Are nappy rash creams medications?
How often do you have parents complaining that they have to authorise the use of nappy creams? Have you ever wondered whether a nappy cream or product is considered to be a medication in the Education and Care Regulations? Is medication actually defined in the Regulations?
The answer to that is yes. The Regulations say medication has the same meaning as medicine does in the Commonwealth Therapeutic Goods Act 1989. Here is where it gets a bit complicated, so I’ll try and give you the short version of what this Act says medicine is.
Under the Therapeutic Goods Act medicine means therapeutic goods that will or are likely to achieve a result by pharmacological, chemical, immunological or metabolic means. Therapeutic goods include things that may prevent, cure or alleviate a disease, ailment or injury. Most nappy rash creams seem likely to fall into this category. If they don’t they are probably not very good at fixing nappy rash.
Still not sure if nappy rash creams are medicines? In Australia therapeutic goods can be lawfully supplied if they are entered in the Australian Register of Therapeutic Goods (ARTG). You can search the register to see if a product if entered by going online at http://www.tga.gov.au/industry/artg.htm
There were approximately 73,434 products on the ARTG as at July 2013. I just did a quick search and found several products listed including Curash brand products and some pawpaw ointments.
However, there will undoubtedly be some nappy rash products that aren’t listed on the ARTG. This may include products that people have imported for personal use and which don’t need to be listed on the ARTG or “natural” products that don’t make therapeutic claims about preventing, curing or alleviating something.
To avoid confusion, doubt and extra work, it would be appropriate to treat all nappy rash creams as medications. Stating this explicitly in your policies and procedures will make this clear to parents and educators.