From Mr K. M. Youings, MRPharmS
SIR,—It is interesting to see that the topic of packaging has come up in correspondence in one way or another regularly for the past 40 years. I do not suggest I have the answers, but perhaps I could comment. As with most things in life, some compromise and understanding in reaching a satisfactory outcome are needed.
Labelling has long been a contentious subject. I suspect the arguments have not changed too much over the years. I believe it was "Onlooker " in about 1954 who featured a report by a "moon man " to his lunar masters following a trip to England. He recommended adoption of a system of 26 letters and 10 digits that have an infinite number of combinations and was more reliable than the use of the limited range of lunar colours for identification purposes.
From the dispensing pharmacist's viewpoint, clarity of labelling is a key feature of achieving accuracy of dispensing. However, the argument that in a busy pharmacy, pharmacists do not have time to read every label in detail is a dubious line that I have had quoted to me. Some understanding of reality is needed. Investigating mistakes of all kinds over many years, one never ceases to be amazed at how often a mistake is missed even when checks are made by several people. What is the chance of someone who has checked 1,000 labels that have been correct identifying number 1,001 that is incorrect? Pharmacists are no less susceptible to this than anyone else. Labelling quality will never make mistakes a thing of the past; at best it can help reduce them. Dispensing pharmacists must recognise their potential for fallibility too.
One has sympathy with the industry's need to reduce the number of label variants to a minimum. International companies have a wide range of regulations to meet in many countries, What might be a prescription pack in the United Kingdom may be an over-the-counter pack elsewhere. The cost implications of variants are significant, hence every effort is made to find a compromise. Some countries do regulate concerning minimum sizes for type faces for certain label data. This does not result in clear labels in many cases. The industry should remember back to the time that the UK regulations were being drafted: the initial draft specified minimum type sizes, but this was changed because of the reality that size in itself is not a guarantee of clarity and that the use of space and colour in combination with size and type face gave the best opportunities for clarity to be achieved. This is why regulations use terms like "conspicuous " and "prominent " for certain labelling requirements. On most labels, the data are not present within what I see as the ordinary meaning of these words. This is perhaps an area that the industry should reflect upon.
Is this not an area where the Royal Pharmaceutical Society's common interest groups could come together to try to find a way through the problem? It requires a non-dogmatic approach on all sides, and much goodwill. But surely a set of well thought out and practical proposals
within the scope of existing regulations would receive a sympathetic hearing from an industry for which safety has to be a major concern.
K. M. Youings Romford, Essex