Q.01

Can UK schools keep spare adrenaline nasal sprays?

Not yet. The law currently in force lets schools keep spare adrenaline auto-injectors without a prescription, but not adrenaline nasal sprays. On 19 October 2026 (today) the MHRA opened a consultation on changing the Human Medicines Regulations 2012 so schools could hold nasal sprays as well.

What the law allows now (Schedule 17, Human Medicines Regulations 2012)

  • Supply to schools: Prescription-only medicines can be sold or supplied to a school only if they are "(a) an inhaler containing salbutamol; or (b) an auto-injector containing adrenaline". The head teacher or principal must sign an order giving the school's name, why the product is needed and the total quantity. The product may only be used to supply or give medicine to pupils in an emergency. [1]
  • Giving it to a pupil: A trained person carrying on the business of a school may give "an auto-injector containing adrenaline", but only to a pupil at that school who is known to be at risk of anaphylaxis and needs it in an emergency. [1]
  • The schedule text I searched does not mention a nasal or intranasal adrenaline product anywhere.

The MHRA states this directly: "supply to schools of self-administered adrenaline products without a prescription is currently limited to Adrenaline Auto-Injectors and does not extend to Adrenaline Nasal Sprays" (MHRA consultation document).

What the MHRA is proposing

  • Adrenaline nasal spray was authorised in July 2025. The MHRA now proposes adding it to the Schedule 17 school exemptions alongside auto-injectors (consultation page).
  • Schools could choose to hold auto-injectors, nasal sprays or both. They would not have to stock both (MHRA press release).
  • The current safeguards would stay. Emergency adrenaline could only be given to children known to be at risk of anaphylaxis, and only by appropriately trained school staff (press release).
  • The consultation covers the whole UK and is run jointly with the Department of Health in Northern Ireland. It closes at 11:59pm on 14 December 2026 (consultation page).

Until an amending instrument is made, a school can only hold nasal sprays prescribed to named pupils. It cannot buy spare ones under the school exemption.

Approach: I read the latest revised text of the Human Medicines Regulations 2012 (Schedule 17) and checked it against the MHRA's consultation document, consultation page and press release on GOV.UK. I found no amending regulations yet.

Q.02

What do the rules allow for spare auto-injectors now?

Schools across the UK can buy spare adrenaline auto-injectors without a prescription and keep them for emergencies. Under Schedule 17 of the Human Medicines Regulations 2012, a trained member of staff may use one on a pupil known to be at risk of anaphylaxis. These provisions have applied since 1 October 2017 [1].

1. Buying them (Schedule 17, Part 1, entry 12) Part 1 lets suppliers sell or supply prescription-only medicines to a school without a prescription. Entry 12 covers "(a) an inhaler containing salbutamol; or (b) an auto-injector containing adrenaline". Two conditions apply:

  • The supplier must receive an order signed by the principal or head teacher. The order must give the name of the school, the purpose the product is needed for, and the total quantity.
  • The product must be for supplying or administering to pupils at the school in an emergency.

The auto-injector wording was substituted by SI 2017/715 (S.R. 2017/241 for Northern Ireland). The same instrument inserted "or administering". Both changes took effect on 1 October 2017 [1].

2. Using them (Schedule 17, Part 3, entry 11) Part 3 covers who may administer prescription-only medicines. Entry 11 lets "a person ('P') carrying on the business of a school who is trained to administer the relevant medicine" give "an auto-injector containing adrenaline". The administration must meet all three conditions:

  • (a) it is in the course of P carrying on the business of a school;
  • (b) it is to a pupil at that school who is known to be at risk of anaphylaxis;
  • (c) the pupil needs the product in an emergency.

SI 2017/715 and S.R. 2017/241 inserted this entry from 1 October 2017 [1].

What the exemption does not cover

  • Who can receive it: only pupils at that school who are known to be at risk of anaphylaxis. It does not reach visitors, staff, or pupils not known to be at risk.
  • How it is given: the auto-injector entry sits in Part 3, which covers administration. In Part 2, which covers supply, the school entry (entry 11) lists only salbutamol inhalers for pupils known to have asthma. No auto-injector appears there. So the school's role with spare auto-injectors is for trained staff to administer them [1].
  • Which products: only auto-injectors. Nasal sprays are the subject of the MHRA consultation discussed earlier, which closes on 14 December 2026.

Approach: I read the current revised text of Schedule 17 to the Human Medicines Regulations 2012 (legislation.gov.uk), including its amendment notes. Government guidance for schools on spare auto-injectors (storage, consent, registers) is not in the datasets I searched; I can look for it on GOV.UK if useful.

Q.03

Who is allowed to give it to a child?

Under Schedule 17, Part 3, entry 11 of the Human Medicines Regulations 2012, a school's spare adrenaline auto-injector can be given by "a person ('P') carrying on the business of a school who is trained to administer the relevant medicine". That means trained school staff. They can give it only to a pupil at that school who is known to be at risk of anaphylaxis and who needs it in an emergency [1]. A separate, wider rule in the Regulations covers giving adrenaline to save a life.

Why the law needs an exemption at all Regulation 214(2) says a person may not give a prescription-only medicine by injection ("parenterally administer") to someone else unless they are an appropriate practitioner, or are acting on that practitioner's directions. Appropriate practitioners include doctors, dentists, and nurse or pharmacist independent prescribers. Injecting yourself is not covered by this restriction [2]. Teachers and other school staff are not appropriate practitioners, so they need an exemption.

Route 1: trained school staff (Schedule 17, Part 3, entry 11) All of the following must apply [1]:

  • Who gives it: a person carrying on the business of a school who is trained to give the medicine. The Regulations do not set out what the training must be.
  • Which product: "a prescription only medicine comprising an auto-injector containing adrenaline".
  • Who receives it: (a) it must be given in the course of carrying on the school's business, (b) to a pupil at that school who is known to be at risk of anaphylaxis, and (c) the pupil must need it in an emergency.

So the exemption does not reach staff who have not been trained. It also does not cover visitors, staff, or pupils who are not known to be at risk.

Route 2: anyone, to save a life (regulation 238 and Schedule 19) Regulation 238 says the regulation 214(2) restriction "does not apply to the administration of a prescription only medicine specified in Schedule 19 where this is for the purpose of saving life in an emergency" [3]. Schedule 19 lists "Adrenaline 1:1000 up to 1mg for intramuscular use in anaphylaxis" [4]. This route is not limited to schools, trained staff or pupils known to be at risk. Its only conditions are that the purpose is to save life in an emergency and the product falls within that Schedule 19 description.

Approach: I read the current revised text of the Human Medicines Regulations 2012 on legislation.gov.uk: regulation 214, regulation 238, Schedule 17 and Schedule 19. GOV.UK guidance for schools on spare auto-injectors (training, consent, registers) is not in the datasets I searched. I can look for it on GOV.UK next if that would help.

Q.04