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Letters to the Editor
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Controlled drugs
New CD regulations — advice please
From Mr F. Royle, MRPharmS and Miss J. Cram, MRPharmS
Recently, the regulations relating to prescriptions for Controlled Drugs
were changed, permitting pharmacists to make alterations to otherwise
legally valid prescriptions where technical information was missing.
We have some interesting points we would like to share with the wider
membership after we both, separately, received incomplete prescriptions
for schedule 2 CD medicines. Both the prescriptions in question required
the total quantity in words to be added, as permitted by the regulations.
The guidance provided by the Royal Pharmaceutical Society states that
the amendment made by the pharmacist must be “attributable to them”.
If a pharmacist alters a prescription and a balance is owed, or the stock
has to be ordered, how does another pharmacist know who has amended that
prescription, and is that pharmacist then obliged to make a supply?
If an alteration is made, and subsequently the patient chooses not to
have his or her prescription dispensed at that pharmacy, is the next
pharmacist who encounters the prescription obliged to dispense that prescription,
given that he or she would not necessarily know who had made the alteration?
A clearly attributable amendment would presumably include a name, registration
number and possibly even a contact telephone number and would take up
a great deal of space on a prescription if completed properly. Is this
practicable? What if the pharmacist who makes the amendment does not
make it attributable to them in a clear enough manner?
We would be interested to hear the advice of the Society’s law
and ethics department and of any other examples of a similar nature,
as we are sure the points we have raised are not exhaustive.
Finlay Royle
Julia Cram
Cardiff
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PRIYA SEJPAL, professional ethics pharmacist, Royal Pharmaceutical
Society, responds:
Following the changes to the Misuse of Drugs Regulations
2001,
as amended, pharmacists may make changes to CD prescriptions in certain
defined circumstances, where the prescriber’s intentions are
absolutely clear. (See PJ, 1 July, pp 25–9 (PDF 90K)
or the Society's website (PDF 200K)). The pharmacist must ensure that
the prescription is
marked so that
the amendment is
attributable to them. The Regulations do not specify exactly how the
prescription should
be marked. A pharmacist may write their name, registration number
or signature on the prescription, or could alternatively place an
asterisk
by the change
and place a footnote on the script. The Society is currently awaiting
further advice from the Home Office on issues surrounding technical
errors and a Law and Ethics Bulletin providing further guidance on
this will
be published in due course. |
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The
Pharmaceutical Journal