Local arrangements can be made to allow health and care professionals who are not prescribers to supply or administer medicines
The different methods or “mechanisms” that enable this are:
- Rights reserved for emergencies
- Patient specific directions (PSDs)
- Patient group directions (PGDs)
- Occupational Health Schemes
- Legal exemptions
These mechanisms are not the same as prescribing.
Registrants must have the proper skills, knowledge and experience before acting under any mechanism and should follow policies set by their employer.
Some registrants will gain this experience through their pre-registration education and training. This will be reflected in the standards of proficiency for that profession. For others, this will need to be through continuing professional development (CPD) or post-registration training provided by their employer.
Registrants also need to ensure their professional indemnity arrangement covers them to use these mechanisms.
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The law allows certain medicines to be administered by injection in an emergency, in order to save a life. This exemption applies to anyone, regardless of their profession.
A list of medicines subject to this exemption can be found in Schedule 19 of the Human Medicines Regulation 2012.
If your employer has policies or procedures around this exemption, we expect you to follow them.
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This is a signed and written instruction by a prescriber to another professional to supply/administer medicine to a named person. The person must have been individually assessed by the prescriber.
This instruction may be written in a service user's notes or, in a hospital, on their medicine chart. A PSD can be for a list of named service users who have been individually assessed. A PSD for supply of medicines is a prescription form.
Any professional can do this, provided they have the skills, knowledge and experience to do so and are under the instruction of a prescriber.
Further information on PSDs can be found on the NHS Specialist Pharmacy Service website. -
This is a written instruction for the supply/administration of medicines to a group of service users by a named health professional. PGDs can be useful in routine care pathways such as immunisation programmes.
A PGD must be authorised by a health authority, special health authority, NHS trust/foundation trust or primary care trust. Only certain professions can administer under PGDs.
When supplying and/or administering a medicine under a PGD, registrants must follow local organisational policies.
Before practising under a PGD, healthcare professionals should ensure that they have undertaken the necessary training. They must also have been assessed as competent and authorised to practice by the provider organisation.
Read NICE guidance for developing, authorising, using and updating PGDs
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This is a scheme in which a person provides facilities for employees for the treatment and prevention of disease, such as the deployment of a vaccine.
Schedule 17 of The Human Medicines Regulations 2012 provides specific exemptions for occupational health schemes from some of the restrictions that apply to prescription only medicines. This allows prescription only medicines to be supplied or administered by certain professions acting in accordance with the written and signed instruction of a doctor. These include ODPs, paramedics and physiotherapists, following recent changes in the law preparing for the deployment of a COVID-19 vaccine.
Learn more about occupational health schemes the NHS Specialist Pharmacy Service guidance.
Exemptions
Exemptions are exceptions to the general rules on selling, supplying and/or administering medicines for some groups of healthcare professionals.
Chiropodist / Podiatrists, Orthoptists and Paramedics all have exemptions which allow them to sell, supply and / or administer certain medicines in particular scenarios.
A chiropodist / podiatrist may sell, supply and administer certain medicines in the course of their professional practice.
To do so, they must have successfully completed approved education and training in these areas and have the relevant annotation(s) (marks) on our Register.
Medicines
A list of medicines included in this exemption is available on the MHRA website.
Annotations
- Prescription only medicines – administration (POM-A)
Allows registrants to administer certain prescription only medicines. They cannot mix medicines and must use pre-combined preparations if required.
- Prescription only medicines – sale / supply (POM-S)
Allows registrants to sell and supply certain prescription only medicines, pharmacy medicines and all General Sale List medicines.
These annotations were renamed in 2016 and were previously called 'local anaesthetics' and 'prescription only medicines’.
An orthoptist may sell and supply certain medicines in the course of their professional practice.
They must have successfully completed approved education and training in this area and have an annotation (mark) on our Register.
Medicines
Trained and annotated orthoptists may sell all pharmacy medicines, all General Sale List and the following prescription only medicines in the form of eye drops and ointments for topical use:
- Atropine
- Cyclopentolate
- Tropicamide
- Lidocaine with fluorescein
- Oxybuprocaine
- Proxymetacaine
- Tetracaine
- Chloramphenicol
- Fusidic acid
Annotation
- Prescription only medicines – sale / supply (POM-S)
Standards
Orthoptists with this training must abide by our Standards for orthoptists using exemptions in legislation for the sale and supply of medicines.
A paramedic may administer certain medicines by injection on their own initiative for the immediate, necessary treatment of sick or injured people.
All paramedics are trained to administer medicines under this exemption.
Medicines
A list of medicines included in this exemption is available on the MHRA website.
Annotation
We do not annotate our Register in relation to this exemption, as all paramedics on our Register are trained in this area.
Guidance