between the two premises is easy with wide primarily flat well-lit pavements on both sides of Collier Row Lane. There are crossing points directly outside the existing pharmacy and further South along Collier Row Lane. There is a zebra crossing allowing residents to easily negotiate the junction at Collier Row Lane/Having Road and the junction with Eastern Avenue can be crossed with the assistance of controlled lights or via a subway. Several buses regularly run all the way along Collier Row Lane from north to south and then along North St eventually ending up at Romford Town Centre. There are bus stops close to both the proposed and existing premises on both sides of the road. The journey between them takes just a few minutes. In summary we believe the new premises will be at least as accessible and more so for many. For the few who have slightly further to travel as a result of a relocation the new premises cannot be considered to be significantly less accessible. Patients working within the vicinity of the pharmacy who use it because it is close to work. Whilst there are not extensive employment facilities close to the existing site the people who do work in the local shops etc are likely to either live in the surrounding residential turnings or possibly travel from further afield. For those travelling by car the journey will be no more difficult due to the better parking facilities at the proposed site. If they travel to work on foot we have described the journey between the two sites and it is not a difficult one. This patient group will not find the proposed premises significantly less accessible. Patients attending North Street Medical Centre and subsequently seeking pharmaceutical services. Around 50% of items dispensed originate from this surgery at present. It is believed that 10% of these are walk in patients. Those who are not walk in patients will be local residents or employees and will fall into the patient groups above. For patients that currently visit the surgery by car then require pharmaceutical services, the journey to the proposed site would be far easier as it is next door to the practice. There is parking at both the surgery and the proposed premises. For those on foot, again the premises are next door. For those using public transport, the same routes serve the proposed site and the existing pharmacy and there are bus stops close to both sites.

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Patients attending other surgeries and subsequently seeking pharmaceutical services. With the exception of North St Medical Practice the closest GP surgery to both the existing and proposed sites is Dr Gupta at 206 Mawney Rd. For those on foot the route to the existing pharmacy is a convoluted one which involves several turnings and a route of more than 1.3km. The journey to the proposed site is much more straightforward and simply involves walking along flat wide pavements of Eastern Avenue and crossing the road into North St. We estimate the journey to be less than 1km so not only is the route shorter it is more straightforward. The parking facilities have been described above. For those travelling by public transport to the existing premises is a bus journey North along Mawney Road alighting at Percy Road and a walk of approx. 600m. The journey to the proposed premises is easier, a bus on Eastern Ave which heads into North St. If patients are registered at other surgeries further afield they are unlikely to have walked to the existing site due to distances involved so they are more likely to use public transport or travel by car. Patients attending the pharmacy who do not live within the immediate area and who have not attended a medical centre before visiting pharmacy. In a similar way to the patient group described above these people will have travelled some distance to reach the area already and will therefore not find any significant difference in the length of the journey to access the proposed premises. This would apply whichever for of transport chosen. Patients who wish to access advanced or locally commissioned services from the pharmacy Patients who fall under this category will fall into one of the other patient groups above. For patients wishing to access any of the other services offered the proximity of the proposed premises is such that they will be able to access the services in exactly the same manner. Patients who share protected characteristics. Everyone shares at least one protected characteristic. More commonly this relates to elderly, infirm or disabled. For many who currently access the existing pharmacy “on foot” or by wheelchair either from homes or workplaces, the journey will not be any less accessible due to the relatively short distance between the two sites and the wide flat pavements and crossing facilities already described. Those using other forms of transport will find that the new premises are at least as accessible if not more so. Rowlands Comments We note that the pharmacy would be moving approx. 625m if granted. While it may not seem excessive, the pharmacy would be moving closer to the town centre and a number of other

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contractors. This will affect the current relatively even distribution of existing contractors to a degree of clustering. The applicant has identified 8 patient groups, but has not indicated the size of these. For patients who have prescriptions collected and delivered we agree that they would not find the new location significantly less accessible. Patients who use the pharmacy as it is close to their home, we believe would find the proposed location less accessible due to the distance and the main road that needs to be crossed. We believe that these patients are more likely to use another pharmacy rather than make a journey to the proposed location. Patients with shared protected characteristics, the elderly or infirm that are accessing the pharmacy on foot or by wheelchair we believe would find the new location less accessible. 625m is not an insignificant distance if you have mobility problems and we therefore cannot agree with the applicant’s assertion. Lloyds Comments It is noted this is an application to relocate over 600 metres and across the busy A12 Dual Carriageway. The current premises are also part of a local parade of shops that includes a laundrette. The applicant has regard to the next nearest medical centre to the current premises, Dr Gupta; but it is noted from NHSBSA data (January 2017) that the pharmacy receives few prescription items (40) from Dr Gupta’s Practice. By contrast almost 21 per cent originated from the Lynwood Medical Centre which is situated to the north of the current premises. The applicant has provided limited information with regards to this group. WH Burdess Chemists Ltd The proposed relocation will make a significant change in serving the locality. The catchment of the new location would be less accessible to the existing public. There is a 5 lane dual carriageway, which the public have to pass through the several pedestrian crossings to access, meaning it will make it very difficult to access the new pharmacy at the new location. MIM Pharmacy (The comments from this party included maps and further evidence; this has been made available for the PSRC committee to review.)

The applicant has failed to provide sufficient evidence in support of the application and must be refused. It is for the applicant to provide evidence regarding the patient groups that are accustomed to accessing pharmaceutical services from the existing premises. A general observation has been made that the application has been made for business interests and not for patients. The applicant claims that it is following “many” of the Bay Tree MC patients, who chose to register with North Street MC, are spurious and not supported by evidence. We suggest that more realistically those patients would be evenly split between North St MC and Lynwood MC(1),

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Ingrebourne MC(2), Lawns MC(3) and possibly Dr Gupta’s surgery on Mawney Road. We consider that patients within the blue outlined area are more likely to register with (1), (3) and Dr Gupta as above, in order to avoid navigating the A12 . For the same reasons we submit that those patients who are resident in the red outlined area would be more likely to register with (1) and (2). We therefore dispute the accuracy and significance of the applicant’s assertion that many patients chose to register with North St MC. The applicant has described the business and residential community, which surrounds the Existing Premises (the Pharmacy "serves a large residential area" and "forms part of a small parade of shops" and "opposite the pharmacy is another parade of shops" etc.). The local business community comprises businesses which would attract people on a daily basis e.g. newsagent, cafe, takeaways and off-licence), the workers within and customers of which may justifiably be described as its own patient group, to the extent that such persons are accustomed to accessing pharmaceutical services from the Existing Premises. It is evident that this patient group would find the location of the Proposed Premises significantly less accessible than the Existing Premises. The Applicant also mentions what it considers to constitute parking difficulties associated with the Existing Premises. We attach at Appendix 2 photos of the parking arrangements at the Proposed Premises, which demonstrate double yellow lines at the front of the Proposed Premises, and at the rear, the private parking facilities (namely, five bays) which are not as the Applicant describes "free customer parking to the .... Rear of the premises" but are reserved exclusively for residents of the five flats situated at the site and for which a number of no parking enforcement penalty notices are prominently displayed (see photograph at Appendix 2). We note from the Application that the Proposed Premises at "a long established family business, currently trading as a furniture shop" are not currently in the Applicant's possession and not even the most rudimentary of floor plans has been submitted with the Application, which together casts some uncertainty as to whether the Applicant will in fact be able to provide pharmaceutical services from the Proposed Premises. The Applicant has identified a number of patient groups to which we respond as follows: 1. Patients receiving a delivery service The Applicant submits, without having provided any evidence to substantiate its claim, that "around 25% of the Pharmacy's prescriptions are handled via its long-standing delivery service". It concludes from this unsubstantiated submission that this patient group's access to pharmaceutical services will be therefore be unaffected by the proposed relocation. Such an erroneous conclusion fails to address the needs of the sub-group within this patient group, namely those patients who may receive a delivery service for their dispensed items but who routinely attend the Existing Premises for receipt of other essential services. Due consideration needs to the made to the needs of this patient sub-group, many of whom will find the Proposed Premises significantly less accessible than the Existing Premises for receipt of such other essential services. 2. Patients living within the vicinity [of the Existing Premises] who use it because it is

close to home We consider that this patient group includes: (i) those patients living in the blue outlined area on the map at Appendix 1; (ii) those patients living in the red outlined area; and (iii) those who live to the south of the A 12 and who currently cross it in order to access pharmaceutical services at the Existing Premises rather than access such services at the nearby and more convenient pharmacy owned by the Respondent, MIM Pharmacy (5).

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The Applicant considers, without having provided any evidence to substantiate its claim, that of this patient group, many are used to travelling from their homes on a regular basis to cater for their everyday needs, as the facilities close to Existing Pharmacy are limited. Such an assertion appears to conflict with the reality of the business community described earlier by the Applicant on page 1 of its supplementary information. The Applicant makes reference to the journey from the Existing Premises to the Proposed Premises and the need for this patient group (being (i) and (ii) above) to navigate the crossing of the A 12 either by car, on foot or by public transport. The expense, regularity and reliability of bus services, which run between the Existing Premises and the Proposed Premises, are not known and we would ask that the Committee satisfies itself that those patients within this group, who rely on such public transport, are not significantly inconvenienced by the proposed relocation. It is undeniable that the A 12 is a very busy road, being known as a notorious accident blackspot in this locality, at which numerous car crashes, accidents and fatalities have occurred. We attach at Appendix 2 a selection of photographs depicting the junction and the physical obstacles, which patients will be forced to navigate, and also at Appendix 3 a sample of press clippings and a signed letter from Mr Edward Kiely, the father of a young man, Eddie John Kiely, who was tragically run over and killed by a car at the junction of North Street and Havering Road and the A 12 a few years ago. Mr Kiely understandably has strong views on the safety of this junction and has sought fit to put in writing the perils of how dangerous he considers the A 12 and this junction to be, including drivers' propensity for speeding along it when traffic permits, the high speed limit (50 miles an hour) and the lack of traffic cameras, all of which make this junction a significant and perilous physical obstacle for patients from sub-groups (i) and (ii), who wish to access pharmaceutical services at the Proposed Premises. Patients from such sub-groups, who choose to access pharmaceutical services from the Proposed Premises on foot, will have to cross the A12 either via a central railed area or will need to walk westwards along the A12 and cross the road through a poorly lit subway, a mode of crossing which we submit holds a significant amount of fear for elderly, immobile and vulnerable patient groups (i.e. those with protected Characteristics). Wheelchair users and young mums with prams will also be required to navigate the steep inclines of the subway's ramps, which those patients in sub-groups (i) and (li), who currently access pharmaceutical services from the Existing Premises, are not currently required to do. The subway entrance is some distance from the A 12/North St/Havering Rd junction. The ramp system on both sides of the A 12 makes it a convoluted walk of over 400 metres from the junction itself to the Proposed Premises. This involves crossing Havering Rd from the east side to the west side (there is no subway here), then a walk to the start of the ramps, which head northward first then southward, before coming out of the ramp system on the south side of the A 12 and heading off to the Proposed Premises. Alternatively, patients, who choose to cross the A 12 at the railed area, will need to navigate seven lanes of traffic (three in each direction and a right turn lane) in order to access pharmaceutical services at the Proposed Premises. This is not an easy task for elderly, immobile, wheelchair users and young mums with prams (Le. those with protected characteristics), which will make it significantly less accessible for them to access pharmaceutical services form the Proposed Premises than from the Existing Premises. We consider that for the reasons stated above, those patients within sub-groups (i) and (ii), whether travelling by car (see Appendix 3 news clippings), public transport but especially on foot, who are accustomed to accessing pharmaceutical services from the Existing Premises will find the Proposed Premises significantly less accessible than the Existing Premises.

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3. Patients working in the area who access the Pharmacy because it is close to work The Applicant submits (incorrectly) that the parking facilities at the Proposed Premises are better than those at the Existing Premises. For the reasons stated above, as demonstrated by the photos submitted at Appendix 2, we consider the Applicant's submission to be untrue. To the extent that patients within this patient group are residents of areas (i) and (ii) above, the same difficulties in accessing pharmaceutical services at the Proposed Premises, which we have described in paragraph 2 above, will be relevant. We consider therefore, for the reasons stated above, that a significant proportion of this patient group, who are accustomed to accessing pharmaceutical services from the Existing Premises, will find the Proposed Premises significantly less accessible than the Existing Premises. 4. Patients attending North Street Medical Centre The Applicant submits, without having provided any evidence to substantiate its claim, that "around 50% of items dispensed by the Pharmacy originate from this surgery at the present time" and that 10% of which (i. e. 5% of its overall items) emanate from "walk-ins". There is inevitably a degree of cross-over between this patient group 4 and patient groups 1, 2 and 3 described above. We consider therefore that only the proportion of this patient group, which does not form part of a sub-group identified in any of the three paragraphs above as being significantly is advantaged by the proposed relocation, would not find the Proposed Premises significantly less accessible than the Existing Premises. However, we consider that the remainder of the group, for the reasons stated above, will find that accessing pharmaceutical services at the Proposed Premises will be significantly less accessible than from the Existing Premises. 5. Patients attending other surgeries The Applicant makes an incomprehensible and unevidenced submission in respect of the journey length for patients within this patient group, which does not stand up to scrutiny, claiming that the current journey to the Existing Premises is in the region of 1.3km. Such an assertion fails to consider the journey lengths of those patients who are registered with Lynwood MC (1), Ingrebourne MC (2) and Lawns MC (3), who would live in the surrounding areas to these surgeries and who would, if the Application was successful, be required to cross the busy A 12, the perils of which have been described above. To state that for this patient group, the "journey to the proposed site is much more straightforward" is simply not true. 6. Patients attending the Pharmacy who do not live in the immediate area We concur with the Applicant's analysis of what we would reasonably consider to be a very small patient group. 7. Patients who wish to access advanced or locally commissioned services We concur with the Applicant's analysis of this patient group in so far as it relates to patients who do not fall into any other patient groups or sub-groups, who we have submitted will find accessing pharmaceutical services significantly less accessible at the Proposed Premises than the Existing Premises. 8. Patients who share protected characteristics We disagree once more with the Applicant's analysis of the journey across the A 12, which it considers to create no significant issues for patients with protected characteristics. We have already commented above on patients who share protected characteristics and those who we consider will find accessing pharmaceutical services Significantly less accessible at the Proposed Premises than the Existing Premises. In conclusion, given the significant differences and distance between the Existing Premises and

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the Proposed Premises, it is self-evident that the Proposed Premises would be Significantly less accessible for at least some of the patient groups, described above, that are accustomed to accessing pharmaceutical services from the Existing Premises. Further, it seems extremely unlikely that any of the Applicant's current walk-in patients would choose to travel from the Existing Premises to the Proposed Premises including crossing the extremely busy A 12 road, in order to continue to access pharmaceutical services from the Applicant at the Proposed Premises. Given the detailed explanations provided above, it is evident that NHS England cannot be reasonably satisfied that the regulatory test contained in Regulation 24(1)(a) is met and therefore the Application must be refused. NHS England Comments The distance between the two sites is approx. 625m and to access the proposed site from the existing one the A12 has to be crossed, this is a major road and is not easy to cross. The applicant has outlined who they believe are the patient groups that use the pharmacy. Patients receiving a delivery service Patients in this group if their prescriptions are collected and delivered would not find the new site less accessible for dispensing; however, the applicant has not made any comments about other parts of the essential services or need to access the pharmacy in an emergency. There may be some patients for whom the new site may not be less accessible. Patients living within the vicinity of the pharmacy who use it because it is close to home or close to work. We have grouped these two patient groups together as the reasoning would be the same. This is a densely populated area, residents may be are used to travelling from their home on a regular basis to cater for their everyday needs however there is not sufficient evidence to conclude this. Residents would use a variety of methods of travel including, by car, public transport or on foot. Those traveling by car would need to travel the 625m distance and negotiate the A12. There is a difference of opinion as to whether there is free parking available at the proposed premises. There is also a difference of opinion as to if there are traffic lights at the junction with the A12. For those on foot some would find the journey slightly longer and some considerably shorter depending on where they live and start their journey from. The walk between the two premises is along wide primarily flat well-lit pavements on both sides of Collier Row Lane. There are crossing points directly outside the existing pharmacy and further South along Collier Row Lane. There is a zebra crossing allowing residents to negotiate the junction at Collier Row Lane/Havering Road and the junction with Eastern Avenue can be crossed with the assistance of controlled lights or via a subway. There were comments about both the traffic lights and the subway. Several buses regularly run all the way along Collier Row Lane from north to south and then along North St eventually ending up at Romford Town Centre. There are bus stops close to both the proposed and existing premises on both sides of the road. The journey between them takes just a few minutes.

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Comments have been made regarding the A12 being a very busy road and being known as a notorious accident blackspot in this locality, at which numerous car crashes, accidents and fatalities have occurred. There were some specific instances relayed within the comments, which highlight crossing the A12 as an issue. NHS England considers therefore, that a significant proportion of this patient group, who are accustomed to accessing pharmaceutical services from the Existing Premises, will find the Proposed Premises significantly less accessible than the Existing Premises. Patients attending North Street Medical Centre and subsequently seeking pharmaceutical services. For patients in this group the proposed premises would not be less accessible as this site is next to the medical centre, for these patients the proposed site would be more convenient. Patients attending other surgeries and subsequently seeking pharmaceutical services.

The information from the BSA statistics shows that out of the total number of prescriptions dispensed by this pharmacy, approx. 44% are from the North St MC, 16% from Lynwood MC, 9% Chase Cross MC, 8% Dr Joseph Chase Cross Rd, 5% Mawney MC, 4% Western Rd MC. Whilst the applicant has provided information on the percentage of patients receiving deliveries, this has not been broken down any further and could be a high proportion of those from North St MC currently. The statistics show that the pharmacy does currently provide services to patients from other local surgeries and that moving location across the A12 may not be accessible for some of these patients, especially those from Lynwood MC, Chase Cross MC and Chase Cross Rd as the distance from these practices to the proposed location is approx. 2.1km for Lynwood and 1.9km for the other two practices. Those practices that are on the other side of the A12 currently are only a small proportion of the dispensing, possibly due to patients need to cross over the A12. Patients attending the pharmacy who do not live within the immediate area and who have not attended a medical centre before visiting pharmacy. This patient group will have travelled some distance to reach the area already and will therefore not find any significant difference in the length of the journey to access the proposed premises. This would apply whichever for of transport chosen. Patients who wish to access advanced or locally commissioned services from the pharmacy Patients who fall under this category will fall into one of the other patient groups above and therefore would have the same reasoning for accessibility. Patients who share protected characteristics. For patients who are elderly, disabled or infirm who live close to the current premises and walk to the pharmacy, the new site would potentially be less accessible as these patients would have to cross the very busy A12. The PSRC have determined that some patients would find this new site significantly less accessible. The application is therefore refused.

(b) in the opinion of the NHSCB, granting the application would not result in a significant change to the arrangements that are in place for the provision of local pharmaceutical

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services or of pharmaceutical services other than those provided by a person on a dispensing doctor list— (i) in any part of the area of HWB1, or (ii) in a controlled locality in the area of a neighbouring HWB, where that controlled locality is

within 1.6 kilometres of the premises to which the applicant is seeking to relocate;

Applicants Comments

In our opinion it is clear that granting this application will not result in a significant change to the arrangements currently in place. The existing and proposed premises are relatively close to each other and will serve the same population. The distance between the sites is such that there is no reason to believe that dispensing patterns in the area will be affected in any way as a result of this relocation. There is no pharmacy close to the North Street Medical Centre at the present time so approving this application will have little impact on them. Patient groups accessing pharmaceutical services in the area will still be able to access them in the same way so there is no reason to suggest that this relocation will result in a significant change to the arrangements in place. MIM Pharmacy Comments The pharmacy is currently located at the existing premises in a distinct locality, which benefits from a mixture of residential and business properties, but not, from the applicant’s perspective, since August 2016 a doctor’s surgery. In contrast, the proposed premises are located to the South of the busy A12 in an entirely distinct and separate part of Romford. We have submitted earlier that the patients who are resident in the blue outlined and red outlined areas of the map at Appendix 1, who live north of the A12 will be most adversely affected by the proposed relocation, which if granted would leave a gap in pharmaceutical services provision in the locality immediately north of the A12. We submit that granting the application would consequently result in a significant change in arrangements which are in place for the proper provision of pharmaceutical services in this local area. NHS England Comments There would be changes to the arrangements in place for provision of services, however, there is no evidence to suggest either way if this change would be significant. The PSRC have determined that the move may result in a change to the arrangements that are in place for the provision of local pharmaceutical services or pharmaceutical services, however, there is no evidence to suggest that this would be significant.

(c) the NHSCB is satisfied that granting the application would not cause significant detriment

to proper planning in respect of the provision of pharmaceutical services in the area of

HWB1;

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MIM Pharmacy Comments

Submit for the reasons stated above that the application would cause significant detriment to

proper planning in respect of the provision of pharmaceutical services in this area.

It is the opinion of NHS England Officer that granting this application would not cause

detriment to proper planning.

(d) the services the applicant undertakes to provide at the new premises are the same as

the services the applicant has been providing at the existing premises (whether or not, in the

case of enhanced services, the NHSCB chooses to commission them); and

The applicant will provide the same services at the new location as at the existing location. The hours of the pharmacy will also be the same for the new premises as for the current one. (e) the provision of pharmaceutical services will not be interrupted (except for such period as

the NHSCB may for good cause allow).

There will be no interruption of services except for any period that NHS England Agrees.

Decision The PSRC have determined that there is enough information within the papers to decide the application without an oral hearing. There are no pharmacies within close proximity of the proposed site, therefore regulation 31 does not apply. Regulation 24(1)a – the new premises could be significantly less accessible for some patients, therefore the application is refused on these grounds. Regulation 24(1)b – this move may result in a change to the arrangements that are in place for the provision of local pharmaceutical services or pharmaceutical services, however there is no evidence to suggest that this is significant. Regulation 24(1)c - this application would not cause detriment to proper planning. Regulation 24(1)d – the same services and hours are planned for the new premises. Regulation 24(1)e – there will be no interruption of services The PSRC have determined that the application does not fit the criteria for regulation 24 and is therefore refused.