Written evidence submitted by PAGB, the consumer healthcare association (PHA0034)



  1. Introduction


1.1         PAGB, the consumer healthcare association, is the UK trade association representing manufacturers of branded over-the-counter (OTC) medicines, self-care medical devices and food supplements.


1.2         Self-care comprises of the actions that individuals take for themselves, on behalf of and with others, to develop, protect, maintain and improve their health, care, wellbeing or wellness.


1.3         The COVID-19 pandemic has had a significant impact on the ways in which the Government promotes, and the public considers, self-care, as well as the role pharmacy has played in supporting it.


1.4         Prior to the coronavirus pandemic, there were 18 million GP appointments[i] and 3.7 million visits[ii] to A&E every year for minor ailments which people could have looked after themselves or sought advice from a pharmacist about. It is estimated that this was costing the NHS approximately £1.5bn a year.[iii]


1.5         During the first national lockdown, a PAGB survey indicated a greater willingness among the public to self-care for self-treatable conditions.[iv] For example, 31% of people who would not have consulted a pharmacist as their first option said they were more likely to do so after the pandemic.[v] Whilst this behaviour shift is encouraging, a more recent PAGB survey suggests that people may be starting to return to pre-pandemic behaviours.[vi]


1.6         PAGB has worked with leading health and pharmacy organisations to forge a clinical consensus on how best to support self-care. This has culminated in the formation of the Self-care Strategy Group and the development of a blueprint for a new self-care strategy for England.[vii]


1.7         The blueprint sets out a vision for a system that is designed to support self-care, with pharmacy much more embedded in the primary care pathway and clear routes to self-care across primary and secondary care. [viii] We welcomed the Primary Care Recovery Plan which adopted many of the recommendations contained in the blueprint, particularly around the role of pharmacy in promoting and supporting people to self-care for minor ailments.


1.8         Our submission to this inquiry focuses on how the role of pharmacy can be enhanced to support the health system’s recovery from the COVID-19 pandemic and how the Government’s aspirations set out in the Primary Care Recovery Plan can be realised.


  1. What does the future of pharmacy look like and how can the Government ensure this is realised?


2.1         PAGB welcomes the vision for community pharmacy set out in the Primary Care Recovery Plan and the Government’s commitment to invest up to £645 million over two years to expand services offered by them.


2.2         Community pharmacists are well placed to drive a holistic approach to self-care. They can help to advise people on the most effective OTC treatments, as well as self-care techniques, helping to alleviate pressure on GPs and A&E services.


2.3         Pharmacies also have longer opening hours than GP surgeries and are often open at the weekends. Furthermore, over 99% of those living in areas of the highest deprivation are within a 20-minute walk of a community pharmacy,3 making the medicines available at pharmacies and the advice of pharmacists, an accessible resource for people with health concerns.


2.4         The Community Pharmacy Consultation Service (CPCS) has been an important initial step in ensuring the system is designed to support self-care for self-treatable conditions and the skills of pharmacist are optimised to alleviate pressure on other services.


2.5         However, it is evident that the CPCS has not been fully optimised. Since its launch in October 2019, there have been over 340,000 referrals for minor ailments made to the CPCS from NHS 111[ix] and nearly 184,000 referrals from GPs to the CPCS.[x] In the context of 300 million GP appoints each year, uptake of the service has been relatively low.[xi]


2.6         PAGB has therefore welcomed the Government’s announcement in the Primary Care Recovery Plan that it will be launching a Pharmacy First scheme so that, subject to consultation, by the end of 2023 community pharmacies can supply prescription-only medicines (POM) for seven common conditions, and services for oral contraception and blood pressure.


2.7         The Primary Care Recovery Plan also recognised the important role that medicine reclassification can play in alleviating pressure on the system and optimising the role of community pharmacists. When data shows that a medicine can be used appropriately and effectively without intervention from a doctor, its legal status can be changed via reclassification. This makes it available OTC without a prescription, empowering patients to self-care and alleviating demand for NHS services.


2.8         PAGB welcomes the commitment in the Primary Care Recovery Plan to identify medicines which could be reclassified from POM to Pharmacy and we look forward to working with the MHRA, DHSC, and NHSE along with pharmacy representative bodies and suppliers to increase the availability of OTCs in England.


2.9         In doing so, the Government should learn from the success of the 2001 reclassification alliance. The alliance included industry, patient groups, regulators, and health professionals, and set and met the ambition of switching 50 products by 2007. Now is an opportune time to build on this success, in light of the shifting life sciences landscape and the UK’s position as a regulatory leader.


2.10     PAGB has commissioned research into the potential savings of a POM to Pharmacy reclassification for the NHS which is due to be published in July and we would be happy to share these findings with the Committee in due course so it can understand the scale of the opportunity for pharmacies and the NHS.


  1. What are the challenges in pharmacy workforce recruitment, training and retention, and how might these best be addressed?


3.1         PAGB does not feel best placed to respond to this question.


  1. To what extent are digital systems used in pharmacy sufficiently interoperable with those in general practice and hospitals?


4.1         The CPCS, the precursor to Pharmacy First was to some extent limited by the lack of interoperability between pharmacy, GP and hospital IT systems and the lack of write access for pharmacists to populate patient records.


4.2         Whilst most pharmacies can ‘read’ the summary care record, they cannot routinely record the advice or medication they give people. In this regard, England lags behind other comparable nations, such as Singapore and Austria.[xii]


4.3         Central to the success of Pharmacy First will be ensuring improved system-wide communication and appropriate access to medical records. The Primary Care Recovery Plan has committed to improving IT connectivity between GPs and community pharmacy, and allowing pharmacists to populate a patient’s healthcare record following supply of oral contraception or a blood pressure consultation in community pharmacy.


4.4         During its consultation on Pharmacy First, the Government should consider extending pharmacists write access so that they can take general health, underlying conditions and medicines use into account when providing services, and ensure that a consistent and comprehensive record of an individual’s treatment is maintained.


4.5         With all new pharmacists able to prescribe from 2026, write access will be increasingly important over the coming years.


  1. What innovations could have the biggest impact on pharmacy services and why?


5.1         From the perspective of increasing utilisation of pharmacy services, and as described above, we believe that the biggest impact will derive from the introduction of Pharmacy First accompanied by comprehensive write access for pharmacists and effective interoperability of IT systems with GP practices and hospitals.


5.2         Scotland has had a Pharmacy First service since 2020 and data published by the Scottish Government identified that 200,000 GP appointments and A&E visits were avoided by pharmacists being able to deal with minor ailments.[xiii] It also found that use of the scheme can be seen across all levels of deprivation in the population with 45% using the service in 2021/22 living in the two most deprived quintiles.[xiv]


5.3         Increasing the number of OTC medicines available in pharmacies through reclassification, will further optimise the role that pharmacy can play in alleviating pressures on GP and A&E services, shift individual behaviour patterns in accessing care and promoting self-care.


5.4         PAGB believes that the Government should also consider enabling community pharmacists to refer people directly to other healthcare professionals to ensure that people receive the right care in the right place at the right time.


5.5         PAGB’s 2022 self-care survey indicates that there is broad public support for this:



5.6         Primary Care Networks can play a crucial role through place based partnerships to agree and facilitate referral pathways from community pharmacy to GPs, dentistry,  optometry, allied healthcare professionals and secondary care consultants.


  1. To what extent are funding arrangements for community pharmacy fit for purpose?


6.1  PAGB does not feel best placed to respond to this question.


  1. What factors cause medicine shortages and how might these be addressed in future?


7.1  Manufacturers of medicines plan medicines supply with the aim of ensuring stock availability at all times. Companies have resilience plans in place to activate should they face unexpected events which may potentially cause shortages. In the vast majority of cases, the close monitoring of events, forecasting of demand, scheduling of manufacturing and availability of safety stock (stock of medicines to cover forecast for a number of weeks in case of an issue) means that these shortages never materialise at the end of the supply chain.


7.2  Resilience tends to be maintained when only one or two external factors arise. However, in recent times due to global instability, the COVID-19 pandemic and Brexit a larger number of unprecedented factors have impacted manufactures concurrently. This multifaceted complexity has meant that there is more potential for supply issues.


7.3  Home grown issues can also cause problems and the industry has seen supply disruption due to petrol availability, work force strikes, energy crisis and labour force reduction. 


7.4  Industry and the trade associations already work very closely with DHSC to advise of imminent issues or supply concerns and generally these are managed very well.  However, in the case of over-the-counter medicines, which are not supplied via NHS, but to retailers and pharmacies through other channels, the amount of support they can provide is limited.


7.5  One of the biggest factors which can compound supply is a sudden unexpected increase in demand. While over-the-counter manufacturers may prepare and stock build for a winter cough and cold season, if the incidence is unprecedently high (as per winter 22/23) keeping up with this demand can be challenging. However, supply by the manufacturers was maintained during this time. What caused further disruption was media coverage on the availability of specific brands of cough and cold treatments. 


7.6  Most over-the-counter medicines, unlike prescription medicines, are supplied directly from the manufacturer’s designated warehouse straight to the retailers and large pharmacy chains. During winter 22/23 there were no reported issues here and products were widely available in supermarkets and retailers. Supply to smaller independent pharmacies or shops is more likely to come via orders from wholesalers. Local community pharmacies reported having challenges in obtaining products from their wholesalers. Unfortunately, this led to media headlines which in turn then leads to an increase in consumer demand.


7.7  The most significant way to prevent shortages of medicines in the OTC sector is to try and ensure that the demand remains steady and that the public aren’t caused to “panic buy” by misleading headlines. Therefore, ensuring that there is an accurate picture of the wider availability of medicines is imperative, rather than just using issues in a small sector of where the products can be bought, as proof there is an issue. The Government and organisations representing pharmacies can help bring this accuracy and perspective to the situation.


  1. To what extent does community pharmacy have the resource and capacity to realise the ambitions in DHSC's Primary Care Recovery Plan?


8.1  PAGB does not feel best placed to respond to this question.


  1. Are there the right number of community pharmacies in the right places, and how can we ensure that is the case across the country?


9.1  PAGB does not feel best placed to respond to this question.


  1. To what extent are commissioning arrangements for community pharmacy fit for purpose?


10.1 PAGB does not feel best placed to respond to this question.


For more information about PAGB, please see: https://www.pagb.co.uk/about-us/ For more information about the blueprint for a self-care strategy, please see: https://selfcarestrategy.org/






[i] Practice Business (2019), NHS campaign aims to drive patients to pharmacists, available at: https://practicebusiness.co.uk/nhs-campaign-aims-to-drive-patients-to-pharmacists/

[ii] NHS England (2016), News: Use the high street health expert – your pharmacist, available at: https://www.england.nhs.uk/2016/11/use-your-pharmacist/

[iii] PAGB (2019), A Self Care White Paper: supporting the delivery of the NHS Long Term Plan, available at: https://www.pagb.co.uk/content/uploads/2019/03/PAGB_Self-Care_White-Paper_v1-0.pdf

[iv] PAGB (2020), PAGB Self Care Survey 2020, available at: https://www.pagb.co.uk/policy/self-care/self-care-survey-report-download-pagb/

[v] PAGB (2020), PAGB Self Care Survey 2020, available at: https://www.pagb.co.uk/policy/self-care/self-care-survey-report-download-pagb/

[vi] PAGB (2021), PAGB Self Care Survey 2021, available at: https://www.pagb.co.uk/content/uploads/2021/09/PAGB_SelfCare_Survey_2021_web.pdf

[vii] Self-care Strategy Group (2021), Realising the potential: Developing a blueprint for a self care strategy for England, available at: https://www.pagb.co.uk/content/uploads/2021/10/Realising-the-potential-developing-a-blueprint-for-a-self-care-strategy-for-England-WEB-VERSION_final.pdf 

[viii] Self-care Strategy Group (2021), Realising the potential: Developing a blueprint for a self care strategy for England, available at: https://www.pagb.co.uk/content/uploads/2021/10/Realising-the-potential-developing-a-blueprint-for-a-self-care-strategy-for-England-WEB-VERSION_final.pdf

[ix] Royal College of General Practitioners (2021), GP CPCS: General Practice and Community Pharmacy
Working Together, available at: https://www.youtube.com/watch?app=desktop&v=ejNEMPp22-k&t=4979s

[x] Hansard (2022), HC Deb Vol 712 cc 266-280WH, available at: https://hansard.parliament.uk/Commons/2022-04-26/debates/77644B86-5AEC-4B96-AEFD-B62D29FC973D/NationalStrategyForSelf-Care

[xi] NHS England (2021), Plan set out to improve access for NHS patients and support GPs, Available at: https://www.england.nhs.uk/2021/10/plan-set-out-to-improve-access-for-nhs-patients-and-support-gps/

[xii] Pharmaceutical Journal (2018), Access to patient records: Britain lags behind other countries, available at:


[xiii] Scottish Government (2021), Pharmacies ensuring swift patient care, available at: https://www.gov.scot/news/pharmacies-ensuring-swift-patient-care/#:~:text=More%20than%202%20million%20consultations,infections%20in%20the%20last%20year

[xiv] Public Health Scotland (2023), NHS Pharmacy First Scotland: Financial year 2021/22, available at: https://publichealthscotland.scot/publications/nhs-pharmacy-first-scotland/nhs-pharmacy-first-scotland/

[xv] PAGB (2022), Taking care, taking control, available at: https://www.pagb.co.uk/content/uploads/2022/11/Taking-care-taking-control.-Self-care-attitudes-2022.pdf.

[xvi] PAGB (2022), Taking care, taking control, available at: https://www.pagb.co.uk/content/uploads/2022/11/Taking-care-taking-control.-Self-care-attitudes-2022.pdf.

[xvii] PAGB (2022), Taking care, taking control, available at: https://www.pagb.co.uk/content/uploads/2022/11/Taking-care-taking-control.-Self-care-attitudes-2022.pdf.


July 2023