We are updating our content for unapproved therapeutic goods. Please give your feedback.
How you prescribe an unapproved product for an individual patient depends on if the:
- patient is seriously ill (Category A – medical practitioners only)
- product and your practitioner type is on our established history of use list (Category C)
In these cases you can prescribe immediately. You must notify us within 28 days.
If you aren't eligible to apply through categories A or C, use the application pathway (Category B). You must apply and wait for approval before prescribing.
If you want to prescribe medicinal cannabis, it is generally faster to do so through the application pathway (Category B).
You must register an account to apply using the online system.
SAS and AP Online System- external site
Register an account
- Go to the SAS and AP Online System.
- Select Register now.
- Follow the prompts.
Submit the form
- Go to the SAS and AP Online System.
- Select the SAS Dashboard.
- Select New SAS submission.
- Fill in and submit the form.
To find out more read the SAS online system guidance.
Patient is seriously ill (Category A)
You can prescribe an unapproved therapeutic good for an individual patient who is seriously ill.
You must be a medical practitioner to use Category A.
A health practitioner can submit the form on your behalf. For example, a pharmacist.
Medicines and biologicals
To prescribe medicines or biologicals under Category A, your patient must be
seriously ill with a condition from which death is reasonably likely to occur within a matter of months, or from which premature death is reasonably likely to occur in the absence of early treatment.
Medical devices
To prescribe medical devices under Category A, your patient must be
seriously ill with a condition that is reasonably likely to lead to the person’s death within less than a year or, without early treatment, to the person’s premature death.
If your patient is not 'seriously ill'
If your patient does not fit the ‘seriously ill’ definition, consider prescribing under categories C or B.
Find out other ways to access unapproved therapeutic goods.
Notify us (Category A)
If your patient is seriously ill, you can prescribe the unapproved product immediately.
You must submit a form to notify us within 28 days of use of the unapproved product. You can fill in and submit the form in the online system.
A copy of the form must be kept with the patient’s medical record. As it is a notification system, you will not receive an approval letter.
The prescriber must be a medical practitioner. A health practitioner such as a pharmacist can submit the form on behalf of the prescriber.
SAS and AP Online System- external site
Product is on our established history of use list (Category C)
We have deemed some unapproved therapeutic goods to have an established history of use.
These goods are recorded in the SAS Category C lists.
You can prescribe unapproved products on the lists.
Whether you can prescribe a product depends on your profession and the patient's medical condition. These requirements are recorded in the list.
Check the list of products with an established history of use
Notify us (Category C)
You can prescribe the unapproved product immediately.
You must submit a form to notify us within 28 days of use of the unapproved product. You can fill in and submit the form in the online system.
A copy of the form must be kept with the patient’s medical record. As it is a notification system, you will not receive an approval letter.
A health practitioner such as a pharmacist can submit the form on behalf of the prescriber.
SAS and AP Online System- external site
Application pathway (Category B)
You can prescribe unapproved products through the application pathway (Category B):
You should do this if you can't apply through categories A or C.
You can’t prescribe immediately. You must apply and wait for an approval letter.
Another health practitioner such as a pharmacist can submit the form on your behalf.
Medical and other health practitioners can apply to prescribe unapproved products through this pathway.
What you can prescribe depends upon your scope of practice, qualifications, condition being treated and state and territory requirements.
If you don't have experience with a product or condition, you must get a letter of support from an appropriate specialist.
Clinical justification
You must provide brief clinical justification that supports the use of the product for the medical condition.
Your brief clinical justification should summarise relevant past treatments and procedures trialled or considered.
You should give reasons why products in the Australian Register of Therapeutic Goods may not be an appropriate treatment.
Summarise the expected clinical benefits versus the potential risks.
How to apply (Category B)
To apply to prescribe an unapproved product under Category B, submit the form in the online system.
SAS and AP Online System- external site
How your application is assessed
Your application will be processed in 2 to 5 days.
It may take longer if we need to ask you for more information.
It will be assessed by an officer of the Therapeutic Goods Administration. The officer will be a registered medical practitioner or pharmacist.
Decisions are made on a case-by-case basis.
Obtain unapproved products
As the prescriber, it is your responsibility to source the product.
You can do this in conjunction with the dispensing pharmacy.
If you can't source a product, contact someone experienced with importing unapproved products. For example:
-
a hospital pharmacy
-
wholesalers
-
sponsors.
We give health practitioners approval to access unapproved products.
We don't arrange the supply of therapeutic goods.
Report adverse events and product defects
You are responsible for reporting adverse events or defects from the use of unapproved products you've prescribed.
You must report any suspected adverse events or defects within 15 days of learning of them.
Frequently asked questions (FAQ)
What is an unapproved therapeutic good?
In general, medicines used in Australia must be entered in the Australian Register of Therapeutic Goods (ARTG), which is regulated by the Therapeutic Goods Administration (TGA).
All other therapeutic goods not included in the ARTG are considered ‘unapproved’ medicines. Importantly, unapproved medicines have not been assessed by the TGA with regards to safety, quality, and effectiveness.
Which pathway should I use?
The TGA has developed an interactive accessing unapproved therapeutic goods tool to assist health practitioners to determine the most appropriate pathway (if any) to access an unapproved therapeutic good.
Which therapeutic goods are available through the SAS?
Potentially any unapproved therapeutic good can be supplied through the SAS Category A and B pathways, with the exception that the SAS Category A pathway cannot be used to access drugs of abuse in Schedule 9 of the Poisons Standard where the manufacture, possession, sale or use is prohibited by State or Territory law.
For SAS Category C, there is a list available that specifies the medicines, biologicals and medical devices, their indications and the type of health practitioner authorised to supply these products. See the SAS Category C list.
Can health practitioners apply to have unapproved goods added or removed from the SAS Category C legislative instrument?
Health practitioners cannot apply to the TGA to have therapeutic goods included or removed from the legislative instruments.
The TGA will regularly review unapproved therapeutic goods and make changes to add or remove products from the Category C legislative instruments as appropriate. For example, if TGA believed there were significant safety concerns with a therapeutic good it may be removed from the instrument and any further supply of the product would need approval via the existing Category B pathway.
I am having issues with logging into my online system account, how do I get help?
In order for the Special Access Section to assist with all portal enquiries, please send an email with the below information to sas@health.gov.au:
- full first and last name
- AHPRA number
- username
- email address linked to the account
- screenshot of the issue.
The team will review the issue you are having and respond within 3 business days.
When do SAS approvals or notifications expire?
The SAS Category A notification will remain valid as long as the patient continues to meet the Category A definition.
The SAS Category B approval is valid for the period of time specified on the approval letter signed by the TGA delegate as long as the conditions of approval are upheld.
The SAS Category C notification will remain valid as long as supply of the unapproved good continues to meet the conditions specified in the SAS Category C list, except for medicines containing substances captured by the Customs (Prohibited Imports) Regulations 1956, which a new Category C notification form will need to be submitted if further quantities are required.
What clinical justification is required for a SAS Category B application for an unapproved therapeutic good?
When applying to access an unapproved product on behalf of a patient under the SAS Category B pathway, prescribers must provide a clinical justification. The justification should include the seriousness of the patient's condition, consideration for the use of medicines that are included in the ARTG and the potential risks and benefits of using the proposed unapproved medicine.
The clinical justification may be succinct and should summarise:
- an outline of the patient's symptoms and/or diagnosis
- details of relevant past treatments and procedures trialled or considered, including reasons why therapeutic goods currently included in the ARTG may not be the most appropriate treatment for the individual patient in the particular circumstance
- an appraisal of the expected clinical benefits versus the potential risks of the proposed treatment.
How should I submit my SAS application and notifications?
The preferred pathway of submission is via the SAS and AP Online System.
Can copies be provided of previous SAS application submitted to TGA?
Requests for original application forms submitted to TGA will be considered on a case-by-case basis and will only be provided to the health practitioner whose details are provided on the form. Please email sas@health.gov.au with your request.
Does a completed SAS Category A notification form, Category B approval letter or authorisation through SAS Category C automatically grant access to a therapeutic good?
Sponsors are under no obligation to supply an unapproved therapeutic good. Before considering accessing unapproved therapeutic goods or submitting an application to the TGA, health practitioners should check with the sponsor of the goods to confirm that they will supply the product.
In addition, TGA approval does not override any State or Territory requirements for lawful supply of an unapproved good. These requirements can be product specific, and may be checked with contacts for state/territory medicines & poisons regulation units.
How do I get the product once the TGA has given approval/authorisation?
The TGA does not supply any therapeutic goods.
If the product is available from a supplier in Australia, you should contact the supplier (sponsor) to organise supply. Within an institution such as a hospital, supply of a medicine may be arranged through the pharmacy department. The supplier will require authorisation to release the product. In the case of supply for a Category A patient, the completed Category A form acts as the authorisation. For Category B, an approval number is issued by the TGA and will appear in an approval letter sent to the requesting doctor by the TGA. For Category C, the inclusion of a product in the legislative instruments acts as the authorisation. See the SAS Category C list.
A completed notification form is not required to authorise supply of products through SAS Category C, however a completed notification form must be submitted to the TGA no later than 28 days after the product has been supplied.
If the product is not available from an Australian sponsor, the requesting health practitioner will need to find an overseas source. The product will then need to be imported from that supplier. This can be done by the doctor, a pharmacist, hospital, by the patient or by a licensed importer. When seeking to arrange importation of an unapproved medicine, it is important to check whether it is controlled under Customs (Prohibited Import) Regulations, in which case it cannot be imported without an import permit. A full list of controlled substances is available on the Office of Drug Control website.
If the product is a prohibited import, a permit or licence (or both) may be required. Permits and licences are administered by the Office of Drug Control. For further information please email dcs@health.gov.au
Downloadable forms
You can apply using a downloadable PDF form in exceptional circumstances.
For example, if you are unable to access the online system.
Information entered into the form must be typed, not handwritten.
Your application will be processed within 7 days. We won’t process your application if information is missing or it is not legible.
To submit the form, email it as a PDF or Microsoft Word document to sas@health.gov.au
Category A
Category B
Category C
Contact us
To find out more email sas@health.gov.au
Medicinal cannabis
For questions related to medicinal cannabis email medicinal.cannabis@health.gov.au