Submission

AMA Submission on interim decisions to amend the Poisons Standard for paracetamol

The AMA supports the interim decision to change the scheduling of paracetamol preparations as outlined in the interim decision with the caveat that we remain supportive of limiting the number of packs available for purchase outside of pharmacies and of upscheduling modified release paracetamol.

The AMA supported the proposal to require blister packaging for paracetamol available in retail settings and the reduction of maximum pack sizes for general sale and available in pharmacies.

The AMA appreciates that many consumers raised concerns with the potential impact some of the recommendations could have had on their management of chronic pain. The AMA feels that in general, the interim decision has struck a good balance in implementing changes that will limit the ability for paracetamol to be used for self-poisoning while ensuring consumers managing their pain safely are able to continue to do so.

The AMA did not support age restrictions or behind the counter sales as other measures could achieve the desired outcome without overstating the risk of paracetamol which is a potential outcome of such measures.

The AMA continues to support limiting the quantity of packs available for purchase in retail settings other than pharmacies and we encourage the final decision to reconsider this proposal. The intention of this recommendation was to ensure that people using paracetamol to manage chronic pain have regular interactions with health professionals.

The AMA appreciates that many consumers are able to safely manage their pain and use of paracetamol, however there are some who may benefit from a discussion with their GP or attending a local community pain clinic. A pharmacist can assist a consumer in navigating this.

The AMA remains supportive of modified release paracetamol being upscheduled. The AMA respects the comments in the interim decision regarding impact on consumers, particularly osteoarthritis sufferers, and concerns about access in rural areas. However, people with osteoarthritis should have regular interactions with their GP or non-GP specialist in the management of their condition, including prescribing medicines to manage the condition.

It is a significant concern to the AMA if people aged over 55 with osteoarthritis are not regularly visiting their GP. We would see it as a positive if this were to encourage more people with osteoarthritis or chronic pain to have more regular interactions with their GP.

A constructive approach would be to allow doctors to prescribe in quantities of one month with up to five repeats. This would require only two visits to the doctor per year which would be beneficial. It would be reasonable to have a smaller pack size of modified release paracetamol still available under Schedule 3 for those who need it urgently. This should be less than one month’s supply.

Noting that there are significant concerns around the poorer outcomes from self-poisoning with modified release paracetamol, we strongly recommend reconsideration of this proposal before the final decision is made. The model proposed by the AMA would not unreasonably limit access to patients while limiting the ability for it to be used in self-poisoning.

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