Open consultation

Extend medicines for optometrists and contact lens opticians - consultation document

Published 4 September 2025

Introduction

The Human Medicines Regulations 2012 (‘the HMRs’) is the main UK-wide legislation covering the sale and supply of medicinal products for human use.

Exemptions within the HMRs allow certain medicines or classes of medicine (for example, prescription-only medicines) listed in legislation to be lawfully sold and/or supplied to patients by specific health professional groups, within their clinical competence, without the need for a prescription, patient group direction or patient specific direction.

Types of medicines in scope

General sale list medicines

General sale list (GSL) medicines are medicines that can be purchased from pharmacies, supermarkets or corner shops and do not need to be sold by or under the supervision of a pharmacist.

Pharmacy medicines

Pharmacy (P) medicines are those that must be kept behind the counter, and sold or supplied by, or under the supervision of, a pharmacist.

Prescription-only medicines

Prescription-only medicines (POMs) are not available for sale over the counter and require a prescription.

Regulated eye care professionals in scope

Registered optometrists

Registered optometrists are already able to sell and supply certain medicines under exemption through the HMRs. These exemptions include GSL and P medicines provided it is during their professional practice.

Registered optometrists can provide a signed order for certain POMs that can be fulfilled by a pharmacy. They can also sell and supply those medicines directly to patients during their professional practice and in an emergency.

These exemptions enable registered optometrists to manage a range of minor eye conditions, such as bacterial conjunctivitis and allergic conjunctivitis, eliminating the need for the patient to be seen in other settings such as general practice.

Additional supply optometrists

Some of the existing exemptions require registered optometrists to have undergone additional training to become ‘additional supply’ (AS) optometrists.

Registered dispensing opticians

Exemptions exist in the HMRs to allow registered dispensing opticians (DOs) to sell and supply certain P medicines during their professional practice for the treatment of bacterial conjunctivitis.

Contact lens opticians

The HMRs also give registered DOs who have undertaken additional training to become a contact lens optician (CLOs) access to certain prescription-only topical anaesthetics, through wholesale suppliers, for administration during contact lens fittings.

Throughout this consultation document, the words ‘optometrist’, ‘DO’ and ‘CLO’ refer only to those who are registered with the General Optical Council (GOC).

Reason for proposed changes

It is the ambition of NHS systems across England, Wales, Scotland and Northern Ireland to make better use of the primary eye care workforce, enabling them to meet more of the health needs of their local populations.

This consultation is seeking views on extending the range of medicines available to optometrists and CLOs across the UK, so they can treat a wider range of minor eye conditions. This will:

• make it easier for patients to get the medicines they need
• avoid the need for patients to see additional healthcare professionals just to receive medicines, helping to release capacity across other parts of the NHS

This aligns with wider work across all 4 nations of the UK to extend the medicines responsibilities of non-medical professionals. A further consultation on proposals to extend medicines responsibilities for allied health professions was published by the Department of Health and Social Care (DHSC) in August 2025.

During 2024 to 2025, 1.99 million of the medicines covered by these policy proposals, including chloramphenicol, were prescribed by GPs, walk in centres, out of hours services, and urgent and emergency care (A&E) in England. These policy proposals would enable some of this activity to instead be undertaken by optometrists and CLOs in the community, as part of local services commissioned to meet patient need.

How we will make the changes

Provisions in the Medicines and Medical Devices Act 2021 (‘the MMD Act’) allow the Secretary of State for Health and Social Care to make changes to the HMRs where it is safe and appropriate to do so.

Medicines regulation is a reserved matter (to the UK Parliament) in relation to Scotland and Wales. It is a transferred matter in Northern Ireland.

In accordance with the requirements of the MMD Act, this consultation is being conducted by the appropriate authority (pursuant to section 2(6) of the MMD Act), which is:

• the Secretary of State for Health and Social Care in so far as the proposals relate to England, Wales and Scotland
• jointly with the Secretary of State for Health and Social Care and the Department of Health in Northern Ireland in so far as the proposals relate to Northern Ireland

We are seeking your views on the proposal to amend the HMRs to update the medicines that optometrists and CLOs can sell, supply and, in some cases, administer across England, Wales, Scotland and Northern Ireland.

The amendment will be implemented by a statutory instrument under enabling powers in the MMD Act.

Current relevant exemptions in the regulations

Regulation 250: POM exemptions for the sale of medicines by wholesalers

Regulation 250 of the HMRs permits wholesalers to sell to DOs a POM that:

• is required for use during their professional practice as a contact lens specialist
• contains one or more of the following substances:
  • lidocaine hydrochloride
  • oxybuprocaine hydrochloride
  • proxymetacaine hydrochloride

These medicines are topical anaesthetics that are used to numb the surface of the eye during the fitting of hard contact lenses.

This regulation also permits wholesalers to sell to AS optometrists a POM that contains thymoxamine hydrochloride.

This medicine was historically used to reverse pupil dilation caused by medicines during sight tests but has not had a UK licence since May 1993.

Regulation 235 and schedule 17 part 1: POM exemptions for optometrists

Regulation 235 and schedule 17 part 1 of the HMRs provide exemptions for:

• registered pharmacies to sell and supply certain POMs to a patient when presented with an order signed by an optometrist
• optometrists to sell and supply these medicines directly to a patient during their professional practice and in an emergency

The medicines in question are not for parenteral administration (meaning they should not be given by injection or infusion).

The following POMs are used to treat bacterial eye infections:

• eye drops containing no more than 0.5% chloramphenicol
• eye ointments containing no more than 1% chloramphenicol
• medicine containing fusidic acid

The following POMs are used to dilate the pupil for examination of the internal eye and relieve spasm of the iris - those containing:

• cyclopentolate hydrochloride
• tropicamide

Regulation 235 and schedule 17 parts 1 and 4: POM exemptions for AS optometrists

Regulation 235 and parts 1 and 4 of schedule 17 provide exemption for:

• registered pharmacies to sell and supply the below POMs to a patient when presented with an order signed by an AS optometrist
• AS optometrists to sell and supply these medicines directly to a patient during their professional practice and in an emergency

The medicines in question are not for parenteral administration.

Medicines containing acetylcysteine can be used to treat tear film abnormalities where there is impaired or abnormal mucus production.

Medicines containing atropine sulphate or homotropine hydrobromide can be used to dilate the pupil and relax the muscle of the eye. This facilitates the examination of the internal eye and allows a more accurate determination of spectacle prescriptions, particularly in children.

Medicines containing any of the following substances can be used to treat allergic eye conditions:

• azelastine hydrochloride
• emedastine
• ketotifen
• levocabastine
• lodoxamide
• nedocromil sodium
• olopatadine
• sodium cromoglycate

Medicines containing diclofenac sodium can be used to reduce post-operative pain and inflammation, and treat seasonal allergic conjunctivitis.

Medicines containing pilocarpine hydrochloride or pilocarpine nitrate can be used to reduce the pressure inside the eye as an emergency treatment for patients with suspected acute angle closure glaucoma, giving patients time to seek emergency hospital treatment.

Medicines containing polymyxin B/bacitracin or polymyxin B/trimethoprim can be used to treat bacterial eye infections.

Regulation 235 and schedule 17 part 4: GSL, P and POM exemptions for optometrists

Regulation 235 and schedule 17 part 4 provide exemption for optometrists to sell and supply all GSL and P medicines during their professional practice.

Optometrists can also sell and supply the POMs below during their professional practice and in an emergency.

The medicines in question are not for parenteral administration.

The following POMs can be used to treat bacterial eye infections:

• eye drops or eye ointments containing no more than 30% sulphacetamide sodium
• eye drops containing no more than 0.5% chloramphenicol
• eye ointments containing no more than 1% chloramphenicol
• medicine containing fusidic acid

The following medicines are used to dilate the pupil for examination of the internal eye and relieve spasm of the iris - those containing:

• cyclopentolate hydrochloride
• tropicamide

Regulation 235 and schedule 17 part 4: P medicine exemptions for DOs

Regulation 235 and schedule 17 part 4 provide exemption for DOs to sell and supply the P medicines below during their professional practice.

The following P medicines are used externally for the treatment of bacterial conjunctivitis:

• eye drops containing no more than 0.5% chloramphenicol
• eye ointment containing no more than 1% chloramphenicol

Professional eye care regulation and training

Regulated eye care roles

Registered optometrists

Optometrists are trained to examine the eyes to detect:

• defects in vision
• signs of injury
• ocular diseases or abnormality
• problems with general health, such as high blood pressure or diabetes

They:

• make a health assessment
• offer clinical advice
• prescribe spectacles or contact lenses
• are required to refer patients for further specialist investigations, when clinically necessary

Registered DOs and CLOs

DOs are specially trained to fit and dispense glasses, and those that have undergone additional training to become CLOs have the skills to:

• examine the external surface of the eye and related structures
• recognise ocular abnormalities
• understand the management of a range of common ocular conditions
• with additional training, manage patients with red eyes

This enables CLOs to work alongside optometrists in the delivery of community minor and urgent eye care services and community glaucoma schemes.

CLOs, upon qualification, are also able to use anaesthetics during their professional practice for the fitting of contact lenses. With additional training, a CLO’s scope of professional practice can be expanded to encompass the use of anaesthetics as part of other eye care services.

For example, the Association of British Dispensing Opticians’ (ABDO’s) extended services for contact lens opticians training, run in conjunction with Wales Optometry Postgraduate Education Centre and Cardiff University, qualifies CLOs to use anaesthesia to perform contact tonometry to measure eye pressure and remove foreign bodies from the eye.

CLOs may also undertake training offered by specialist companies providing dry eye treatments, enabling them to provide treatments such as intense pulse light therapy.

Once they have undertaken this training and accreditation, these new skills become part of their scope of practice and they can, with suitable indemnity insurance in place, start to offer these services.

Relevant regulatory and professional bodies

General Optical Council (GOC)

Optometrists and DOs, including CLOs, are statutory regulated healthcare professionals who must be registered with GOC to practise in the UK.

GOC is an independent regulatory body that is responsible for the register of optometrists and DOs in the UK. The purpose of professional regulation is to protect the public.

GOC sets the regulatory standards that all regulated optometrists and regulated DOs, including CLOs, must meet in order to be entered into, and remain on, the relevant GOC register. These are relevant to their scope of practice and span:

• education
• performance
• conduct
• ethics

College of Optometrists

The College of Optometrists is the professional body for optometry.

It is responsible for:

• assessing optometry students for their final qualifying exams
• delivering guidance and training to support optometrists to provide the best possible care
• producing guidance for professional practice, alongside clinical management guidelines, to provide evidence-based advice for a range of eye conditions

Association of British Dispensing Opticians (ABDO)

ABDO is the professional body for DOs, including those who have undertaken further training to become CLOs.

It is responsible for:

• assessing DO and CLO students for their final qualifying Fellowship Dispensing Diploma and Diploma in Contact Lens Practice exams, which are the recognised qualifications for DOs and CLOs
• overseeing training requirements for DOs and CLOs

History and background

Optometrists’ scope of practice and training

In 2005, medicines regulations were amended to recognise that the scope of practice of optometrists was changing and they were beginning to deliver more services in the community. Optometrists who had undertaken additional training to become AS optometrists were granted exemption to sell and supply POMs during their professional practice and in an emergency, or provide signed orders for a number of POMs to be fulfilled by a pharmacy. This allowed them to effectively manage a range of minor eye conditions.

Despite this, the numbers of optometrists choosing to train to become AS optometrists has remained low, with only 9 optometrists with this qualification currently on the GOC register in England. No AS training courses were introduced across Scotland, Wales and Northern Ireland.

Training courses to allow optometrists to be independent prescribers (IP) were introduced in 2009 and optometrists have instead favoured this route as it gives access to a greater range of medicines. As of 6 March 2025, there were:

• 14,729 optometrists in England
• 792 optometrists in Wales
• 1,691 optometrists in Scotland
• 691 optometrists in Northern Ireland

Of these, there are:

• 1,201 IP optometrists in England
• 600 IP optometrists in Scotland
• 120 IP optometrists in Wales
• 89 IP optometrists in Northern Ireland

This shows that not all optometry practices will have access to IP optometrists, meaning patients may still need to be referred to an alternative healthcare provider to access the medicines covered by these proposals.

Since the 1960s, optometry qualifications have included training relating to the use of drugs for both the diagnosis and treatment of ocular disease and, since the 1990s, there has been a significant increase in the quality and volume of training in ocular pharmaceuticals and ocular pathology.

For over 20 years, optometry qualifications have comprised bachelor’s or master’s degrees, which include the requirement for supervised clinical placements. The qualifications are overseen by GOC and placements are overseen and delivered by the College of Optometrists.

During clinical placements, students are required to demonstrate, to the satisfaction of trained independent assessors and examiners, that they can apply their knowledge and skills consistently to safe and effective practice. Their understanding of and compliance with legal, ethical, commissioning and patient safety requirements is explicitly assessed, including:

• consent
• administration and supply
• limitations
• contraindications
• management of adverse reactions

DOs’ and CLOs’ training

Since 2006, DOs who undertake additional contact lens qualifications to become CLOs have been trained to bachelor’s degree level. This qualification is regulated by the Office of Qualifications and Examinations Regulation (Ofqual) and awarded by ABDO. The contact lens qualification syllabus includes training on the use of and interactions associated with medications for eye infections and allergic eye disease.

As of 6 March 2025, there were:

• 1,257 DOs holding a CLO specialty in England
• 55 DOs holding a CLO specialty in Wales
• 68 DOs holding a CLO specialty in Scotland
• 5 DOs holding a CLO specialty in Northern Ireland

Continuing professional development (CPD) and guidance

CPD is a regulatory requirement for all fully qualified optometrists and DOs (including CLOs) to ensure they keep their skills up to date and develop new ones to practise safely and protect their patients.

GOC requires practitioners to comply with CPD requirements as part of a commitment to maintaining and developing knowledge and skills throughout their career. All currently practising optometrists and DOs, including CLOs, are required to keep their knowledge and skills up to date, and there are processes in place to ensure the most current evidence-based treatment recommendations and guidance are disseminated to practitioners. 

Clinical management guidelines (CMGs) produced by the College of Optometrists provide support to optometrists to assist in decisions about appropriate care for specific eye conditions. The CMGs provide an important and reliable source of information on the diagnosis and management of a number of anterior and posterior eye conditions to support clinical judgement and decision making.

Optometrists and DOs, including CLOs, are also aware of the need for antimicrobial stewardship, and the College of Optometrists’ Use and supply of drugs or medicines in optometric practice and ABDO’s Use and supply of drugs guidance set out clear expectations around how and when to use antimicrobial products. The guidance states that practitioners should:

• consider alternative options and only prescribe antimicrobials when this is clinically appropriate
• be aware of local guidelines on antimicrobial prescribing
• not issue an immediate prescription for an antimicrobial to a patient who is likely to have a self-limiting condition
• only issue repeat prescriptions for antimicrobials if these are needed for a particular clinical condition or indication

The guidance also directs practitioners to the National Institute for Health and Care Excellence (NICE) guideline [NG15] on Antimicrobial stewardship: systems and processes for effective antimicrobial medicine use, published in August 2015, which sets out the importance of antimicrobial stewardship in greater detail.

Conclusion

As set out above, optometrists and CLOs receive specialist education and training, and have statutory requirements placed upon them for post-registration CPD.

Having consulted relevant professional bodies, it is our view that this is equivalent to the AS qualification, and demonstrates that optometrists and CLOs have the clinical skills to be able to sell, supply and administer the medicines set out in this consultation document safely and effectively under exemption, without the need for any further additional training.

DHSC will, however, work in collaboration with ABDO, the College of Optometrists and the devolved governments to consider what further CPD materials may be provided to support this change.

If the proposals in this consultation document are accepted, our intention would be to repeal the exemptions relating to AS optometrists in the HMRs and replace them with new provisions that will allow all optometrists and CLOs (for certain medicines) to provide the same level of care as the AS exemption does, including those optometrists currently holding the AS qualification.

Proposed amendments to the regulations

Hospital eye service demand is increasing across all 4 nations of the UK - however, some patients are being seen by GPs and in hospital that do not need to be seen in those settings.

To help alleviate secondary care pressures and provide much-needed capacity, high-street optometrists are being commissioned to deliver increasing levels of eye care in the community, over and above sight testing, including seeing patients with minor or urgent eye care needs and delivering post-cataract checks. This aims to help free up GP and secondary care capacity for those patients that need face-to-face specialist care.

As set out above, CLOs have the skills to be able to examine and treat patients with ocular allergies, bacterial eye infections and dry eye-type conditions. This will allow them to play a greater role in the delivery of community services, such as minor and urgent eye conditions services and glaucoma schemes.

Since the HMRs were introduced in 2012, optometrists and DOs’ clinical practice has evolved. Some of the medicines used by optometrists and DOs that are in scope of the current exemptions in the HMRs have been discontinued and no longer have an active UK licence. Therefore, they are no longer available to be sold or supplied and alternative medicines have become available.

The proposals below, which have been requested and developed in conjunction with the eye care sector, are intended to:

• make it easier for patients to be managed within primary care optometry
• reduce the need for patients to be referred to alternative healthcare providers to access medicines
• allow us to make the best use of the eye care workforce

Having consulted relevant professional bodies, the proposals to amend the HMRs have been made on the basis that optometrists and CLOs have the clinical skills to be able to sell, supply and, in some cases, administer these medicines safely and effectively.

The proposals set out in this consultation fall into 6 categories - proposals to:

1. Remove from the HMRs a number of medicines that have been discontinued and are no longer available to be sold or supplied in the UK.
2. Allow all optometrists to provide signed orders for or directly sell and supply specified POMs in an emergency - an ability currently restricted to AS optometrists.
3. Allow CLOs to provide signed orders for or directly sell and supply specified POMs in an emergency - an ability currently restricted to AS optometrists.
4. Allow all optometrists to provide signed orders for or directly sell and supply new POMs in an emergency for the treatment of allergic and bacterial conjunctivitis.
5. Allow CLOs to provide signed orders for or directly sell and supply new POMs in an emergency for the treatment of allergic and bacterial conjunctivitis.
6. Allow wholesalers to supply specified topical anaesthetics to CLOs so they may be used beyond contact lens fitting.

These proposals are set out in more detail below. The relevant consultation questions can be found in the ‘Consultation questions’ section.

The rationale behind proposals 2 to 6 is the same. These changes would:

• help optometrists or CLOs to manage a wider range of patients in the community
• eliminate the need for unnecessary onward referral to other healthcare professionals

Proposal 1: remove medicines that have been discontinued

The following medicines have been discontinued, do not have an active UK licence and are no longer available to be sold or supplied in the UK:

• emedastine
• levocabastine
• nedocromil sodium
• polymyxin B/bacitracin
• polymyxin B/trimethoprim
• sulphacetamide sodium
• thymoxamine hydrochloride

The proposal would remove these medicines from the HMRs.

Proposal 2: allow all optometrists to supply POMs currently restricted to AS optometrists

This proposal would allow all optometrists to:

• provide signed orders for specified POMs to be fulfilled by a pharmacy
• directly sell and supply these medicines to a patient in an emergency, providing it is during their professional practice

The medicines in question are set out below.

Acetylcysteine

This medicine is used to treat tear film abnormalities where there is impaired or abnormal mucus production. This medication allows the management of dry eye where lubricants alone are not sufficient because the tears contain too much mucous.

Atropine sulphate and homatropine^{[footnote 1]} hydrobromide

These medicines are used to relax the eye to allow a more accurate measurement of the patient’s spectacle prescription, which is particularly useful for children.

Optometrists who are unable to access this medicine would have to refer some children to hospital for a sight test.

These medicines would be provided so the parent, carer or guardian can apply the drops at an agreed time before the examination.

Azelastine hydrocholoride, ketotifen, olopatadine and lodoxamide

These medicines are used to treat allergic eye conditions.

Sodium cromoglycate^{[footnote 1]}

This medicine, in preparations up to 10ml, is a P medicine licensed only for the treatment of seasonal allergic conjunctivitis (hay fever) and is already available to all optometrists.

The preparations of this medicine that are larger than 10ml are a POM and are licensed to treat other forms of allergic eye conditions.

Allowing all optometrists access to the larger POM version of this medicine will allow optometrists to treat other forms of allergic eye conditions.

Pilocarpine hydrochloride and pilocarpine nitrate

These medicines are used to reduce the pressure inside the eye as an emergency treatment for patients with suspected acute angle closure glaucoma, giving patients time to access emergency hospital treatment.

Allowing all optometrists access to these medicines will ensure there is no delay in patients being able to access emergency treatment to reduce eye pressure, which will in turn lower the risk of avoidable sight loss.

Diclofenac sodium

This medicine is used to:

• reduce post-operative pain and inflammation
• treat seasonal allergic conjunctivitis

Allowing all optometrists access to this medicine will allow patients who are experiencing discomfort after they have undergone cataract surgery to be managed in the community. It would also allow optometrists to manage pain for patients suffering with uncomfortable scratches to the cornea (front of the eye).

Proposal 3: allow CLOs to supply POMs currently restricted to AS optometrists

This proposal would allow CLOs to treat allergic eye disease by:

• providing signed orders for specified POMs to be fulfilled by a pharmacy
• directly selling and supplying these medicines to patients in an emergency, providing it is during their professional practice

The medicines in question are:

• azelastine hydrocholoride
• ketotifen
• olopatadine

Proposal 4: allow optometrists to supply new POMs to treat conjunctivitis

This proposal would allow all optometrists to treat forms of allergic and bacterial conjunctivitis by:

• providing a signed order for these POMs to be fulfilled by a pharmacy
• directly selling and supplying these medicines to patients in an emergency, providing it is during their professional practice

The proposed new POMs, which are not currently subject to exemption within the HMRs, are set out below.

Azithromycin

This medicine is used to treat bacterial conjunctivitis. Conjunctivitis is more common in children. Unlike other similar medicines, this is licensed for use in younger children.

Gentamicin

This medicine is used to:

• treat bacterial conjunctivitis
• prevent infection following the removal of ocular foreign bodies or corneal trauma
• treat infections of the tissues surrounding the eye
• effectively fight bacteria that is resistant to other current medicines

Epinastine

This medicine is used to treat allergic conjunctivitis.

Proposal 5: allow CLOs to supply new POMs to treat conjunctivitis

This proposal would allow all CLOs to treat forms of allergic and bacterial conjunctivitis by:

• providing a signed order for these POMs to be fulfilled by a pharmacy
• directly selling and supplying these medicines to patients in an emergency, providing it is during their professional practice

The proposed new POMs, which are not currently subject to exemption within the HMRs, are:

• gentamicin
• epinastine

For details of the usage of these medicines, see ‘Proposal 4: allow optometrists to supply new POMs to treat conjunctivitis’ above.

Proposal 6: allow wholesalers to supply specified topical anaesthetics to CLOs

Regulation 250 of the HMRs already gives DOs access to the following 3 topical anaesthetics for use during their professional practice as a contact lens specialist:

• lidocaine hydrochloride
• oxybuprocaine hydrochloride
• proxymetacaine hydrochloride

In practice, this restricts the use of these medicines to CLOs, who will use them to numb the surface of the eye during the fitting of hard contact lenses.

As set out above, CLOs may choose to undertake additional training to deliver a greater range of eye care services including:

• contact tonometry, which measures eye pressure by placing a small probe on the surface of the eye
• the removal of foreign bodies from the eye
• dry eye treatments such as:
  • intense pulse light therapy, which improves tear quality and reduces inflammation
  • punctal plugs, which are inserted into tear ducts to reduce tear drainage and allow tears to stay on the surface of the eye for longer

Some of these services will require the use of topical anaesthetics to numb the surface of the eye.

To enable wholesalers to supply these medicines to CLOs for use beyond contact lens fitting, we are seeking to expand the current wording in regulation 250 of the HMRs to allow fully trained and accredited CLOs to use these topical anaesthetics during their professional practice.

Legal assessment under section 2 of the Medicines and Medical Devices Act 2021

The MMD Act came into force on 11 April 2021. We propose to make legislative changes using powers in part 2 of the MMD Act, which includes powers to make amendments to the HMRs.

This consultation is conducted in line with the consultation requirement in section 45(1) of the act.

Section 2 of the MMD Act requires that patient safety is the overarching objective of the appropriate authority when making regulations (in this case, the required amendments to implement the proposals set out above). This means that, when assessing whether regulations would contribute to the objective of safeguarding public health, the appropriate authority must have regard to 3 factors:

• the safety of human medicines and that the benefits outweigh any risks
• the availability of human medicines
• the likelihood of the relevant part of the UK being seen as a favourable place in which to:
  • carry out research relating to human medicines
  • conduct clinical trials
  • manufacture or supply human medicines

As set out in section 2(3) of the act, where regulations under section 2(1) may have an impact on the safety of human medicines, the appropriate authority may make the regulations only if the authority considers that the benefits of doing so outweigh the risks.

In this section, we have assessed the proposal against each of the factors set out in section 2 of the MMD Act.

Safety

The proposals set out in this consultation document will allow for the sale and supply of specified medicines by all optometrists and CLOs, either through the provision of a signed order to be fulfilled by a pharmacy or directly to a patient in an emergency.

Across the UK, the commissioning of enhanced eye care services from high-street optical practices is increasing. This includes community minor and urgent eye care services. These services will often be the first port of call for patients seeking treatment for a range of minor eye conditions.

The core professional training and ongoing requirements for CPD among both optometrists and CLOs - set out earlier in the ‘Professional eye care regulation and training’ section of this consultation document - demonstrate that these professions have the professional training and clinical knowledge to be able to safely supply medicines to patients. Extending access to medicines also has the potential to improve patient safety by reducing delays in care (if patients needed to be referred to other healthcare professionals for a medicine).

Optometrists and CLOs, by virtue of their training and access to specialist equipment, are also better placed, compared with general practice, to determine when eye conditions require a medicine-based intervention. Therefore, allowing optometrists and CLOs access to medicines through proposals in this consultation document should reduce the prescribing of antibiotic eye treatments.

Availability

As set out above, high-street optical practices are delivering increasing levels of enhanced eye care services, including community minor and urgent eye care services, which will be seeing patients with minor eye conditions.

The current exemptions in the HMRs are limiting optometrists’ and CLOs’ ability to sell and supply medicines to patients to treat these conditions. Optometrists and CLOs will be required to refer patients either to optometrists within the practice with IP qualifications or to their GP.

Allowing all optometrists and CLOs to sell and supply certain medicines through exemptions in the HMRs will ensure there are no barriers or delays to patients accessing clinically necessary treatment.

This includes a medicine that can be supplied in an emergency to reduce the pressure inside the eye for patients with suspected acute angle glaucoma, giving patients time to access emergency hospital treatment - any delay in providing this treatment could result in avoidable sight loss. These proposals will also help to improve access to timely treatment for those receiving care in their own home or a nursing or residential care home.

We do not envisage that these proposals will negatively impact the supply chain in relation to these medicines. However, if these proposals are accepted, we will seek to engage with the industry ahead of implementation, so it is sighted on these proposals and can plan accordingly.

Favourability

The proposals will extend the range of medicines that can be sold or supplied by optometrists or CLOs. This aims to improve medicines supply, which directly supports the health system by:

• ensuring reliable access to essential medicines
• optimising patient care
• improving the efficiency of healthcare in the UK

This ultimately:

• contributes to better health outcomes and reduced healthcare costs
• creates a favourable market for manufacturers and distributors of medicines used in the eye care sector

These proposals will not, in our view, have a direct impact on the UK being seen as a favourable place in which to carry out research relating to human medicines or conduct clinical trials.

Statutory duties

Public sector equality duty

The general equality duty that is set out in the Equality Act 2010 requires public authorities, in the exercise of their functions, to have due regard to the need to:

1. Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the act.
2. Advance equality of opportunity between people who share a protected characteristic and those who do not.
3. Foster good relations between people who share a protected characteristic and those who do not.

The protected characteristics covered by this duty are:

• age
• disability
• gender reassignment
• marriage and civil partnership
• pregnancy and maternity
• race
• religion or belief
• sex
• sexual orientation

DHSC does not consider that the proposals detailed in this consultation document would have an impact on objective 1. On objectives 2 and 3, DHSC’s view is that these proposals will not have an adverse or differential impact on individuals with protected characteristics.

This policy will:

• remove barriers to patients receiving the care and support they need
• ensure equality of opportunity in receiving care
• foster good relationships by increasing access to clinical services to all patients, with protected characteristics or otherwise, in the community

The reduction in unnecessary delays will benefit any patient requiring clinically necessary treatment for a minor eye condition.

This proposal has the potential to help optical practices deliver more patient-facing clinical services, further integrating them into the NHS and allowing them to become the first contact for minor self-limiting illnesses (illnesses that often resolve without the need for a GP or hospital appointment). This will provide patients with greater opportunities to access local services and treatments if clinically necessary.

Duties under the NHS Act 2006

The National Health Service Act 2006 contains a number of overarching duties on the Secretary of State for Health and Social Care that apply to every action undertaken in relation to the NHS and public health. Although all duties have been considered, the following duties are particularly affected by these policy proposals:

The duty to continue to promote a comprehensive health service in England (section 1)

DHSC’s view is that this proposal supports the duty to promote a comprehensive health service as it enables optometrists and CLOs to treat a range of minor eye conditions directly, making the best use of their clinical skills and training.

Patients will not need to be referred to alternative healthcare providers to access medicines, therefore:

• removing barriers to treatment
• providing care more promptly
• helping to free up capacity in other areas of the NHS, such as GP appointments or secondary care

The duty as to improvement in quality of services (section 1A)

DHSC’s view is that this also contributes to improvement in the quality of services by facilitating timely access to medicines.

The ability of optometrists and CLOs to sign orders for or directly sell and supply medicines, where it is safe and appropriate to do so, will ensure patients receive the right treatment at the right time, reducing delay.

This will:

• make the best use of the skills of our primary eye care professionals
• contribute to better patient outcomes
• provide additional capacity for delivering care

Duties under the Family Test

In developing policy, consideration needs to be given to the effect it will have on family relationships and functioning. In particular, we are required to have regard to any negative impact on:

• family formation
• families going through key transitions
• ability of family members to play a full role in family life
• families before, during and after couple separation
• families most at risk of deterioration of relationship quality and breakdown

These proposals are designed to improve the range of eye care services available to patients, making it easier for patients to access the medicines they need without unnecessary referral to alternative healthcare professionals.

Our view is that these proposals will not, therefore, have a direct impact on family relationships and functioning.

Environmental principles policy statement duty

On 1 November 2023, the environmental principles policy statement duty came into force in relation to England, Wales and Scotland. This places a legal duty on UK ministers to have due regard to the government’s environmental principles policy statement when developing policy.

The statement sets out 5 internationally recognised environmental principles to be considered. The 5 principles work together to help create opportunities to avoid, minimise and remedy environmental damage and improve environmental protection.

The 5 principles are:

• integration - environmental protection should be integrated into the making of policy
• prevention - damage to the environment should be prevented before it has occurred and/or existing damage should be contained
• rectification at source - damage to the environment should be tackled at its origin
• polluter pays - the costs of pollution should be borne by those causing it, wherever possible
• precautionary - policymakers need to make a reasonable assessment of the environmental risk, particularly where there is a lack of scientific certainty

DHSC’s view is that there will be environmental benefits as a result of this policy, although it is difficult to estimate the full extent of those benefits.

This policy will enable optometrists and CLOs to sign orders for or directly sell and supply a range of medicines to treat minor eye conditions, which will in turn reduce the need for patients to be referred to alternative healthcare providers.

Therefore, it should, for example, result in fewer journeys from the optical practice to a GP practice, which could be some distance away, resulting in fewer emissions.

Duties in Northern Ireland: equality and rural screening

In Northern Ireland, new policies must be screened under section 75 of the Northern Ireland Act 1998, which places a statutory duty on public authorities to mainstream equality in all its functions. This means that equality of opportunity and good relations are central to policy making and service delivery.

In addition, new or revised policies must be ‘rural proofed’ in line with the Rural Needs Act (Northern Ireland) 2016, which requires public authorities to have due regard to rural needs.

The Department of Health in Northern Ireland does not consider that these policy proposals will create inequalities or risk impacting people differently with regard to where they live geographically in Northern Ireland.

How to respond

Please respond using the online survey.

Do not provide personal data when responding to free-text questions. Any personal data included will be removed before analysis of these responses and will therefore not be considered in the consultation outcome.

The consultation is open for 12 weeks and will close at 11:59pm on 27 November 2025. If you respond after this date, your response will not be considered.

If you have any queries on this consultation or require an alternative format, contact communitypharmacyteam@dhsc.gov.uk. Do not send your consultation answers or any personal information to this email address.

Consultation questions

About you

In what capacity are you responding to this survey?

• An individual sharing my personal views and experiences
• An individual sharing my professional views
• On behalf of an organisation

Questions for individuals

What is your age? (Optional)

• Under 13
• 13 to 15
• 16 to 24
• 25 to 34
• 35 to 44
• 45 to 54
• 55 to 64
• 65 to 74
• 75 or above
• Prefer not to say

What is your sex? (Optional)

• Male
• Female
• Prefer not to say

Where do you live in the UK?

• England
• Scotland
• Wales
• Northern Ireland
• I live outside the UK

Questions for professionals

What best describes your profession?

• Optometrist
• Optometrist with a medicine prescribing qualification (for example, an independent prescribing or additional supply qualification)
• Dispensing optician
• Dispensing optician with a contact lens specialism
• Ophthalmologist
• Orthoptist
• General practitioner (GP)
• Pharmacist
• Other health care professional
• Other non-health care professional

Where do you practise in the UK? 

• England
• Scotland
• Wales
• Northern Ireland
• Outside the UK

What best describes the setting you work in?

• Primary care
• Secondary care or other equivalent hospital provider
• Primary and secondary care
• Other, please specify

Questions for organisations

What is the name of the organisation you are responding on behalf of?

What type of organisation are you responding on behalf of?

• Professional membership body
• Optical practice providing NHS sight testing services
• Optical practice providing NHS sight testing services and enhanced eye care services
• Optical practice providing entirely private services
• Regulatory body
• General practice
• Pharmaceutical
• Hospital trust
• Integrated care board
• Voluntary sector or patient group
• Other healthcare provider
• Other, please specify

Where does your organisation operate or provide services? Select all that apply:

• England
• Wales
• Scotland
• Northern Ireland
• The whole of the UK
• Outside the UK

What is your job title?

Proposal 1: remove medicines that have been discontinued

The following medicines have been discontinued and are no longer available to be sold or supplied in the UK:

• emedastine
• levocabastine
• nedocromil sodium
• polymyxin B/bacitracin
• polymyxin B/trimethoprim
• sulphacetamide sodium
• thymoxamine hydrochloride

Do you agree or disagree with the proposal to remove these medicines from the HMRs on the basis that they have been discontinued and are no longer available to be sold or supplied in the UK?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please provide further information to support your answer. (Optional, maximum 150 words)

Proposal 2: allow all optometrists to supply POMs currently restricted to AS optometrists

The following questions are about enabling optometrists to sell and supply specific POMs so that they can manage patients in the community and eliminate the need for unnecessary onward referral to other healthcare professionals.

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply acetylcysteine in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply atropine sulphate in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply homatropine hydrobromide in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply azelastine hydrocholoride in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply ketotifen in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply olopatadine in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply lodoxamide in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply sodium cromoglycate in preparations that are larger than 10ml in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply pilocarpine hydrochloride in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply pilocarpine nitrate in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply diclofenac sodium in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please provide further information to support your answer. (Optional, maximum 150 words)

Proposal 3: allow CLOs to supply POMs currently restricted to AS optometrists

The following questions are about enabling CLOs to sell and supply specific POMs so that they can manage patients with allergic eye disease in the community and eliminate the need for unnecessary onward referral to other healthcare professionals.

Do you agree or disagree with the proposal to allow all CLOs to provide a signed order for, or directly sell and supply azelastine hydrocholoride in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all CLOs to provide a signed order for, or directly sell and supply ketotifen in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all CLOs to provide a signed order for, or directly sell and supply olopatadine in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please provide further information to support your answers. (Optional, maximum 150 words)

Proposal 4: allow optometrists to supply new POMs to treat conjunctivitis

The following questions are about enabling optometrists to sell and supply specific POMs so that they can manage patients in the community with forms of conjunctivitis and eliminate the need for unnecessary onward referral to other healthcare professionals.

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply azithromycin in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply gentamicin in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal to allow all optometrists to provide a signed order for, or directly sell and supply epinastine in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please provide further information to support your answers.  (Optional, maximum 150 words)

Proposal 5: allow CLOs to supply new POMs to treat conjunctivitis

The following questions are about enabling CLOs to sell and supply specific POMs so that they can manage patients in the community with forms of conjunctivitis and eliminate the need for unnecessary onward referral to other healthcare professionals.

Do you agree or disagree with the proposal that CLOs should be able to provide a signed order for or directly sell and supply gentamicin in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Do you agree or disagree with the proposal that CLOs should be able to provide a signed order for or directly sell and supply epinastine in an emergency?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please provide further information to support your answers. (Optional, maximum 150 words)

Proposal 6: allow wholesalers to supply specified topical anaesthetics to CLOs

This question is about enabling wholesalers to supply the following 3 topical anaesthetics to CLOs for use during the course of their professional practice:

• lidocaine hydrochloride
• oxybuprocaine hydrochloride
• proxymetacaine hydrochloride

Do you agree or disagree with the proposal to allow wholesale suppliers to supply CLOs with these 3 topical anaesthetics for use during the course of their professional practice?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please provide further information to support your answer. (Optional, maximum 150 words)

Legal considerations

In considering the amendments to the HMRs, ministers must comply with the public sector equality duties. In Northern Ireland, new policies must also be screened under section 75 of the Northern Ireland Act 1998. In addition, new or revised policies must be rural proofed in line with the Rural Needs Act (Northern Ireland) 2016.  

Protected characteristics under the Equality Act 2010 are:

• age
• disability
• gender reassignment
• marriage and civil partnership
• pregnancy and maternity
• race
• religion and belief
• sex
• sexual orientation

The Department of Health and Social Care (DHSC) and the Department of Health in Northern Ireland (DoH (NI)) do not consider that these policy proposals will create inequalities or adversely impact individuals with protected characteristics.

Do you agree or disagree with the view of DHSC and DoH (NI) on the impact these policy proposals will have on individuals with protected characteristics?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please provide further information to support your answer. (Optional, maximum 150 words.)

Question for respondents who live or work in Northern Ireland

DoH (NI) does not consider that these policy proposals will impact people differently with regard to where they live geographically in Northern Ireland.

Do you agree or disagree with the view of DoH (NI) about the impact these policy proposals will have on where people live geographically in Northern Ireland?

• Agree
• Neither agree nor disagree
• Disagree
• Don’t know

Please provide further information to support your answer. (Optional, maximum 150 words)

Privacy notice

Data controller

The Department of Health and Social Care (DHSC) is the data controller.

What personal data we collect

We will collect the following types of personal data:

• whether you are responding as an individual member of the public, an individual sharing your professional views or on behalf of an organisation
• your profession, where you practise in the UK and what best describes the setting you work in, if you are responding as an individual sharing your professional views
• the name, type and sector of your organisation, where your organisation operates or provides services and your job title, if you are responding on behalf of an organisation
• where you live

If volunteered by you, we will also collect data on your personal characteristics (your age and sex).

How we use your data (purposes)

The data we collect is used:

• to inform DHSC of the demographic range of respondents
• for the development of government policy

DHSC will process your personal data in accordance with the Data Protection Act 2018.

Legal basis for processing personal data

Under Article 6 of the UK General Data Protection Regulation (GDPR), the lawful basis we rely on for processing this personal data is:

• the processing is necessary to perform a task or function in the public interest or for our official functions and the task or function has a clear basis in law (DHSC’s statutory functions under section 1 of the National Health Service Act 2006 as to the improvement in quality of services)

Data processors and other recipients of personal data

Responses to the online consultation may be seen by:

• data analysts, economists, lawyers and officials in DHSC supporting HMRs policy
• DHSC’s third-party supplier (SocialOptic), which is responsible for running and hosting the online survey

International data transfers and storage locations

Storage of data by DHSC is provided via secure computing infrastructure on servers located in the European Economic Area (EEA). DHSC platforms are subject to extensive security protections and encryption measures.

Storage of data by SocialOptic is provided via secure servers located in the UK.

Retention and disposal policy

Data will be stored in line with DHSC’s data protection policy. We will retain your data for 12 months after the consultation closes. Data will be collected and stored virtually and will be removed from the system when appropriate.

We will ask SocialOptic to securely delete the information held on their system one year after the online consultation closes.

How we keep your data secure

DHSC uses a range of technical, organisational and administrative security measures to protect any information we hold in our records from:

• loss
• misuse
• unauthorised access
• disclosure
• alteration
• destruction

DHSC has written procedures and policies that are regularly audited and reviewed at a senior level.

SocialOptic is Cyber Essentials certified. This is a government-backed scheme that helps organisations protect themselves against the most common cyberattacks.

Your rights as a data subject

By law, data subjects have a number of rights, and this processing does not take away or reduce these rights under the UK GDPR, and the UK Data Protection Act 2018 applies.

These rights are:

• the right to get copies of information - individuals have the right to ask for a copy of any information about them that is used
• the right to get information corrected - individuals have the right to ask for any information held about them that they think is inaccurate, to be corrected
• the right to limit how the information is used - individuals have the right to ask for any of the information held about them to be restricted, for example, if they think inaccurate information is being used
• the right to object to the information being used - individuals can ask for any information held about them to not be used. However, this is not an absolute right, and continued use of the information may be necessary, with individuals being advised if this is the case
• the right to get information deleted - this is not an absolute right, and continued use of the information may be necessary, with individuals being advised if this is the case

Comments or complaints

Anyone unhappy or wishing to complain about how personal data is used as part of this consultation should contact data_protection@dhsc.gov.uk in the first instance or write to:

Data Protection Officer
1st Floor North
39 Victoria Street
London
SW1H 0EU

Anyone who is still not satisfied can complain to the Information Commissioner’s Office. Their postal address is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Automated decision making or profiling

No decision will be made about individuals solely based on automated decision-making (where a decision is taken about them using an electronic system without human involvement) that has a significant impact on them.

Changes to this policy

We keep this privacy notice under regular review, and we will update it if necessary. All updated versions will be marked by a change note on the consultation page. This privacy notice was last updated on 4 September 2025.

1. ‘Homatropine’ and ‘sodium cromoglycate’ are currently spelled incorrectly in the HMRs and will be amended as part of these policy changes, if agreed. ↩ ↩²