MEMORANDUM 61
Submitted by the Royal Pharmaceutical
Society of Great Britain (RPSGB)
BACKGROUND ABOUT
THE ROYAL
PHARMACEUTICAL SOCIETY
OF GREAT
BRITAIN (RPSGB)
1. The RPSGB founded in 1841 is the professional
and regulatory body for Pharmacists in Great Britain. The RPSGB
represents 44,000 pharmacists in England, Scotland and Wales—the
vast majority of whom are employed by, or work for, companies
contracted to provide services to the NHS and who are involved
in providing support and services to drug misusers in the community.
2. The Society has the responsibility of
undertaking regular inspection of pharmacies to monitor standards
of practices and compliance with legal and professional requirements.
INCREASE IN
THE NUMBER
OF DRUG
MISUSERS
3. The current framework of regulations
used for providing services to drug misusers through community
pharmacies is in urgent need of review. Community pharmacists
throughout Great Britain are facing many difficult problems resulting
from the current Misuse of Drugs Regulations which were never
designed to deal with the current numbers of clients. Community
pharmacy has an important role in providing support services to
drug misusers and their involvement has helped reduce the harm
resulting from illicit drug misuse. However, the current out of
date regulations compound the problems of managing the provision
of these services to an often demanding cohort of patients.
4. There has been a dramatic rise in the
number of drug misusers in the last ten years and this has been
reflected in the growing provision of services to drug misusers
provided by community pharmacies. However since local needs for
pharmaceutical services to drug misusers requirements have not
been comprehensively assessed on a nation-wide basis, the service
provision has not always matched local needs. Services for drug
misusers now cover rural areas as well as large conurbations.
For example, by March 2000, over 78 per cent of community pharmacies
in Scotland were involved in dispensing prescriptions for methadone.
5. If the supply of services to drug misusers
is restricted to clinics and a small number of pharmacies, the
resulting daily concentration of drug misusers in an area attracts
others and may lead to street dealing of prescribed medication.
This "honey pot" effect is politically and socially
unacceptable. It is also difficult to manage within local communities
and it contributes to the "diversion" of prescribed
drugs onto the illicit street market which leads to increased
opportunities for "dealing".
6. Concern has been expressed by a number
of organisations representing both professional bodies and the
public relating to the threats about community safety from drug-related
crime and the level of availability of drugs to young people.
Spreading the service to drug misusers helps reduce this problem.
7. In recent years, more pharmacists have
expanded the range of services they offer to drug misusers including
needle exchange facilities and the supervised self administration
of Controlled Drugs and medication on the premises, which probably
helps reduce drugs available on the street.
THE EVIDENCE
8. Although it is not possible to measure
the exact extent of a covert activity such as drug misuse—the
following data indicates a rise in the number of drug misusers
and a growing provision of services to drug misusers through community
pharmacies.
— The number of NHS prescriptions for
methadone dispensed annually in the community in England rose
from 403,300 in 1991 to 891,000 in 1996.
— The number of NHS prescriptions for
methadone dispensed annually in Scotland rose from 64,500 in 1992
to 240,400 in 1999.
SECURITY OF
PHARMACIES
9. Managing this difficult problem and producing
an even spread of services to drug misusers will only be achieved
if pharmacists feel confident about the security and service/clinical
issues in providing such services. Such confidence will only be
a reality if there are substantial changes to the entire framework
surrounding the provision of services to drug misusers.
LEGAL FRAMEWORK
10. The main issues that need to be addressed
relate to:
Misuse of Drugs Regulations
Misuse of Drugs Act—harm minimisation
MISUSE OF
DRUGS REGULATIONS
11. Pharmacists providing services for drug
misusers are often placed in potentially confrontational situations
with clients as a result of:
— Prescriptions not satisfying legal
requirements
— Requests for collections by clients
representatives
— Dispensing for public and local holidays
12. The Society has requested the Home Office
and the Department of Health to set up a small multidisciplinary
group to review the current legal framework and allow pharmacists
to exercise professional judgement when dealing with trivial or
clerical errors or omissions in prescriptions for controlled drugs.
13. These points were accepted in the report
of an Independent Inquiry into the Misuse of Drugs Act chaired
by Dame Ruth Runciman (Paragraphs 38 and 39). The key areas relate
to:
(i) the rules for prescribers' handwriting
exemptions on controlled drugs prescriptions should be reviewed
by the Home Office.
(ii) pharmacists should be able to amend
instalment prescriptions after contacting the prescriber
(iii) the Misuse of Drugs Regulations relating
to instalment dispensing need updating and amendment of facilitate
action when a client fails to collect.
(iv) the Regulation should be amended to
allow an instalment scheduled for supply on a day when the pharmacy
will be closed to be supplied on the preceding day
(v) there should be a review of the legality
of dispensing prescriptions for methadone mixture where the client
asks for variation from the formulation prescribed
(vi) the maximum number of days' treatment
on any prescription for drug misusers should be 14 days
CONCLUSION
14. The RPSGB is fully aware of the importance
that pharmacists have to play in the control of substance misuse
and in providing support to drug misusers in the Community. However,
pharmacists and the public using pharmacies are increasingly becoming
vulnerable in attempting to provide a service to a growing number
of clients.
15. The Society therefore asks the support
of the Home Affairs Select Committee to press for the establishment
of a small multidisciplinary group to update the existing regulations
and enable pharmaceutical services to continue to support drug
misusers in the community within a more suitable framework.
16. The RPSG would be willing to provide
detailed oral evidence to the Committee and expand on these or
other key issues.
September 2001
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