Using PGDs in occupational health services (OHS)

Considerations when using PGDs

The need for a PGD in an NHS or Local Authority (LA) occupational health service (OHS) needs to be carefully considered, especially as NICE guidance (MPG 2 2017) recommends that PGDs should not be used where they are not required, irrespective of care setting. The Human Medicines Regulations (HMR) 2012 provides a legal framework with alternative exemptions in Schedule 17, specifically for the delivery of an OHS.

For example, PGDs should not be used for vaccination provision within any OHS due to the HMR 2012 Schedule 17 exemption for occupational health vaccinators (further information is available in Seasonal influenza vaccination and occupational health services (SPS page)).

PGD use may be appropriate if it offers a benefit to service delivery, such as provision of medicines, other than vaccinations, by healthcare practitioners other than nurses who may legally operate under a PGD.  However, as detailed below they can only be used for in-house OHS provision.

PGDs in NHS OHS

Under the HMR 2012, NHS bodies and local authorities are exempt from the restrictions that apply to the supply of prescription only medicines, where they are supplied or administered in accordance with a PGD.

In-house OHS

If an organisation’s OHS for their own staff is being provided by a doctor or registered nurse acting in accordance with the written instructions of a doctor, written instructions can be used and should be considered in preference to PGDs.

NHS/LA in-house OHS services can use PGDs to provide OHS services to their own staff, including staff who are contracted to work for the organisation, where it has been locally determined that a written instruction does not adequately meet the needs of the service.  This should only be considered for the provision of medicines, other than vaccinations, by healthcare practitioners other than nurses who may legally operate under a PGD.

It would be the responsibility of the NHS or LA organisation to develop and authorise any PGD in accordance with HMR 2012

PGDs in independent provider OHS

Private services include those provided by independent healthcare providers. NHS and non-NHS publicly funded OHS who provide OHS to external organisations are also acting in a private capacity.

Services can only use PGDs when they are registered with the CQC to provide one or more regulated activities, in compliance with section 10 of the Health and Social Care Act 2008. OHS are not a regulated activity and as such are not registered with the CQC. This means that PGDs cannot be used for private provision of OHS. This is also the case when an NHS or other publicly funded body provides OHS to another organisation, be it private or publicly funded, as the OHS is being provided as a private service.

Private OHS services for the supply or administration of medicines other than vaccinations can only be provided by a suitably trained and competent person acting under the instructions (i.e. PSD or prescription) of a doctor, independent prescriber or by a registered nurse working in line with the legal exemptions afforded to OHS in the HMR 2012 (i.e. a written instruction (SPS page)). This OHS exemption cannot be used by professions other than registered nurses and the written instruction must be signed by an OHS doctor.

Private OHS services for the supply or administration of vaccinations can only be provided by a suitably trained and competent person acting under the instructions (i.e. PSD or prescription) of a doctor, independent prescriber or by an Occupational Health Vaccinator working under a Written Instruction as permitted within the legal exemptions afforded to OHS in the HMR 2012.  This OHS exemption cannot be used by professions other than those listed in Schedule 16 Part 4 of the HMR 2012 and the written instruction must be signed by an OHS doctor.

Further resources

For more information please refer to Legal mechanisms to supply and administer medicines to individuals (SPS page)

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