An injection of local anaesthetic or the provision of high concentration fluoride products are procedures that are controlled by the Medicines Act 1968 because they involve the use of prescription-only medicines (POMs). This means they can only be prescribed by a suitably qualified prescriber. The General Dental Council has no influence over this legislation and it is quite separate from the direct access regulations introduced in May 2013.
Traditionally the prescriber would be a doctor or a dentist, but legislation was introduced throughout the UK in 2000 that allows certain other healthcare professionals to administer POMs in specific circumstances.
POMs may be administered by hygienists and therapists in one of two ways:
- Patient group direction (PGD) – this is a legal framework allowing a listed group of healthcare professionals to administer medicines to a group of patients (fulfilling certain pre-defined criteria) without the need for a written patient-specific prescription or instruction from the approved prescriber
- An approved prescriber may provide a documented, patient-specific direction (PSD) (a written instruction) which allows the healthcare profession to administer a POM to a specific patient
The Human Medicines Regulations 2012 allow independent hospitals, clinics and medical agencies to authorise their own PGDs. The regulations also allow dental practices and clinics which are registered with the CQC (or the HIW in Wales or the RQIA in NI) for the treatment of disease, disorder or injury and/or diagnostic and screening procedures to authorise PGDs. This applies to treatment carried out privately and under the NHS.
Preparing a PGD
Patient group directions are specific to individually-named hygienists or therapists working in a particular dentist’s practice. Consequently it is necessary to generate a new document every time a new hygienist or therapist comes to work in that practice. This has implications for new staff members as well as locum staff and agency staff who will be providing treatment under an NHS contract.
The NHS provides guidance on the development and use of PGDs here