Today’s correspondent says:
Given that you have declared your imminent retirement from blogging, I too have a question to put to you:
I am a doctor and volunteer with an emergency service in WA. From time to time I find myself in a situations where I would like to be able to provide additional medication to what is provided for volunteers in my organisation, These medications might include S4 and S8 drugs, e.g. ondansetron or morphine.
Putting aside questions about scope of practice and organisational policy, as I feel that you have covered this well in the past (e.g. Doctor as volunteer Life Saver and scope of practice), and assume that the organisation itself does not hold these drugs for my use (which I assume would not pose an issue, but might not be practical to meet the whims of a single doctor). I’m interested to know if I am legally allowed to purchase, carry, and administer these medications in my personal capacity as a doctor.
I read your reply to a similar question from a doctor in Victoria (Doctors carrying drugs in Victoria), but I’m curious if these matters vary state-to-state and particularly in WA, or are uniform across the nation. I’ve seen some references to “doctor’s bag” in WA Department of Health guidelines around schedule drug storage, but these talk about the bag being “left at the surgery” and seem targeted at GPs doing home visits.
Section 25 of the Medicines and Poisons Act 2014 (WA) says:
(1) A health professional acting in the lawful practice of his or her profession is authorised to administer, possess, prescribe, supply or use a medicine if —
(a) the health professional is a member of a class of health professional prescribed by the regulations; and
(b) the medicine is prescribed by the regulations as one that may be administered, possessed, prescribed, supplied or used by a member of that class of health professional; and
(c) the administration, possession, prescription, supply or use of the medicine is in accordance with the regulations.
(2) Regulations referred to in subsection (1) may make provision in relation to the circumstances and manner in which, and the conditions on which, a member of a prescribed class of health professional may administer, possess, prescribe, supply or use a medicine.
Medical practitioners are a relevant class of health professional (Medicines and Poisons Regulation 2016 (WA) r 50) and they are authorised administer, possess, prescribe or supply any schedule 4 or 8 drug and supply any schedule 2 or 3 drug (r 51).
It follows that as a registered medical practitioner you are entitled to ‘administer, possess, prescribe, supply or use’ any schedule 4 or 8 medicine if that is relevant to your practice. It is up to you to decide what is your practice and to ensure that you have the necessary skills and knowledge to safely prescribe those drugs. It would also be up to you to make sure you comply with the other regulatory requirements such as the Medicines and Poisons Regulation 2016 (WA) Part 11 (with respect to sch 8 drugs) and the relevant laws on storage and security for restricted drugs.
As for the ‘doctor’s bag’ I’m not sure what guidelines you are referring to but I see for example that ‘Australian Prescriber’ has a page on the doctor’s bag – see https://www.nps.org.au/australian-prescriber/articles/drugs-for-the-doctors-bag-3 but that is a guide to assist doctors to decide what to carry, not any regulatory provision. They say
The choice of drugs depends on several factors including the practice location, conditions likely to be met, the shelf-life and climatic vulnerability of the various drugs (e.g. antibiotics, vaccines), and the design and size of the bag.
Pharmacists may also supply prescription medicines to an authorised health practitioner, in quantities reasonable for that purpose (such as doctors bag supplies), on receipt of a valid requisition to supply.
These references reinforce my conclusion that it’s ‘your call’ what drugs you carry taking into account what is your practice (and “[p]utting aside questions about scope of practice and organisational policy” and issues of your own professional indemnity insurance as opposed to the organisations insurance policy).