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Picture this! It is mid December 2015 and legislation allowing limited advertising
for Schedule 3 medicines to start on 1 January 2016 has been passed by the Senate
in the final sitting days of the year.
This might sound a bit like a pipe dream
On 31 March (yes, at the end
of this month) the report and
recommendations of the Review
of Medicines and Medical Devices
Regulation is due to be released.
One of the issues it is reviewing is
direct-to-consumer (DTC) advertising
A discussion paper released in
November 2014 by the reviewers
(Emeritus Professor Lloyd Sansom,
Will Delaat and former Australian
Government Chief Medical Officer
Professor John Horvath) includes
a section on S3 advertising. It says,
‘Restrictions on the advertising of
Schedule 3 medications in Australia are
generally considered to be out of step
with international practice and recent
media reports, along with submissions
to the TGA, have called for advertising
of Schedule 3 medicines to be brought
in line with jurisdictions such as the
UK, Canada, New Zealand and the
It goes on to point out however,
that media reports and submissions
have not outlined opposing views.
The paper lists two questions for
• What are the risks and benefits
of allowing direct to consumer
advertising of Schedule 3 Medicines?
• How might any risks be managed?
The Australian Self Medication Industry
is strongly in favour of DTC advertising
of S3s. PSA and the Pharmacy Guild
also support limited DTC advertising.
The Consumer Health Forum and
the Australian Medical Association
strongly oppose it, so it isn’t going to be
By the end of March the Federal
Government may well have a
recommendation to allow DTC
advertising of S3 medicines – just in
time to potentially be included in the
Allowing S3 advertising would increase
consumer awareness of the S3 range of
medicines available from pharmacies
for minor ailments which would
presumably increase S3 sales.
We know the Government is looking
to save money on the health budget.
The potential spin off for it would be
two-fold – savings on the PBS and
savings on Medicare as customers ask
their pharmacist about their problem
and buy an S3 (not PBS listed) instead
of visiting a doctor (and claiming
a Medicare rebate) and getting
Of course it put the onus back on
pharmacists to get out of the dispensary
and spend more time in the front of
shop counselling customers.
If customers do need to see a GP the
pharmacist can still refer them to
It is safe to assume any government move
to allow DTC advertising would draw a
swift and negative response from the
AMA and other GP organisations and
consumers. But the AMA has so far been
unsuccessful in stopping the spread of
pharmacist-delivered vaccinations across
In this case the Government can argue
that it is simply encouraging people
to look at the existing Pharmacist-Only
range of medicines for a minor ailments
solution before going to their GP – simple
triage. They can also point to minor
ailments programs being considered in
the UK, Ireland and elsewhere.
It will be interesting to see what the
Review of Medicines and Medical Devices
Regulation report recommends. If it
opts for allowing S3 DTC advertising
the impetus for community pharmacies
moving to a health hub or health
destination model could get a
All will be revealed at the end of
If it does the next hurdle could well
be getting the Government to notice.
Presently it has some bigger problems
to sort out, leadership being the most
obvious. The way it is going, quite a
few Government MPs could be visiting
pharmacies to ask their pharmacist
about S3 remedies for minor ailments
and hoping their don’t need more drastic
S3 advertising for
BY ANDREW DANIELS
» CANBERRA COMMENTARY
Andrew Daniels is Managing Editor of Australian
Pharmacist. Opinions expressed in this column are
not necessarily those of the Pharmaceutical Society,
its Board or staff.
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