Submission to the Medicines Control Agency in response to their consultation to remove prescription only status from 'Morning after' pills

20th June 2000

To: Martin Bagwell, Esq., Ref MLX 263
Medicines Control Agency
1413 Market Towers
1 Nine Elms Lane


Dear Mr Bagwell,

I write on behalf of the Guild of Catholic Doctors in response to the consultation on the supply of 'morning after' pills through pharmacies. We oppose the release of these medications 'over the counter'.

From a medical point of view we believe it is unacceptable for powerful hormonal agents to be available in this way with little or no proper scrutiny. Is it intended that pharmacists should receive training in counselling and the giving of medical advice? Would such a trained pharmacist always be on duty? How much will a pharmacist be able to ask at the counter and will he be told the true medical history, etc. when he does? The pharmacist will have no recourse to the medical records and cannot carry out a physical examination. The patients, keen to obtain the pill, will be tempted to give incomplete or even false medical details. Who will be responsible for any follow up in case things go wrong (eg ectopic pregnancy)? The duty of confidentiality of the pharmacist remains undefined, I understand, and the GP will not generally be informed, whatever the age of the patient.

These are powerful substances which could have serious or even fatal side effects. The drug currently proposed is new, the specification is only with difficulty available, and the long term side effects cannot be known. Who will be legally responsible to pay any compensation (as appropriate) when things go wrong? The proposed release of these medications 'over the counter' risks serious harm to patients and, from a medical point of view, is a recipe for chaos.

From an ethical point of view we also have serious concerns. The 'morning after' pill, taken at certain times of the menstrual cycle, does not act as a contraceptive at all but prevents implantation or nidation, and thus in effect is an abortifacient. There will be a number of pharmacists, not necessarily of our faith, who will find themselves, in conscience, unable to issue these pills. We believe it to be important that their rights of conscience should be upheld and that no one must be required by their terms of service to 'prescribe' them. Only those who so choose should be expected to do so (ie there should be an 'opt_in' type of conscience clause for pharmacists).

Yours sincerely,

Chairman of the Standing Parliamentary Committee
Guild of Catholic Doctors