Should all S2 and S3 medicines to be kept behind the counter, with a completely separate area for CMs? And who supports this proposition?
Recently the Review of Pharmacy Remuneration and Regulation released its interim report, and submissions to the report have begun flowing in over the past few weeks.
One contentious suggestion by the review panel was to have all S2s behind the counter with S3s, while complementary medicines (CMs) would not be allowed behind the counter but would be required to be placed in a clearly separated area of the store (see Options 3-2 and 3-3).
“The Panel notes that, whereas the supply of Pharmacist Only and Prescription Only medicines in community pharmacies must be from behind the counter and involve interaction with a pharmacist, Pharmacy Only medicines may not be provided with consistent recourse to professional advice when this would be of benefit to the consumer,” it says in the interim report.
“When the availability of this advice is not obvious, there would appear to be little from a consumer’s perspective to distinguish the availability of Pharmacy Only medicines from unscheduled medicines, including complementary medicines otherwise available from supermarkets, groceries or convenience stores.
“Regarding the supply of complementary medicines in community pharmacy, the Panel sees further benefit in clearly separating access to Pharmacy Only and Pharmacist Only (Schedule 2 and Schedule 3) medicines from complementary medicines so that, from the consumer’s perspective, the potential health benefits and risks associated with use of these products are clear,” the panel suggests.
Some groups have agreed wholeheartedly with the Review Panel’s suggestions.
For example, the Consumers Health Forum of Australia says that it supports Option 3-2 which requires pharmacies to have CM products in a clearly separated area of the store, “as this would help minimise confusion with over-the-counter medicines”.
“We also support Option 3-3 which precludes complementary medicines being behind the counter”, says the CHF.
“Their placement behind the counter is misleading as it makes consumers think they are the same as S2 and S3 medicines which have had to satisfy a higher level of evidence on efficacy.”
A question of feasibility
PSA says that while it agrees with the principle behind option 3-3, there is a question of feasibility.
“The placement and location of Pharmacy Only (Schedule 2) and Pharmacist Only (Schedule 3) [medicines] is regulated by State and Territory poisons legislations,” says the PSA.
“Feedback from PSA members indicates that the solution proposed in Part B of this option would be contentious and challenging to implement in a nationally consistent approach.”
It says some members have also indicated that they specifically stock CMs behind the counter and out of reach of the consumer, in order to prompt intervention by the pharmacist.
PSA calls for the development of a structured consultation framework for providing information related to S2, S3 and complementary medicines.
While Schedule 3 medicines are stored out of reach of the public, the inclusion of Schedule 2 medicines ‘behind the counter’ could necessitate significant structural changes in many pharmacies, says AHPRA.
“Appropriate placement of scheduled an unscheduled medicines including complementary and alternative medicines can facilitate engagement between consumers and pharmacists or trained pharmacy staff,” it says, reminding of the importance of ensuring that both potential health benefits and risks associated with use of these products is clear.
The Pharmacy Guild has argued the case for pharmacists to continue to sell complementary medicines.
However it reminds the panel that pharmacists are reliant on the TGA and its role to ensure all medicines are safe for public consumption.
It doesn’t specify a particular approach regarding placement of the medicines, except to say that its firm position is that “the sale of CMs from community pharmacies is not only appropriate, but essential to ensure the use of these medicines is consistent with the National Medicines Policy”.
Call for a national approach
Others agree with the issue of feasibility, but are calling for the implementation of a nationally consistent approach.
Professional Pharmacists Australia (PPA) acknowledges that there are variations between states on storage requirements, with some states requiring both S3 and S2 being stored behind the counter, while others allow S2 medicines stored away from the counter but in a position that enables supervision by the pharmacist.
“There is a need for harmonisation of the laws pertaining to supply and storages of these medicines,” writes PPA CEO Chris Walton on behalf of the organisation.
“Pharmacists are legally required to be involved in the sale of Schedule 3 medicines and be available for consultation with Schedule 2 medicines,” he says, adding that the PPA supports both Option 3-3 and Option 3-4 of the interim report.
Dispute over the options
“The option suggested by the Panel to require that complementary medicines not be displayed behind the counter in community pharmacy presumably stems from the misapprehension that this is done to create a pseudo-registration for such products … This is not the case,” Complementary Medicines Australia (CMA) has written to the Review Panel.
CMA argues that complementary medicines differ from other medicines in that the ingredients may have multiple actions, and consequently there are a number of medicines that healthcare professionals can use on a case-by-case basis.
It calls for a differentiation between practitioner-only products (which require consultation with a healthcare professional at the time of dispensing) and non-practitioner-only products.
Chemist Warehouse/My Chemist Group also does not believe in the separation of complementary medicines from S2 medicines.
“It is possible to display most complimentary[sic] medicines in a separate area away from scheduled medicines however for various reasons this will not be the case for all complimentary[sic] medicines,” writes group commercial manager Damien Gance, who poses several questions to the panel.
“If a product’s classification is unclear, which government agency is to be empowered to determine the classification and hence where a product can and cannot be displayed? Who will be charged with policing and enforcing compliance to this merchandising standard?” the discount retail pharmacy chain asks.
“Does the benefit to the consumer of product segregation justify all this administrative, legal and compliance expense? Chemist Warehouse does not believe so.
“Product scheduling clearly delineates scheduled medicines from complimentary[sic] medicine, if there is a failing in understanding … the failing is simply that consumers are not adequately and fully informed about the existing laws and what they mean.
“Public education would not simply be a more practical solution but in the long run would be a more economical one too,” write Mr Gance.
Government intervention in how and where complementary products are displayed in a retail pharmacy should not be an area of concern for the government or the panel, he adds.