JOINT ORDER OF I.O. MINISTER OF HEALTH OF THE REPUBLIC OF KAZAKHSTAN AND MINISTER OF NATIONAL ECONOMY OF THE REPUBLIC OF KAZAKHSTAN

of May 24, 2023 No. 87, on May 24, 2023 No. 77

About modification and amendments in the joint order of the Minister of Health of the Republic of Kazakhstan of November 15, 2018 No. KR DSM-32 and the Minister of national economy of the Republic of Kazakhstan of November 15, 2018 No. 70 "About approval of criteria for evaluation of risk degree and checking sheets in spheres of quality of rendering medical services, drug circulation and medical products"

WE ORDER:

1. Bring in the joint order of the Minister of Health of the Republic of Kazakhstan of November 15, 2018 No. KR DSM-32 and the Minister of national economy of the Republic of Kazakhstan of November 15, 2018 No. 70 "About approval of criteria for evaluation of risk degree and checking sheets in spheres of quality of rendering medical services, drug circulation and medical products" (it is registered in the Register of state registration of regulatory legal acts at No. 17744) the following changes and amendments:

in Item 1:

subitems 15) to state 16), 17), 18), 19), 20) and 21) in the following edition:

"15) criteria for evaluation of risk degree in the field of drug circulation, products of medical appointment and medical equipment according to appendix 15 to this joint order;

16) checking leaf in the field of drug circulation and medical products on compliance to qualification requirements concerning subjects (objects) of control according to appendix 16 to this joint order;

17) checking leaf in the field of drug circulation, products of medical appointment and medical equipment concerning the medical organizations for provision of medicines according to appendix 17 to this joint order;

18) checking leaf in the field of drug circulation, products of medical appointment and medical equipment concerning subjects (objects) of pharmaceutical activities performing production of medicines, products of medical appointment and medical equipment according to appendix 18 to this joint order;

19) checking leaf in the field of drug circulation, products of medical appointment and medical equipment concerning subjects (objects) of pharmaceutical activities performing production of medicines and products of medical appointment according to appendix 19 to this joint order;

20) checking leaf in the field of drug circulation, products of medical appointment and medical equipment concerning subjects (objects) of pharmaceutical activities enabling wholesale of medicines, products of medical appointment and medical equipment according to appendix 20 to this joint order;

21) checking leaf in the field of drug circulation, products of medical appointment and medical equipment concerning subjects (objects) of pharmaceutical activities enabling retail sale of medicines, products of medical appointment and medical equipment according to appendix 21 to this joint order;";

add with the subitem 25) of the following content

"25) checking leaf in the field of drug circulation and medical products concerning the state expert organization in the field of drug circulation and medical products according to appendix 25 to this joint order.";

15, of 16, of 17, of 18, of 19, 20 and 21 to the specified joint order to be reworded as follows appendices according to appendices 1, of 2, of 3, of 4, of 5, of 6, and 7 to this joint order;

add with appendix 25 to the specified joint order in edition according to appendix 8 to this joint order.

2. To provide to committee of medical and pharmaceutical control of the Ministry of Health of the Republic of Kazakhstan in the procedure established by the legislation of the Republic of Kazakhstan:

1) state registration of this joint order in the Ministry of Justice of the Republic of Kazakhstan;

2) placement of this joint order on Internet resource of the Ministry of Health of the Republic of Kazakhstan after its official publication;

3) within ten working days after state registration of this joint order in the Ministry of Justice of the Republic of Kazakhstan submission to Legal department of the Ministry of Health of the Republic of Kazakhstan of data on execution of the actions provided by subitems 1) and 2) of this Item.

3. To impose control of execution of this joint order on the supervising vice-Minister of Health of the Republic of Kazakhstan.

4. This joint order becomes effective after ten calendar days after day of its first official publication, except for subitems 2), 3) and 4) of Item 13 of Criteria for evaluation of risk degree in the field of drug circulation and medical products which become effective since December 1, 2024 and the subitem 5) of Item 13 of Criteria for evaluation of risk degree in the field of drug circulation and medical products which becomes effective since June 1, 2024.

Minister of national economy of the Republic of Kazakhstan

__________ A. Kuantyrov

Acting minister of health care of the Republic of Kazakhstan

__________ T. Sultangaziyev

It is approved Committee on legal statistics and special accounting of the Prosecutor General's Office of the Republic of Kazakhstan

Appendix 1

to the joint Order of the deputy. The Minister of Health of the Republic of Kazakhstan and the Minister of national economy of the Republic of Kazakhstan of May 24, 2023 No. 87, on May 24, 2023 No. 77

"Appendix 15

to the joint Order of the Minister of Health of the Republic of Kazakhstan and the Minister of national economy of the Republic of Kazakhstan of November 15, 2018 No. KR DSM-32, 15 of November, 2018 No. 70

Criteria for evaluation of risk degree in the field of drug circulation and medical products

Chapter 1. General provisions

1. These Criteria for evaluation of degree of risks in the field of drug circulation and medical products (further – Criteria) are developed according to the subitem 16) of article 10 of the Code of the Republic of Kazakhstan "About health of the people and health care system", Items 5 and 6 of Article 141 and Item 1 of article 143 of the Entrepreneurial code of the Republic of Kazakhstan, Rules of forming by the regulatory state agencies of system of assessment and risk management approved by the order of the acting minister of national economy of the Republic of Kazakhstan of June 22, 2022 No. 48 (it is registered in the Register of state registration of regulatory legal acts at No. 28577) and the order of the acting minister of national economy of the Republic of Kazakhstan of July 31, 2018 No. 3 "About approval of form of checking leaf" (it is registered in the Register of state registration of regulatory legal acts at No. 17371).

2. In these Criteria the following concepts are used:

1) point – quantitative measure of calculation of risk;

2) normalization of data – the statistical procedure providing reduction of the values measured in different scales to conditionally general scale;

3) risk – probability of damnification as a result of activities of the subject of control of life or to health of the person, the environment, legitimate interests of physical persons and legal entities, valuable interests of the state taking into account severity of its effects;

4) system of assessment and risk management – process of acceptance of the management decisions directed to decrease in probability of approach of adverse factors by distribution of subjects (objects) of control on risk degrees for the subsequent implementation of preventive control with visit of subject (object) of control and (or) the inspections which are carried out on compliance to qualification or allowing requirements on the issued permissions, requirements for directed notifications according to the Law of the Republic of Kazakhstan "About permissions and notifications" (further – check on compliance to requirements) for the purpose of minimum possible extent of restriction of freedom of enterprise, providing at the same time admissible risk level in the corresponding fields of activity, and also directed to change of risk level for specific subject (object) of control and (or) release of such subject (object) of control from preventive control with visit of subject (object) of control and (or) checks on compliance to requirements;

5) objective criteria for evaluation of risk degree (further – objective criteria) – the criteria for evaluation of risk degree used for selection of subjects (objects) of control depending on risk degree in certain field of activity and which are not depending directly on separate subject (object) of control;

6) criteria for evaluation of risk degree – set of the quantitative and qualitative indexes connected with the direct activities of the subject of control, features of industry development and factors influencing this development, allowing to carry subjects (objects) of control to different risk degrees;

7) subjective criteria for evaluation of risk degree (further – subjective criteria) – the criteria for evaluation of risk degree used for selection of subjects (objects) of control and depending on results of activities of specific subject (object) of control;

8) the checking sheet – the list of requirements imposed to activities of subjects (objects) of control which non-compliance involves threat of life and to health of the person, the environment, legitimate interests of physical persons and legal entities, the states;

9) sample (selection) – the list of the estimated subjects (objects) carried to homogeneous group of subjects (objects) of control in the specific sphere of the state control according to Item 2 of article 143 of the Entrepreneurial code of the Republic of Kazakhstan.

Chapter 2. Procedure for forming of system of assessment and risk management when carrying out preventive control of subjects (objects) control

3. Risk management when implementing preventive control with visit of subject (object) of control are created by means of determination of objective and subjective criteria which are performed step by step (the multicriteria analysis of decisions).

At the first stage by objective criteria subjects (objects) of control are distributed to one of the following risk degrees:

1) high risk;

2) average risk;

3) low risk.

On risk exponents by subjective criteria the subject (object) of control belongs:

1) to high risk – in case of exponent of risk from 71 to 100 inclusive;

2) to average risk degree – in case of exponent of risk from 31 to 70 inclusive;

3) to low risk degree – in case of exponent of risk from 0 to 30 inclusive.

4. Criteria for evaluation of risk degree for carrying out preventive control of subjects (objects) control are created by means of determination of objective and subjective criteria.

Paragraph 1. Objective criteria

5. Risk identification by objective criteria is performed depending on specifics of the sphere in which the state control taking into account one of the following criteria is exercised:

1) level of danger (complexity) of object;

2) scales of weight of possible negative effects, harm on the regulated sphere (area);

3) possibilities of approach of adverse incident for life or health of the person, legitimate interests of physical persons and legal entities, states.

6. After carrying out the analysis of possible risks subjects (objects) of control are distributed on three risk degrees by objective criteria (high, average and low).

7. Subjects (objects) of control performing the activities connected with belong to high risk:

1) production of medicines;

2) production of medicines;

3) wholesale of medicines;

4) production of medical products;

5) production of medical products;

8. Subjects (objects) of control belong to average risk degree:

1) the subjects in the field of drug circulation and medical products enabling retail sale of medicines;

2) the organizations of health care giving out-patient and polyclinic help;

3) the organizations of health care giving stationary help and (or) the hospital-replacing help;

4) the organizations of health care, providing emergency medical service and (or) services of sanitary aircraft;

5) the organizations of health care performing procurement, preservation, conversion, storage and realization of blood and its components.

9. Subjects (objects) of control belong to low risk degree:

1) the subjects in the field of drug circulation and medical products who are enabling retail sale of medicines, having the certificate of proper pharmaceutical practice (GPP);

2) subjects (objects) of control performing the pharmaceutical activities connected with wholesale and retail sale of medical products.

10. For subjects (objects) of control carried to high and average risk degree by objective criteria are carried out check on compliance to requirements, preventive control with visit of subject (object) of control, preventive control without visit of subject (object) of control and unscheduled inspection.

11. For fields of activity of subjects (objects) of control carried to low risk degree by objective criteria are carried out check on compliance to requirements preventive control without visit of subject (object) of control and unscheduled inspection.

Paragraph 2. Subjective criteria

12. Determination of subjective criteria in the field of drug circulation and medical products is performed using the following stages:

1) forming of the database and information collection;

2) information analysis and risks assessment.

13. Forming of the database and information collection are necessary for identification of subjects (objects) of control.

For assessment of risk degree the following sources of information are used:

1) results of the previous checks and preventive control with visit of subjects (objects) of control;

2) availability of the adverse incidents which arose because of the subject of control;

3) availability and the number of the confirmed claims and addresses;

4) results of preventive control without visit of subject (object) of control (the resulting documents issued following the results of preventive control without visit of subject (object) of control);

5) analysis results of the data represented by state bodies and the organizations;

discrepancy, absence and (or) availability of the negative decision received by results of quality evaluation of the medicines and medical products registered in the Republic of Kazakhstan and also discrepancy, absence and (or) availability of the negative decision received by results of selection from the market including in the medical organizations, medicines and the medical products which are subject to quality control taking into account risk - the oriented approach.

For risk degree assessment when forming the schedule for checks on compliance to requirements the following sources of information are used:

1) results of the previous checks and preventive control with visit of subjects (objects) of control;

2) availability of the adverse incidents which arose because of the subject of control;

3) availability and the number of the confirmed claims and addresses;

4) results of preventive control without visit of subject (object) of control (the resulting documents issued following the results of preventive control without visit of subject (object) of control);

14. Based on the available sources of information the data on subjective criteria which are subject to the analysis and assessment are created.

The analysis and assessment of subjective criteria allows to concentrate conducting check on compliance to requirements and preventive control of subject (object) of control concerning subject (object) of control with the greatest potential risk.

At the same time in the analysis and assessment the data of subjective criteria which are earlier considered and used concerning specific subject (object) of control or data according to which the term of limitation period according to the legislation of the Republic of Kazakhstan expired are not applied.

Concerning the subjects of control which eliminated in full the issued violations following the results of the carried-out previous preventive control with visit and (or) check on compliance to requirements, their inclusion when forming schedules and lists for the next period of the state control is not allowed.

15. Extent of violations of requirements to subjects (objects) of control in the field of drug circulation and medical products on compliance to qualification requirements are determined according to appendix 1 to these Criteria and Extent of violation of requirements to subjects (objects) of control in the field of drug circulation and medical products for carrying out preventive control of subjects (objects) control are determined by sources of information according to appendix 2 to these Criteria.

16. Proceeding from priority of the applied sources of information and the importance of indicators of subjective criteria, according to risk exponent procedure of payments by subjective criteria, determined in the List of subjective criteria for determination of risk degree by subjective criteria in the field of drug circulation and medical products according to article 138 of the Entrepreneurial code of the Republic of Kazakhstan concerning all subjects (objects) it agrees appendix 3 to these Criteria, the risk exponent by subjective criteria is calculated.

17. Check on compliance to requirements and preventive control with visit of subject (object) are carried out depending on purpose and types of activity of objects, according to checking sheets in the field of drug circulation and medical products according to appendices 16, of 17, of 18, of 19, of 20, 21 and 25 to this joint order.

18. For fields of activity of subjects (objects) of control carried to high risk, checks on compliance to requirements are determined by criteria, but carried out not more often than once a year.

For fields of activity of subjects (objects) of control carried to average risk degree, checks on compliance to requirements are determined by criteria, but carried out not more often than once in two years.

For fields of activity of subjects (objects) of control carried to low risk degree, frequency rate of conducting checks on compliance to requirements is determined by criteria for evaluation of risk degree, but is not more often than once in three years.

Chapter 3. Risk degree procedure of payments by subjective criteria

19. Measure calculation of risk degree by subjective criteria (R) is perfromed in the automated mode by summing of exponent of risk on violations by results of the previous checks and preventive control with visit of subjects (objects) of control (SP) and exponent of risk by the subjective criteria determined according to Item of 13 these Criteria (SC) with the subsequent normalization of the values this in the range from 0 to 100 points.

Rprom = SP + SC, where

Rprom – intermediate exponent of risk by subjective criteria,

SP – risk exponent on violations,

SC – risk exponent by the subjective criteria determined according to Item of 13 these Criteria.

Calculation is made on each subject (object) of control of homogeneous group of subjects (objects) of control of each sphere of the state control. At the same time the list of the estimated subjects (objects) of control carried to homogeneous group of subjects (objects) of control of one sphere of the state control forms sample (selection) for the subsequent normalization of data.

20. According to the data obtained by results of the previous checks and preventive control with visit of subjects (objects) of control the risk exponent on violations estimated in points from 0 to 100 is created.

In case of identification of one gross violation on any of the sources of information specified in Item of 16 these Criteria, the subject of control the exponent of risk of 100 points is equated and concerning it it is performed on compliance to requirements or preventive control with visit of subject (object) of control.

In case of not identification of gross violations the risk exponent on violations is calculated total indicator on violations of considerable and insignificant degree.

In case of measure definition of considerable violations 0,7 coefficient is applied.

This indicator is calculated by the following formula:

SRZ = (SP2 x 100/SP1) x 0,7, where:

SRZ – indicator of considerable violations;

SP1 – the required number of considerable violations;

SP2 – the number of the revealed considerable violations;

In case of measure definition of insignificant violations 0,3 coefficient is applied.

This indicator is calculated by the following formula:

SRN = (SP2 x 100/SP1) x 0,3, where:

SRN – indicator of insignificant violations;

SP1 – the required number of insignificant violations;

SP2 – the number of the revealed insignificant violations;

The risk exponent on violations (SP) is calculated on scale from 0 to 100 points and is determined by summing of indicators of considerable and insignificant violations by the following formula:

SP = SRZ + SRN, where:

SP – risk exponent on violations;

SRZ – indicator of considerable violations;

SRN – indicator of insignificant violations.

The received risk degree measure value on violations joins in measure calculation of risk degree by subjective criteria.

21. Measure calculation of risk degree by the subjective criteria determined according to Item of 16 these Criteria is made on scale from 0 to 100 points and performed on the following formula:  

xi – indicator of subjective criterion,

wi – specific weight of indicator of subjective criterion of xi,

n – quantity of indicators.

The received risk degree measure value by the subjective criteria determined according to Item of 13 these Criteria joins in measure calculation of risk degree by subjective criteria.

22. The values calculated by subjects (objects) by indicator are normalized by R in the range from 0 to 100 points. Normalization of data is performed on each sample (selection) with use of the following formula:

 

R – risk exponent (final) by subjective criteria of separate subject (object) of control,

Rmax – the greatest possible value on risk degree scale by subjective criteria on subjects (objects) entering one sample (selection) (the upper bound of scale)

Rmin – minimum possible value on risk degree scale by subjective criteria on subjects (objects) entering one sample (selection) (the lower bound of scale)

Rprom – the intermediate exponent of risk by subjective criteria calculated according to Item of 16 these Criteria.

Appendix 1

to Criteria for evaluation of risk degree in the field of drug circulation and medical products

Extent of violation of requirements to subjects (objects) of control in the field of drug circulation and medical products on compliance to qualification requirements

№ of payment order	Requirements	Extent of violations
1.	Compliance of the room or building on the property right or lease or trust management of state-owned property to the health regulations establishing sanitary and epidemiologic requirements to objects in the field of drug circulation and medical products	rough
2.	Availability of the equipment and furniture, stock, devices and the equipment for ensuring quality control and observance of conditions of production, production, storage and realization of medicines and medical products	rough
3.	Availability of the automotive vehicle with the corresponding cases and refrigeration and other equipment if necessary providing observance of storage conditions and realization of medicines and medical products for mobile pharmaceutical unit for rural settlements	rough
4.	Availability of the staff of the workers having the corresponding education, length of service and the certificate of the specialist for the organizations for production of medicines and medical products: the higher pharmaceutical or chemical and technological, chemical education and length of service in at least three years at division managers which is directly borrowed on production of medicines and medical products, or technical from the division managers who are directly occupied on production of medical products; the higher pharmaceutical or chemical, biological education at the workers exercising quality control of medicines and medical products, or technical at the workers exercising quality control of medical products; technical education at the equipment maintenance specialist used in engineering procedure of production of medicines and medical products	rough
5.	Availability of the staff of the workers having the corresponding education, length of service and the certificate of the specialist for the organizations in the field of drug circulation and the medical products performing production of medicines: the higher pharmaceutical education and length of service at least three years in the specialty at the head the drugstore performing production of medicines, and its production departments, and also the workers exercising quality control of medicines and medical products; the higher or secondary pharmaceutical education at the workers performing direct production of medicines and leave of the made medicines; secondary pharmaceutical education and length of service at least three years in the specialty at the head drugstore and its production departments in the absence of specialists with the higher pharmaceutical education in the district center and rural settlements	rough
6.	Availability of the staff of the workers having the corresponding education, length of service and the certificate of the specialist for drugstores: the higher or secondary pharmaceutical education (length of service in at least three years) at the head drugstore or its departments; the higher or secondary pharmaceutical education at the specialists enabling the realization of medicines and medical products; in case of realization of medicines on the Internet transport availability on the property right or leases for delivery implementation by the method which is not allowing change of their properties in the course of storage and transportation	rough
7.	Availability of the staff of the workers having the corresponding education, length of service and the certificate of the specialist for pharmaceutical Item in the organizations of health care giving primary medical and sanitary, consulting and diagnostic help: the higher or secondary pharmaceutical education (length of service in at least three years) at the pharmacy manager, and also workers enabling the realization of medicines and medical products. In pharmaceutical Items for rural settlements where there are no drugstores, in case of absence of specialists with pharmaceutical education for implementation of realization of medicines and medical products the specialists with medical education who were trained for their realization are allowed	rough
8.	Availability of the staff of the workers having the corresponding education, length of service and the certificate of the specialist for pharmaceutical warehouse: the higher pharmaceutical education and length of service at least three years at the head of pharmaceutical warehouse; the higher or secondary pharmaceutical education at heads of departments of pharmaceutical warehouse and workers performing acceptance, storage and leave of medicines and medical products	rough
9.	Availability of the staff of the workers having the corresponding education, length of service and the certificate of the specialist for mobile pharmaceutical unit for rural settlements: the higher or secondary pharmaceutical education at the manager of mobile pharmaceutical unit, and also workers enabling the realization of medicines and medical products. In case of absence of specialists with pharmaceutical education for implementation of retail sale of medicines and medical products the specialists with medical education who were trained for their realization are allowed	rough
10.	Availability of the staff of the workers having the corresponding education, length of service and the certificate of the specialist for production of medical products and the higher or secondary pharmaceutical, medical or technical education	rough
11.	Availability specialization or enhancements and other types of advanced training for the last 5 (five) years on the declared subspecies of pharmaceutical activities	rough
12.	Availability of the higher or secondary pharmaceutical education (length of service in the specialty - at least three years) for the physical persons applying for occupation pharmaceutical activities without formation of legal entity	rough

 

Appendix 2

to Criteria for evaluation of risk degree in the field of drug circulation and medical products

Extent of violation of requirements to subjects (objects) of control in the field of drug circulation and medical products for carrying out preventive control of subjects (objects) control on information sources

No. p\p	Name of criteria	Extent of violation
Section 1. Concerning the medical organizations for provision of medicines
1.	Observance of prescription of medicines, containing drugs, psychotropic substances and their precursors in case of out-patient and hospitalization in the organizations of health care by the doctor of the organization of health care having access to work with drugs and their precursors	rough
2.	Observance of fixation in the medical documents of the patient of prescription of medicines containing drugs, psychotropic substances and precursors of the Table II, III, IV of the List of drugs of psychotropic substances and precursors, which are subject to control in the Republic of Kazakhstan (further – the List), with indication of one-time dose, method and frequency rate of acceptance (introduction), duration of course of treatment, and also reasons for prescription of medicines	rough
3.	Ensuring use (acceptance) of the medicines containing drugs, psychotropic substances of Tables II, III of the List strictly under observation of medical personnel at the time of their issue: 1) oral administration, imposings of transdermal therapeutic systems (plaster, film); 2) in the presence of the nurse, introductions of injections - in the presence of the doctor	considerable
4.	Observance of rules and procedure for writing out of the recipes on medicines containing drugs, psychotropic substances and precursors	considerable
5.	Availability of the responsible person for storage and issue of special prescription forms	considerable
6.	Ensuring subject and quantitative accounting of special prescription forms	rough
7.	Availability of the safe or metal case for storage of special prescription forms. The room upon termination of work is sealed and sealed up. Room keys, seal and (or) ice cream are stored at the responsible person	rough
8.	Ensuring storage and destruction of the unused special recipes which are handed over by relatives of the died patients. Destruction of recipes is made in process of accumulating of recipes, but at least 1 (one) time a month, by burning in the presence of the permanent commission which structure joins the representative of law-enforcement body. The fact of destruction of unused special recipes is drawn up by the relevant act	considerable
9.	Availability of the head of the organization of health care of the list of the medicines containing drugs, psychotropic substances of the Table II of the List which is not exceeding five-day inventory which is used on permission of the responsible doctor on duty, for rendering the emergency medical care in the organization of health care giving stationary help in evening and night time determined by the order	rough
10.	Ensuring collection and destruction of empty ampoules from the medicines containing drugs, psychotropic substances of the Table II of the List which content is not used or used partially, and also tablets and plasters (transdermal therapeutic systems)	rough
11.	Order availability on the health worker responsible for execution of the temporary certificate of death, providing the notification of relatives of the died oncological patient about delivery of the unused special prescription forms and medicines containing narcotic and psychotropic substances of the Table II of the List, and also acceptance of the special prescription forms and unused medicines containing narcotic and psychotropic substances of the Table II of the List after the sick dead at home. Availability of delivery-acceptance certificates of the medicines containing drugs, psychotropic substances and their precursors, which remained after the death of the patient	rough
12.	Availability of the permanent commission which structure joins representatives of law-enforcement bodies and territorial subdivision of state body in the field of sanitary and epidemiologic wellbeing of the population for destruction of the medicines containing drugs, psychotropic substances of the Table II of the List expired, which are handed over by relatives of the died patients and also fight, marriage, empty ampoules, tablets and plasters (transdermal therapeutic systems), and also ampoules, tablets and plasters (transdermal therapeutic systems) which content is partially used	considerable
13.	Availability of acts of destruction of the medicines containing drugs, psychotropic substances and their precursors of Tables II, III, IV of the List	considerable
14.	Observance of the rules and procedure for registration and storage of medical documentation, requirements of medicines containing drugs, psychotropic substances and precursors of Tables II, III, IV of the List	considerable
15.	Observance of rules on writing out of recipes	considerable
16.	Ensuring accounting and monitoring of recipes on free or preferential receipt of medicines	considerable
17.	Providing the direction of specimen signatures of the authorized persons having the right to sign recipes, in objects of the pharmaceutical organization	insignificant
18.	Reflection in the out-patient card of the patient of content and number of recipes on free or preferential receipt of medicines	considerable

Disclaimer! This text was translated by AI translator and is not a valid juridical document. No warranty. No claim. More info