Narcotics control in Switzerland
B. Legislative bases of control
C. Control system
D. Organization of control
Author: J. P. BERTSCHINGER,, E. GNADINGER,, P. WEISS,, A. DURRER,
Pages: 1 to 16
Creation Date: 1964/01/01
Dr. E. GNADINGER, Deputy Chief of Section
P. WEISS, Technical Consultant
A. DURRER, Central Office for Organizational Questions, Federal Administration
B. Legislative bases of control
C. Control system
Manufacturers and undertakings processing narcotic drugs
Medical practitioners, dentists and veterinarians
Delivery vouchers for narcotic drugs
Imports and exports
D. Organization of control
Control at the frontier
Control within the country
Preparation of annual statistics for the United Nations
One of the fundamental conditions of the successful control of the illicit traffic and of drug addiction is the strict supervision, without loopholes but simple in character, of all persons who come into contact with narcotic drugs. In Switzerland, although the legislative provisions on the subject are of recent date, narcotics control properly so-called has been in effect for over forty years, albeit with obsolete office techniques. Accordingly, we set ourselves the task of devising a more "streamlined" procedure that would guarantee an effective control of narcotic drugs. The achievement of this aim has made possible a great saving of time in administrative work, with the consequence that the control itself will be intensified.
The control system has been reformed under the direction of Dr. A. Sauter, Director of the Federal Public Health Service, and Dr. O. Hongler, Director of the Central Office for Organizational Questions, Federal Administration.
Since analogous problems might arise in the offices responsible for narcotics control in other countries, we describe below the system introduced in Switzerland. As a background of the situation in Switzerland we shall first give some statistical data:
According to the 1960 census, Switzerland has a resident population of 5,429,000 persons; 9 establishments are authorized by their respective cantons 2 to manufacture, prepare and trade in narcotic drugs; 71 establishments are authorized by their respective cantons 2to prepare and trade in narcotic drugs; 40 establishments are authorized by their respective cantons 2 to trade in narcotic drugs; 1,100 pharmacists may acquire, possess, use and dispense narcotic drugs; 417 hospitals and 61 scientific institutes are authorized by their respective cantons 2 to acquire, possess and use narcotic drugs; 5,500doctors, 2,365 dentists, and 780 veterinarians hold cantonal licences to practise their professions; 45 customs houses are competent to deal with imports, exports and the transit of narcotic drugs.
States which, like Switzerland, have ratified the international conventions of 1925 and 1931 relating to narcotic drugs have thereby undertaken to furnish reports to the international control bodies.
The contracting parties to the international Convention relating to Dangerous Drugs, 1925, are required by the relevant articles of those instruments to submit periodically the following forms to the Permanent Central Opium Board:
The Swiss Confederation is a federal republic consisting of twenty-two cantons, three of which are subdivided into half-cantons. For the purpose of the control of narcotic drugs, the Principality of Liechtenstien is governed by Swiss regulations and is deemed to be a canton.
Quarterly statistics of imports and exports (statistical form A/1);
Annual estimates of raw materials (form B/1);
Annual statistics of consumption (statistical form C/I);
Annual statistics of production and manufacture (statistical form C/2, part I);
Annual statistics of prepared (smoking) opium (statistical form C/3);
Annual statistics of stocks (statistical form D);
Annual statistics of confiscation (statistical form E).
By virtue of articles 1 to 5 of the Convention for limiting the Manufacture and regulating the Distribution of Narcotic Drugs, 1931, the contracting parties are in addition required to prepare and send to the Permanent Central Opium Board:
Annual statistics of imports and exports of drugs of group II (statistical form A/2);
Annual estimates of narcotic drugs (form B/2); and
A summary of the returns made by the manufacturers (statistical form C/2, part II).
For the sake of completeness, we should add that various other articles of the conventions refer to the statistics and estimates to be submitted; such references occur in article 1 of the 1925 Convention, in articles 1, 13, 17 and 22 of the 1931 Convention, in articles 1 and 2 of the Protocol of 1948 bringing under international control drugs outside the scope of the 1931 Convention as amended by the 1946 Protocol, and in articles 8 and 9 of the Protocol of 1953 for limiting and regulating the cultivation of the poppy plant, the production of, international and wholesale trade in, and use of opium. Since to a large extent these articles simply supplement or clarify earlier provisions, we consider it superfluous to cite them here.
In Switzerland, the Federal Act on Narcotic Drugs of 3 October 1951, and the regulations issued pursuant thereto, constitute the fundamental provisions governing narcotics control. Within the country, this control is the responsibility of the cantons; the central authorities (Federal Public Health Service - hereinafter referred to as the Health Service - , the Customs Administration and the Federal Department of Public Prosecutions) supervise this control. In addition, the Health Service is responsible for preparing the reports required by the international conventions on narcotic drugs.
In principle, all undertakings and persons wishing to manufacture, prepare or trade in narcotic drugs must be licensed for this purpose by the competent cantonal authority, whereas any medical practitioner, dentist, veterinarian or responsible manager of a public pharmacy or hospital who is practising under his own responsibility in virtue of a decision given by the cantonal authority may, without licence, obtain, possess, use and dispense narcotic drugs subject to the limits implicit in the rules governing the practice of his profession. Medical practitioners and veterinarians are alone permitted to use, dispense and prescribe narcotic drugs; dentists may only use and dispense such drugs.
Provision is made for the following measures of narcotics control.
Undertakings and persons licensed to manufacture and prepare narcotic drugs are required to report to the Health Service, every quarter, particulars of the types and quantities of narcotic drugs manufactured and prepared by them. They must complete their inventory of stocks at the end of each year and send the results to the Health Service, for communication to the appropriate cantonal authority.
At the end of each year, these undertakings must report to the Health Service, for communication to the appropriate cantonal authority, particulars of receipts, deliveries and stocks of narcotic drugs.
Undertakings, persons and scientific institutes holding a licence to obtain, possess and use narcotic drugs according to their needs must keep up to date a ledger recording all receipts and deliveries of such drugs.
These book-keeping records consist of the following registers in which the undermentioned particulars are entered.
(a) Manufacturing Register
Withdrawals from stock for manufacturing purpose, the date of the withdrawal being specified; as regards raw materials other than poppy straw and coca leaf, the alkaloid content must be stated;
Types and quantities of narcotic drugs introduced into the manufacturing process, with the dates;
Each batch of narcotic drugs manufactured, with the date of manufacture;
Narcotic drugs placed in storage, with particulars of the dates;
Losses during manufacture;
Inventory of narcotic drugs at the end of each quarter;
(b) Storage Register
Inventory of stocks at the beginning of the year;
Incoming movements of narcotic drugs acquired or manufactured with the dates; with regard to raw materials other than poppy straw and coca leaf, the alkaloid content must be stated;
Withdrawals from stock, with the dates;
Deliveries for use, with the dates; in the case of raw materials, the alkaloid content must also be stated;
Losses in storage;
Inventory of stocks at the end of the year.
In the case of ampoules, tablets and other preparations, and of solutions and mixtures, not only the number of units or the weight, but also the dosage and the total narcotic drug content, must be shown at the beginning and at the end of the storage register.
These persons must be in a position at all times to produce satisfactory evidence regarding their acquisition and use of narcotic drugs; they must obtain, the narcotic drugs they need from a public pharmacy against a prescription or written order. The same rule applies to hospitals licensed to obtain, possess and use narcotic drugs according to their needs, provided that a medical practitioner, dentist, veterinarian or pharmacist makes himself responsible for the possession and use of such drugs.
A pharmacist may not dispense narcotic drugs to the public except against a prescription from a medical practitioner or a veterinarian.
Pharmacists must be in a position to produce satisfactory evidence of their acquisition and dispensing of narcotic drugs.
Every acquisition of drugs must be attested by a delivery voucher; all quantities supplied must be attested by written orders of medical practitioners, dentists, veterinarians and scientific institutions, and by prescriptions and copies of prescriptions.
In respect of every delivery of narcotic drugs, a delivery voucher must be drawn up and sent to the consignee with the goods; two copies of this voucher must be sent to the Health Service for transmission to the appropriate cantonal authorities (canton whence the consignment originates and canton to which the drugs are consigned). However, delivery vouchers are not required, for example, for consignments within the canton if that canton requires the periodical production of the necessary control documents.
The delivery voucher must give the following particulars: the address of the supplier and that of the consignee, the date, the quantity of the goods delivered in weight or in units and the alkaloid content in grammes or per cent.
A separate delivery voucher must be prepared for each type of drug and for each dosage.
Narcotic drugs may be imported or exported only by an undertaking or person holding a licence to manufacture or trade in narcotic drugs, or on the basis of an application supported by evidence by a pharmacist or scientific institution. In all cases, a permit from the Health Service is necessary.
The duplicates of the permit, on which the customhouse attests the routing of the goods, form the basis for the statistical returns to the Permanent Central Opium Board.
As we briefly indicated in the preface, we set ourselves the task of reorganizing the control of narcotic drugs in Switzerland. For this purpose, the previous control system was submitted for an expert opinion to the Central Office for Organization of Questions of the Federal Administration. This office stated its views on that system in a detailed report and arrived at the conclusion that: the control system was too complicated; control operations were not being made on the basis of the documents specified by the law; instead, a cumbersome and purely book-keeping control system had been set up (see fig. 1); the yearly "storage register" which the law requires of factories and commercial undertakings has not been construed at all as a means of computation, but has been used merely as a point of reference for comparison with the manufacturing register (four rectangular books, size 297 mm x 420 mm).
This book-keeping was rendered even more complicated by the use of large-sized and cumbersome registers (12 volume) weighing about 53 kg (see fig. 2).
FIG. 1 CONTROL OF NARCOTIC DRUGS AND ANNUAL NOTIFICATIONS TO THE UNITED NATIONS OPIUM AUTHORITIES CONTRÔLE DES STUPÉFIANTS ET RENSEIGNEMENTS FOURNIS AU SERVICE DES NATIONS UNIES CHARGÉ DE LA QUESTION DE L'OPIUM
FIGURE 2 Books formerly used as "manufacturing registers"
Accordingly, the Health Service sought to simplify the control of narcotic drugs; this simplification could not, however, consist simply of the introduction of secondary improvements to bolster up the existing system; instead, an attempt had to be made to place on a simpler basis the whole edifice of narcotics control itself.
Two essential conditions had to be fulfilled for the purpose of the reorganization of the control: (1) the statutory provisions relating to narcotics control had to be respected; (2) the figures obtained had to be capable of being used for the preparation of the statistics supplied annually to the Permanent Central Opium Board.
With regard to the first point, we had to determine precisely how the duties and responsibilities in the matter of the control of narcotic drugs are apportioned. The fundamental provision on the subject is the following clause in the Federal Act on Narcotic Drugs:
"The said control shall be exercised -
"1. In Switzerland, by the cantons under the supervision of the Confederation;
"2. the frontiers of Switzerland (import, transit and export) and in customs houses (federal warehouses and free ports), by the Confederation."
This provision shows clearly that detailed control is exercised by the Confederation only at the frontier and in customs warehouses. Inside Switzerland (i.e., with regard to stocks, purchases and sales within the country, as well as manufacture), the cantons are responsible for control, and the Confederation carries out only an over-all supervision. The Health Service is empowered to carry out spot checks in agreement with the cantonal authorities or to ask these authorities to inquire into particular cases.
The estimates published annually by the Drug Supervisory Body form the basis of the control of applications for import and export permits; they cover the reserve stocks of narcotic drugs which the various countries desire to maintain for the following year. In accordance with the Federal Act on Narcotic Drugs mentioned above, the Health Service prepares, in consultation with the Federal Narcotic Drugs Commission, the estimates of narcotics requirements which must be furnished annually under the international conventions on narcotic drugs ratified by the Swiss Confederation. In order to facilitate this work, the leading establishments are asked to indicate on a special form their probable production, imports, sales in Switzerland and abroad and their estimated stocks at the end of the following year.
(a) Applications for Import and Export Permits (see fig. 3 and fig. 4)
The import and export permits issued by the Health Service constitute the central feature of the direct control exercised by that service. About 130 import permits and about 230 export permits are issued annually.
When we first approached the task of amending these application forms, we had to devise a system which would be in keeping with the procedure followed and which would enable the applicant to give the fullest particulars possible, while at the same time relieving the Health Service of administrative work. In order to facilitate the checking of applications, a space has been left on the form for two additional columns, in which the international non-proprietary name of the substance and its percentage content of pure anhydrous base can be given. In addition, it was decided to dispense with the inconvenient procedure of stamping a forwarding stamp on every copy of the permit.
In order to achieve these purposes, the entire printed text had to be set out more clearly and all superfluous material had to be dropped. By means of more uniform typography (only three sizes of type being used), by a rearrangement of the various boxes so as to conform with the procedure followed and by a better use of the space available, it became possible to add the two extra columns and, furthermore, to enlarge the space (previously much too small) for entering particulars of the substance.
The use of sets of forms with disposable carbons means that both the applicant and the Health Service are saved the bother of inserting carbon papers. A further advantage of this system is that the addressee of each form can also be printed in advance (the Health Service stamp being dispensed with).
The forms are printed in such a manner that all particulars are entered by the applicant (no longer by the Health Service). The clearer print makes it easier for the applicant to fill in the forms and for the Health Service to verify the entries. Moreover, the new forms conform as far as possible to the spacing of typewriters. Ail the entries are typed on all forms simultaneously on all copies; the signature alone is hand-written, but only on the top form, since it is transferred by carbon paper to the others instead of each form being signed separately as was done until now. This procedure is necessary for the applicant, in order that the set of forms does not become separated; this is all the more justified in that the Health Service has to verify the signature; in this way the Service receives the whole set of forms bearing the original signature.
Similarly, the entries made by the Health Service on issuing the permits should in principle be carbon-copied. The office stamp alone is appended on each form separately. The comparison made in fig. 5 shows, by means of the specific example of the issuing of an export permit, how the administrative work of the Health Service has been simplified. A number of tests have been made with the old and the new systems, and timings showed an average saving of time of 75 % in the administrative work.
In order to facilitate the work of filling in the new forms and to avoid requests by applicants for additional information, a model application for an export permit, duly completed, was mimeographed (see reproduction in fig. 3) and sent by circular to the establishments concerned at the time when the new system was introduced.
In order that the various forms should be easily distinguishable, import permit forms are printed on yellow paper and export permit forms on blue paper.
EXPLANATION OF THE FORMS
Form A is the original for the purpose of obtaining the export permit abroad;
Form B (first copy) is the duplicate which is to accompany the consignment;
Form C (second copy) is intended for the customs house of entry;
Form D (third copy) is intended for the appropriate cantonal authority;
The fourth copy is the duplicate for the registry.
On the back of Form B the following notice is printed:
"The consignee of the goods must complete this acknowledgment of receipt and return it immediately to the address given below:
Service fédéral de l'hygiène publique Section pharmaceutique Falkenplatz 11 Berne
Acknowledgment of receipt, place, date and signature."
(The address has been so placed that it is possible to send the duplicate in any one of three sizes of window-envelopes.)
Form A "to be attached to the consignment with the other accompanying documents "; Form B (first copy) is intended for the customs house of exit; Form C (second copy) is intended for the appropriate cantonal authority;
Form D (third copy) is the copy for the authority of the importing country;
The fourth copy is the duplicate for the registry.
On the back of form B the following notice is printed:
"After clearance, or after the expiry of the period fixed for the importation, form B must be returned to:
Service fédéral de l'hygiène publique Section pharmaceutique Falkenplatz 11 Berne, Switzerland
"Form A must be attached to the other accompanying documents.''
On the back of Form D the following notice is printed:
"When the importation has been effected, this document must be returned to:
Service fédéral de l'hygiène publique Section pharmaceutique Falkenplatz 11 Berne, Switzerland
"in conformity with article 13, paragraph 5, of the International Convention relating to Dangerous Drugs of 19 February 1925."
(b) The Import and Export Control System
Comparison of the various control systems used hitherto (see fig. 5, left-hand side). - Formerly, particulars of the narcotic drugs imported or exported were entered in a loose-leaf book in chronological order and according to groups of drugs, the country of origin or destination being indicated. This method of control made it necessary, in respect of each application, to look for the appropriate group in the loose-leaf book and to assemble and add up the entries for the country concerned in order to determine whether the estimates had not been already used up by past imports or exports. For the more important substances, this process could be quite time-consuming.
Formerly: five individual forms
Now: set of five forms with disposable carbon
FIGURE 5 Office work in issuing an export permit for narcotic drugs
1. Enter control serial number
2. Enter amount of customs duty
3. Interleave four carbons
4. ( a) Entry by the office abroad which issued the import permit
( b) Enter the exact place of destination
( c) Enter number and date of foreign import permit (under "Comments")
5. Take out carbon interleaves
6. Enter date of permit
7. Turn date stamp forward
8. Enter period of validity
9. Turn date stamp back
10. Sign permit (in ink and dry with blotter)
11. Separate the set of forms
12. Affix office stamp and
13. routing stamp A on the original
14. routing stamp A and B on the first copy
15. routing stamp C on the second copy
16. routing stamp D on the third copy
|17. routing stamp A on the fourth copy as a check|
The new control system (see fig. 5, right-hand side). - In order to dispense with the laborious search for all the entries relating to a particular country for purposes of control, the quantities imported and exported are entered on cards, size 148 mm x 210 mm. Blue cards are used for exports and yellow cards for imports. The cards are filed according to country, with sub-classifications by groups of drugs; they are kept constantly up to date. In this way it is possible to determine at any moment the quantities of a particular drug which have been imported or exported by a given country. This means that the comparison of import and export applications with the estimates is much less time-consuming. In addition, the card index is a very valuable source of data.
(c) Quarterly Statistics of Imports and Exports (Form A/l)
The Health Service is required to furnish to the Permanent Central Opium Board quarterly statistics of imports and exports. These statistics are based on the customs copies, after clearance, of the import and export permits. It is therefore important for the Health Service that all the customs copies for any quarter should be returned to it in good time.
Old system (see fig. 6). - At the end of each quarter, on the basis of the customs copies after clearance, the number and date of the permit, the type of substance and the weight were entered on the import and export register (five rectangular books, size 210 mm x 297 mm); the pure anhydrous base equivalent was then immediately entered in the relevant column. For purposes of conversion, a manuscript table was kept showing the percentage (alkaloid) content of the various substances.
FIGURE 6 Preparation of quarterly statistics for the Permanent Central Opium Board at Geneva Old method New method
The converted figures were then added up according to groups of narcotics and carried forward on to the green statistical form A/1 of the Permanent Central Opium Board. For this purpose, the eight-page form A/1 printed on both sides had to be taken apart and later stapled together again after being completed. Besides, the space provided was often insufficient for the entries, with the consequence that additional sheets had to be attached. Nor did the printed lines on the form of the Permanent Central Opium Board correspond to the spacing of typewriters.
Criticism of old method. - Making the entries in the books (import and export registers) was a complicated and time-consuming task. One could not obtain a general picture of the situation, for neither the drugs nor the countries were classified in alphabetical order. To transfer the data to the forms of the Permanent Central Opium Board one had to go through all the books every time and to verify in respect of each drug whether a particular country had imported or exported any quantity of that drug, and how much, during the preceding quarter.
New method (see fig. 6). - The data given in the customs copies are no longer entered in books; the customs copies themselves are used as the direct basis for the statistics of the Permanent Central Opium Board. A card index, size 210 mm by 297 mm, in which the countries are arranged in alphabetical order, is used for this purpose. The particulars given in the customs copies of import and export permits are then transferred, according to country and to drug, to the forms of the Permanent Central Opium Board in the pre-printed order. The particulars appearing in the customs copies which are in the card index are then added up according to country and to drug and communicated to the Permanent Central Opium Board. The Health Service is relieved of the task of converting the drug into anhydrous equivalent, for on the new application forms the applicants do this. The customs copies are then removed from the card index and filed in numerical order. The card index can thus be used again in the following quarter.
In order to facilitate the forwarding of the forms to the Permanent Central Opium Board, only the first page of the official form is completed in handwriting (by agreement with the Board). It is no longer necessary to take the eight-page form apart and to staple it together again. The particulars are carbon-copied on an additional mimeographed sheet. The columns of these additional sheets are so arranged that it is possible to use the tabulator of a typewriter, and their size (210 mm x 297 mm) makes it easy to introduce them into the typewriter.
Because the new system eliminates conversions and makes it possible to fill in the separate sheets by typewriter, the entire process is so much simplified that even a person not familiar with the subject can prepare the quarterly statistics for the Board.
The supervision which, as mentioned above, the Confederation exercises over the cantonal control pursuant to the Federal Act on Narcotic Drugs involves a number of duties for the Health Service. In the first place, the Confederation must supply to the cantonal authorities the documents necessary for the purposes of control.
(a) Lists of Substances and Preparations
In the Federal Act on Narcotic Drugs the following substances are defined as narcotic drugs:
A. (1) Opium;
(2) Poppy straw used for the manufacture of substances and preparations which are referred to in group B.1, C or D;
(3) Coca leaf;
B. (1) The phenanthrene alkaloids of opium and their derivatives and the salts thereof which are addiction-producing;
(2) Ecgonine and its derivatives, and the salts thereof which are addiction-producing;
(3) The resin of the glandular hairs of hemp.
C. Other substances capable of producing addiction and harmful effects similar to those of morphine, cocaine and hashish;
D. Any preparation containing the substances mentioned in A, B or C.
The Federal Public Health Service draws up a list of substances and preparations deemed to be narcotic drugs within the meaning of sub-paragraphs A to D.
The regulations under the Act describe in detail each category of the substances, of which a list must be published. These lists are published every year in the Bulletin du Service fédéral de l'hygiène publique and are sent to the following establishments and persons: manufacturers; undertakings which prepare narcotic drugs; commercial undertakings; pharmacists; hospitals; scientific institutes; medical practitioners; dentists; veterinarians; custom houses.
The first innovation was to draft the explanatory notes accompanying the new lists in three languages (German, French and Italian, instead of German and French only as in the past). The new booklet contains the five lists prescribed by the Act:
List of narcotic drugs;
List of substances which, although not addiction-producing in themselves, can be converted into addiction-producing prod- ucts and which the Federal Council accordingly places under the narcotic drugs control;
List of substances exempted by the Federal Council from the application of the Act (" the Federal Council may exempt wholly or partially from the operation of this Act a substance mentioned in article 2 which does not produce addiction in the concentration or quantity used and which cannot be practically converted into another narcotic drug or recovered ");
List of substances and preparations which are not narcotic drugs but which have a similar chemical composition and are thought to be capable of producing similar effects; accordingly, these substances and preparations may not be manufactured, imported or used except with the express consent of the Federal Health Service;
List of prohibited narcotic drugs.
An annex contains the table showing the approximate content of pure anhydrous base and the compendium of substances and preparations subject to control under the Federal Act on Narcotic Drugs.
These two tables are based on the list of narcotic drugs of the Permanent Central Opium Board (annex to the statistical forms). They have, however, been enlarged to adapt them to the situation in Switzerland. The nomenclature of the various lists is consistent with the language of the Act. The annex indicates how the substances are to be converted into pure anhydrous base equivalent and helps the undertakings to complete their applications for import and export permits. As far as possible, footnotes have been avoided. The re-drafting of these lists involved a great deal of preparatory work for the Health Service. For example, it had to find out which narcotic drugs, substances, preparations and dosages are manufactured or marketed in Switzerland.
The indications are based partly on such sources as the former storage registers of some 120 undertakings, various statistical records, applications for import and export permits, and the catalogues of undertakings. In order to be able to specify accurately what percentages should be used for the purpose of conversion (which are printed as an annex to the list) the Health Service had to consult the undertakings concerned and the appropriate authorities at Geneva, so as to eliminate the many existing differences. The language of the lists was concorded with that used in the Act in the course of a number of meetings with the jurists of the Health Service. The number of sizes of printing type used has been kept at a minimum.
In 1963, the lists of substances and preparations were sent to all persons practising a medical profession; in the past, these lists were published in the Bulletin du Service fédéral de l'hygiène publique and thus reached only duly licensed medical practitioners. Establishments receive these lists direct from the Health Service, whereas pharmacists and - since 1963 - persons practising other medical professions receive them through the cantons.
As a general rule, supplements to these lists appear once a year; the presentation of these supplements is similar to that of the lists.
(b) Lists of Undertakings, Persons, Pharmacists, Hospitals, Scientific Institutes and Customs Houses
The Health Service is required by the Federal Act on Narcotic Drugs to publish these lists. They appear every year in the Bulletin du Service fédéral de l'hygiène publique and are sent in the form of off-prints to the following firms and persons: manufacturers; undertakings which process narcotic drugs; commercial undertakings; pharmacists. These lists of firms, persons, etc. have been prepared exactly as required by the Act. They form a booklet of 56 pages, which has a comprehensive table of contents to facilitate reference. The undertakings are classified according to canton; a number of columns indicate clearly the responsible manager and give full particulars of the type of licence granted and of the narcotic drugs manufactured. The list of customs houses, which previously was printed on a separate sheet, has now also been included in the booklet as an annex. The customs houses are now arranged in alphabetical instead of geographical order. Moreover, for the first time, an annex is included explaining the responsibilities of the International Committee of the Red Cross and the Swiss Red Cross. For the purpose of preparing these lists, the Health Service requires accurate information from the cantons. The regulations under the Federal Act on Narcotic Drugs accordingly specify:
"The competent cantonal authority shall forthwith inform the Health Service of the grant, modification, refusal or withdrawal of a licence, with a report on the facts."
In order to make it easier in the future for the cantons to perform their duty of notification in this respect, and in order that the Public Health Service should not have to ask for further details on receiving incomplete particulars, a form on which modifications and additions are to be reported has been made available to the cantons. Any modifications so reported are added to the lists and are published once a year in the form of a supplement.
(c) Prohibition List
The Federal Act on Narcotic Drugs provides:
"A medical practitioner may report to the competent cantonal authority cases of drug addiction observed by him in his practice if in his opinion the interests of the addict's family or of the public require action by the authority.
"A pharmacist shall have the same power in respect of persons presumed by him to be drug addicts.
"Cantons shall deal with drug addicts as the circumstances require. They may prohibit addicts from obtaining narcotic drugs or withdraw such prohibition and shall notify accordingly the Federal Health Service, which shall notify the competent authorities of the other cantons, for the information of medical practitioners and pharmacists."
A form for entering particulars of changes and additions has also been devised for the prohibition list, in order to avoid misunderstandings and to make it easier for the cantons to comply with the compulsory notification. A supplement to the prohibition list appears as a rule also once a year.
(d) Control of Manufacture (see 3.1 and 3.2)
Under the Federal Act on Narcotic Drugs, undertakings and persons licensed to manufacture and prepare narcotic drugs must report to the Health Service every quarter particulars of the types and quantities of narcotic drugs manufactured or prepared by them. These quarterly reports enable the Health Service to control the manufacture in the country by means of spot checks. The particulars in question also form the basis for the statistics of production sent annually to the PCOB at Geneva (statistical form C/2).
(e) Control of Storage
Storage control applies to 120 manufacturers, to undertakings which process narcotic drugs and to commercial undertakings. This control makes it possible to ascertain the position at the beginning of the year, the imports, the purchases made in Switzerland, the quantities manufactured and those exported, sales in Switzerland, withdrawals from manufacturing establishments and year-end stocks. The annual returns made by the undertakings to the Health Service constitute the most important element both in narcotics control and for the purpose of the appropriate notifications to PCOB by the Health Service.
Former procedure. - Although "storage register" forms were formerly sent by the establishments concerned at the end of the year, the Health Service used to prepare at the same time a "manufacturing register" on the basis of the original documents. The returns of the establishments were only used at the end of the year for purposes of comparison and in order to ascertain whether there was any inconsistency in the data supplied. For making out their returns, the undertakings used to employ a register, size 210 mm by 297 mm, the 14 sheets of which were printed on both sides. The text was printed in two languages. The narcotic drugs were arranged in groups - i.e., in accordance with the international conventions ratified by the Swiss Confederation. The drugs were not enumerated in alphabetical order, even within each group. There was an additional final column for entering the (estimated) active substances of each narcotic drug entered.
New procedure (see fig. 7 and fig. 8). - In 1961, punch cards were to be used for the first time for the estimate based on the "storage register ", and accordingly it became necessary to alter the presentation of the notification forms. To make it easier to complete the forms by typewriter, the system of registers was discontinued. Instead, a cardboard cover is used containing 29 rectangular loose leaves size 297 mm x 420 mm, folded in the middle and printed only on one side. The groups of narcotic drugs have been numbered by order of importance. Proprietary products have been classified in alphabetical order within each group. The substances and preparations have been divided into two parts:
FIGURE 7 Cardboard cover of the storage register
First part. - Substances for which the quantity must be indicated in kilogrammes, grammes and milligrammes;
Second part. - Preparations for which the number of units must be indicated.
A comprehensive table of contents gives explanations about the narcotic drugs mentioned. The explanations have been printed in three languages. The name of each drug is given in Latin, except in the case of proprietary products and registered names. Because the calculations are now made by means of punch cards, the firms need no longer indicate in a separate column the active principle of each preparation manufactured. The storage register henceforth contains only narcotic drugs used in Switzerland. Narcotic drugs which have the same dosage and the same medicament form, but which contain substances that are not narcotic drugs, have been arranged in a group under the heading "cum et sine ... "
FIGURE 8 Extracts from pages 1 and 14 of the storage register
In order to make the use of electronic computers possible, it was necessary to devise, for all narcotic drugs, a code for the percentage content of anhydrous base, the medicament form and the dosage. For example:
104.76.1.05,00 corresponds to:
104. = morphine;
76. = hydrochloride (morphine hydrochloride contains approximately 76 % of pure anhydrous morphine base):
1. = medicament form = injectable;
05,00 = 5 mg of morphine hydrochloride per ampoule.
In devising the new storage register forms, the Health Service used the forms for the years 1958-1959. The various undertakings had entered on these forms, apart from the narcotic drugs already mentioned, a large number of additional preparations. On the basis of these particulars, a card index of about 500 cards was prepared; with the help of this card index it was possible to work out the storage control in such a way that even a person without specialized knowledge could operate it. Because the column giving the active substances has been dropped, the work of the reporting undertakings has been greatly facilitated, in that they no longer need to convert the substances into anhydrous base equivalents. Since the entries will henceforth be made by undertakings by means of perforations in the punch card, the particulars need no longer to be expressed in decimals and should as far as possible be typewritten. Only about one-half of the storage registers for 1961 were received by the Health Service in good time. The reason is that this service was not formerly required to demand the missing storage registers. The new form of storage register has the further advantage that only the sheets which are filled in have to be kept and sent to the cantons. The yearly totals, which were formerly worked out by means of very elaborate transfer entries, conversions and recapitulations on the basis of the original documents, will henceforth be derived from the storage registers filled in by the undertakings themselves. In this manner, the proposal that there should be a return showing the movement of drugs out of stock, which had been made in the report by the Central Office for Organizational Questions of the Federal Administration of 18 June 1960, has been implemented and the storage register has for the first time become the centre of the whole narcotics control system. The annual statistics for the United Nations at Geneva will to a large extent be taken from the storage registers.
(f) Inventory of Narcotic Drugs stocked by Pharmacists
Pharmacists are likewise required to report their stocks to the cantonal authorities in accordance with the regulations issued by the canton concerned. The forms for pharmacists' inventories were formerly pre-printed by the Health Service, which sent them to the cantonal authorities. An effort was therefore made to bring these inventory forms and their presentation into line with the storage registers. The code numbers for narcotic drugs used for the storage registers have been introduced also into the pharmacists' inventories; in this way the cantons can evaluate (possibly by means of punch cards) the data received from the pharmacists. In order to make them clearer than in the past and so that they can be typewritten, the registers have also been replaced by loose-leaves. A draft of the new form was submitted to the cantons for their opinion.
(g) Delivery Vouchers
The Federal Act on Narcotic Drugs provides that a delivery voucher must be made out in respect of every quantity of narcotic drugs delivered; the voucher must be sent to the consignee with the goods. In addition, all deliveries of narcotic drugs must be reported to the Health Service by forwarding two copies of the delivery voucher.
Old form. -The delivery vouchers used previously were printed in perforated strips of four. Since the delivery vouchers have to be made out in triplicate, the four forms had to be detached so that they could be completed together by means of carbons.
Five lines were provided for entering particulars on the delivery voucher. Sometimes, however, particulars of several drugs and of various dosages were entered on the same voucher, even although according to the Act a separate voucher ought to be made out for each kind of drug and for each dosage.
The delivery vouchers were classified by the Health Service according to the cantons of the supplier and the consignee; they were then sent to these cantons for use by their control bodies. This procedure was quite complicated, particularly so far as the canton of the consignee was concerned, for very commonly this canton was not indicated for the simple reason that there was no separate space in the form for indicating the canton. Where small localities were concerned, one first had to look up in which canton they were situated, and besides, in some cases several localities having the same name are situated in different cantons.
New form (see fig. 9). - The new form of the delivery voucher should above all facilitate classification according to the supplier's and the consignee's canton. A separate space is provided for indicating the canton. The box provided for the name of the drug has been made smaller, so that in future it will be impossible to enter in the same box particulars of more than one narcotic drug. The lines have been eliminated, for delivery vouchers are generally completed by typewriter. Since the form is to be used throughout Switzerland, it is printed in three languages. Separate boxes are provided for indicating whether the transaction constitutes an exchange or a return to the sender.
In order to make it easy for those who complete a delivery voucher to keep a copy, the new forms are no longer supplied in strips of four but in bound blocks of one hundred. This system allows for the fact that certain firms complete a fourth copy for their own files. In addition, it is simpler to detach three forms from a block than to separate the strips and assemble the forms and introduce them into a typewriter.
Since the undertakings often have to send out duplicate delivery vouchers, in this respect suitable envelopes and gummed labels are provided (postage being prepaid at bulk rates); this should simplify matters.
Old method (forms C/1, D, A/2, C/2/fig. 1). - Formerly, the "manufacturing register" kept by the Health Service served as the basis for the statistics required annually by the Permanent Central Opium Board in respect of imports and exports, consumption, production and stocks of narcotic drugs. The particu- lars which it contained, given by the various firms, were transferred together to the "long register I" and converted into anhydrous base equivalent. The converted quantities were then assembled by group of drugs in "long register II "; from these figures the annual statistics were prepared.
The process of adding up, transferring, converting and assembling the data, classified according to group of drugs, was very time-consuming and the size of the books (297 mm x 644 mm, weighing about 8 kg each) made them very unwieldy; besides, no very clear picture emerged from all these tabulations. Hence it is not surprising that it used to take several months to work out the figures for the annual statistics.
New method. - Thesupporting documents required by the Act are now being used for the preparation of the annual statistics as well. The documents in question are, firstly, the storage registers prepared by the undertaking and, secondly (for production statistics), the returns of the output of drugs which are sent in every quarter by the leading manufacturers.
The data contained in the storage registers are recorded by means of punch cards (for 1961 - 6,466); they are then converted and assembled electronically at the computer centre of the Federal Administration (time taken by the computer: about 15 minutes).
The returns of the quarterly output of drugs are used in particular for determining the production of morphine, codeine, ethylmorphine, hydrocodone, dyhydrocodeine, benzylmorphine, etc. As regards other substances made by one firm only, the particulars appearing in the storage registers generally suffice.
Since the storage registers prepared by the various undertakings in accordance with the Federal Act on Narcotic Drugs have to be transmitted to the cantons for the purposes of physical inspection, all the particulars entered therein are tabulated according to undertaking. In this manner, the Health Service will later be in a position - e.g., in criminal cases, even after the abolition of the "manufacturing register"- to verify the figures given for an earlier year by a particular undertaking.
The completion of the work of reorganization proper has confirmed the accuracy of earlier observations; this is shown by the following facts:
The simplification of narcotics control has made the whole system clearer and hence more effective;
The Health Service can now dispense with all additional book-keeping;
The storage registers form the central element of the whole control system; these are transmitted to the Health Service and the year-end figures have to be notified;
For the quarterly notifications to the Permanent Central Opium Board, the supporting documents prescribed by the Act (import and export permits, returns of output of drugs and particularly storage registers) are likewise being directly used as a basis.
Of course, a number of difficulties arose when the new control system was applied for the first time.
We may, however, confidently expect that these difficulties will be largely overcome in 1964 and that the work of the Health Service will as a consequence be substantially reduced.
When the new control system functions normally and the "storage registers" of the various undertakings are submitted in good time duly completed, the work of preparing the statistics for the Permanent Central Opium Board will also be considerably simplified. The main task of the Health Service in the matter will be confined to checking the storage registers sent to it. This checking is, however, extremely important, for any inaccurate entry by the undertakings will affect the results obtained by the electronic computer, and mistakes of this kind are difficult to detect and to correct at a later stage.
The saving of time resulting from this reorganization will enable the pharmaceutical section to intensify its supervision of the cantonal control of narcotic drugs. For the control exercised within the country by the cantonal authorities will be effective, within the meaning of the Act, only if there is effective supervision by the Federation. This requires an increased co-operation between the Health Service and the cantonal authorities and the latter's firm support for the control measures of the Health Service.
The reorganization will not have been in vain and will have achieved its purpose, thanks in particular to the elimination of the work involved in keeping books at the Health Service, if the control of narcotic drugs becomes more intensive and more effective.
The foregoing is a description of the new organization of the control of narcotic drugs in Switzerland.