Recent public statements have suggested that pharmacists may independently administer vaccines by injection. This has created confusion among health care providers and the public.
Federation of Private Medical Practitioners’ Associations, Malaysia (FPMPAM) states the position clearly and accurately.
Vaccination By Injection Is A Medical Act Under Malaysian Law
Vaccination is a clinical procedure, not a retail transaction.
Under Malaysian legislation, including the Medical Act 1971 (Act 50) and the Private Healthcare Facilities and Services Act 1998 (Act 586) and its regulations, only registered medical practitioners, and where expressly allowed, other authorised clinical personnel, may administer invasive clinical procedures such as vaccines.
No press release, advocacy effort, or proposed training programme can alter this statutory scope. Training alone does not create clinical authority. Clinical authority requires legislation.
Vaccination Requires Training, Competency, Credentialing, And Privileging
A vaccination encounter involves:
- Clinical assessment and evaluation.
- Screening for comorbidities and contraindications.
- Emergency management of anaphylaxis, shock, or collapse
- Access to oxygen, emergency drugs, and resuscitation capability.
In health care governance, clinical procedures are authorised only when four elements are in place, namely training, competency, credentialing, and privileging.
These come only with comprehensive medical education and supervised clinical training in:
- Anatomy, physiology, pathology, immunology.
- Emergency medicine and resuscitation.
- Medico-legal accountability under the Medical Act.
Vaccination is not just an injection, it is a clinical responsibility.
National Precedent Is Clear, Even During The Covid-19 Pandemic
During the global Covid-19 vaccination programme at vaccination centres across Malaysia, involving millions of injections:
- Doctors vaccinated.
- Pharmacists counselled.
Despite the urgency, volume pressure, and manpower needs, pharmacists were not authorised to vaccinate. If the law did not permit pharmacists to vaccinate even in a national emergency, it cannot suddenly be reinterpreted under normal circumstances.
This Is Not About Turf Protection, It Is Safety And Legal Accountability
Characterising this as “gatekeeping” or “turf protection” is inaccurate. This issue relates to:
- Patient safety.
- Scope of practice compliance.
- Clinical accountability under statute.
Convenience cannot replace competence.
Pharmacists Are Vital Within Their Legal Scope
Pharmacists play an indispensable role in:
- Medication safety.
- Pharmaceutical counselling.
- Chronic care support.
Collaboration is encouraged, provided each profession practices within its legally defined scope. Respect for scope protects patients and preserves public confidence.
Ministry Of Health Enforces The Law To Ensure Patient Safety
The Ministry of Health (MOH), through the director-general, administers and enforces the Private Healthcare Facilities and Services Act 1998 (Act 586) to ensure clinical services, including vaccinations, are conducted safely and lawfully.
The DG’s statement on October 24, 2025 reflects the current regulatory position applied in Malaysia.
Regulatory clarity protects patients and prevents unauthorised clinical practice.
Conclusion
The message is simple:
- Respect the law.
- Respect professional boundaries.
- Protect patients.
Doctors must be allowed to perform procedures for which they are trained, competent, credentialed, and accountable.
Pharmacists should continue their vital role in pharmaceutical care and patient counselling.
When every profession fulfils its duty within the law, the rakyat will benefit, and Malaysia’s health care system remains safe, strong, and credible.
This statement was issued by FPMPAM president Dr Shanmuganathan Ganeson.
Supported by:
- Private Medical Practitioners’ Association of Kuala Lumpur and Selangor (PMPASKL).
- Penang Private Medical Practitioners’ Society (PMPS Penang).
- Perak Medical Practitioners’ Society (PMPS Perak).
- Association of Private Practitioners Sabah (APPS).
- Private Medical Practitioners’ Society Kedah and Perlis.
- Private Medical Practitioners Association Pahang.
- Sarawak Private Medical Practitioners Association.
- This is the personal opinion of the writer or publication and does not necessarily represent the views of CodeBlue.
