A suitable environment?


Hospital pharmacy group shares concerns about community pharmacy environment over downscheduling medicines – but the Guild says most pharmacies are properly equipped

The Society of Hospital Pharmacists of Australia (SHPA) has reiterated concerns to the TGA around what it describes as “the suitability of the retail environment of community pharmacies and their practices, to support appropriate supply and quality use of medicines”.

Its concerns were shared as part of a submission to the TGA’s consultation on proposed criteria for Appendix M to support rescheduling of medicines from Schedule 4 (S4) to Schedule 3 (S3).

Appendix M is intended to include substances that have formerly been scheduled as S4, but if rescheduled to S3 could be dispensed by a pharmacist with specific controls in place to guide appropriate use.

The PSA provided the TGA with a list of suggested priority substances for re-scheduling, after surveying which medicines its members believed were appropriate to consider for Appendix M.

These medicines included triptans, melatonin, ondansetron, oral contraceptive pills, trimethoprim, adapalene and sildenafil.

However SHPA said: “Given these medicines are currently S4 in recognition of their risk to the public if misused and the seriousness of the conditions which they treat, the community pharmacy environment needs to be meet consumer expectations of health service requirements to support the quality use of medicines.

“Many retail pharmacies do not have private consultation rooms, which are essential given some of the medicines presented to the TGA for pro-active down-scheduling are for urinary tract infections (UTIs) and erectile dysfunction (ED).”

The Pharmacy Guild responded that retail pharmacies are appropriately equipped to provide medicines such as those for UTIs and ED through the S3 Appendix M framework.

“Most modern Australian pharmacies have consultation rooms or private areas for any interaction with patients that require a more private environment,” said a spokesperson for the Guild.

“We believe around 60% of pharmacies currently have separate consultation rooms or areas, and this number is growing all the time.”

SHPA added that supply of certain Appendix M medicines could lead to potential equity issues.

“If the supply of certain Appendix M medicines hinges on the pharmacist undergoing specific training, issues around equity of access to trained pharmacists may arise,” it said.

“It would be important to consider the expectation of patients regarding access to these medicines from community pharmacies, particularly in rural and regional areas where some inequities in medicines access already exist.”

However the TGA responded that it is beyond the powers of the Poisons Standard to require all pharmacists to supply S3 Appendix M substances and thus complete training.

“It is expected that, as part of their initial deliberations, sponsors seeking to downschedule S4 goods to S3 with Appendix M conditions will conduct preliminary discussions with the pharmacy profession to gauge interest in the supply of these medicines as OTC products,” said the TGA.

“It is common for substances to be listed in more than one schedule in different forms, and this will remain an available option if a pharmacy did not have pharmacists trained in the supply of a class of S3 Appendix M medicines.”

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5 Comments

  1. Ron Batagol
    08/08/2019

    I share some of SHPA’s concerns. I think it’s important to separate and to understand the staged implementation process, from a national policy decision to move some potent medications to a schedule M, to the details and inbuilt checks and balances in implementing such a decision at a practical level. No matter what the Guild or others say, clearly additional training and guidelines and strict criteria are needed if pharmacists are to supply Medications such as Sildenafil or antibiotics for symptoms of UTI infection, since
    pharmacists, in whichever clinical environment they practice, are not fully trained in differential diagnosis. Thus, to avoid obvious potential risk management issues with medications such as antibiotics or Sildenafil, training and strict guidelines will, no doubt, need to be developed, (and, despite current “huffing and puffing turf war protestations”, no doubt will be), through professional consensus, prior to the new arrangements coming into effect, so that patients can benefit from the new changes in scheduling.

    • john gardiner
      08/08/2019

      Ron the same old arguments are rolled out. Hospital pharmacists are hardly in a position to complain. Remember the huge doses of Pethidine we gave out to one customer until you and I jacked up. A professor ordering 800 Mg of Tramadol with impunity. As commonly discussed in the beer halls of Munich as appropriate. I refused to dispense them.. The disgraceful usage of Endone 5 mg for any sort of discomfort etc. Most retail pharmacists are diligent in this legal climate. I think supermarkets selling NSAID s is far more of a potential problem

      • Pete Tzimos
        08/08/2019

        John you are and remain a gentleman of our profession. 🙂

      • Ron Batagol
        08/08/2019

        Hi John,
        Good to hear from you. But, in my comments, I said I agree with some of SHPA concerns.
        Specifically, I’ve no doubt that, since community pharmacies already carry out routine, sbd when required, discreet,counselling on many S3!s ( eg.emerg.contraception-ECPs), and, I believe they most , if not all, community pharmacies have private counselling areas.

        Specifically, my main focus was mainly on the (hopefully), agreed need for additional training to ensure that appropriate checks and balances, consistent with best quality practice occur, with UTI antibiotics and Sildenafil supply as has already occurred with ECPs. The only other issue I raised, related to the need for inter-professional collaboration on these changes instead of turf wars!

  2. Pete Tzimos
    08/08/2019

    The appropriateness of Appendix M notwithstanding – I find it a bit rich that the SHPA is criticising retail Pharmacy for their lack of private consulting areas….. I’d love to see the private consult rooms that you get in hospital Pharmacy – oh wait – there is none… It’s just a counter (usually with a glass partition so the Pharmacist has to loudly explain the directions to the patient collecting their meds) or at the patient’s bedside – where those curtains separating the beds in a 4-bed room have great soundproofing….

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