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WHO resolution - Action taken etc.



to: ip-health@cptech.org, pharm-policy@cptech.org,     
    e-drug@usa.healthnet.org
subj: WHO Resolution - Action taken
no/dt: H.4/1998.5.6
from: cutscal@cal.vsnl.net.in


Dear Sir/Madam,

Greetings from CUTS!

I have the pleasure to introduce myself, Rajat Chaudhuri, as  the 
Coordinator of Consumer Unity and Trust Society (CUTS), Calcutta, 
India. 

Consumer Unity & Trust Society (CUTS) is a leading social  action 
group  in India, and an active member of Consumers  International 
(CI),   working   at  the  grassroot,  national,   regional   and 
international  levels  by pursuing social  justice  and  economic 
equity within and across borders. 

Presently  our Calcutta office is working on health  and  related 
areas   of   TRIPS  (Agreement  on  Trade  Related   Aspects   of 
Intellectual Property rights) and Pharmaceuticals etc.    

This  mail is with reference to the new WHO  resolution  appended 
below  (a  list  of appendices is provided at  the  end  of  this 
letter)  that is to be tabled at its regular Assembly to be  held 
in  May.  The  new  resolution makes  some  important  points  in 
relation to the TRIPS agreement and its probable implications for 
the health sector.      

The  new WHO resolution urges Member states primarily  to  ensure 
that "public health rather than commercial interests have primacy 
in  health  policies  and  to  review  their  options  under  the 
Agreement  on  Trade related Aspects  of   Intellectual  Property 
Rights (TRIPS) to safeguard access to essential drugs." 
     
In  this context it may be noted that India which is a  signatory 
to  the TRIPS agreement needs to change its patent  laws  (Indian 
Patent  Act,  1970) by 31st December, 1999, to bring it  in  line 
with  the  international  laws  on  patenting  of  pharmaceutical 
products. Being a developing nation India  has been given a grace 
period  of ten years for technologies previously  unprotected  in 
its  market. During this interim period of ten years  all  patent 
applications will be put in a `black box'. However pharmaceutical 
corporations  can apply for an `exclusive marketing  right  (EMR) 
for  their  products for five years only even  before  India  has 
phased   into   the  new  patent  protection   system.   In   the 
pharmaceuticals  sector  India presently allows  process  patents 
only. 

The implications of the above and related rules are:

*  the  introduction  of product patents  may  imply  significant 
social costs due to the higher prices charged for medicaments;
*  the access to local firms of protected technology will  become 
more difficult because of the enforcement of the  patent-holder's 
bargaining position through investments in R&D; and
*   there is the  possibility that the most dynamic  segments  of 
the  pharmaceutical  market, where the prospects  of  growth  are 
highest, will be excluded from domestic firms.  
 
Side by side with the above some facts revealed by a recent study 
by Consumers International are poignant in this respect:

A  critical analysis of the retail prices of 22 dosage  forms  of 
common  essential  drugs in over 30 countries  around  the  world 
revealed -

* The average retail price of 18 out of 20 dosage forms are  very 
much higher in developing countries of South and Central  America 
than in developed countries

* Many consumers in developing countries with low per capita  GDP 
are  paying much higher retail prices than some consumers in  the 
affluent and developed countries.

The situation being such it can be well imagined what will be the 
consequences when transnational pharmaceutical giants get most of 
the patent rights for pharmaceutical products.

It is expected that the United States will seek to exclude  point 
no.  2 from the WHO resolution. 

The  WHO resolution among other things also urges member  nations 
to  promote rational use of drugs through independent  up-to-date 
and  comparative  drug  information.  It  further  requests   the 
Director-General  of  the  WHO to continue  the  development  and 
dissemination of information on rational prescribing.

In this context we can mention an India-wide prescription   audit 
study  done  by our organisation in 1995 which brought  to  light 
alarming facts like:

*   Propensity  to  prescribe drugs carrying   brand  names  when 
generic names were also available.
*   Affinity to prescribe drugs manufactured by MNCs. 
*   Tendency  to  prescribe  comapratively  costlier  and  higher 
generations of medicines. 
*   Rampant polypharmacy
*   A large number of unnecessary prescriptions
*   A large number of incomplete prescriptions
*   A  large number of irrational,  semi-rational  and  alarming 
prescriptions

Studies done by others have come to similar conclusions.  

Our  organisation  is seeking funds for launching  a  nation-wide 
advocacy  campaign  with  various  state  governments  and  other 
decision-making  bodies to install a standing prescription  audit  
in  various  states  of the country and to get  a  list  of  safe 
essential  drugs  adopted  by  the  governments.  

We take this opportunity to ask all readers to help us in getting 
funds  to  implement  this project which in the  long  run  would 
translate to improved health for the people of one of the world's 
most  populous countries. Please find appended below (a  list  of 
appendices  is provided at the end of this letter)  an  executive 
summary of this project. 

Please  also  find  appended   below  (a list  of  appendices  is 
provided at the end of this letter)a letter which we have sent to 
our  Health, Commerce and Industry ministries as also the  Indian 
ambassador  to the United Nations asking them to support the  new 
WHO   resolution   and  take  appropriate  policy   measures   in 
concurrence with its contents.

We  feel  that  the  US opposition to point  no  2.  of  the  WHO 
resolution  needs to be countered with cogent logic and facts.  

The appended mail which we have sent to our governement will give 
you an outline of our stand and the future work we would like  to 
do  in  the  area of health. (In this context  please  also  find 
appended  below an executive summary of a health related  advocay 
project  that we have designed. We will feel obliged if  you  can 
guide  us  to  funders who may be interested  in  financing  this 
project) 

With regards

Rajat Chaudhuri <Coordinator>
Consumer Unity & Trust Society (CUTS),
3-B Camac Street, Calcutta 700016.
Ph: 91.33.29 7391/2786
Fax: 91.33.29 7665/249 6231
Email: <CUTSCAL@CAL.VSNL.NET.IN>   
Website: http://www.cuts.org
(KINDLY ALWAYS QUOTE THE REFERENCE NUMBER/DATE IN YOUR RESPONSE)

APPENDICES: 1) MAIL SENT BY OUR ORGANISATION TO THE INDIAN GOVERNMENT 
            2) THE NEW WHO RESOLUTION   
            3) EXECUTIVE SUMMARY OF THE HEALTH ADVOCAY PROJECT   


[][][][][][][][]   COPY OF LETTER TO GOVERNMENT [][][][][][][][][][][][]


To: Mr Dilip Sinha, India's Ambassador to the United Nations 
    Secretary, Ministry of Health and Family Welfare
    Secretary, Ministry of Commerce  
    Secretary, Ministry of Industry 

Dear Sir, 

Greetings from CUTS!

You  may  be aware that the World Health  Organisation  (WHO)  is 
going to hold its regular Assembly in May of this year and  among 
other  things consider a new resolution. The new  WHO  resolution 
(appended  below)  is  also  available on the  WHO  web  page  at 
http://www.who.ch/gb/pdfangl/angr24.pdf

The  new WHO resolution urges Member states primarily  to  ensure 
that "public health rather than commercial interests have primacy 
in  health  policies  and  to  review  their  options  under  the 
Agreement  on  Trade related Aspects  of   Intellectual  Property 
Rights (TRIPS) to safeguard access to essential drugs." 
     
In  this context it may be noted that India which is a  signatory 
to  the TRIPS agreement needs to change its patent  laws  (Indian 
Patent  Act,  1970) by 31st December, 1999, to bring it  in  line 
with  the  international  laws  on  patenting  of  pharmaceutical 
products. Being a developing nation India  has been given a grace 
period  of ten years for technologies previously  unprotected  in 
its  market. During this interim period of ten years  all  patent 
applications will be put in a `black box'. However pharmaceutical 
corporations  can apply for an `exclusive marketing  right  (EMR) 
for  their  products for five years only even  before  India  has 
phased   into   the  new  patent  protection   system.   In   the 
pharmaceuticals  sector  India presently allows  process  patents 
only. 

The implications of the above and related rules are:

*  the  introduction  of product patents  may  imply  significant 
social costs due to the higher prices charged for medicaments;
*  the access to local firms of protected technology will  become 
more difficult because of the enforcement of the  patent-holder's 
bargaining position through investments in R&D; and
*   there is the  possibility that the most dynamic  segments  of 
the  pharmaceutical  market, where the prospects  of  growth  are 
highest, will be excluded from domestic firms.  
 
Side by side with the above some facts revealed by a recent study 
by Consumers International are poignant in this respect:

A  critical analysis of the retail prices of 22 dosage  forms  of 
common  essential  drugs in over 30 countries  around  the  world 
revealed -

* The average retail price of 18 out of 20 dosage forms are  very 
much higher in developing countries of South and Central  America 
than in developed countries

* Many consumers in developing countries with low per capita  GDP 
are  paying much higher retail prices than some consumers in  the 
affluent and developed countries.

The situation being such it can be well imagined what will be the 
consequences when transnational pharmaceutical giants get most of 
the patent rights for pharmaceutical products.

It is expected that the United States will seek to exclude  point 
no.  2  from the WHO resolution. You would appreciate  very  much  
the implications of such an exclusion. Moreover we would  request 
your  good offices to coordinate and brainstorm on  the  delicate 
areas of the TRIPS agreement so that our options remain open  and 
the  health of the nation is not left at  the mercy  of  mindless 
profit-seekers. In this context we would request you to  strongly 
support the WHO resolution and especially point no 2.

The  WHO resolution among other things also urges member  nations 
to  promote rational use of drugs through independent  up-to-date 
and  comparative  drug  information.  It  further  requests   the 
Director-General  of  the  WHO to continue  the  development  and 
dissemination of information on rational prescribing.

These  are some of the other areas which needs your  support.  In 
this  context  we can mention a nation-wide  prescription   audit 
study  done  by our organisation in 1995 which brought  to  light 
alarming facts like:

*   Propensity  to  prescribe drugs carrying   brand  names  when 
generic names were also available.
*   Affinity to prescribe drugs manufactured by MNCs. 
*   Tendency  to  prescribe  comapratively  costlier  and  higher 
generations of medicines. 
*   Rampant polypharmacy
*   A large number of unnecessary prescriptions
*   A large number of incomplete prescriptions
*   A  large number of irrational,  semi-rational  and  alarming 
prescriptions

Studies  done by others have come to similar  conclusions.    (In 
this  context   it  can be mentioned that our   organisation   is  
seeking funds for launching a nation-wide advocacy campaign  with  
various  state  governments and other decision-making  bodies  to 
install   a  standing  prescription audit  in various  states  of  
the   country  and  to  get  a  list of  safe   essential   drugs  
adopted  by  the governments.) 


In view of these and the new WHO resolution we again request  you 
to take a stand supporting the points of the resolution which you 
may  think  would be beneficial for our country.  Especially  the 
items  dealing  with  TRIPS, rational   use  of  drugs,  rational 
prescribing,  we  feel,   need  to  be  supported  with  all  our 
collective might. 

It is expected that such support which you might provide to  this 
WHO resolution and the possible changes in government policy that 
you  may  influence  in  the process, will   go  a  long  way  in 
promoting consumer benefits and health of the nation.  

With regards

Rajat Chaudhuri <Coordinator>
Consumer Unity & Trust Society (CUTS),
3-B Camac Street, Calcutta 700016.
Ph: 91.33.29 7391/2786
Fax: 91.33.29 7665/249 6231
Email: <CUTSCAL@CAL.VSNL.NET.IN>   
Website: http://www.cuts.org
(KINDLY ALWAYS QUOTE THE REFERENCE NUMBER/DATE IN YOUR RESPONSE)


[][][][][][][]    END OF LETTER   [][][][][][][][][][][][][][][][][]

THE  NEW WHO RESOLUTION TO BE CONSIDERED IN ITS REGULAR  ASSEMBLY 
TO BE HELD IN MAY.


101st Session                                 EBl0l.R24
Agenda item 9                            27 January 1998


                   Revised drug strategy

The Executive Board

>RECOMMENDS to the Fifty-first World Health Assembly the adoption 
of the following resolution:
>
>    The Fifty-first World Health Assembly,
>
>Recalling resolutions WHA39.27, WHA41.16, WHA43.20, WHA45.27, WHA47.12,
>WHA47.13, WHA47.16, WHA47.17, and WHA49.14;
>
>    Having considered the report of the Director-General on the revised
>drug strategy;
>
>Noting the activities of WHO to further the implementation of the
>revised drug strategy, in particular through support to the development
>and implementation of national drug policies; the strategy to review and
>assess the effectiveness of the WHO Ethical Criteria for Medicinal Drug
>Promotion; the flow of market information; guidelines for drug
>donations; and model drug information;
>
>Recognizing with satisfaction the progress made, and approving WHO's
>comprehensive response to current and new challenges in the
>pharmaceutical sector;
>
>Commending the strong leadership shown by WHO in promoting the essential
>drugs concept and national drug policies, which are contributing to the
>rational use of resources in the pharmaceutical sector and to improved
>health care;
>
>Noting with satisfaction that a number of Member States have adopted
>guidelines for drug donations that were based on the interagency
>guidelines issued by WHO, but concerned that inappropriate drug
>donations, such as donations of expired, mislabelled, in essential
>products, continue to be common;
>
>Concerned about the situation in which one third of the world's
>population has no guaranteed access to essential drugs, in which new
>world trade agreements may have a negative impact on local manufacturing
>capacity and the access to and prices of pharmaceuticals in developing
>countries, and in which poor quality pharmaceutical raw materials and
>finished products continue to move in international trade;
>
>Concerned also that drugs continue to be irrationally used by
>prescribers, dispensers and the general public, and because unethical
>promotion in developed and developing countries and a lack of access to
>independent, scientifically validated drug information contribute to
>such abuses,
>
>URGES Member States:
>
>(1) to reaffirm their commitment to develop, implement and monitor
>national drug policies to ensure equitable access to essential drugs;
>
>(2) to ensure that public health rather than commercial interests have
>primacy in pharmaceutical and health policies and to review their
>options under the Agreement on Trade Related Aspects of
>Intellectual Property Rights to safeguard access to essential drugs;
>
>(3) to establish and enforce regulations that ensure good uniform
>quality assurance standards for all pharmaceutical materials and
>products manufactured in, imported to, exported from, or in transit
>through their countries; :
>
>(4) to enact and enforce legislation or regulations in accordance with
>the principles of the WHO Ethical Criteria for Medicinal Drug Promotion,
>and to monitor drug promotion in collaboration with interested parties;
>
>(5) to develop or maintain national guidelines governing drug donations
>that are compatible with the interagency guidelines issued by WHO and to
>work with all interested parties to promote adherence to such
>guidelines;
>
>(6) to promote the rational use of drugs through the provision of
>independent, up-to-date and comparative drug information, and to
>integrate the rational use of drugs and information about commercial
>marketing strategies into training for health practitioners at all
>levels;
>
>(7) to promote and support consumer education on the rational use of
>drugs and its inclusion into school curricula;
>
>(8) to evaluate progress regularly, making use of indicators developed
>by WHO or other suitable mechanisms;
>
>(9) to continue their funding and material support for the revised drug
>strategy especially by the provision of extra budgetary resources to
>WHO;
>
>2. REQUESTS the Director-General:
>
>(1) to support Member States in their efforts to develop and implement
>policies and programmes that achieve the objectives of the revised drug
>strategy, including the development of tools, guidelines and
>methodologies for evaluation and monitoring;
>
>(2) to adopt a comprehensive strategy to implement the WHO Ethical
>Criteria for Medicinal Drug Promotion and to continue to review its
>effectiveness with all interested parties;
>
>(3) to extend the guidelines incorporated in the WHO Certification
>Scheme on the Quality of Pharmaceutical Products Moving in International
>Commerce to cover pharmaceutical starting
>materials; develop and disseminate uniform guidelines on the regulatory
>control, export, import and transit conditions of pharmaceutical
>products; and develop standards of practice for entities involved in
>international trade in pharmaceuticals and pharmaceutical raw materials;
>
>(4) to strengthen and expand the provision of independent information on
>market prices of raw materials of assured quality for production of
>essential drugs;
>
>(5) to continue the development and dissemination, also using electronic
>media such as the Internet, of independent information on pharmaceutical
>product safety and instances of counterfeit drugs or medicines, on drug
>selection and on rational prescribing;
>
>(6) to assist Member States to analyse the pharmaceutical and public
>health implications of agreements overseen by the World Trade
>Organization and to develop appropriate policies and regulatory
>measures;
>
>(7) to review and update the revised drug strategy to reflect current
>and continued challenges in the pharmaceutical sector and the principles
>articulated in the renewed health-for-all policy;
>
>(8) to report comprehensively to the Fifty-third World Health Assembly
>on progress achieved and problems encountered in the implementation and
>renewal of WHO's revised drug strategy, with
>recommendations for action.

=================================================================
[][][][][][][][][]      EXECUTIVE  SUMMARY  OF  HEALTH   ADVOCACY 
PROJECT   [][][][][][][][][][][][][][][][][][][][][][][][][][][][]

CUTS                       Consumer Unity and Trust Society
                                 3-B, Camac Street, 
                                 Calcutta 700 016 
                                 Ph: 91.33.29 7391/2786 
                                 Fx: 91.33.249 6231/29 7665
                                 Email: cutscal@cal.vsnl.net.in
                                 Website: http://www.cuts.org


STANDING PRESCRIPTION AUDIT AND A LIST OF SAFE ESSENTIAL DRUGS


Funding Proposal: EXECUTIVE SUMMARY


BACKGROUND

Consumer Unity & Trust Society (CUTS) is a leading social  action 
group  in India, and an active member of Consumers  International 
(CI),   working   at  the  grassroot,  national,   regional   and 
international  levels  by pursuing social  justice  and  economic 
equity within and across borders.     

In a four series workshop for training of young consumer  leaders 
organised  by  CUTS the Voluntary Consumer  Action  Network(V-CAN 
i.e.We  can!)  was launched which adopted the  vision  statement: 
"Affordable  and  sustainable  health care  for  all",  with  the 
mission: "Equipping activists to empower people to achieve  their 
right to health."

In a nationwide survey done in 1995 by V-CAN, data of about  2000 
prescriptions from Rajasthan, West Bengal, Gujarat,  Maharashtra, 
Tamil  Nadu  and Andhra Pradesh were  assessed and the  data  was 
analysed  using  World  Health  Organisation's  guidelines.   The 
analysis  showed alarming trends of  misprescription,  irrational 
prescription,   unnecessary  prescription  of   costlier   drugs, 
predeliction for brand names, incomplete prescriptions and  other 
such serious lacks. 


THE PROPOSAL

The  dismal scenario prevalent in this country as brought out  by 
the  report  of  the  prescription audit,  coupled  with  a  more 
liberalised  drug policy and reduced controls  on  pharmaceutical 
industry  necessiates follow up. Health being a state subject  it 
has  been  decided to pursue state level advocacy  for  having  a 
standing  prescription audit. Under similar situations  elsewhere 
in  the  world  standing  prescription  audits  have  shown  good 
results.  It is also proposed to use advocacy to make  the  state 
governments adopt a list of safe essential drugs.




GOALS

To  undertake  advocacy and communicate with  the   legislatures, 
executive, judiciary and the medical profession for installing  a 
standing  prescription  audit  system  and get  a  list  of  safe 
essential  drugs adopted by state governments. The object  is  to  
improve  the quality of health delivery systems available to  the 
common man.


METHODOLOGY

1.  VCAN will organise four advocacy workshops in four  different 
states. The aim will be to get  standing prescription audits  and 
a list of essential drugs declared in these four states.

2.  The advocacy workshops will involve representatives from  the 
legislatures, the executive, the judiciary, media persons and the 
medical profession and representatives from civil society  groups 
(NGOs  and other voluntary organisations). So both  the  decision 
making  strata and civil society-where opinion is built, will  be 
represented.     

3.   The  workshops  will discuss in detail the  results  of  the 
previous  prescription audit done by VCAN and other  such  audits 
done elsewhere in this country. Placing these results against the 
broader   perspective  of  the  prevalent  health  scenario   and 
liberalised   drug  policy  as  also  reduced  controls  on   the 
pharmaceutical  industry  the interactions will  be  tailored  to 
impress  upon  the decision makers the importance of  the  avowed 
aims.

4.  These workshops will   review  plans for further advocacy and 
campaign, identify media strategies for national and zonal  level 
advocacy  and  campaigns.  It  is  also  proposed  to  publish  a 
quarterly newsletter highlighting various facets of health issues 
in  the  country as well as editorialising upon the  need  for  a 
standing  prescription  audit,  a list of  safe  essential  drugs 
declaration.     

ANTICIPATED OUTCOME

The advocacy workshops and newsletter will serve to increase  the 
awareness  of decision makers about the importance  of  improving 
prescribing  practices.  Public opinion coupled with a  sense  of 
belongingness  and  motivation that will be imbibed  in  decision 
makers as well as the medical fraternity to lead to adoption of a 
standing prescription audit and a list of essential drugs. 

Publication  of  newsletter  as well  as  transactional  analysis 
techniques(used in the advocacy workshops) will help to  generate 
increased  awareness and responsibility on part  of  prescribers. 
These would serve as self-regulatory devices and further help  to 
improve  the quality of health delivery systems available in  the 
country.  

FUNDS SOUGHT

   Head                                            Rs.

     
A.   4 Regional Workshops:                         2,20,000
     i) Travel 
     [ Average Rs.1,000 X 20 ]        20,000

     ii) Boarding & Lodging
     [ Rs.450 X 2 days X 20 ]         18,000

     iii) Venue & Seminar kit         12,000
       [hiring charges of hall, 
       P.A. system photocopier, 
       computer etc]

     iv)  Communication & Overheads     5,000


B.    National Workshop:                          1,80,000

     i) Travel 
     [ Average Rs.5,000 X 20 ]        1,00,000
          
     ii) Boarding & Lodging
     [ Rs.750 X 3 days X 20 ]           45,000
    
     iii) Venue & Seminar kit           28,000
     [ hire of hall, P.A. system
       photocopier, computer etc]

     iv)  Communication & Overheads      7,000


E.   Newsletter 
     (Writing, printing, posting
      & presentation etc)
     [ 2000 copies x Rs.12.50 x 4]                    1,00,000

                                                    ----------
GRAND TOTAL                                      Rs.  500,000 
                                                    ----------
                                               ( US $ 12,820  
                                                 US $ 1.00= Rs 39)     


Rupees five lac only
     
US dollar twelve thousand eight hundred and twenty only

                    ===============  

[][][][][][][][][][][]  END  [][][][][][][][][][][][][][][][]