The consultation includes proposals to amend the Misuse of Drugs Regulations 2001 such as to enable pharmacists and nurses to possess and then to supply and administer the drugs morphine and diamorphine under PGDs to treat sick and injured people under identified clinical situations. There is also a proposal to remove current restrictions on the location where the supply and administration under PGD of diamorphine can take place, in effect allowing the supply and administration of diamorphine and morphine under PGD to be made in any suitable location.
Rationale for proposal
The training to become a pharmacist involves four years of full time education coupled with a full year of further training providing the necessary backbone of knowledge required by a healthcare professional to take on the clinical roles which pharmacists are increasingly undertaking. In the last few years, pharmacists have been involved in blood pressure, diabetes and cholesterol testing, as well smoking cessation and asthma management services all of which have been very successful enterprises.
The expanding roles of pharmacists and nurses have resulted in them being heavily involved in PGDs covering a wide range of clinical conditions with a range of prescription only medication. For pharmacists, these have ranged from PGDs for emergency hormonal contraception, influenza vaccination, weight loss programmes using orlistat to PGDs for sexually transmitted disease treatment such as chlamydia. To date no negative feedback about the provision of these services under PGD by pharmacists has emerged.
Furthermore the NPA agree with the consultation document that the safeguards currently in place with reference to PGDs are appropriate and more than sufficient to ensure that controlled drugs would be used safely, correctly and effectively with little risk of misuse or diversion by healthcare professionals with the correct skills.
The PGD scheme requires the active approval of three parties; a senior doctor, a senior pharmacist and the organisation it is to be used within. This would normally be the NHS Trust or the PCT and in the independent sector, the independent hospital or clinic. This effectively ensures that PGDs will only be approved when there is an advantage to patient care without compromising either patient safety or compliance with Department of Health guidance that the majority of patient care should be on an individual patient specific basis.
The NPA supports the proposals and believe that the proposals fulfil a common sense approach to dealing with the current situation. Factors such as the historical shortage of diamorphine coupled with the clinical requirement for diamorphine or morphine for pain relief, the trend towards the provision of healthcare services in community rather than a hospital setting, and enhanced roles for both pharmacists and nurses, (all of which is robustly explained in the consultation document) will be dealt with effectively by the proposals.
The control and management of pain is certainly an area where it is correct and proper for both pharmacists and nurses to play a prominent role. Pain is not acceptable in our society and is a symptom that we have a vast array of medicines at our disposal to treat. Both diamorphine and morphine are important drugs for controlling pain and it would benefit patients to have other avenues open to them should they require pain relief when conventional channels are not available. PGDs for pharmacists and nurses to administer diamorphine and morphine can meet this need under certain clinical circumstances.
As a result of this, the NPA would support the proposals to enable both pharmacists and nurses to possess, supply and administer diamorphine and morphine under PGD, the removal of restrictions on where this supply or administration could take place, and the enabling of both diarmorphine and morphine to be supplied under PGD for the immediate treatment of sick or injured persons.
Further proposals
Furthermore, the NPA would welcome further proposals to expand the range of controlled drugs which are allowed under PGD for pain relief beyond morphine and diamorphine to include other suitable drugs such as transdermal buprenorphine, fentanyl and oral or injectable forms of oxycodone. We believe that uncontrolled pain is unacceptable when there are a wide range of treatment options available and yet there continues to be problems for many patients with treatment of both acute and chronic pain. Appropriate PGDs for specified clinical conditions could help address these problems.
Proposal to expand the use of PGDs in the independent healthcare sector in Northern Ireland
The NPA support the proposal to expand the use of PGDs in the independent healthcare sector in Northern Ireland. PGDs in the independent sector have been used safely and successfully in the rest of the United Kingdom with a range of medicines and indications including flu vaccine provision, chlamydia testing and treatment, and weight loss with orlistat. In addition to promoting consistency in healthcare provision throughout the United Kingdom, the beneficial effect on workload and expenditure by publicly funded services would result in real benefits to patients and public healthcare systems.
1. National Prescribing Centre – Patient Group Directions March 2004
