14^th October 2022

Consumer Healthcare Products (CHP) Australia supports the implementation of balanced, evidence-based and practical measures to address the challenges of intentional misuse of paracetamol medicines, while maintaining convenient access for consumers to everyday pain relief.

There is also a clear need for a robust and multi-dimensional response to the increasing levels of mental and emotional distress in the community, as demonstrated by the increase in intentional overdose from all medicines including paracetamol in the past decade, cited in the expert panel’s report.

When used according to the label instructions, over-the-counter paracetamol medicines are safe and effective[1], and convenient consumer access to pain relief has a proven public health value. However, as with all medicines, misuse can be harmful.

While the vast majority of Australians continue to use paracetamol medicines safely and responsibly, we share the community’s deep concern about the many complex factors, including those related to mental health, involved in the intentional misuse of medicines.

As the association representing manufacturers and distributors of nonprescription medicines, including over-the-counter analgesics for pain relief, CHP Australia and our members remain absolutely committed to supporting medicines safety. Prior to the commencement of the paracetamol review, our industry was proactively working to implement a two-pack purchase limit for OTC pain relief medicines, as we believe it would strengthen medicines safety protocols.  

CHP Australia response to the specific recommendations in the Report is as follows:

Blister packs

CHP Australia supports the proposal for all single active tablet or capsule paracetamol available to the general public to be sold in blister packs.

Pack size reductions

In principle, CHP Australia supports the reduction of pharmacy and grocery pack sizes for single active ingredient paracetamol medicines as a likely means of reducing medicines stockpiles in the home. However, the proposed pack reductions are too restrictive to meet the legitimate therapeutic needs of consumers, particularly those living in rural or remote areas or in larger households. A pack of 10 only represents just over 1 days’ supply for a single adult, and a pack of 32 only represents 2 days’ supply for two adults.

Purchase limits

Since March 2021, prior to the commencement of the review, CHP Australia has supported, and been actively working with to introduce a two-pack purchase limit in grocery.

CHP Australia and our members continue to wholeheartedly support reasonable purchase limits in grocery, and the implementation of suitable purchase limits in pharmacy. We believe reasonable purchase limits would strengthen medicines safety protocols, while maintaining consumers’ important access to convenient pain relief.

Behind the counter

CHP Australia does not support this proposal as we do not believe it to be a practical or balanced measure, and emphasises that there are better options available.

In practice, this proposal would likely negatively impact everyday Australians, unduly restricting their ability to treat pain as it occurs, and practice responsible self-care.

Implementing this proposal presents numerous practical and logistical challenges for retailers. Most concerningly, with the limited space available behind the counter, retailers will likely have to reduce the product range and stock levels of paracetamol available to consumers.

Paracetamol is the most widely used nonprescription pain relief medicine in the world, and its wide availability has a proven public health benefit. As such, we firmly believe that any measures implemented should not result in the direct or indirect restriction of consumers’ convenient access to pain relief.

Additionally, this proposal would restrict consumers’ access to medicines label information, impeding their ability to responsibly self-select the appropriate medicine for their ailment

Upscheduling Modified Release Paracetamol to Prescription

CHP Australia does not support this proposal as there is no evidence to suggest this significant restriction would reduce the risks or incidence of intentional overdoses, or that the current scheduling is inappropriate.

In fact, we believe this proposal to be counterproductive as it would result in larger volumes of medicines being readily available in the home. The expert panel’s report found that in the majority of paracetamol overdoses, individuals used product already in the home. 

As prescription medicines are dispensed a month’s supply at a time, the average chronic pain sufferer would be dispensed a minimum of 200 tablets, and potentially up to 400 tablets at once. Such quantities are highly unlikely to be dispensed under the current arrangements.

Additionally, Painaustralia has advised us that further restrictions on legitimate access to effective pain relief will likely have a profound and negative impact on those living with chronic pain.

Age restrictions

CHP Australia is not opposed to the introduction of age restrictions for the purchasing of paracetamol. However, we suggest that further consultation be undertaken before proceeding with this proposal as there are a number of issues (including ensuring access for minors living independently or those with carer responsibilities) that need to be resolved.

 

Consumer Healthcare Products (CHP) Australia's response to the consultation is available HERE.

We encourage those with questions or concerns about their medicines to speak with their healthcare professional.

CHP Australia continues to encourage the use of the Mindframe guidelines when communicating about the intentional misuse of medicines.

If you or someone you know are experiencing signs or symptoms of poor mental health, it is important to speak to a healthcare professional or contact one of the services below (dial 000 in an emergency):

Lifeline Australia 13 11 14
Suicide Call Back 1300 659 467
Kids Help Line 1800 551 800
BeyondBlue 1300 224 636
eheadspace 1800 650 890

National Indigenous Postvention Service After Suicide Support 1800 805 801