Dose form Intended sites vs. Routes of administration

Hello DEUSG,

Please provide feedback here concerning the Dose form Intended sites vs. Routes of administration discussion on April 9th, 2025 DEUSG Meeting.

Key Points:
Discussing the difference between the dose form intended sites, and routes of administration.
Evaluating whether these can use the same list of concepts in SNOMED CT.
Considering the mapping to different EDQM code lists.

Considerations:
Dose form intended sites refer to the locations where a medication is applied or administered.
Routes of administration describe the path by which a drug enters the body.
While there may be some overlap, these concepts serve different purposes in medication documentation.

SNOMED CT Usage:
SNOMED CT has separate hierarchies for these concepts today.

EDQM Mapping:
EDQM maintains different code lists for these concepts.

Consultation:
Are there requirements from real-world use cases to change the SNOMED representation of these concepts to use a single list of concepts for both? What are the risks and challenges of such an approach?

Original topic and comments can be viewed here.

Linda Bird gave a very good explanation and clarification in her Comments.

Current Definitions

736474004 |Has dose form intended site (attribute)|
Dose form intended site describes the general anatomic location that the dose form has been formulated for administration to or at. The intended site is not intended to describe a precise site or route of administration. For example, eye drops (prepared for ocular intended site) are subject to pharmacopoeial standards for pH, and sterility.
410675002 |Route of administration (attribute)|
The route of administration is the path by which the product is taken into or makes contact with the body, and is a property of the administration action. The route of administration of a medication is determined by the prescriber in their prescription dosage instructions for a particular patient.
736479009 |Dose form intended site (intended site)|
The set of values for dose form intended site that relate to characteristics associated with a pharmaceutical dose form and do not refer to a precise anatomic location.
284009009 |Route of administration value (qualifier value)|
The set of values for route of administration. For medicinal products these values are associated with the action of administration.

Consultation:
Are there requirements from real-world use cases to change the SNOMED representation of these concepts to use a single list of concepts for both? What are the risks and challenges of such an approach?

The definition of ā€œhas intended siteā€ is wrong (or doesn’t align with the range).
You don’t need to look far to see:

  • 738956005|Oral (intended site)| - doesn’t mean ā€œpertaining to the mouthā€ oral site.
    It means something like ā€œtaken by the mouth for systemic effect via entral routeā€.
    <738982001|Oromucosal| - ā€œpertains to the mouthā€ - but are not subsumed by ā€œOralā€.
  • Similarly <385287007|Parenteral dose form (intended site)| or <738904002|Cutaneous (intended site)| and 738987007|Transdermal (intended site)| - are not ā€œsitesā€. The upper part of my arm is a site - to which I might receive an injection or apply a patch (systemic effect) or cream (local).

EDQM might call this ā€œintended siteā€ but that doesn’t mean it’s right. (I assume the definition is lifted from there?)

What want for the drug model is a route of administration. Because that’s what’s clinically relevant.

This hints at what the use case is - closed loop logic between medication instructions (pre or post coordinated) and dispense.

For example if I have a medication instruction ā€œParacetamol 500 mg p.o.ā€ .

This might be coded in the back end using
777067000|Paracetamol only product|
#500 258684004|mg|
26643006|Oral route|

Possible medications for dispense should then be able to be identified using ECL, but they can’t be because the dose forms use ā€œintended sitesā€.

We’ve been trying to support this exact use case for years in our dose based prescribing support (particularly for hospitals) - but it just doesn’t work due to the current modelling. This has been a known issue since 2017.

I suspect the motivation for creating ā€œintended sitesā€ is probably similar to that for Unit of Presentation - in that the existing content was a bit messy, and EDQM alignment…
The problem is also that for both areas - extensions are going to need (already are) add further content - so the range for both is never going to be a pure mirror of EDQM - which should never be the goal anyway.

Tricky, looking at EDQM this is their definition for the Intended site - Oral (taken from the EDQM Stabdard Terms website):

Relating to the mouth as the intended site of administration, but where the pharmaceutical product is administered with the intention of passing into the stomach via the oesophagus; the mucosa of the mouth itself is not the intended site of action (see oromucosal).

But I agree with the problem, there isn’t an obvious to go from ā€˜I want a patient to get a drug orally’ as a route of administration to the set of possible dose forms that can be used to deliver that route of administration.

At the moment the UK handles this by mapping every route and form combination to a series of prescribing patterns and refsets (mainly at Clinical drug / VMP) to support that dose based prescribing. This is extra and manual on top of the SI modelling.

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Just for clarification : in EDQM standard terms, the ā€œintended siteā€ (of administration) is the ā€œgeneral body site at which a pharmaceutical product is intended to be administered. EXAMPLES: Auricular; ocular; oral.
NOTE: The intended site is a general term that is used to group related pharmaceutical dose form concepts, and is not intended to describe a precise site or route of administration. (cf. Standard Terms - Introduction and Guidance for Use).

So the problem here is EDQM. And is the model they use really the right model for SNOMED CT.

ā€œgeneral body site at which a pharmaceutical product is intended to be administered. EXAMPLES: Auricular; ocular; oral .
NOTE: The intended site is a general term that is used to group related pharmaceutical dose form concepts, and is not intended to describe a precise site or route of administration.

So we have an ā€œintended siteā€ 738956005|Oral (intended site)|
But it has NO relation to any of these intended sites

But those ā€œsitesā€ are all in the mouth (oral)?

If we look at the text definition for 738956005|Oral (intended site)| (which I assume is lifted from EDQM)

An intended site for a dose form that is for administration by swallowing.

by swallowing…

The dose form model already has ā€œswallowā€

So let’s look at the combinations of ā€œsiteā€ and ā€œmethodā€ā€¦

Dose Form intended site administration method
1217288001|Soft oral capsule| Oral Swallow
1255338008|Chewable soft capsule| Oral Chew
385019009|Oral drops solution| Oral Instill
385023001|Oral solution| Oral Swallow
447079001|Orodispersible tablet| Oral Orodisperse

We can see that there’s a few different methods of administration. But these are all oral (via the mouth, swallowed, and processed by the digestive system) - that sounds like a route?

How are |Oral drops solution| different to 385072008|Oromucosal drops|?

Concerns about ā€œintended siteā€ being different from ā€œroute as instructedā€ or ā€œapproved routes for a productā€ - fail to acknowledge that we’ve got a hierarchy in SNOMED CT and can be more or less specific as required.

This concept has an intended route ā€œparenteralā€.

This one has a more specific intended route.

Just as this one is also a more specific ā€œParenteral dose formā€

It also looks like the 736665006|Dose form administration method| subhierarchy duplicates 420247005|Dosing instruction imperative (qualifier value)|.

Dosing instruction imperative Dose form administration method
417924000|Apply - dosing instruction imperative (qualifier value)| 738991002|Apply (administration method)|
419747000|Chew - dosing instruction imperative (qualifier value)| 738992009|Chew (administration method)|
421538008|Instill - dosing instruction imperative (qualifier value)| 738994005|Instill (administration method)|
422145002|Inject - dosing instruction imperative (qualifier value)| 740685003|Inject (administration method)|
421521009|Swallow - dosing instruction imperative (qualifier value)| 738995006|Swallow (administration method)|

Again, I suspect this is due to a combination of ā€œtight binding to EDQMā€ and ā€œnot wanting to resolve issues with the existing contentā€ (hence the creation of new semantic tags…) as with sites vs routes, and Unit of Measure

If we insist on having parallel hierarchy describe the same thing, it makes implementing things like processing coded prescription sentences/instructions to in conjuction with Medicinal Products just about impossible. Supporting prescribing and dispensing should be the primary use case for this content - but maybe that’s not the intent?

Of the 448 dose forms in core (<736542009) - only 182 are actually used (<763158003.411116001). I’m guessing the other 266 were generated from an EDQM transform. Yet, we’ve got 54 extra dose forms in AMT (some might exist in core and need fixing) but most are more or less specific that. e.g. |Intrathecal injection|. Can new dose forms be added to core? Or are we bound to what EDQM describes?

We’re not going to change EDQM - nor should we, it’s none of our business. But we can/should fix SNOMED CT. We should model dose forms, ontologically. Not shoehorn an existing model based on different principles.

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Hi,

We have an interest in this topic of routes of administration mapping between EDQM and SNOMED CT in Belgium. Currently the national drug database (SAMv2) uses Routes that match the EDQM labels. But for the project of nurse ePrescription, for our Vaccination Care set, the preferred choice of the NIHDI is to use SNOMED CT concepts since the rule in Belgium is to use SNOMED CT for data standardisation whenever possible (except labs where it’s LOINC).

So we have been asked at CSCT level to produce a mapping between the SAMv2 and SNOMED CT Routes for those national projects. Which we did, but there are unresolved issues. As you point out above, EDQM definitions are sometimes a bit contra-inutitive to the term used for them and result if ā€œtranslatedā€ to SNOMED CT to concepts subsuming others they should not given their definition and concepts not being the child of others when if seems from the term that they should. There are a few ā€œnon symetricalā€ (missing) entries in both. Then there are entries in EDQM that are not routes but methods (and what should we do with them?).

Here is a link to my working document with the pending questions we identified. Happy to work on this with anyone interested. ROA_v1.4

If we have differences in meaning/scope of concepts between the content of the drug prescription and the nursing administration data set, it’s a problem and I would not agree that errors in EDQM is not our problem. It’ll be a problem for implementers, so at least for me, it’s my problem.

I would suppose the people making EDQM are humans like us we could send remarks to and collaborate to produce alignment. It’s not like there are a thousand concepts concerned here. Plus we have the EEHRxF coming, that uses SNOMED quite a lot, so we have ground to go toward alignment and collaboration with EDQM like alignment was needed with LOINC to make things interoperable when one domain of data touches another. In Drugs you have borders with Findings (allergies, adverse effects) and with Procedures (administration, education).

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Apologies for such a long post, especially to those for whom English is not your mother tongue. But I wanted to be as comprehensive as I could because this topic seems to rumble on and on, which is not great for anyone.

Very few substances can be (legally!) administered directly; even a line of cocaine is probably cut with something! Olive oil as an ear drop is maybe one example of a pure substance being used as a medicine; enflurane liquid is another. So dose forms are the things that take a therapeutic substance from being just a substance to being something that can be administered to a patient: they allow us to formulate a medicine for administration.

Dose forms are therefore definitional to the description of a medicine (manufactured and/or administrable) because of their intrinsic characteristics. For the purposes of this discussion I have picked out just two characteristics:

Ā· the potency of an administration (a tablet contains xxx mg of therapeutic substance, a solution contains yyymg/mL) – without a dose form to describe a medicine, it is impossible to know the strength of a medicinal product

Ā· the level of ā€œpharmaceutical qualityā€ for a medicinal product, and hence have a sense of what would be appropriate routes for the administration

I suspect, from the threads in this post, that it is this second characteristic that is causing the discussion.

Dose forms are defined and controlled by pharmaceutical standards; they are in no sense arbitrary. A tablet must be produced by dry powder compression within a dye mould, whereas a pessary is produced by the cooling of molten material in a mould that is usually in two parts. That is why clotrimazole is presented as vaginal tablets not pessaries.
Within those pharmaceutical standards, there are considerations of pharmaceutical kinetics (an oral tablet must dissolve in x minutes in ph1-2 at 37C) and of appropriate quality (an injection must be sterile and have no pyogenicity; an eye drop solution must have a pH in a particular range). As you can see, these quality standards are quite closely related to where the dose form is intended to be used in the body, and often includes a body site in the name of the monograph for that dose form.

These standards apply to ALL dose forms regardless of the therapeutic moiety that will be incorporated into them. Therefore, when designing a model to fully define dose forms (as was originally done in SNOMED CT in 2005, long before EDGM were involved) this aspect of a dose form was named ā€œsite prepared forā€ or ā€œintended siteā€. Obviously, we can debate whether that was a good name for the attribute or not, but that is the name as it exists in informatic standards now. And because the value set of concepts that can fill this characteristic is not route of administration, and not strictly body site – really the concept is adjectival rather than noun-like (ocular drops is could be considered more correct than eye drops) and because there is no body site for parenteral, or possibly even ā€œcutaneousā€ or ā€œoralā€, a separate set of concepts was authored.

Route of administration is separate clinical concept. It is concerned with the administration of a particular medicinal product and its posology (so, this solution for injection containing 10mg/mL of gentamicin is suitable for intravenous administration and intramuscular injection). Although it meets the quality standards as a parenteral dose form, gentamicin injection is not suitable for subcutaneous injection, because it will be a little irritant and it will not provide sufficient therapeutic blood levels.

Route of administration is also concerned with the prescription and administration of a particular product for a particular patient at a particular point in time – hence we see route of administration as an attribute in most information models for prescriptions (HL7 V2, V3, FHIR etc).

Clearly, there can be a ā€œrelationship of sortsā€ made between a dose form’s intended site of administration and the likely route(s) of administration that a medicinal product with that dose form could be used with. But it is not absolute. The relationship is absolutely not always and necessarily true.

If I had absolutely no other options to treat a Pseudomonas conjunctival infection, I could take my 10mg/mL gentamicin solution for injection and prescribe it for a patient to use by putting drops into their eye (ocular route). Because of the pharmacopoeial standards that govern the dose form ā€œsolution for injectionā€ I can know that the patient will receive a sterile solution, so no risk of introducing further infection, and there will be no particulate matter, so no risk of scratching the cornea. But, because the pharmacopoeial standards for an injection solution are not as restrictive on pH and osmolarity as for an eye drop, I can be fairly sure that the patient is going to experience a lot of uncomfortable stinging. But if I am desperate to save their sight and I have no properly formulated gentamicin eye drops, I would do it.

So, for me, I could not support having a single set of concepts to describe a dose form intended site and a medicine’s routes of administration, or use a single set of concepts in a value set for prescribing and dispensing. If SNOMED CT and this group decide to go that way, for the implementations I am responsible for, I will have to branch away from SNOMED CT for this, which I would find somewhat sad, and definitely not good for my user community.

I will also offer some specific comments on the threads:

The only mapping I have ever found to be useful in clinical practice is a mapping FROM route of administration TO a group of medicinal products, based on dose form site prepared for. So the clinician selects ā€œgentamicinā€ and ā€œintravenousā€ and….the products that can be used are….the children of the MPF parenteral – which of course is based on dose form intended site :blush:
To have a subset of (for example) of the oral MPF medications that are liquid in their administrable form for patients with issues swallowing, it is really easy to get that from the basic dose form after any transformation to work the closed loop system. I’ve had such systems successfully deployed now for several years – including offering clinicians the option of ā€œauthorised routeā€ (for a particular actual product within a local environment) versus ā€œgeneric route setā€ providing the internationally accepted posologies for the particular medication.

As Stuart says, it is possible to maintain an ontology for this, and it can end up being a lot of work to maintain; but it is also possible to maintain something very clinically relevant using good rules and tools with only a reasonable maintenance overhead, especially if the raw data is available and well structured, as exists in a good medicines knowledgebase (not knowledgebase, not terminology).

I must admit I go slightly white at a statement that says ā€œoral means something like ā€œtaken by the mouth for systemic effect via enteral routeā€ – there are so many cases where that is not ā€œalways and necessarily trueā€ to list here, but the gut disinfectants and all of the antacids are good examples. And ā€œoromucosalā€ is quite a complex concept to use – particularly because if used as a route of administration, it is a grouper concept but when used as a dose form intended site, it indicates a particular set of pharmaceutical characteristics.

And of course, I have to fundamentally disagree that route of administration is definitional for the medicinal product model; it is a clinical concept (knowledge concept) that can change over time for any one medicinal product – so it cannot be always and necessarily true and definitional. Again, there are so many examples of medicinal products that extend (or reduce) their set of routes of administration over time that I will not list them here.

I do agree that some of the methods in the dose form model need further work, especially around ā€œswallowā€ and oromucosal medicines. But that is a complex topic that is beyond the core principle of how intended site concepts should nor should not be related to route of administration concepts.

I think we also need to be careful about current content. There is no such thing pharmaceutically as a specific ā€œintraperitoneal injectionā€ dose form even though EDQM possibly allows it (although not specifically with those words) ; there are injection (solutions) that can be administered as an intraperitoneal infusion or irrigation (which is actually a route plus a method). Actually, if I remember correctly, the SNOMED CT dose form hierarchy contains many concepts that are non-standard. These were not retired when the EDQM mapping was done, because retirement is always a little challenging, and there was no request to do so. But if one looks at the current SNOMED CT dose form hierarchy as if it is a fully quality assured hierarchy without applying any pharmaceutical principles, I think one could be misled. Similarly, I personally do not use the EDQM concepts ā€œwholesaleā€ without applying some judgement to them, because my clinical use cases are not the same as EDQM’s regulatory ones.

To Marie-Alexandre’s comments about EDQM routes of administration, to me this is a separate topic. As I am emphasising, route of administration is a clinical concept, and therefore not so directly relating to pharmacopoeial standards. For our pan-European work, we go some way beyond the EDQM routes of administration because our clinical use cases need more granularity and more specificity with regard to method of administration etc.

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MedDRA state these are different from their perspective (MedDRA collect adverse events data). When ā€˜wrong site’ is stated, it could be that a drug is given by the correct route, e.g. IV, intraocular, etc. but given at the wrong body site. Example: eye drops are given to the left eye instead of the right one. The dose form intended site is correct, but the site of administration is wrong.

Thanks @klilly and that’s exactly my point.

The forms have ā€œintendedā€ (site/route). And in practice there might be a different ā€œactualā€ site/route.

So eye drops might be intended for left eye (prescribing instruction - forms aren’t that specific) but accidentally administered to the right eye. Those are different sites.

The product dose for 385125006|Eye drops solution| - Has dose form intended site=Ocular.
If the patient drank that, it is a different site to what was intended, but more importantly it is a different route (to what the form was intended).

I agree that pharmaceutical standards define dose forms and that pharmaceutical quality is essential. In practice, though, most of that quality is already captured by how the product is intended to be used (what SNOMED currently models as ā€œintended siteā€). A solution for injection and a solution for ocular use have different quality requirements, and the dose form reflects that.

I also agree that the actual route used in a clinical situation isn’t definitional and people can (and do) administer products in off-label ways. What is definitional is the intended mode of use. Whether we call it ā€œintended siteā€ or ā€œintended routeā€, most users interpret this as the same thing: the functional route the form is designed for. Other attributes then refine this (e.g. injections vs infusions under parenteral).

An oral tablet has an intended route; using it differently doesn’t change what it is. And for practical use cases, like identifying forms appropriate for ā€œoral routeā€ on a prescription, it is far simpler to implement systems where the dose-form intent aligns with route concepts (shares the range, rather than navigate (and maintain) a mapping).

I’m not disputing that dose forms are defined by standards (though I don’t think manufacturing technique is a relevant distinction for clinical decision-making). Pharmacopoeias already allow multiple production methods for the same form, and major drug vocabularies don’t consistently distinguish ā€œvaginal tabletā€ from ā€œpessaryā€. That inconsistency suggests manufacturing method isn’t a stable ontological boundary.

This overview of pessary types demonstrates that manufacturing approaches vary, and classification isn’t uniform across jurisdictions.

Only the International Edition uses 784953008|Clotrimazole 100 mg vaginal tablet|

For our prescribing/dispensing use case, what matters is functional behaviour: how the form is intended to be administered.

  • Safety: The key question is whether the formulation is suitable for the intended route (pH, osmolality, sterility, etc.).
  • Interchangeability: If a prescriber orders ā€œvaginal clotrimazoleā€, should a dispenser be limited by manufacturing method, or guided by intended route/site?

I agree with Julie’s comments regarding the differences between intended site and routes of administration. Intended site and route of administration convey different meanings. They are not the same concepts. Intended site effectively indicates suitability of the manufactured dose form (e.g. eye drops don’t sting, parenteral solution don’t have particulate matter etc) and not the intended route of administration. Although I do appreciate that there are different points of view on the subtle differences.

Intended site is defined both in EDQM and ISO 11239 as previously cited. So we do need to consider aligning with such standards. Using intended site and not a route of administration will ensure there is no overlap given the meaning/intent is different. We are defining the dose form (in the absence of any product) and not the product (where licensed route of administration lies) or the intent of the prescriber, be it licensed or unlicensed.

Regarding interchangeability - For dose based prescribing, a clinician can order Clotrimazole with a dose (500mg) and route of administration (vaginal). This will allow a pharmacist/nurse to dispense/administer either pessaries or vaginal tablets, often driven by the hospital’s formulary.

The clinical drug concept in the international release is defined by its manufactured dose form and a distinction is made between a tablet and a pessary (in line with EDQM) based on the product information. Manufacturers are required to stipulate the excipients and release characteristics (disintegration/melting time), and therefore will need to distinguish between a pessary (molded form) and vaginal tablet (compressed form) in regulatory documentation but this may not always be reflected in the manufacturer’s product name or PDF and may vary between regulatory authorities.

Regarding the comment ā€˜whether we call it ā€œintended siteā€ or ā€œintended routeā€, most users interpret this as the same thing’ - One course of action may be to review the intended sites and their associated definitions and provide some additional guidance for users on intended site vs ROA/intended route?

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This use case is good. How do we implement that with the current modelling?

Modelling a generic product with a site looks good when there is a single route. Many products have multiple routes for which they could be used. Would your proposal include all of those routes in the modelling and the term? Also how would you propose to address where a manufacturer extends the product license to include an additional route

If the patient drank that, it is a different site to what was intended, but more importantly it is a different route (to what the form was intended).

Intended here can also cause problems as it depends on who depends what.
A manufacturer is likely to intend an eye drop to be administered to the ā€˜eye’, with a site to either left, right or both eyes. But a prescriber may intend that an eye drop is administered orally. Given the eye drop etc this may be completely safe (though a deliberately unlikely example).

For a real example there is a licensed Vancomycin injection, with a form of ā€˜Powder for concentrate for solution for infusion’. This is licensed for both intravenous administration and also licensed for oral administration. A direct link between the form and the ā€˜safe’ routes of administration is probably not possible.

The ā€˜dose form intended site’ intended by the manufacturer / regulator as part of the ā€˜form’.
On the side of keeping separate hierarchies, the EDQM (source for the concepts) states:

Standard Terms: Introduction and Guidance for Use – v.2.1.3 – 16 November 2018
NOTE: The intended site is a general term that is used to group related pharmaceutical dose form concepts, and is not intended to describe a precise site or route of administration

They are expected to be different, but this is the regulatory opinion.

As far as I can tell the main advantage to SNOMED is to allow a better specification that restricts the allowable values of 736474004 |Has dose form intended site (attribute)| and 410675002 |Route of administration (attribute)|. Meaning that the routes of administration that do not overlap with the Dose for intended sites are (correctly) not available for use in modelling a dose form.

The main disadvantage is you can’t have a prescription for a drug with a route and easily return the possible forms that can fulfil that route (even the straightforward ones). If we did have a single hierarchy, even if only some were supposed to be used to model a dose form, that becomes partly possible. It might become a lot more possible if we re-organised the route of admin hierarchy so as much as possible everything was a descendant of an EDQM dose form intended site.

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I’m not sure if this comment was directed at what I’m (proposing) or not.

Essentially my argument is that ā€œHas dose form intended siteā€ is effectively the same the same as ā€œHas dose form intended route of administrationā€ (at least that’s how I think every user is going to read it). And setting the attribute range to <284009009|Route of administration value| - greatly improves implementation support and logic when correlating with coded order sentences.

But I’m not proposing to model anything more than what’s already there.

If we want to get super pedantic/unambiguous about the language we could name the attribute ā€œHas dose form manufacturer intended siteā€ (or ā€œHas dose form manufacturer intended route of administrationā€).

ā€œMany products have multiple routes for which they could be usedā€

If the product has this dose form


Presumably it’s only intended for Parenteral (routes/sites).

If a product is intended for more than one site/route just as is done with this product.

I’m in no way suggesting me model any potential off label usage.

But I’m getting the impression there’s a lot of ā€œloaded languageā€ that I’m not appreciating?
e.g. Manufacturers can only say ā€œsiteā€ and only clinicians can say ā€œroute of administrationā€?

For the Vancomycin injection example.
If the VMP/CD issue currently modelled using this dose form
1237267003|Powder for concentrate for solution for infusion|

All I am proposing is that the target for the |Has dose form intended site| attribute should be from the <284009009|Route of administration value|
(Unfortunately, there’s no |Parenteral route| concept at the moment).

If it’s licensed for oral administration. That’s some other property - Has licensed route.
Licensed routes are out of scope for INT. You could have two (branded) products that are both 1231468000|Vancomycin (as vancomycin hydrochloride) 1 g powder for solution for infusion vial|
But if extensions wanted to have add such an attribute - it should use the same Range.

ā€œnot intended to describe a precise siteā€ - This suggests EDQM intended sites are not supposed to be a hierarchy?
So is this correct?
image

ā€œsite or route of administrationā€ - could be read as these phrases being interchangeable (as per my perspective).

In the EDQM the Intended sites are in a flat list with no hierarchy. Whilst ā€˜Ocular’ is an Intended site in EDQM, Intraocular, Intracameral and Intravitreal are not Intended sites in EDQM.

In EDQM Intraocular, Intracameral and Intravitreal are instead Routes of Administration.
The placing of these in a hierarchy is something SNOMED CT has done, and is not from EDQM.

I’d also note that we don’t exactly replicate EDQM. For example in SNOMED CT:

In EDQM the same ā€˜Pharmaceutical dose form’ has the EDQM characteristics:

The key difference here is in EDQM, it has an Intended site of ā€˜ocular’ but in SNOMED CT it has a Has dose form intended site of ā€˜intraocular’.

So we are already different from the EDQM model.

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