Restricted List medicines and exporting

Wholesale dealers of medicines may not see all the publications that community pharmacists receive, so they may be unaware that the problems that community pharmacists experience in obtaining certain medicines for prescriptions remains a significant problem.

For that small percentage of pharmacies that have obtained a wholesale dealers licence, and are selling medicines for export, then some thought needs to be given to written procedures that will demonstrate to an MHRA inspector how products that are listed on the current months shortage list in the PSNC newsletter are being handled.

For wholesalers of medicines the challenge of exporting restricted list medicines is no easier, particularly for those wholesalers who do have community pharmacy customers. Whilst legal action is yet to be taken against an exporting wholesaler or pharmacy, it would be wise for those involved in exporting to consider what written proof they could provide, if challenged, as to how their actions could be proved not have compromised supply to UK patients.

For example, things that could be considered that may go some way towards showing regard for the restrictions upon exporting certain medicines, if challenged, could include:

* which products are exported, what are they used to treat, and how unique are they. The more serious the condition treated and the more unique the product, perhaps the more serious the breach if exported?

* what records are kept on each sale for export occasion to prove that checks have been undertaken upon stock availability from at least main wholesalers and manufacturers?

* are some buffer stocks retained for the UK market, of products in short supply, and appropriate detailed records kept to prove such?

The current situation is clearly unsatisfactory, and it remains to be seen whether 2012 is the year when this issue is taken more seriously by all actors.  In the meanwhile wholesale suppliers should consider carefully their actions and how they would prove that they have not exacerbated the UK supply problems.