Proposed changes to the Availability of Puberty Blockers – Department of Health and Social Care Consultation

Published: 26/09/2024

This consultation seeks views on the proposal to make a permanent order to come into force when the second emergency order to prevent new patients aged under 18 from beginning to take puberty blockers for the purposes of gender incongruence and/or gender dysphoria, under the care of private prescribers expires.

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On 29 May 2024, the UK government introduced 2 pieces of legislation which restrict how children and young people under 18 years old can access GnRH analogues.  

The first piece of legislation, The Medicines (Gonadotrophin-Releasing Hormone Analogues) (Emergency Prohibition) (England, Wales and Scotland) Order 2024 ('the emergency order'), applies to England, Wales and Scotland. It is a 3-month emergency order, which:  

• banned the sale or supply of the listed medicines prescribed by private UK registered prescribers for gender incongruence and/or gender dysphoria to under 18s not already taking them  

• banned the sale and supply of these medicines against prescriptions from prescribers registered in the EEA or Switzerland for any purpose to those under 18.  

The emergency order came into force from 3 June 2024 in Great Britain and expired on 2 September 2024. A second emergency order has been developed and introduced. This will continue current restrictions and allow time for further consultation to take place ensuring there is no gap in legislative provision. 

A separate set of regulations restrict NHS primary care prescribing of puberty blockers to use only in specific circumstances, and do not have an expiry date. However, these regulations only apply to England and Wales. Equivalent regulations for Scotland are due to commence in early September 2024. 

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The Emergency Order

• To what extent do you agree or disagree with making the arrangements in the emergency order permanent?

  Agree.

Positive Impact

• In your experience, what have been the positive impacts of the emergency order? Please provide evidence to support your answer.

  The regulation is clear and provides pharmacists with direction on what we can and cannot supply. This provides distinct clarity on the parameters that prescriptions must fall within when dispensing puberty blockers. This regulation provides clear ruling on the matter which then leaves pharmacists supported and informed to make clinical decisions, as they would with any other type of prescription or medication.  

Negative Impacts

• In your experience, what have been the negative impacts of the emergency order? Please provide evidence to support your answer.

  From the perspectives and experience of our members in their roles as pharmacy health care providers, there are no negative impacts of the emergency order which have been experienced. 

Benefits

• In your experience, are there benefits in making the arrangements permanent?

  • Yes  

  Please provide evidence to support your answer and explain how you think those benefits could be maximised? 

  Yes, if the arrangements are made permanent, then pharmacists will be supported by clear regulations which will allow them to carry out their clinical responsibilities as pharmacy health care providers.  

Risks

• In your experience, are there risks in making the arrangements permanent?

  No

Impact on Protected Groups

• Do you think the accompanying equality impact assessment (EQIA) appropriately reflects the potential impact on protected groups which might arise from the proposal to make the order permanent?

  No

• Do you have any further comments or evidence about the potential impact on protected groups? If yes, please specify.

  No

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