This position, while perhaps well-intentioned in seeking to modernise access, is fundamentally flawed in its assumptions, lacks sufficient evidentiary support, and risks undermining patient safety, professional standards and public trust in pharmacy practice.
1. Patient safety must remain paramount
The PDA’s recent report presents overwhelming evidence that any form of self-selection, facilitated or otherwise, introduces unacceptable risks:
- Inappropriate use and misdiagnosis: Patients may select medicines based on packaging or prior experience, bypassing critical pharmacist interventions that could prevent adverse drug reactions (ADRs), especially in cases of polypharmacy or comorbidities.
- Health literacy challenges: With 61% of adults struggling to understand health information involving numeracy, the assumption that patients can safely self-select even with ‘facilitation’ is dangerously optimistic.
- Increased ADRs and hospital admissions: The BMJ open study cited in the PDA report estimates that ADRs cost the NHS over £2.2 billion annually, with 39.4% deemed avoidable, many involving medicines available as P products.
Facilitated self-selection does not guarantee pharmacist intervention at the point of decision-making. It reactively engages the pharmacist after the patient has made a choice, often psychologically committing to it, which can lead to resistance, confrontation, or even violence which is an issue already escalating in community pharmacy settings.
2. Facilitated self-selection undermines professional oversight
The RPS’s support for facilitated self-selection contradicts its own long-standing professional standards, which clearly state, “Pharmacy medicines must not be accessible to the public by self-selection.”
This inconsistency creates confusion among pharmacists and the public, weakening the clarity of professional guidance and regulatory expectations. The PDA’s survey of over 1,300 pharmacists found that 93% oppose self-selection, with 94% citing supervision difficulties and 87% concerned about increased risk of violence.
Moreover, the General Pharmaceutical Council’s (GPhC) introduction of the ambiguous term ‘facilitated self-selection’ has further muddied the waters, with no clear evidence base or formal consultation process to support its adoption. Adding the word ‘facilitated’ in front of a practice does not change the fundamental aspects of a process or situation, and the RPS’s alignment with this terminology without robust scrutiny is deeply troubling.
Further, the term is entirely misleading, as the choice of medicine is made by the patient, or their representative, at the point when they select it from the shelf. This decision happens before any professional or clinical input can take place to offer guidance, support, or an intervention to prevent the purchase and use of a potentially inappropriate or harmful medicine.
3. Commercial pressures vs. clinical judgement
Facilitated self-selection risks shifting the pharmacy model from healthcare-led to retail-driven, where commercial incentives may override clinical judgement. The PDA’s report documents:
- The use of eye-catching packaging to influence consumer behaviour.
- The risk of pharmacy owners prioritising sales over safety, especially in large multiples.
- The erosion of the pharmacist’s gatekeeping role, reducing opportunities for meaningful clinical dialogue.
This model contradicts with the NHS’s direction of travel, which emphasises prevention, integration, and professional-led care as seen in the Pharmacy First Service programme and digital patient records.
4. Legal and regulatory incompatibility
Facilitated self-selection is at odds with the Medicines Act 1968 and Human Medicines Regulations 2012, which require that P medicines be sold under the supervision of a pharmacist. The PDA’s report highlights that:
- The legal precedent (Pharmaceutical Society v Boots) was based on a pharmacist being able to intervene before the sale is completed, not after a product has been selected.
- The GPhC’s own standards previously prohibited open display of P medicines, and no compelling new evidence has been presented to justify reversing this position.
5. Undermining the viability of the P-medicine category
If P medicines are made available for self-selection, even in a facilitated model, it raises the question; why should they remain classified as P medicines at all? As Professor Bill Scott, former Chief Pharmaceutical Officer (CPhO) for Scotland stated, “If [a medicine] can be self-selected… then it shouldn’t be a P medicine, it should be general sales list (GSL).”
This shift could jeopardise future prescription only medicine (POM) to P medicines reclassifications, as regulators may no longer trust that pharmacist oversight is meaningfully maintained.
6. Legislative reform risks distancing pharmacists from patients
The PDA is also concerned that the RPS’s support for facilitated self-selection of P medicines is being advanced at a time when the UK government is introducing significant legislative changes to pharmacy supervision. These changes may allow pharmacists to delegate a broader range of tasks to registered pharmacy technicians, including the preparation, assembly, dispensing, sale, and supply of medicines.
While the stated aim of this reform is to free up pharmacists’ time for more clinical services when combined with the liberalisation of P medicine sales through facilitated self-selection, this could result in several risks to putting patients at harm. This could also affect the advising pharmacist/patient interactions at the point of medicine selection and supply, the eroding the pharmacist’s gatekeeping role, and undermine the very rationale for maintaining the P medicines category.
Conclusion and call to action
The RPS’s support for facilitated self-selection is misguided, premature, and potentially harmful.
The recently published NHS 10 Year Plan for England describes how strategies such as pharmacogenomics and genetics will be deployed to ‘optimise medication effectiveness for individual patients and prevent adverse drug reactions that cause patients harm.’ Despite the emphasis on prevention of harm from medicines, changes in pharmacy practice are emerging that could contradict government policy, and which undermine the professional position of pharmacists as guardians of medicines safety.
The convergence of facilitated self-selection and supervision reform could create a dangerous vacuum in professional oversight, where no one is clearly accountable for ensuring the safe and appropriate use of P-medicines at the point of sale.
The PDA urges the RPS to:
- Reaffirm its commitment to the prohibition of self-selection of P medicines
- Engage in transparent, profession-wide consultation before endorsing any policy change
- Prioritise patient safety and professional integrity over convenience or commercial interests
Until such steps are taken, the PDA will continue to oppose any model that dilutes the pharmacist’s critical role in safeguarding medicine use.
The PDA wants to again hear from pharmacists regarding their views and encourages all PDA members and pharmacists to complete this survey.
This survey aims to:
- Understand pharmacists’ awareness and views on facilitated self-selection.
- Explore how pharmacists perceive the clinical and safety implications.
- Assess whether other members of the pharmacy team could safely support this process.
- Ensure pharmacists’ voices are heard.
The responses will help shape the PDA’s position and advocacy on this important issue and will close at 5 pm on Wednesday 20 August.
Learn more
- PDA launches case against the liberalisation of P medicine sales
- Pharmacist time freed up to treat patients more
- Fit for the future: 10 Year Health Plan for England
- Adverse drug reactions, multimorbidity and polypharmacy: a prospective analysis of 1 month of medical admissions
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