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Section VI

The Imperative to Evaluate National Drug Control Policy

Both the INCB and the WHO have called on governments to evaluate their health care systems and laws and regulations, and to identify and remove impediments to opioid availability for medical needs (3, 4, 5, 9, 10, 11). While it is equally important to evaluate national drug control policy for its potential ability to prevent trafficking, diversion and abuse of controlled substances, information and guidance are available for such evaluation (12).

A 1995 INCB report (3) commented on the extent of diversion of narcotic drugs:

"The international system to prevent diversion of narcotic drugs is working well. The number of incidents involving diversion of narcotic drugs is small considering the large number of transactions at the international and national level" (p. 1).

Therefore, the sole focus of this Guideline is on the evaluation of national drug control policies that affect opioid availability.

In 1989, the INCB (9) stated:

"One of the objectives of the Single Convention on Narcotic Drugs, 1961, and of that Convention as amended by the 1972 Protocol amending the Single Convention on Narcotic Drugs, 1961, is to ensure the availability of opiates, such as codeine and morphine, that are indispensable for the relief of pain and suffering, while minimizing the possibility of their abuse or diversion" (p. 3).

In 1989, the INCB (9) reviewed the reasons for inadequate opioid availability in cooperation with the WHO, and requested governments throughout the world to:

"...examine the extent to which their health-care systems and laws and regulations permit the use of opiates for medical purposes, identify possible impediments to such use and develop plans of action to facilitate the supply and availability of opiates for all appropriate indications" (p. 17).

In 1990, the WHO Expert Committee on Cancer Pain Relief and Active Supportive Care (4) recommended that national governments should provide for:

"...regular review [of legislation], with the aim of permitting importation, manufacture, prescribing, stocking, dispensing and administration of opioids for medical reasons,...[and] review of the controls governing opioid use, with a view to simplification, so that drugs are available in the necessary quantities for legitimate use..." (p. 65-66).

In 1995, the INCB (3) surveyed all governments[8] to determine if they had responded to the Board's 1989 recommendation. Responses to the survey were analyzed and published, and a number of conclusions and recommendations were made, including that:

"Governments that have not done so should determine whether there are undue restrictions in national narcotics laws, regulations or administrative policies that impede prescribing, dispensing or needed treatment of patients with narcotic drugs, or their availability and distribution for such purposes, and should make the necessary adjustments" (p. 15).

"The Board notes that most governments in the world did not respond to its questionnaire; thus, the Board did not have sufficient information concerning approximately one half of the world’s population. Among those governments that did not respond were most of the developing and least developed countries, as well as those governments that had frequently failed to submit annual estimates of narcotic drug requirements as required by the 1961 Convention. The Board is cognizant that less developed countries have more difficulty meeting basic health-care needs. Nevertheless, the Board encourages governments of such countries to make efforts to examine their medical needs for narcotic drugs as well as the impediments to their availability" (p. 14).

"The Board concludes that the recommendations contained in its 1989 special report are far from being implemented and that, while there have been efforts by some governments to ensure the availability of narcotic drugs for medical and scientific purposes, it appears that many others have yet to focus on that obligation" (p. 14).



[8]        Sixty-five governments responded in time to be considered in the INCB’s 1995 report, published in 1996. Since then, 57 more countries responded. Analysis of all 122 surveys indicates that problems with availability of opioids are even more severe than was thought based on the initial response (to be published in the INCB 1999 annual report).

 

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