Disproportionate burden assessment: patient group directions

As of September 2018, accessibility legislation states that public sector websites must publish content in an accessible format. This means making our website content ‘perceivable, operable, understandable and robust’. You can read more about how our website complies with this regulation in our accessibility statement.

Patient group directions (PGDs) have been published on our website in PDF format only.  This format may not be fully accessible to users of assistive technologies.

Patient group directions provide a legal framework that allows some registered health professionals to supply and/or administer specified medicines to a pre-defined group of patients, without them having to see a prescriber such as a doctor or nurse prescriber.

For example, we provide PDGs for response to a hazardous materials (HAZMAT) and chemical, biological, radiological and nuclear (CBRN) event. There are also a variety of other PGDs available on our website.

Assessment outcome

We have assessed the requirements for providing this information as web copy (in HTML) and have concluded that to do so presents a disproportionate burden for the following reasons:

Target audience

This clinical operational information has a limited and highly specific target audience. For example, the patient group direction: Ciprofloxacin 500mg (Plague) was accessed 30 times in the 6 months between September 2023 and March 2024, indicating that the likely audience is small.

Cost and volume of resource to produce

PGDs can be lengthy and are regularly updated. The format specifies some elements (for example UKHSA co-branding and a series of signatures) to be legally compliant. Creating these in HTML would require a legally compliant web template to be developed, at significant cost to NHS England’s digital services.

Creating and maintaining the hundreds of PGDs would not be possible within the existing capacity of the NHS England web team.

Benefit of greater accessibility

We have concluded that despite recognising the accessibility limitations of publishing PGDs in PDF, it would be a disproportionate burden to publish them in HTML.

The documents will be published as PDF, acknowledging the limitations this causes to users of assistive technologies, and providing users with a contact to request alternative formats.

How long this assessment will apply

This assessment is likely to apply until the work to develop a new NHS England website is concluded. Discovery work on this project started in March 2024.

Reasonable adjustments

Under the Equality Act 2010 or the Disability Discrimination Act 1995 (in Northern Ireland) we will make reasonable adjustments for people who need information in a more accessible format. You can find out more about reasonable adjustments in our Accessible Information Standard.