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Shardul Nautiyal, Mumbai February 22 , 2019
In its ongoing crackdown on illegal sale of narcotic drugs, the Drug Controller General of India (DCGI) has directed all the state drug controllers and the industry to urgently address non-compliance to Schedule H, H1 and X and plug the loopholes in the drug supply chain system.

In a letter addressed to the state drug controllers and industry associations, DCGI has stated that concerns have been raised regarding illegal sale of prescription medicines in a clandestine manner. Representations have been received in the context of sale of psychiatric medicines without prescription also.

This letter is a wake up call for the drug regulatory mechanism across the country as the central drug regulator has been getting reports of rampant misuse of certain habit forming drugs and illegal sale of psychiatric medicines without prescription over the past few months.

Taking cognizance of the scenario, Gujarat Food and Drug Control Administration (FDCA) recently canceled 27 drug retail licenses and suspended 35 drug retail licenses for illegal sale of codeine containing cough syrup without prescription and purchase bill

It seized 40,352 codeine phosphate containing cough syrup bottles of 100 ml each worth Rs. 46 lakh from a firm based in Ahmedabad.

Following its irrational use, some companies have, however, stopped producing codeine phosphate containing brands. This has led to circulation of spurious brands in the market, according to an official.

However, unscrupulous drug dealers posing as authorised stockists have found their way in violating the conditions of license as stipulated in Rule 65 of the Drugs and Cosmetics (D&C) Rules. It has also been observed that cough syrups are also sold in the absence of pharmacist.

The Central government through a notification dated November 14, 1985 had declared the list of narcotic drugs and preparations to be considered to be manufactured drugs. At Serial Number 35 codeine is stated. This entry has exemption for preparations compounded with one or more other ingredients and containing not more than 100 mg of the drug per dosage unit and with a concentration of not more than 2.5 per cent in undivided preparation.

Besides this, it also stipulates as being established in therapeutic practice as another criteria for its exemption as manufactured narcotic drug.

Hence, these preparations are also as per Rule 97(c) not to be labeled with suffix NRx (narcotic drugs) but rather to be labeled as Rx (Schedule H) as per Rule 96(b) of Drugs and Cosmetics Act, 1940 and Rules thereunder.
 
Schedule H and H1 implies that it contains a substance specified in Schedule H and H1 with the symbol Rx. The symbol need to be conspicuously displayed on the top left corner with the warning that it has to be sold in retail on the prescription of a registered medical practitioner only.

Schedule X contains a substance specified in Schedule X to be labeled as XRx which shall be in red conspicuously displayed on the top left corner of the label with the words saying to be sold in retail on the prescription of a registered medical practitioner only.

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