The Pharmaceutical Journal
Vol 273 No 7315 p312-315
4 September 2004

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· The Charter
· Charter ballot
· Volunteer agencies
· Voting
· Personal control
· Medicines and devices
· Simvastatin
· Ward technicians
· CAM
· Remuneration
· The Profession
· Education
· CRCs
· Retention fee
· Onlooker

Letters to the Editor

CRCs

Still confused over CRCs

From Mr P. D. Burgess, MRPharmS

About three years ago I wrote to various companies asking them to repackage their non child-resistant packs into child-resistant containers but some things fall on deaf ears. So I still have a dilemma every time I dispense a medicine in a pot with a patient information leaflet attached. Do I transfer it to a child resistant bottle and throw away the pot with the patient information leaflet or use the original pot and run the risk that I will be found out for not using child resistant packaging? What does the law department of the Royal Pharmaceutical Society advise? Presumably I have some safety nets in the supplier’s liability if they are packaged.

Does the Society not have any control or influence over pharmacists in the pharmaceutical industry? Why are superintendent pharmacists not appointed for each pharmaceutical company so that someone is accountable for faulty packaging. Pressure could be brought so that packaging could be altered to a standard that community pharmacists would have no problems with. If there was an issue in the past with packs being tampered with, then the Society could insist that all the packs have seals. Perhaps I should have considered this when voting on the Charter?
If the Government took control could it do a better job and come up with commonsense judgements instead of knee-jerk reactions to single incidents that seem to be someone trying to cover the extreme risks associated with the chance of the same incident occurring twice?

Paul Burgess
Kingston-upon-Thames, Surrey

Priya Sejpal, pharmacist adviser, fitness to practise and legal affairs directorate, Royal Pharmaceutical Society, replies:

The Royal Pharmaceutical Society does not have regulatory authority over the pharmaceutical industry, and the labelling and packaging of medicinal products by manufacturers falls within the remit of the Medicines and Healthcare products Regulatory Agency.
Pharmacists are required under the Medicines for Human Use (Marketing Authorisations) Regulations 1994, to supply a patient information leaflet with all dispensed medicinal products. Details on the supply of PILs can be found in Fact Sheet 3, and can be accessed at www.rpsgb.org

The supply of dispensed medicinal products in a child resistant container is a requirement of the Code of Ethics. The Code requires that “apart from under certain circumstances all solid and all oral and external liquid preparations must be dispensed in recloseable child resistant containers”. It is recognised that there may be circumstances where this is not possible. A list of such circumstances is detailed on p89 of the ‘Medicines, ethics and practice’ guide. One such circumstance is where the medicine is in an original pack or patient pack such as to make this inadvisable.

Pharmacists must act in the best interests of the patient, and should use their professional judgement in each individual situation to determine what is most appropriate for the patient.

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