Our Proposed Alteration of PSI Guidelines

The Pharmaceutical Society of Ireland (PSI) are in control of drafting guidelines regarding the provision of NorLevo (the only emergency contraception available over the counter) by pharmacists in Ireland, and did so in 2011. These guidelines were updated in 2015, but little has changed. We feel that something is missing from these guidelines. Our voices and real-life experiences need to be heard. After all, it concerns us, and only us. Here at Re(al)-Productive Health we believe in taking action into our own hands. We strongly believe in sustained criticism of the current state of affairs regarding reproductive and sexual health and rights, but we also believe in offering clearly defined alternatives.

Below you will find our vision of alternative guidelines regarding the provision of emergency hormonal contraception in pharmacies. We have taken the guidelines and altered them in a way in which we believe reproductive and sexual rights can be enforced and protected. We have also proposed additions to the guidelines. We feel such alteration of the guidelines, in a structured and winnable way, open the possibilities for tangible and relatively rapid change. But these guidelines may only represent our particular perspective. For this reason we want you to let us know your thoughts on how such change can happen. If you think we should change something, if we’ve left something out or if you feel we could add something, please drop us an e-mail. We want to hear your voices.

Our Proposed Alteration of PSI Guidelines

Please find below our alterations to different sections of the PSI Guidance. Not all sections of the guidance are included here – only those we feel should be altered. The original PSI Guidance is in orange type, and our proposed alterations are in black.

Introduction 

Due to the nature of these medicines and associated patient counselling requirements, a private consultation between the pharmacist and the individual patient herself is required to determine the appropriateness of the supply and provide an opportunity to meet the appropriate patient counselling requirements. This consultation should take place in the pharmacy’s patient consultation area.

Due to the nature of these medicines and associated patient counselling requirements, a private consultation between the pharmacist and the individual patient themself to determine the appropriateness of the supply and provide an opportunity to meet the appropriate patient counselling requirements should be provided upon request of the patient. All patients, however, should be provided with necessary information regarding the contraindications, effects, and usage of the drug. This consultation may take place in the pharmacy’s patient consultation or in the main area of the pharmacy, depending on the wishes of the patient.

Guidelines

1. Supply by a pharmacist of Norlevo® 1.5mg tablets

a) The supply of Levonorgestrel 1500mcg tablets should only be made personally by a pharmacist following a structured, documented consultation with the patient. Each time this medicine is supplied the pharmacist must be satisfied that, in the exercise of his or her professional judgment, the supply of such a medicine is safe and appropriate for the individual patient.

The supply of Norlevo® 1.5mg tablets should include the provision of an optional consultation (on the basis of request by the patient) with the patient. Each time this medicine is supplied the pharmacist must be satisfied that the patient has received all the necessary information, in the exercise of his or her professional judgment, regarding the safety and appropriateness of the drug for the individual patient.

1. b)  Consultations between the pharmacist and the patient should take place in the pharmacy’s patient consultation area and due consideration must be given to the patient’s right to privacy and confidentiality. All requests for this medicine should be handled sensitively.

Such optional consultations between the pharmacist and the patient should either take place in the pharmacy’s patient consultation area, or in the main area of the pharmacy, depending on the wishes of the patient, with due consideration given to the patient’s right to privacy and confidentiality. All requests for this medicine should be handled sensitively.

3. Code of Conduct for Pharmacists

Principle One of the Code of Conduct for pharmacists states that the practice by a pharmacist of his/her profession must be directed toward maintaining and improving the health, wellbeing, care and safety of the patient. The Code also requires pharmacists to ensure, that in instances where they are unable to provide services to a patient, they take reasonable action to ensure those medicines/services are provided and that the patient’s care is not jeopardised. If supply to a patient is likely to be affected by the personal moral standards of a pharmacist, he or she must inform their superintendent and supervising pharmacist, who must ensure that suitable policies and procedures are in place to ensure patient care is not jeopardised and the patient is facilitated in accessing the information or service required to meet their needs.

Principle One of the Code of Conduct for pharmacists states that the practice by a pharmacist of his/her profession must be directed toward maintaining and improving the health, wellbeing, care and safety of the patient. The Code also requires pharmacists to ensure, that the personal moral standards of a pharmacist should not impact upon services to a patient.

7. Policies, procedures and training within a pharmacy

Superintendent and supervising pharmacists must ensure that there is adequate staff training in place to ensure compliance with all of these policies. All pharmacists providing the service should be trained in these policies and procedures. All other staff in the pharmacy should be familiar with the policies of the pharmacy and should be appropriately trained in the procedures relevant to their role.

Superintendent and supervising pharmacists must ensure that there is adequate staff training in place to ensure compliance with all of these policies. All pharmacists providing the service should be trained in these policies and procedures. All other staff in the pharmacy should be familiar with the policies of the pharmacy and should be appropriately trained in the relevant procedures. Such training should involve in-person training with specialists in the area, which deals with usual issues regarding the safety and use of the drug, as well as issues regarding social stigma surrounding female sexuality, and measures by which pharmacists can seek to reduce its effects specifically in terms of their approach to provision of NorLevo.

Additions to PSI Guidance

Cost 

(a) The cost of NorLevo should be set a maximum, standard level in all pharmacies in Ireland, in order to provide equal access to healthcare for those on varying incomes.

(b) NorLevo should be available free of charge, without prescription, for those in possession of a medical card in Ireland.

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All pharmacies stocking NorLevo should clearly advertise the availability of the drug in a location visible to passersby, i.e. on the window of the pharmacy or on an external sign.

Sunday opening hours

All areas where pharmacies may not be open on a Sunday (e.g. rural areas) must operate a clearly defined and collectively agreed rota system, in order to ensure access of patients to at least one pharmacy stocking NorLevo in their local area on Sundays. Such a system extends to all cities, towns and villages.

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