AN OPEN LETTER TO DR PAUL ORHII,THE DIRECTOR-GENERAL OF NAFDAC

Sir,
There is no gainsaying the fact that you have recorded unparalleled achievements as the director-general of NAFDAC. Your introduction of SMS confirmation of the authenticity of drugs is very commendable. Under your leadership,the use of law enforcement agents to chase producers and sellers of fake and substandard drugs has reduced. With the introduction of the SMS confirmation of the authenticity of drugs,unscrupulous elements in our drug markets are gradually going into extinction.

Meanwhile,on 26th October 2014 ,I decided to experiment on what had been bothering me. I thought that the system could not recognise multiple SMS using the same secret code hence I bought an antimalarial drug,sent the code to 38353 and immediately I received a text message that the drug was a genuine product. I then used my second phone to send the same code to 38353 and I was very surprised at the response that I received. The system was able to recognise that the secret code had been used by another user(my first phone). In fact,the second message I got read as thus, 'STOP,Your PIN:942824359337 already used on Oct 26,2014 at 5:53PM call 08039012929 NAFDAC &......'

In view of the above,I became optimistic that with the likes of Dr Paul Orhii in Nigeria,this country will certainly get better one day,it is just a question of time. This is because Dr Paul Orhii-led NAFDAC was able to think ahead of the unscrupulous drug dealers because if the system was not built to recognise double/multiple entries using the same code,the dubious drug dealers would just buy one genuine product of a drug they wanted to adulterate and then used the secret code for all their fake and substandard products. This is the type of leader that Nigeria needs,somebody who can think ahead of the masses. Americans are what they are today because they think at least ten years ahead of other nations.

However,I have some observations which I will like your establishment to investigate and make corrections . These observations had been there even before you were made the director-general of NAFDAC. First,I want to be properly enlightened on the criteria for the issuance of NAFDAC registration numbers to herbal medications in Nigeria. This is because an average Nigerian believes that any medication,food product etc without NAFDAC registration number is not safe. To an average Nigerian, any product with NAFDAC registration number is safe for consumption. Having realised this,the producers and sellers of NAFDAC -approved herbal medications go a long way to convince their potential buyers with these NAFDAC registration numbers. They brandish their NAFDAC-approved medications while feeding the public with wrong medical information. Many of them believe that every sickness or health problem is caused by staphylococcus,which is a normal flora of some parts of the body. They are even ignorant that the said Staphylococcus has different species which are aureus, epidermidis,saprophyticus etc. To them,even headache is caused by staph( as they commonly call it).

Many of these herbal medicine dealers have taken the advantage of the high level of illiteracy in the country to exploit the masses. They answer doctors because they know that an average Nigerian believes that the title 'Dr' means a medical doctor. Sequel to this every herbal medicine producer answers a doctor whereas the smart ones among them may pay their way through to get Honorary doctorate degrees. The more academically cunning and devious ones among them may smartly acquire PhD certificates in courses that neither relate to herbal medicine nor science-based hence they will officially be recognised as doctors. Chimamanda Ngozi Adichie captured such scenario in one of her books,The Half Of A Yellow Sun. A woman whose child was having an acute asthmatic attack rushed to a PhD holder living in her neighbourhood believing that as the PhD holder was called a doctor,that meant the PhD holder was a certified medical doctor. Even when the PhD holder in the novel honorably told the woman that he was not a medical doctor,the woman could not believe him. She thought that the supposed 'medical doctor' decided not to help her because the doctor knew that she did not have money to pay him.

The above illustration shows the level of understanding of an average Nigerian. This is a country where a paramedical professional will be parading himself as a medical doctor,treating people and usurping the roles of medical doctors in the society. I was in a seminar recently,where one of the participants asked me ,'why do Nigerian medical doctors refer patients to herbal medicine dealers?' I told her that no qualified medical doctor would ever refer any patient to herbal medicine dealers or the so-called healing homes,that quackery is the bane of medical practice in Nigeria. Anybody that fails out of medicine today will 'smartly' locate one corner of the country to go and carve a niche for himself in the medical profession. Some even have the temerity to use the title 'Dr' in all their official documents without anybody raising an eyebrow even when they are neither medical doctors nor PhD holders. The Nigerian Medical Association(NMA) will believe that it is the responsibility of the state ministries of health to arrest such impostors,whereas the state ministries of health believe that it is the responsibility of NMA hence the impunity goes on in the society . Why can't our PhD holders honorably omit Dr in front of their names while inserting PhD at the end of their names as it is done in saner societies,in order to differentiate between medical doctors and PhD holders? What we have in developed climes these days is as thus: Madueke Benjamin,PhD and not Dr Madueke Benjamin .Also, those that have honorary doctorate degrees are morally not supposed to use the title 'Dr' whenever they write their names. This is one of the ASUU demands when they embarked on nationwide strike last year.

Apart from the noise pollution that the strategically located loud-speakers of these herbal medicine dealers constitute on our roads and public places,they go a long way to disseminate wrong medical information to the mostly uneducated Nigerian masses who expectedly fall prey to their antics. Yes,your agency may give approval to the herbal products based on the samples that the herbal medicine dealers sent to your laboratory for investigations and subsequent approval,but does your agency have a provision where your officials can regularly go to the markets and our public places to buy or collect some of the products that are getting to the final consumers for retesting ? This is because I am aware that no 'good' herbal medicine businessman will ever send to your agency a sample that cannot pass through your laboratory tests.

At times, some products already in the market are banned by your agency after series of complaints are made by consumers and healthcare professionals,a part of pharmaco-vigilance. Surprisingly ,some of these banned products initially scaled though your laboratory tests hence they have their NAFDAC registration numbers. My suggestion is, let there be a provision where products that already have NAFDAC registration numbers are regularly retested by your agency ,and let your agency always collect samples from products that are already in the market just like I have noted earlier on that no 'good' businessman will ever send to your agency any sample that will not scale through your laboratory tests. I think the samples already in the market bought or collected from accredited dealers will go a long way in ascertaining the quality and content of the herbal medications which are available to the final consumers. I solemnly believe that you are aware of what I am saying because as Nigerians whenever an accreditation team is coming to any firm,such firm will get prepared for the accreditation team hence the accreditation team will not find anything wrong with the firm because the firm will be able to borrow the materials that are required only to return them to their rightful owners once the accreditation team returns back. We are all aware how our state governors repair our roads and renovate other dilapidated infrastructures anytime the president or national officials are visiting the states.

Secondly,does your establishment while approving and issuing the NAFDAC registration numbers to the producers of herbal medications deem it necessary to regulate the dosage and duration of the medication for the treatment of a particular ailment? This is because the toxicity of some drugs become conspicuous with increased dosage and duration. It is not uncommon to hear the vendors of these NAFDAC-approved herbal medications informing their patients/buyers to consume as much of the products as they can if they want their ailments to be cured very fast. It is now a marketing strategy that the more a marketer sells ,the more the remuneration and the likelihood the promotion hence the marketer,who is ignorant of the pharmacokinetic and pharmacodynamic properties of drugs, will convince the potential buyer to buy a lot of the medications and continue the medications until the ailment is cured. We are all aware that even paracetamol(Acetaminophen) which is one of the most commonly prescribed over-the-counter drugs,is hepatoxic at high dosage.

Also,does your agency while approving and issuing the NAFDAC registration numbers research on the drug-drug interactions,indications and contra-indications of these herbal medications? This is because it is common to see the leaflets of some NAFDAC-approved herbal medications claiming to cure all ailments known to man. Some producers in order to increase their market size will tell their consumers that anybody can take the medications including pregnant women and children .It is very disheartening when a clinician encounters a pregnant woman with intrauterine fetal death and no other aspect of the clinical history,physical examination or investigations will point to the possible cause of the intrauterine demise except that the expectant mother took one herbal medication in the course of her pregnancy. Some of the active agents in these herbal medications are not only embryotoxic but are also teratogenic.

My heart bleeds when paediatric patients come down with liver and kidney failures for no other reason except that their parents either took these herbal medications during pregnancy or that these innocent children were introduced to herbal medications while at tender ages when their livers and kidneys are still immature to handle the metabolism and elimination of the obnoxious contents of such herbal medications .I do not need to talk about our geriatric patients who come down with liver and kidney failures for no other cause except that they have been using these herbal medications for a very long time.

Meanwhile, while patent medicine dealers are on one side shortening the lifespan of Nigerians and contributing immensely to the high rates of drug resistance we have in our society through the abuse of drugs ,the herbal medicine dealers are on the other side contributing their own quota to the reduction of the lifespan of innocent Nigerians through the productions of medications whose contents are Hepatotoxic and Nephrotoxic. It is not uncommon to see patent medicine dealers combining more than three non-steroidal anti-inflammatory drugs (NSAIDS) while treating pain. Do the patent medicine dealers really know the side effects of these NSAIDS?

Meanwhile,China earmarked some funds for the research of their own herbal medications but here the reverse is the case. Some of our herbal medications are prepared in unhygienic environments. In fact,some of these herbal medications that finally get to the consumers are 'culture media' themselves encouraging the growth and multiplication of bacteria and other microorganisms. By issuing the much-respected NAFDAC registration numbers to the producers of these herbal medications ,are they also empowered to disseminate wrong medication information to the members of the Nigerian public? Are the registration numbers the licence for them to go on with noise pollution on our roads and public places,even going on air to feed the masses wrong medical information? Apart from NAFDAC, do the state ministries of health,information and environments and the federal ministries of health,information and environment have any regulatory functions on the productions and marketing of these herbal medications? Which agency of the government controls the medical information that these herbal medicine dealers disseminate to the members of Nigerian public?

Finally,I want to state clearly that I do not doubt any approval that your agency gives to any particular product, my concern is whether the content of the sample of a product sent to your agency for approval truly reflects the content of the same product that finally gets to the consumers?Also, does your agency have any regulations on the information about the said product that will get to the final consumers?

Dr Paul John
Port Harcourt,
Rivers state,
[email protected]
08083658038