Can our programs make over-the-counter medication, pregnancy tests, and emergency contraception* available to people using our services?
Yes! The good news is that we can remove barriers and give people access to over-the-counter (OTC) medication for themselves.
*Plan B One-Step/morning after pill/levonorgestrel is available without a prescription or age restriction. This means anyone can buy it with without ID.
Things to consider: offering vs. dispensing
When you offer a first aid kit to someone who has cut themselves, the adult chooses whether or not to use what you are offering. You are not ordering them to use a bandage, just offering. By letting folks know that you have Tylenol, aspirin, cough syrup, pregnancy tests, emergency contraception, etc. available, you are providing information, not direction someone to use any of these items.
Dispensing has a particular legal implication and refers to prescriptions drugs*. Letting someone know that you have OTC medication available is not the same as dispensing medication. Programs are neither prohibited from nor director to make OTC medication available to their participants according to WAC 388-61A-0560. WAC 388-61A-0570 requires programs to have a secure way to store medications with immediate access to the program participants.
*Drug dispensing: the preparation, packaging, labeling, record keeping, and transfer or a prescription drug to a patient or an intermediary, who is responsible for administration of the drug. (Mosby’s Medical Dictionary, 8th edition, 2009)
Survivor-centered, empowerment-oriented programs want to avoid controlling survivors’ medications. This is why the WAC specifies that individuals must have secure storage and ready access to their medications. Survivors should be in control of their own and their children’s medicine. But when we make it difficult for survivors to have immediate and timely access to OTC medication, we are controlling their choices, and failing to offer a full range of options for responding to the abuse and making one’s own choices. It is okay to expand a survivor’s control and choices over their and their children’s health by safely making OTC medications available – just as we would make bandages or ice available for a wound. Increasing the ease with which a survivors can make choices about OTC medications can impact their life beyond their interactions with the program. In particular, making emergency contraception available can give a survivor the change to prevent an unintended pregnancy.
What are programs doing?
Programs around the state have implemented many creative ways of meeting the medication and contraceptive needs of survivors.
- Providing sample sizes of Tylenol, ibuprofen, aspirin, cold medicine, etc.
- Offer the larger-size items and ask for participants to take what they need and return the item immediately
- Let participants know that the program has pregnancy tests and emergency contraception available (don’t wait until someone asks)
- Give everyone an individual lock box for personal medication storage
What first aid supplies must be provided?
“You must keep first-aid supplies on hand and accessible to clients residing in emergency shelter for immediate use. In instances where an adult or child has ingested a potentially poisonous chemical or substance, you must call the Washington poison center for further instruction. Instructions for contacting the Washington poison center must be included with either the first-aid supplies or visibly posted for residents, or both.” WAC 388-61A-1185
What are the requirements for storing medications?
“(1) Clients residing in emergency shelter must be provided with a means to safely and securely store, and have direct and immediate access to, their medications such as individual lock boxes, lockers with a key or combination lock, or a similar type of secure storage.(2) All medications, including pet medications and herbal remedies, must be stored in a way that is inaccessible to children.” WAC 388-61A-1190