I dispute that this is a correct interpretation of the Human Medicines Regulations 2012, as if this were the case there would be limited need for the exemptions in Part 12 Chapter 3 - for instance why do other healthcare services bother using Patient Group Directions for administration of non-parenteral POMs if a local protocol would do?
So I refreshed my memory of the HMR and gave it some thought. Here is my understanding of the Regs.
Provision 214 states:
(1) A person may not sell or supply a prescription only medicine except in accordance with a prescription given by an appropriate practitioner.
(2) A person may not parenterally administer (otherwise than to himself or herself) a prescription only medicine unless the person is -
(a) an appropriate practitioner other than an EEA health professional; or
(b) acting in accordance with the directions of such an appropriate practitioner.
- From 214-2 it can be deduced that a person MAY administer a non-parenteral POM without being either an appropriate practitioner or acting in accordance with the directions of one.
- Sale, supply and administer are three distinct activities, defined in the Regs.
- A person could administer a POM to a patient, with no additional authority, providing the patient legally possessed the POM.
- If the patient didn't possess the POM, the person would need to SUPPLY the POM to the patient prior to administering it. Supply is not permitted under 214-1.