What mistakes are common for the process of obtaining the License to work with precursors?

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Our company has provided assistance in obtaining a license for the treatment of precursors, narcotic drugs and psychotropic substances for more than ten years now. During this time, we have noticed that at the stage of collecting documents, clients make many similar kinds of mistakes, and they turn to us when correcting them has taken too much of their extra time.

Therefore, today we’ll talk about the most common mistakes made in the process of preparation for obtaining a license for precursors.

Related article: What should you know when planning to start work with precursors, psychotropic substances and narcotic drugs?

1.A Narcologist’s Certificate

Certificates of taking a drug test must be obtained for all personnel who will have access to precursors. Clients do not always take into account that in order to obtain this license only certificates issued by state or municipal medical institutions are suitable. Certificates from private clinics are not suitable.

Related article: We got a license for handling the precursors for a government laboratory whose drug test certificate was about to expire

2.Missing on the head

A certificate of no criminal record and a certificate from a narcologist must also be obtained from the head of the enterprise, even if he/she will not directly work with chemicals.

3. A certificate of psychiatric examination

For some reason, many people think that a certificate of a narcological examination and a certificate of psychiatric examination are always submitted together.

A certificate of psychiatric examination is not needed to obtain a license to work with precursors. Therefore, there is no need to waste time getting it.

4.Confusion with a document on the occupational aptitude of the head

According to subparagraph 1 of paragraph 6 of the terms and conditions, it must be a certificate of a specialist. The licensing conditions do not specify what is meant by the above-mentioned document, but in practice, this is a document on obtaining a higher education in a chemical, medical or veterinary specialty (depending on the type of institution).

The practice of the licensing authority changes periodically. If a few years ago they completely turned a blind eye to the lack of a diploma with the indicated specialties, now they began to demand that there should be at least one chemist on the staff.

Now the practice of the State Service is such that either the head of the enterprise or the head should have a higher education in the corresponding specialty, department or unit directly working with substances. And to obtain a license, you must submit a notarized copy of his diploma.

5.Lack of premises or warehouse in the case of the sale of precursors only

Even before the beginning of 2019, the State Service had really had such a practice that if only precursors were bought and sold, there was no need for a storage room for them, which was logical and related to the interpretation of paragraph 2 of clause 2 of the terms.

This norm provides that if the licensee is engaged in some type of activity not fully, but partially, then these terms and conditions apply to him only in so far as this part of the activity is concerned. But at the same time, the list of documents submitted for obtaining a license mentions Permission to use the premises, which is issued by the National Police. And the note that it is not to be submitted if the room is not used is absent.

Therefore, the licensing body at some point “forgot” about subparagraph 2 of paragraph 2 and now requires a permit for the premises even in cases where chemicals haven’t been delivered to the premises.

Related article: Obtainment a license for use of precursors: innovations in procedure

The above problem points are the most common mistakes that can lead to a refusal to issue a license for precursors or to a waste of time and money.

However, it should be noted that each case has to be considered individually.

Therefore, if you have any questions about the license for precursors, please get in touch with our specialists!

Publication date: 14/10/2019
Marina Losenko

About author

Name: Marina Losenko

Position: Associate

Education: National Aviation University

Knowledge of languages: Russian, Ukrainian

Email: [email protected]

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Marina Losenko
Kuzava Vlasta
Junior lawyer
Ivanna Stefanchyshena
Assistant of the Lawyer