Policy responses and statements

Name of organisation:

Medicines and Healthcare Products Regulatory Agency

Name of policy document:

MLX 330: Proposal for Amendments to Medicines Legislation to Allow Supply and Administration of Medicines by Members of Mountain Rescue Teams

Deadline for response:

13 January 2006

Background: The MHRA requested comments on proposals to allow suitably trained members of mountain rescue teams to supply and administer medicines to sick or injured people involved in mountain rescue emergencies. This will benefit the care of casualties in emergency situations by allowing them timely access to appropriate drugs. This consultation was made available in Wales, Scotland and Northern Ireland. The proposed changes to legislation would apply throughout the United Kingdom.

A voluntary committee was set up in 1933 to respond to accidents in mountains. This evolved into the Mountain Rescue Council of England and Wales. The equivalents in Scotland and Northern Ireland and the Mountain Rescue Committees of Scotland and the Northern Ireland Mountain Rescue Co-ordinating Committee. Teams of volunteers affiliated to these organisations cover mountain, upland and remote areas of the country. Although most teams have a team doctor, they are not always available to attend every incident because of other commitments. In England and Wales, the attendance rate is less than 50%. Because of the remote and isolated nature of mountain rescue work, team members have, for many years, been able to possess and supply morphine under authority issued by the Home Office. Similar arrangements apply in Northern Ireland.

In recent years, the pattern of incidents has changed. From almost exclusively involving limb fractures or similar, there are now more medical emergencies. The age of "hill-goers" has increased and now inclue numbers of elderly people with underlying illness. Common conditions faced by the teams are diabetes and cardiac episodes. The range of incidents dealt with by rescue teams have also expanded from mountaineering and fell walking to include other interests such as airborne pursuits.

To meet these changes, the MRC develop a limited drugs formulary which is formally reviewed by the Council's medical sub-committee every 3 years with input from pharmacists and clinical pharmacologists. Since 2001, it has been required practice to report the use of any drug on the MRC list on the incident report completed for every rescue. From 2004, any team member who wishes to use the drugs must be a current holder of the MRC Casualty Care certificate. This is a national first aid qualification specific to the MRC that encompasses the special circumstances of mountain rescue. Successful candidates are placed on a central register and must resit the full exam every 3 years to maintain registration.

Northern Ireland's mountain rescue service operates in a similar way but those team members who are allowed access to medicines for rescue situations are required to hold a Health and Safety Executive recognised certificate in Rescue Emergency Care to an advanced level. They are also required to undertake additional training and examination organised by the NIMCRCC.

Arrangements in Scotland are currently less formal and morphine is the only drug used extensively. However, should the proposals be adopted, the Scottish mountain rescue committee plans to move towards adopting the MRC certificate as well as their reporting arrangements for the use of drugs.

COMMENTS ON
MEDICINES AND HEALTHCARE PRODUCTS REGULATORY AGENCY MLX 330: PROPOSAL FOR AMENDMENTS TO MEDICINES LEGISLATION TO ALLOW SUPPLY AND ADMINISTRATION OF MEDICINES BY MEMBERS OF MOUNTAIN RESCUE TEAMS

The Royal College of Physicians of Edinburgh is pleased to respond to consultation MLX 330 on the proposals for amendments to Medicines Legislation to allow supply and administration of medicines by members of Mountain Rescue Teams.

In parts of the UK, particularly in Scotland, medical emergencies have become increasingly common on the hills. For example, in the West Highland area comprising Glencoe and Ben Nevis, 18% of emergencies approximately are truly medical as opposed to fractures and affect people having heart attacks, asthmatic attacks, epilepsy and other acute medical emergencies. As it stands currently in Scotland, Team Doctors train individuals in the use of medicines and supply them to team members with consequent risk of censure should something go wrong.

Clearly this situation cannot continue, but the College recognises that there can be no reduction in the duty of Team Doctors to make sure that members who carry these drugs are sufficiently trained in their uses, and have the support of Team Doctors for information should any unusual circumstances arise. It should remain normal practice to seek the advice of a doctor before administration whenever possible but, in the emergency situation, a trained member of the rescue Team could administer agreed drugs carried by the Team.

There have been few problems, although the inclusion of Epinephrine and Morphine may have been considered contentious initially. Epinephrine is essential in cases of anaphylaxis due to sting or other causes. Mountain Rescue Teams have been called to cases of nut allergy and, clearly, it is an essential part of an emergency bag. The case law relating to Morphine has a long history in the UK with two very contentious law suits, one in England where a mountain rescue doctor gave Morphine to his team to give in cases of fractures on the hill and was prosecuted unsuccessfully. A similar incident in Scotland led to a doctor being charged many years ago, but this also did not come to court. Although the decision to administer controlled drugs by non-medically qualified Team members may be contentious, it is most necessary. Carrying a patient with a broken leg for a long distance on a dark mountain in the absence of opiate analgesia is detrimental to both the patient and the team carrying him. The onus is on the Team Doctor to adequately prepare those carrying this drug for the duties inherent within it. Fellows of the College experienced in such matter run regular (yearly) training sessions for all involved, limiting the number who carry and administer the drug and ensuring an even distribution of the drug about the team. This duty will not be removed and may be strengthened within the protective regulations for local teams, with ongoing training an integral part of the license.

The College welcomes the opportunity for improved flexibility by removing the limited formulary. In practice, this may not lead to immediate changes in the drugs carried by the Teams, but it would be important to specify that the introduction of any new drugs (not in the current formulary) must be supported with directly relevant training before these are added to the range of drugs carried by Team members.

In summary, the College is very supportive of the proposals for use in this emergency situation on the hills.

Copies of this response are available from:

Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.

Tel: 0131 225 7324    ext 608
Fax: 0131 220 3939

[12 January 2006]