FREQUENTLY ASKED QUESTIONS ON MANDATORY RECORDING OF P MEDICINES FOR PHARMACISTS
Mandatory recording
Q: In what format should recording be done (eg in a book, electronic form)?
A: HSA does not mandate the format of recording as long as the fields are recorded and there is a system to retrieve the information for audit purposes.
Q: How long do these records have to be kept?
A: These records should be kept for 2 years from date of sale or supply.
Q: Do I have to record concomitant medicines that the patient claims to be taking as well as drug allergies/other medical conditions?
A: Although these fields are not mandatory, recording such information is encouraged as part of good pharmacy practice.
Q: For P medicines which are combination products e.g. cough syrups with antihistamines, or medicines where there is only 1 strength available, is the 'strength' field mandatory?
A: If the name of the medicine is recorded such that it clearly differentiates it from other medicines in the same range with different strengths/active ingredients, or if there is only one available strength of the medicine, the 'strength' field may not be applicable and pharmacists should exercise discretion in filling this field for such products.
Q: How about P medicines without a specific administered dose, e.g. shampoos, lotions, creams?
A: The 'Dose field' may not be applicable and pharmacists should exercise discretion in filling up the 'Dose' field for such products.
Q: Do I have to conduct double recording for codeine preparations?
A: Pharmacies are expected to maintain sale and supply records of codeine cough preparations, in a format according to Rule 17 of Poisons Rules. Double recording is not required if the recording satisfies both requirements.
Q: What if the customer is purchasing P medicines on behalf of the person taking the medicine?
In such instances, the particulars of the purchaser may be recorded instead of the person taking the P medicine if the particulars of the latter are not available. Pharmacists should document that the purchaser is not the patient taking the medicine as well as the relevant information (e.g. name of actual patient) that can be gathered during counselling at the point of supply.
Q: How about oral dental gums?
A: The current recording requirement for chewing gums remains unchanged and is not affected by the new requirements.
Q: Where can the information regarding recording of P-medicine be found?
A: Information regarding mandatory recording is available on the HSA Reclassified Medicines website. Other information regarding P medicines can also be found on this website.
POMs with exemptions for limited sale and supply without a prescription
Q: If the maximum supply for a liquid preparation administered is less than the minimum available pack size, do I have to pour out the exact amount required?
A: The minimum available pack size may still be dispensed with the pharmacist providing the necessary counselling to ensure that medical advice is sought after the maximum duration of treatment if symptoms persist.
Q: Do I dose ibuprofen to children by weight or age?
A: The exemptions of maximum dose for the liquid ibuprofen preparation are in accordance to the age-based dosing regimen approved for the innovator product. This information would be appropriate for a product for self-treatment of the specified indications. The pharmacist should exercise professional judgement when recommending a dose according to weight and document the supply in the dispensing records accordingly.
Q: Is it mandatory for PILs to be given out with the supply of P-medicines and would the process be audited?
A: Pharmacists are encouraged to supply PILs with P-medicines, especially for first-time users. More information on the PILs can be found on HSA Reclassified Medicines website.
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