What should you know when planning to start work with precursors, psychotropic substances and narcotic drugs?
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One of the activities of our firm is the assistance in obtaining a license for work with precursors, narcotic drugs and psychotropic substances.
Today we will give answers to the most frequently asked questions related to this topic, which we constantly hear from our Clients.
What are the requirements for the staff?
Requirements for the staff are determined by paragraph 31 of the License Terms. The criteria that employees must meet differ depending on the type of activity of the licensee and on the type of substances themselves.
For example, if it is a medical institution, then there must be workers with the specialty "Medicine", "Nursing". If veterinary - "Veterinary medicine." If a business entity produces substances that are considered drugs, it must have pharmacists (specialty "Pharmacy"). Characteristically, the number of such employees is not established by the conditions.
A slightly different situation with the precursors from list 2 of table 4 of the List. If the licensee is engaged in the production of precursors from this list, it must have at least 25% of employees with higher education (bachelor's , master's degree) in its main areas of activity. All qualification requirements are defined in the technological regulations of the licensee for the manufacture of these substances.
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In the case of the use, storage and sale of precursors from list 2 of table 4 of the List, the enterprise should also have at least 25% of employees with higher education in the main areas of its activity, but without reference to qualification requirements defined by its regulations. These are usually specialties related to chemistry.
Important! Absolutely all personnel who will have access to substances must undergo a medical examination for any contraindications to working with narcotic and psychotropic substances and receive an appropriate certificate. In other words, everyone should be tested for drug addiction.
Who should be responsible for precursors, psychotropic and narcotic substances and how to properly take this person on the staff: should he/she be on staff or can he/she work part-time?
The person responsible for the chemicals can be either the head of the enterprise or the head of the department / division directly working with the substances.
This person must have a higher education degree in the relevant specialty: chemistry, medicine, veterinary medicine, pharmacy - depending on the type of substances and the nature of the enterprise.
About taking people on the staff or prohibition of part-time jobs, there is not a word in the licensing conditions, therefore up to the licensee to decide.
Related article: Our lawyers obtained a license for operations with precursor chemicals
What are the requirements for the room where chemicals are stored and / or used?
No matter how you intend to work with these materials, before starting work, you need to obtain permission from the National Police to use the facilities and premises intended for the relevant work.
Requirements for the premises where activities with these substances are carried out are determined by paragraphs 80-87 of the terms and conditions. Most often they depend on the type of substances.
The vast majority of the precursors from list 2 of table 4 are flammable. Therefore, special attention should be paid to ensuring fire safety. For example, walls cannot be covered with combustible materials, and the floor must be made of non-combustible materials.
Of course, unauthorized persons should not have access to such premises, there should be bars on the windows, external walls should be solid, and there should not be any outside organizations and orphan rooms in the neighborhood.
For the storage of precursors, narcotic and psychotropic substances used in medical and diagnostic institutions, as well as expert research laboratories, the safety requirements are even more stringent:
- They should be stored in a separate room, which is located in the capital structure;
- The room should be equipped with technical security equipment, safes and / or metal cabinets;
- Doors and windows should be equipped with a locking system.
Related article: We got a license for handling the precursors for a government laboratory whose drug test certificate was about to expire
Therefore, as we see, the requirements for both the staff and the premises depend on the type of substances and the work that will be carried out. That is why it is important to correctly determine to which list and to which table these or those chemicals belong, and also to pay attention to their concentration, percentage in mixtures.
Sometimes it even turns out that a license is not needed at all, but you need to be 100% sure of this. And if you know for sure that you need a license or are unsure how to arrange your activities correctly, you can turn to our specialists for advice.
We also want to draw your attention to the fact that the transportation of precursors, psychotropic and narcotic substances falls within the scope of regulation of other regulatory acts (such as transportation of dangerous goods) and requires separate registration
Related article: Requirement to the staff, which are engaged in the transportation of dangerous cargo and waste.