Medicines
Governing: MSN 1905 (M+F) Amendment 5, Annexes 7-9; REG Yacht Code Annex J3-J6; Table A-VI/4-2 criterion on dosage and application of drugs.
The legal basis
MSN 1905 Annex 7 explains that the Human Medicines Regulations 2012, Schedule 17 let the owner or master of a ship with no doctor administer prescription-only medicines to people on board to comply with merchant shipping law, and the Misuse of Drugs Regulations 2001 let them supply and possess certain controlled drugs for the same purpose. It is the master's dispensation; you act under it.
Obtaining medicines
- From suppliers with the right MHRA authorisation (WDA-H or manufacturer's licence), and for controlled drugs, a Home Office controlled drugs licence.
- A signed order from the owner or master (HMR 2012 Schedule 17); controlled drugs need a signed requisition on the approved form.
- Abroad: products may differ in strength or formulation and be in foreign packs; local law applies, particularly to controlled drugs; counterfeit medicines are a real risk. Buy from regulated pharmacies or wholesalers; online purchase is discouraged.
- Medicines prescribed to a crew member ashore: get a note with the generic name and directions and check it against the pack.
Storage
| Rule | Detail |
|---|---|
| Temperature | 15-25 C where not specified; refrigerated items 2-8 C, not frozen |
| Cabinet | Lockable, dry, not in abnormal heat, lit, readily accessible from (not in) the hospital (REG J3) |
| Controlled drugs | Inner cupboard with a lock the cabinet key cannot open |
| Access | Only the master or a person authorised by the master opens the inner cupboard |
| Disposal (non-controlled) | Store separately, land at the first opportunity to a pharmacy, note in the log |
| Disposal (controlled) | Only to a Home Office licensed person or company (or possibly the police); receipt kept with the register |
Giving a medicine
Before you give anything, check: the right patient, the right drug and strength, the right dose, the right route, the right time, and allergies. Read the patient information leaflet. MSN 1905 Annex 7 includes a table of the listed medicines' doses, routes, uses and side effects, to be used with the SCMG and TMAS. If in doubt, ask TMAS before, not after.
Records
| Record | Requirement |
|---|---|
| Official log book | Every treatment given, including type and quantity of medicines (Official Log Book Regulations 1981) |
| Controlled drugs register | Bound, two sections: receipts (why, when, how much purchased) and issues (dispensing or disposal) |
| Retention | Two years after the date of the last entry |
| Electronic | Acceptable with access control, identifiable authors, no later alteration and an audit log |
| No doctor aboard | The official log may be used as the register |
Annex 9 gives specimen entries. Running balances that do not reconcile are a finding at inspection and, worse, a sign someone is helping themselves.
WARNING — Guests' own medicines Guests may bring controlled or prescription drugs aboard. They are the guest's responsibility, but the master needs to know about anything that could matter in an emergency or at a border.
CAUTION — Expiry MSN 1905 section 7.1 puts the cost of periodic replacement on the owner. Do not let budget pressure keep expired stock in the chest.