Calling all pharmacies!
Don’t get caught out!
Are you supplying products on signed orders without a Wholesale Dealers Authorisation (WDA)?
As per MHRA guidance (in Bold) and provided the ‘transactions’ meet all of the following criteria the MHRA will not deem such transactions as commercial dealing and pharmacies will not be required to hold a WDA(H) if:
- It takes place on an occasional basis
- The quantity of medicines supplied is small
- The supply is made on a not for profit basis
- The supply is not for onward wholesale distribution
The guidance refers to ‘the transaction’ taking place on an occasional basis. It does not refer to a specific transaction to a specific customer. But just the transaction of a wholesale deal itself
Decide on the quantity being supplied. How many patients will that quantity treat? Three tubes (30g each) of anaesthetic cream could potentially treat 90 patients (based on the EMC guidance of 1g per patient – treatment dependent). Can this be justified as small?
Furthermore, are you a Distance selling pharmacy?
These rules may not apply to you and you may need a WDA because the guidance very clearly states that “the supply of medicines by community and hospital pharmacies to other healthcare professionals in the UK…represents an important and appropriate part of the professional practice of both community and hospital pharmacy. Many healthcare professionals and others authorized or entitled to supply medicines to the public in the UK need to hold small quantities of medicines for local healthcare provision and look to a local community or hospital pharmacy to supply them as part of their professional practice.”
If you need advice or help going through the application process call PCL or visit www.pharmacyconsulting.co.uk
Written by Puveshni Pillay