Non Prescription Supply of Medicines 1 Flashcards
How can you supply medication without a prescription?
- emergency supply
- Pandemic exemptions
- wholesale dealing (restricted list of people - not directly to patients)
- PGD
- Signed orders (Restricted list of orders, not directly to patients)
Pandemic Exemptions
- in the event of a pandemic, emergency supply is relaxed
- under certain situations medicine can be collected from designated collection points, which doesn’t have to be a registered pharmacy or take place under the provision of a pharmacist
Wholesale Dealing Definition
Selling or supplying, or procuring or holding or exporting medicines to a person who intends to:
- Sell or supply to anyone other than a member of public.
- Administer it or cause it to be administered to one or more human beings
A person making sales by way of wholesale dealing must possess a wholesale dealers licence
Wholesale Dealers Licence
WDA not necessary for
- Activities of a group of retailers or practitioners who buy medicinal products in bulk and divide the stock amongst themselves e.g. transfer of stock between pharmacy premises that belong to same legal entity.
- Holders of a manufacturers licence don’t require WDA to sell their own products
- Certain supplies of med by pharmacies
WDA does not authorise the distribution of medicinal products by way of wholesale dealing unless a marketing authorisation is in force in respect of the product
What does WDA(H) mean for pharmacists?
- pharmacists who engage in commercial trading (including export) of meds, not solely as part of their professional practice, can only do so if they have WDA(H)
- of wholesale dealing includes CD2-5, then will also need a home office CD licence to legalise the supply
What about supplying to other pharmacies and healthcare providers?
MHRA interpretation: community and hospital pharmacies supplying to other UK healthcare providers who need to holds all quantities of meds for treatment or onward supply to their patients is not considered a commercial dealing and WDA(H) not required
- This includes when community and hospital pharmacies may need to obtain small quantities of medicines from other pharmacies, however they must meet the criteria in order not to need a WDA
What is following criteria for not needing WDA(H) when community and hospital pharmacies need small quantities of medicines from other pharmacies?
- on occasional basis
- quantity of supply is small
- not for profit
- supply is not onward wholesale distribution
- medicines are needed to fulfil and individual patients needs
- dont need to label product when wholesale dealing
MHRA and no WDA(H)
- MHRA not stated what quantity of med to supply before a WDA is required
- mostly has to do with the purpose of the transaction (a clear distinction from supplying to meet healthcare needs vs a commercial trade)
- for non holders of WDA, pharmacists need to have received an order/invoice for the supply and record of supply made, preferable im POM register and keeping order and invoice
Pharmacy-Pharmacy transaction requirements
- Pharmacist must be satisfied that the supply to another pharmacy is for the individual needs of the patient
- Price of med should be recorded, show reasonable price and that it was not for purpose of profit
- Additional costs should be stated and explained. Reasonable costs include administration costs, holding stock, delivery
Applying for licenses
Application for WDA
- Sent to the process licensing section of the MHRA
- Fee for an initial licence, along with a fee for any inspection that is carried out
- Initial licence is continuous
Home office CD license
- Apply directly to home office
- There is a fee
- Licenses are only issued for one year
Requirements of WDA(H) Holder
1) Ensure continued supply of med products
2) Keep documents to facilitate withdrawal or recall, maintain an emergency plan for this purpose
3) keep records of receipt and dispatch
- Date of dispatch
- Name of products
- Quantity received or dispatched
- Name and address of the person from whom, or to whom, the products are sold or supplied
4) distribute only to persons who may lawfully sell by retail or lawfully administer those products
5) Have a suitably experienced responsible person
Who can you wholesale deal to?
- the range of persons and organisations that a pharmacist can wholesale to is controlled by legislation and may also be trusted to certain meds for certain purposes
- eg other wholesale dealers. doctors, dentists, any person lawfully conducting a retail pharmacy business, clinics or independent medical agencies
- doesnt include non-medical prescribers
Supply of salbutamol inhalers to schools
- legislation that enables schools to hold stocks of salbutamol inhalers, which can be supplied in an emergency by persons trained to administer them
- number of inhalers not specified, however can obtain from pharmacies and provided it small quantities and doesn’t constitute to wholesaling
- need to get a signed order from head teacher
- pharmacist may need to explain how to use the inhaler or advise on selection and use of appropriate spacer devices
Adrenaline injectors in schools
- Schools are able to buy AAI devices without a prescription for children who are at risk of anaphylaxis and don’t have device or where device isn’t working
- Should only be used on pupils known to be at risk of anaphylaxis, from whom both MA and written consent for use of spare AAI has been provided
- Any AAI in school for child considered back-up and not a replacement of child own device
- Need to verify brand and strength of AAI (as have different administration instructions)
Signed orders/ Written requisitions
- Communication between a purchaser and a pharmacist to request a medication to be used within that purchaser’s practice
- HMR 2012 states which persons or organisations must provide a written signed order/invoice e.g., optometrists
- Others having a signed order is not outlined but its just good practice
- Be wary of how many pack sizes are being transferred to another pharmacy and the frequency this as this may be seen as wholesale dealing