A pharmacy next door to a surgery

Opening a pharmacy next to a GP surgery usually needs no pharmacy planning permission change of use at all, because dispensing premises sit within Class E and so does almost every shop and health use around them. Movement within a use class is not development, so a former newsagent, bank branch or optician can become a pharmacy without an application. What the business does need is a separate NHS market entry decision, and the two are regularly confused.

Check three things before you assume the planning side is clear.

Where dispensing premises sit in the use classes

The Town and Country Planning (Use Classes) Order 1987, as amended in 2020, puts retail sale of goods other than hot food in Class E(a) and the provision of medical or health services in Class E(e). A pharmacy straddles both: it sells goods over the counter and it dispenses prescriptions, and where it offers vaccinations or a blood pressure service it is providing health services directly.

Because both limbs sit inside Class E, the distinction has no practical consequence for whether permission is needed. A unit lawfully in any part of Class E can become a pharmacy without an application. Our note on the Class E health boundary for opticians and pharmacies goes into where that line actually falls and why it still matters for conditions.

The three situations where permission is needed anyway:

• The unit is sui generis rather than Class E. Hot food takeaways, betting offices, pubs and launderettes sit outside the class, so a change from one of those needs an application.
• An Article 4 direction has removed the right to change use within or into Class E in that area, which some authorities have made to protect retail frontages.
• A condition on an earlier permission restricts the unit to a named use. Conditions survive the Use Classes Order, and a condition limiting a unit to use as a bank is enforceable however wide Class E has become.

Check the planning history for the third one. It is the commonest trap and it is invisible from the street.

The NHS side, which planning does not touch

A pharmacy cannot dispense NHS prescriptions simply because it has premises. Inclusion on the pharmaceutical list is governed by the NHS pharmaceutical services regulations and decided against the local pharmaceutical needs assessment, with routes for applications that meet an identified need and for those arguing unforeseen benefits.

That process runs separately, on its own timetable, with its own appeal route. A planning permission is no evidence at all in it, and a successful market entry application confers no planning rights.

Sequence them with the lease in mind. Signing a lease on the strength of planning advice alone, before the NHS position is settled, is how pharmacy projects fail.

Consultation rooms and access

The fit-out question that reaches planning is accessibility, not clinical function.

A consultation room has to be reachable by a wheelchair user, which on a small shop unit with a level change at the threshold means a ramp, a platform lift or a reconfigured entrance. A ramp projecting beyond the building line is an operation requiring permission in its own right, and in a conservation area the design will be assessed on its appearance as well as its gradient.

The Equality Act 2010 duty to make reasonable adjustments applies independently of whether permission is needed, and Part M of the Building Regulations applies to the works. Neither is a planning matter, but both shape a layout the planning officer may end up seeing.

Internal subdivision to create the consultation room is not development. Adding an extension at the rear to house it is.

Waste medicines, controlled drugs and storage

Pharmacies take back unused medicines from patients, and that waste is stored on the premises before collection. The quantities are small and the arrangements are governed by waste and pharmacy regulation rather than by planning, so a change of use application rarely turns on it.

Where it does surface is in two circumstances. A rear yard used for waste storage that is visible from a residential property can attract an amenity objection. And a listed building or a shopfront in a conservation area may constrain where a secure store or a controlled drugs cabinet can be fixed, because fixing into historic fabric needs listed building consent.

Refrigerated storage for vaccines adds a condenser unit, and a condenser on a rear elevation close to a flat above or behind the unit is a noise question. Where that arises, a short noise assessment settles it before an environmental health officer raises it. Keep the unit off the party wall and specify its sound power level at procurement.

Deliveries, collections and servicing

Wholesaler deliveries to a pharmacy are frequent and small, typically a van rather than a rigid lorry, and in most locations they generate no issue worth assessing.

Two situations change that. A unit with no rear access on a street with waiting restrictions, where the van will stop on the carriageway several times a day. And a pharmacy adjoining a surgery where patient footfall already causes short-stay parking pressure, which is the scenario in the title and the one authorities are most alert to.

Where the officer raises it, a Transport Statement covering delivery frequency, vehicle type, the loading location and the existing parking situation answers it proportionately. Do not over-engineer this. A pharmacy is not a trip generator on the scale that needs modelling, and a short, evidenced statement is more persuasive than a full assessment.

Shopfront, signage and advertisement consent

Changing the fascia is where the planning application you did not need appears.

Alterations to a shopfront that materially affect the external appearance need planning permission, and on a listed building they need listed building consent as well. Replacing a timber shopfront with an aluminium one in a conservation area will be resisted.

Signage is governed separately by the advertisement control regulations. Some signs on business premises benefit from deemed consent subject to limits on size, height, projection and illumination, and anything beyond those limits needs express consent. Illuminated signs and projecting signs are the ones that most often fall outside deemed consent. The green cross is an advertisement like any other.

Apply for the shopfront and the signage together where both are needed, so that the officer sees the whole frontage rather than approving one and objecting to the other.

When no permission is needed, record why

If your conclusion is that the change needs no permission, write that conclusion down with the reasoning, the planning history you checked and the date you checked it. Better still, apply for a lawful development certificate for a proposed use, which is the only formal way to confirm that a use is lawful and which costs a fraction of defending an enforcement notice later. A short Planning Statement setting out the use class analysis supports that application.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.

Browse the 66 report types to see which documents a change of use in a parade of shops is likely to need.

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