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Discussion of the Draft Order of MOZ of Ukraine on Amendments to License Conditions for the Business of Drug Manufacturing, Wholesale, Retail, Pharmaceuticals

23 May 2013


April 17, 2013


On February 27, 2013 State medical service (Derzhliksluzhba) with the representatives of the Ministry of Social Policy, Ministry of Health, Ministry of Regional Development, Construction and Housing and Communal Services of Ukraine (hereinafter - the Ministry of Regional Development), NGOs of people with disabilities of Ukraine, professional pharmacy associations, utilities spent discussing of projects orders of the Ministry of Health of Ukraine on Amendments to license conditions for the business of drug manufacturing, wholesale, retail, pharmaceuticals (hereinafter - the Draft Order). These projects have been published on the website of the ministry on 18 and 24 January 2013.


During participation there were discussed important issues, in particular the definition of requirements for ramps to provide environment without barriers to pharmacies for the people with disabilities.


According to Vladimir Azin, representative of the Ukrainian public socio-political association "National Assembly of People with Disabilities of Ukraine" there should be the specific requirements. Also, there must be kept in mind that there are a large number of people with disabilities not only in wheelchairs but also visually impaired, hearing loss, and people on crutches. Azin said that licensing conditions should be sure to include links to DBN B.2.2-17: 2006 'Buildings. Access to buildings and facilities for the limited mobility people of the population. "Also, according to representatives of the Ukrainian community socio-political association" National Assembly of People with Disabilities of Ukraine ", the appropriate changes also should be made to the procedure for monitoring compliance with the licensing conditions and additions to this document to Order check before issuing a license for the business of drug manufacturing, wholesale, retail, pharmaceuticals, approved by the Ministry of Health of Ukraine of 11.07.2012, № 513.


Representatives of the public social and political association "National Assembly of People with Disabilities of Ukraine" drew attention to the fact that most NGOs entered in committees to ensure the availability of people with disabilities and other limited mobility people to social engineering and transport infrastructure. Therefore, in case of failure of DBN there is need to adapt those items to the needs of people with disabilities.


Instead, professional pharmacy associations and utilities said that there is no need to amend the licensing conditions for improvement pharmacies ramps. In this paper, in their opinion, should refer to the Law of Ukraine "On Principles of Social Protection of the People with Disabilities inUkraine." According to the Article 26 of the Act, institutions and organizations are obliged to create conditions for free access of people with disabilities (including persons with disabilities who use vehicles and dogs) to the objects of the physical environment. It was also noted that according to Article 27 of this law if the current facilities can not be fully adapted to the needs of persons with disabilities, in consultation with NGOs people with disabilities by their reasonable accommodation based on universal design. However, according to the pharmacy associations, creating ramps may cause harmful interference to certain pharmacies put them in unequal and contrary to the laws of business.


According to the Ministry of Regional Development, Standard DBN are performed not only during the construction of new buildings, but also during its reconstruction / repair.


V. Azin pointed out; it is not always possible to arrange a ramp in a particular pharmacy. But for organizations to protect the rights of the people with disabilities does not matter to the pharmacy without fail was just a ramp or a call button pharmacist (pharmacist). The main thing is enabling physical access to pharmaceutical services.


Vadim Karpenko, a representative of the All-Ukrainian Union of Civil Organizations "Confederation of NGOs people with disabilities of Ukraine", also agreed with the Azins` idea. He drew attention to the fact that the rights of persons with disabilities are not intended to close the pharmacy or imposing penalties on them. At the same time, the construction of pharmacies in rural needed endeavor to ensure the availability of people with disabilities at the same time so as not to hurt yourself pharmacies.