In the IMO submission to the Department of Health’s Consultation on the Draft Misuse of Drugs (Amendment) Regulations 2013, the IMO welcomes the tightening of regulations in relation to supply of controlled drugs and makes a number of comments in relation to the prescribing of benzodiazepines and z-drugs and the dispensing of methadone.

Regulations relating to the Prescribing of Benzodiazepines and Z-drugs.

·         The hand-writing of prescriptions is neither safe nor efficient. In order to avoid further confusion over this issue, it must be clearly stated in the regulations that there is no requirement to hand-write prescriptions of Benzodiazepines and Z-drugs;

·         The IMO requests that the Department of Health consider investing in the development of a package for Electronic Prescribing similar to the electronic Acute Medication Service (eAMS) which prevails in the NHS in Scotland;

·         Data must be available in real time both to prescribing GPs and the PCRS to enable monitoring of “Doctor shopping” by recidivist offenders;

·         Doctors whose prescribing rates are found to be above average must be provided with advice and support in addressing prescribing rates;

·         Community mental health services must be adequately resourced to ensure evidence based therapies are available to patients as an alternative to benzodiazepines and z-drugs.

Regulations relating to the Dispensing of Methadone to Opiate Dependent Patients

·         While waiting for a prescription, pharmacists are permitted to continue methadone dispensing to patients who have been in continuous treatment for at least one month, for three days after the date of their last prescription, on the instruction (by phone or fax) of the designated treating doctor.