Research and analysis

Government reponse to UK naloxone implementation report

Updated 26 September 2023

Neil O’Brien MP
Parliamentary Under Secretary of State for Primary Care and Public Health
Department of Health and Social Care
39 Victoria Street
London
SW1H 0EU

Professor Owen Bowden-Jones
Chair, Advisory Council on the Misuse of Drugs
c/o Matthew Brace and Sara Babahami, Naloxone Working Group Secretary
1st Floor
Peel Building
2 Marsham Street
London
SW1P 4DF

By email to: ACMD@homeoffice.gov.uk

25 September 2023

Dear Owen,

I wish to thank the ACMD for its extensive report on UK Naloxone Implementation and am grateful for their detailed recommendations. Please accept my apologies for the delay in responding to the Council.

The government agrees with the Council on the importance of naloxone in reducing opioid overdose-related deaths and acknowledges the need to widen access to, and increase the uptake of, this life saving drug. We accept all 7 recommendations made by the Council and are actively exploring policy changes within legislation to ensure many of these recommendations are legally viable for us to implement.

Recommendations 5,6 and 7

Increasing the number of services and professionals that can supply naloxone without a prescription would help reduce the number of drug related deaths, which is a key ambition of this government. We therefore agree with the Council in recommendations 5, 6 and 7 that these services and professionals should be able to supply take-home naloxone without a prescription. Given the links between these recommendations, I will respond to these together.

Medicinal products containing naloxone are currently classified as prescription-only medicines and can normally only be supplied by a registered pharmacy in accordance with a prescription. However, there is an exemption within the Human Medicine Regulations (HMRs) 2012 that enables drug and alcohol treatment services to supply take-home naloxone without a prescription, where this is for the purposes of saving a life in an emergency. The Office for Health Improvement and Disparities (OHID) within the Department of Health and Social Care (DHSC) is looking to update the HMRs to enable more services and professionals to be able to supply take-home naloxone. The HMRs apply to the whole of the UK, and therefore the policy in each nation is determined by the current and prospective legislative approach. For the purposes of these recommendations, I am therefore responding on behalf of the UK.

In 2021, DHSC in partnership with the devolved governments conducted a consultation on widening access to naloxone by expanding the list of services and professionals that can supply without a prescription or other written instruction. The consultation and a summary of the responses are available.

Based on the responses to the consultation, which are largely supportive of our proposals, OHID is in the process of amending the HMRs under powers in the Medicines and Medical Devices (‘MMD’) Act 2021. These changes are complex and my officials are currently working closely with the devolved governments to design the policy. We will be able to update the Council on the exact detail of this soon.

Alongside the legislative changes, and further to recommendation 5, the National Police Chiefs’ Council are actively considering how to improve carriage of naloxone amongst police forces, to administer in an emergency, with other relevant bodies including government departments.

Recommendation 1

The government also accepts Recommendation 1, that we need better data on take-home naloxone and are exploring how to improve data collection through the future legislative updates.

Recommendation 4

The government agrees with recommendation 4 and take home Naloxone is increasingly being made available by prison health teams to prisoners on release. The number of prisoners being provided with take-home naloxone on release is increasing, across England, with 46% of people leaving prison in 2021/22 being provided with a kit on release compared to 40% the previous year.

Recommendation 3

The government agrees with Recommendation 3 that peer to peer naloxone programmes are beneficial, and there is work ongoing to encourage this across the UK. In England, OHID supported and encouraged the commissioning of peer to peer schemes within drug and alcohol services through the drug strategy. Funding for enhanced naloxone provision, including through peer networks, which totalled £2 million in 2022/23 and a further £1.5m in 2023/24.

Colleagues in the devolved governments have also shared some information of their Peer-to-Peer programmes for your information:

• Scotland’s Drug Death’s Taskforce Innovation Fund has provided £0.5 million funding for a 2 year project to develop and support peer-to-peer naloxone supply in 2020/21, and Scottish Govt have extended this funding to 2025/26. Peers also provide evidence based overdose prevention messages, to help minimise the harms individuals may face when using opioids.
• Wales has a successful peer-to-peer programme which has led to over 3000 kits being supplied across Wales. I understand Welsh Government colleagues have recently given a presentation on this scheme to the Council.
• Northern Ireland is reviewing models in place across the UK, considering evidence within evaluations with a view to assess feasibility within the context of NI.

Recommendation 2

Lastly, the government agrees with Recommendation 2 on exploring evidence-based ways in which the carriage of naloxone can be increased by those at risk of overdose and their families. OHID is currently in the process of exploring potential options for research in this space through the National Institute for Health and Care Research (NIHR). Additionally, you may be interested that the Addiction Healthcare Mission, in partnership with Scottish Government, recently announced the successful projects for its Drug Deaths Innovation Competition.

This included several projects around naloxone, including one specifically exploring a more portable form of naloxone to improve carriage rates. Information about this project, and the other successful projects is available.

Please accept once again our grateful thanks for your work, and that of the Council.

Yours sincerely

[signed]

Neil O’Brien MP