Select Committee on Home Affairs Memoranda


Submitted by 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.


  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 However, the current out of date regulations compound the problems of managing the provision of these services to an often demanding cohort of patients.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.


  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.


  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.


  10.  The main issues that need to be addressed relate to:

    Misuse of Drugs Regulations

    NHS Regulations

    Misuse of Drugs Act—harm minimisation


  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

    —  Instalment dispensing

    —  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


  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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