Correspondence

ACMD advice on the interim podiatrists supply proposal from NHS England (accessible version)

Published 14 June 2022

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From: ACMD Chair: Prof Owen Bowden-Jones
ACMD Secretary: Zahi Sulaiman

1st Floor (NE), Peel Building
2 Marsham Street
London
SW1P 4DF

[email protected]

To: Kit Malthouse MP
Minister of State for Crime Reduction and Policing

2 Marsham Street
London
SW1P 4DF

14 June 2022

Dear Minister

RE: ACMD Advice on the Interim Proposal From NHS-England to Enable Podiatrists to Supply Co-codamol, Co-dydramol and Codeine Phosphate

The Advisory Council on the Misuse of Drugs (ACMD) has considered an interim proposal from NHS-England which would enable advanced clinical practitioner podiatrists to continue to supply co-codamol (8/500, 15/500 and 30/500), co-dydramol 10/500 and codeine phosphate.

The Misuse of Drugs Regulations 2001 were not amended when the Human Medicines Regulations (HMR) were created in 2012, which has led to an anomaly in respect of supply of codeine products by podiatrists whereby co-codamol, co-dydramol and codeine phosphate are included on the exemption list in the HMR and podiatrists continue to supply these medicines via exemptions.

This interim proposal completes the legislative framework for co-codamol, co-dydramol and codeine phosphate products to continue to be supplied in accordance with the exemptions mechanism in the HMR. A future separate longer-term proposal will require further amendment to the Misuse of Drugs Regulations to allow independent prescribing of these medicines by podiatrists.

The Royal College of Podiatry have confirmed to NHS-England that they are unaware of any issues with the supply of these medicines reported by its Fellows relating to the use of the above drugs in surgical practice.

  • Recommendation: As there is potential for misuse with long-term use of co-codamol, codeine phosphate and co-dydramol products, the ACMD supports restricting the duration of supply using the proposed interim mechanism to no more than three days as recommended by current Royal College of Podiatry guidance. [footnote 1]
  • Intended target: Home Office and DHSC
  • Measure of implementation: Change to the Misuse of Drugs Regulations 2001

  • Recommendation: The ACMD’s Technical Committee will consider the longer-term proposal in full following the outcome of a public consultation by NHS-England, for co-codamol, co-dydramol and codeine phosphate products to be added to the controlled drugs list that podiatrists may prescribe within the Misuse of Drugs Regulations 2001.
  • Intended target: Home Office and DHSC
  • Measure of implementation: Future change to the Misuse of Drugs Regulations 2001

Yours sincerely,

Professor Owen Bowden-Jones, Chair of the ACMD
Professor Roger Knaggs, Chair of the ACMD Technical Committee

  1. www.rpharms.com ↩

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