The Pharmaceutical Journal
Vol 269 No 7218 p482
5 October 2002

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Letters to the Editor

Controlled drugs

Are the funds and the workforce available?

From Mr I. G. Simpson, FRPharmS

I was pleased to read that primary care trust chief pharmacists and pharmaceutical advisers have been authorised to witness the destruction of Controlled Drugs (PJ, 21 September, p383).

In my previous post as a health authority pharmaceutical adviser, this was something which I did quite often under the authority previously issued by the Secretary of State,¹ and I regarded the work as an important contribution to pharmaceutical public health. Unfortunately, not all of my colleagues in health authorities around the country viewed the activity in the same light, and it remains to be seen what degree of priority our successors in PCTs will give to it.

Your news item states that PCT pharmacists have been given authority to witness the destruction of CDs in general practitioners' surgeries, and the Department of Health paper on which it is based² is entitled "Destruction of Controlled Drugs in GP practices". However, the letter of authority which accompanies the paper makes no reference to general practitioners' surgeries, or indeed to any other location. From this, I assume that PCT pharmacists may witness the destruction of CDs, wherever they may be located, as was the case for pharmacists acting under the 1997 authority.

I should like to raise a few points for discussion, based on my experience as a health authority pharmaceutical adviser until the end of last year.

The locations to which I was most frequently called to witness the destruction of Controlled Drugs were the hospital pharmacies of my local NHS trust. I know that EL(97)22 gave authority to chief executives of NHS trusts and senior officers in the trust responsible for health and safety, security or risk management, but none of these officers was ever available to carry out the work. Perhaps the NHS chief executive should be asked if he really expects trust chief executives to do this work, and how often he did it when he was a trust chief executive. If NHS trust chief executives do not regard it as a priority, will PCT pharmacists be called upon to witness the destruction of CDs in NHS trusts?

The second most frequent call on my time came from hospices that held stocks of CDs under the exemption granted to charities, or by Home Office licence. I combined this activity with inspections carried out under authority of the Registered Homes Act. This role has now been taken on by the National Care Standards Commission, but pharmacists employed by the Commission or contracted to it do not have authority to witness destruction. Will PCT pharmacists also be called to these locations?

I was required to witness the destruction of CDs in a GP surgery on only two occasions, and both of these were unusual situations. One situation was when a dispensing practice, which was run single-handedly, closed down, and the other was when there was a fire at a dispensing practice and most of the medicines were subjected to heat and smoke damage. Although I was received courteously on both occasions, it was made clear to me that I was there by invitation, and not because I had any right of entry. Will PCT pharmacists exercise their authority in GP surgeries only by invitation? If the emphasis on destruction in GP surgeries is meant to be an "anti-Shipman" measure, I would suggest that the responsibilities of GPs and PCT staff require further clarification. Otherwise, we risk the possibility of a PCT pharmacist or doctor being made a scapegoat, should another disaster involving the use of CDs occur.

Finally, I note that the new Department of Health paper² states that it is good practice to have the destruction of CDs returned by patients witnessed by an authorised person. This advice differs from that given by the Royal Pharmaceutical Society,³ which states that the destruction of CDs returned by a patient should be witnessed by a member of staff. If the DoH advice is to be followed, it will lead to storage and logistical problems in both hospital and community pharmacies, and a considerable increase in the workload of authorised persons. If the brunt of this work is to fall on PCT pharmacists, one must query if there is the workforce available to do it, and how it is to be funded.

Ian G. Simpson
Old Marston, Oxford

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