Providing medicines for employees at remote workplaces

Access to medicines may be necessary for medical treatment in the event of an on-site accident, medical emergency, or for health conditions which, if left untreated, would preclude an employee being considered fit for work.

Health Services Permits to use medicines at high-risk workplaces such as remote mining, oil and gas sites are applicable where the usual supply chain cannot be used due to isolation and where there is limited access to registered health practitioners such as doctors, nurses and pharmacists. These permits are not intended to replace the treatment of ongoing or chronic health conditions by an employee’s usual medical practitioner or other health care provider.

Permit holders should assess the risks associated with any administration of medicines which will occur at remote sites. For example, the risk of administering preventative immunisations at a remote site should be considered in view of the limited access to tertiary health services. Permit holders must weigh up the risks associated with the rare occurrence of anaphylactic reactions to vaccines and the availability of medical evacuation and tertiary care if needed.

Handling of medicines at these sites must comply with the Code of Practice for Health Service Permits for Medical Treatment (the Code) (PDF 117KB). This sets out the requirements for operation of these permits issued under the Medicines and Poisons Act 2014. The Code was developed by a working party of regulators, emergency medicine specialists, occupational health physicians and ambulance service personnel.

Medicines sold at general sales outlets (e.g. supermarkets) are either unscheduled or exempt from scheduling. Unscheduled medicines often include complementary healthcare products and vitamins.

These are controlled by the Commonwealth Therapeutic Goods legislation. It is recommended that only products included on the Australian Register of Therapeutic Goods (external site) with an AUST L or AUST R number included on their label are supplied or used on-site.

If a medicine is not scheduled, there are no restrictions on who may supply. Any product supplied must be kept in the original manufacturer’s packaging with all warnings, indications and doses intact. Ideally, only one pack should be supplied at a time. Permit holders are encouraged to develop clinical guidelines for the best practice supply and use of these medicines

Schedule 2 (S2) medicines are over-the-counter, pharmacy only items. In rural and remote areas, these medicines may be supplied at stores other than pharmacies, under a S2 retail licence. Some mining and resource sites have S2 retail licences, usually as part of hospitality services.

Where an employee purchases a pharmacy medicine from a S2 retailer, the individual employee is taking responsibility for making the purchase, including the correct use of the medicine.

Outside an S2 licence, health service staff can only supply these medicines as part of a consultation with the patient, and cannot offer S2 medicines for retail sale. Where supply occurs, it must be part of a Structured Administration and Supply Arrangement (SASA) issued by a medical practitioner that outlines who can make the supply and the clinical criteria for supply.

These medicines must be supplied in the manufacturer’s original pack with all directions and warnings intact. Pharmacy only medicines are intended for short-term treatment only. Requests for multiple packs or repeated supply should be referred to a medical practitioner.

Schedule 3 medicines are over-the-counter pharmacist only items. They can only be sold or supplied by a pharmacist from a pharmacy.

Health service staff can only supply these medicines as part of a consultation with the patient as part of a Structured Administration and Supply Arrangement (SASA) issued by a medical practitioner that outlines who can make the supply and the clinical criteria for supply. Schedule 3 medicines require an adequate assessment of therapeutic need and may only be supplied when clinically indicated.

These medicines must be supplied in the manufacturer’s original pack with all directions and warnings intact. Pharmacy only medicines are intended for short-term treatment only. A single pack should be supplied and requests for multiple packs or repeated supply should be referred to a medical practitioner.

Before health service staff can administer doses of Schedule 4 and Schedule 8 medicines, they must have been directed to do so by a prescriber. The direction can be for an individual patient (such as by telephone) or through a Structured Administration and Supply Arrangement (SASA).

Schedule 8 medicines cannot be given to employees to take away from the clinic. A complete record of the medicines supplied must be made in the patient’s clinical record.

Schedule 4 medicines supplied for a patient to take away from the clinic must be labelled so the patient knows what dose to take and when and how to best take the medicine. Some medicines also required label warnings about the risk of drowsiness (particularly when driving or operating machinery) and the risk of interaction with alcohol.

Permits are issued to a medical practitioner to holds the permit on behalf of a medical treatment/occupational health business. This business may then contract to a resources company to provide medical treatment services, including use of scheduled medicines.

Permits can be issued to partnerships and corporations, but a medical practitioner must be nominated to be responsible for each site. The nominated medical practitioner is responsible approving the administration of Schedule 4 or Schedule 8 medicines to individual patients or for the issue of any Structured Supply and Administration Arrangement.

The permit holder is responsible for ensuring compliance with all relevant parts of the Medicines and Poisons Act 2014, the Medicines and Poisons Regulations 2016, and the Code of Practice for Health Services Permits for Medical Treatment.

The permit holder must decide which medicines are held on-site and approve orders from wholesalers. Only staff approved in writing by the permit holder can administer and supply scheduled medicines. The permit holder must ensure that standard operating procedures are in place to support all activities on-site relating to scheduled medicines. All activities on site relating to scheduled medicines and all movements of medicines must be documented. Supplies must comply with packaging and labelling requirements.

Compliance may be audited by the Western Australian Department of Health’s authorised investigators and action taken for non-compliance.

Discrepancies in the Schedule 8 inventory or the loss/theft of any medicine must be immediately reported to the Department of Health. Police should be contacted for any confirmed theft.