Medicine supply chain: Community and hospital pharmacies may not engage wholesale trade of medicines

Council inspections have flagged pharmacies ordering unregistered or compounded medicines from other community pharmacies, contrary to the Practice Regulations.

In recent months, Council’s inspections have observed a trend where some pharmacies ordering medicines from other community pharmacies. This practice is inconsistent with the Regulations relating to the practice of pharmacy.

Medicine supply chain: Community pharmacies may not distribute medicines or order from each other

In terms of the Regulations relating to the practice of pharmacy (“Practice Regulations”), there are currently five categories that a pharmacy may be registered in: manufacturing, wholesale, institutional, community, and consultant. The scope of services that may be provided in each category are listed in Chapter 5 of the Practice Regulations.

According to Regulations 16 and 17 of the Practice Regulations, manufacturing pharmacies and wholesale pharmacies may, among other services, engage in the distribution of medicines and scheduled substances. The trade in medicines to community and institutional pharmacies is restricted to these two categories of pharmacies. Community and institutional pharmacies, on the other hand, may supply medicines and scheduled to end users,

Council has observed a concerning trend during inspections – some pharmacies in the community and institutional categories ordering medicines from community pharmacies, most of which unregistered or compounded medicines. Council, therefore, calls upon responsible pharmacists to observe the requirements of Rule 2.3 (“Minimum standards for procurement, storage and distribution”) of the Rules relating to Good Pharmacy Practice by ordering medicine only from legitimate sources of medicines.

Where a pharmacy does not have a certain medicine or the ability to undertake extemporaneous compounded of a specific custom dosage or a medicine for which there is no access, such patient may be assisted to access the services of a pharmacy that may offer the services. However, at no point should keep stock of unregistered medicines or medicines sourced from other pharmacies.

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