中成药中处方药和非处方药“双跨”品种的风险与管理探讨

Discussion about risk and management of Chinese patent medicine with double identity

中成药"双跨"品种同时具有处方药和非处方药身份,是一类临床应用广泛且容易混淆的药品,充分认识和加强该类药品的风险管理非常必要。该文通过查阅分析双跨品种目录及文献,探讨相关法规,药品包装、标签与说明书及生产、流通和使用等方面存在的问题以及由此构成的潜在风险。建议有关部门完善相关法规,严格控制"双跨"品种审批,完善药品包装、标签和说明书,加强生产、流通、使用环节的管理,提高医患认识,构建并完善"双跨"品种的风险管理体系,以保障公众用药安全。

Chinese patent medicine with double identity was a special phenomenon, and many preparations not only were prescription drugs but also over the counter （OTC） drugs, which brought a lot of trouble. Based on statistics of list of OTC medicines of CFDA, related varieties, route of administration and functions of these drugs were searched. The causes of insufficient were analyzed and the potential risk was investigated. To ensure the safety of drug usage for the patient, risk management system should be set up by improving the technical requirements for registration, improving the drug labels and manuals, playing the role of pharmacists in pharmacy services and raising awareness of doctor and patient for these drugs.