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To be over-the-counter or not to be – That is the question: Reconsidering over-the-counter access – When convenience becomes a public health risk

*Corresponding author: Mridul Madhav Panditrao, Department of Anaesthesiology and Intensive Care, Adesh Institute of Medical Sciences and Research, Adesh University, Bathinda, Punjab, India. drmmprao1@gmail.com
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Received: ,
Accepted: ,
How to cite this article: Panditrao MM. To be over-the-counter or not to be – That is the question: Reconsidering over-the-counter access – When convenience becomes a public health risk. Adesh Univ J Med Sci Res. 2025;7:1-6. doi: 10.25259/AUJMSR_56_2025
To be, or not to be, that is the question:
“Whether ‘tis nobler in the mind to suffer The slings and arrows of outrageous fortune,
Or to take arms against a sea of troubles And by opposing end them. To die—to sleep,”
William Shakespeare in “Hamlet”
INTRODUCTION
In our country, where a fast-paced life, desperation for conveniences, and craving for instant solutions are the norm, “over-the-counter” (OTC) medications have become everyday tools for self-care. They promise relief without a prescription, freedom from waiting rooms, and control over minor ailments. However, some drugs available “OTC” today arguably belong behind the pharmacy counter, “not to be OTC” – not to restrict, but to protect.[1]
In India, with its vast, diverse, and one of the largest pharmaceutical markets (with more than 80,000 brands) and where access to healthcare is often uneven, the pharmacy counter has quietly become a surrogate clinic. With minimal regulation and oversight, often without any clear classification, a wide array of drugs – from cough syrups to antibiotics and painkillers – are sold OTC, often without a prescription.[2] The pharmacies or what is colloquially called “Medical Shops” and their operators also called “Chemists” are often the first point of contact for healthcare. With the widespread availability of medicines and limited regulatory oversight, OTC drug dispensing is a prevalent and largely unmonitored practice. While convenient for patients, especially in rural and underserved areas, providing essential relief to them, the unrestricted sale of OTC medications, especially high-risk drugs, without proper guidance or documentation poses serious public health risks, such as misuse, resistance, addiction, and preventable hospitalizations.[3] In addition, certain other occurrences such as excessive drug dosage, polypharmacy, drug abuse, and drug interactions also raise an uncomfortable public health question: “Should all these drugs really be available so freely, OTC?”[4]
The very premise of OTC availability is that consumers can safely use these drugs without a healthcare professional’s oversight. For many medications – mild pain relievers, antihistamines, antacids – this holds true. However, “not all drugs are created equal, and some pose risks that outweigh the benefits of unrestricted access.”
THE OTC PARADOX
India’s pharmaceutical landscape is unique. Unlike countries with clear regulatory distinctions between prescription and non-prescription drugs, India lacks an officially codified and enforced list of OTC drugs. Instead, the market operates in a gray area, governed loosely by the “ancient” Drugs and Cosmetics Act, 1940 and its subsequent amendments. Although the Drugs and Cosmetics Act, 1940 classifies drugs into schedules, such as H, H1, and X, which require prescriptions, many prescription-only drugs are dispensed over the counter in community pharmacies. In addition, drugs such as antibiotics, anti-inflammatory agents, antitussives, and even opioid analgesics are commonly sold without a prescription, often at the discretion of the pharmacist or pharmacy assistant because enforcement of regulations is patchy and, in many cases, non-existent – particularly in semi-urban and rural areas.[5]
The absence of a legally defined OTC category further dilutes the practice of prescribing. Most Western countries have systems in place that categorizes OTC drugs and prescription drugs based on safety and usage profiles and ensure adherence to these categories; however, India operates with a de facto OTC system that is vulnerable to misuse.[1]
While OTC access promotes convenience and autonomy, it can come at the cost of safety, especially if:[6]
The drug has a high potential for misuse or abuse
Side effects are serious or hard to self-manage
The drug interacts dangerously with common medications or conditions
Proper dosing or diagnosis requires professional guidance.
Here are some examples of drugs that arguably should not be OTC (or at least should have stricter controls):
Take codeine or dextromethorphan (Corex-DX®)-based cough syrups, still available without a prescription in several countries. Codeine, an opioid, can cause addiction, respiratory depression, and in some cases, fatal overdose – particularly in children. The U.S. has already moved to restrict such products to prescription-only status, but globally, the picture is inconsistent. Abuse of these syrups has sparked public health crises in many countries, including India. When dealing with a drug like codeine or dextromethorphan, the line between medicine and narcotic is dangerously thin.
The most troubling example, especially in the northern states (Punjab and Haryana), is tramadol.[7] In general, a naïve patient is coincidentally exposed to it, either in the immediate post-operative period by the surgical team or in the orthopedic/surgical or pain clinics for some chronic pain-related issues such as backache or knee pain. Whichever way, this, now “hooked” patient, starts drug-seeking at the local pharmacies, illicitly in connivance with the “co-operative” chemist. Whole generation after generation of productive youths has been utterly destroyed by this drug and now its successor “tapentadol.” A similar routine is being followed in the case of drugs such as gabapentin or pregabalin. Not surprisingly, all of these drugs are available, of course, OTC!
Then, there is pseudoephedrine (SudaFed®), a common decongestant which is also a key ingredient in methamphetamine. While effective for colds, its misuse in the manufacturing of methamphetamine has led to tighter regulations in some jurisdictions, including ID tracking and purchase limits.[8] Yet, it remains technically OTC in India. Convenience persists – so does abuse.
Even non-steroidal anti-inflammatory drugs (NSAIDs) like aspirin, which are well and truly OTC, can be hazardous if abused chronically and without medical consultation – leading to numerous adverse effects such as gastrointestinal bleeding, increased risk of bleeding, and liver damage. Using OTC NSAIDs such as ibuprofen, acetaminophen, and diclofenac/aceclofenac as a self-prescribed band-aid for everyday symptoms can lead to masking of more serious medical issues; not to mention, these drugs have their own harmful side effects, to which most people are ignorant.
Perhaps more insidiously, proton pump inhibitors (PPIs) such as omeprazole (Omez®) lull users into long-term dependence. Marketed for heartburn relief, they can mask symptoms of more serious conditions such as esophageal cancer and carry their own long-term risks – including osteoporosis, kidney disease, and vitamin deficiencies. Yet, they sit on the shelf, marketed for daily use.
Even benign-seeming drugs like diphenhydramine (Benadryl®) have drawn concern. Misused as a sleep aid, it can cause next-day grogginess and confusion in older adults and has even been implicated in teenage overdoses through social media “challenges.” Its sedative properties and toxic dosage threshold make it a poor candidate for unrestricted use – yet it is often one of the first remedies people reach for.
Despite being classified under Schedule H, corticosteroids in any kind of oral, topical, and injectable formulations are widely sold OTC across the country. Pharmacy shelves carry dexamethasone, betamethasone, prednisolone, hydrocortisone, and potent steroid-antibiotic skin creams, which are readily handed over to patients seeking quick relief from symptoms such as itching, pain, swelling, cough, breathlessness, or even “feeling weak.” Of course, in many instances, neither the patient nor “pharmacist” is aware of the laundry list of adverse effects caused by these “wonder drugs.”
Probably the most abused drugs in healthcare, antibiotics have become more like “nutritional supplements” in any household. Not distinguishing whether their complaints are due to allergies or simple self-limiting viral infections, both the “pharmacist” and patient fervently believe that antibiotics are the “cure-all” for any disease. This, of course, has put India at the forefront of the list of countries with an established antimicrobial resistance (AMR) crisis.
The problem with loperamide (ROKO®) is that the initial use is definitely for a medical condition – diarrhea. However, it is quickly abused and misused, in the name of convenience, leading to a physiological dependence that has long-term consequences (particularly cardiovascular). The dependence may not always be related to the central nervous system; in some individuals, the act of not having to go to the toilet itself becomes a compulsion.
Benzodiazepines, such as alprazolam (Alprax®) and lorazepam (Larpose®), have become household names in India. Dispensed without regulation or prescription, for any number of complaints ranging from “lack of sleep” (insomnia) to “tension” (anxiety) to just feeling good (euphoric), patients simply turn up at the chemist shop and demand a pack of these agents. The unregulated sale of alprazolam and other benzodiazepines without prescription in India is a silent public health threat, contributing to the growing burden of drug dependence, psychiatric emergencies, and preventable deaths.
It is not the purpose of this editorial to criticize the use of these OTC and/or prescription drugs; however, to point out that the indiscriminate and unregulated use of either class of drugs can be detrimental and must be “checked.”
THE IMPLICATIONS OF UNCHECKED ACCESS
The harms of unregulated OTC drug sales are not theoretical – they are real, ongoing, and escalating. Self-medication often leads to delayed diagnosis, adverse drug reactions, and interactions with other medications. The casual sale of antibiotics has turned India into one of the epicenters of AMR, threatening the very foundation of modern medicine.
The economic burden is also considerable. Misuse leads to more hospitalizations, longer treatments, and higher out-of-pocket expenses – particularly devastating for low-income households. Moreover, then, there is the social cost: The growing misuse of codeine and other sedative agents has fed into addiction crises, especially among the youth.
THE CHEMIST CONUNDRUM: LACK OF TRAINING, UNETHICALITY AND IMMORALITY
A significant contributor to unsafe OTC dispensing practices is the widespread lack of formal training, ethical values, and regulatory accountability among retail pharmacy personnel. Although legal mandates require a registered pharmacist to be present at retail counters, in reality, many outlets are staffed by untrained assistants or sales personnel lacking even basic pharmacological knowledge.
Pharmacological Illiteracy: Many chemists dispense drugs based on anecdotal experiences or commercial incentives, rather than evidence-based recommendations or therapeutic guidelines.
Malpractice and overreach: In rural and peri-urban India, it is common for pharmacy staff (often not registered pharmacists) to act as informal prescribers – advising on dosages, substituting drugs without medical consultation, and in some cases, selling combinations of medications without any documentation.
Incentivized Dispensing: Pharmaceutical companies often offer incentives to chemists to push specific brands, further undermining rational drug use. This commercial influence often trumps patient welfare and clinical appropriateness.
Prescription recycling and duplication – In the absence of electronic health records and e-prescriptions, many a time, patients will reuse the same prescription for months together or fulfill the same prescription at different pharmacies to get more pills – usually in an effort to get their “fix.”
Neglect of Counseling: Patient education – on dosage, duration, side effects, and contraindications – is virtually absent in most retail settings.
This ecosystem of informal and profit-driven dispensing results in irrational polypharmacy, patient harm, and wider public health fallout.
UNDERLYING CHALLENGES
Lack of Enforcement: Although Schedule H and H1 drugs require prescriptions, enforcement at the pharmacy level is minimal.
Pharmacist Shortages: Many retail outlets operate without a qualified pharmacist on site or with pharmacists who are not actively involved in patient counseling.
Consumer Perceptions: Patients often equate accessibility with safety, believing that easily available drugs are inherently safe.
Absence of Awareness Campaigns: Public health messaging around rational drug use is limited or nonexistent in most regions.
WHAT NEEDS TO BE DONE URGENTLY? - STRENGTHENING OTC DRUG DISPENSING PRACTICES IN INDIA
To reform the prevailing OTC drug dispensing practices and ensure safe, rational medicine use, India needs a multi- pronged strategy involving policy, enforcement, education, and legal action.
Creation of a legally defined OTC drug list
India currently lacks a designated list of approved OTC drugs.[1]
The Central Drugs Standard Control Organisation (CDSCO), in collaboration with the Indian Pharmacopoeia Commission (IPC) and the Indian Council of Medical Research, should formally define and publish an OTC schedule based on safety profiles, risk categories, frequency of use, and pharmacovigilance data.[4]
This list must exclude high-risk drugs such as antibiotics, steroids, sedatives, and hormonal agents.
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Reclassify high-risk OTC drugs:[9] Moving certain drugs (e.g. codeine, pseudoephedrine, strong NSAIDs, diphenhydramine) from OTC to:
Behind-the-counter: Available only after a consultation with a registered pharmacist
Prescription-only: For drugs with serious misuse or side effect risks.
Mandatory licensing and on-site pharmacist enforcement
Enforcement of the rule that “no pharmacy can operate without a full-time registered pharmacist present on-site at all times.”
Similar to the NMC-mandated attendance for doctors, the introduction of compulsory digital attendance and biometric verification systems for pharmacists linked with pharmacy registration numbers must be enforced.
State Drug Control Authorities must conduct regular and surprise inspections to check for license misuse or proxy operation by unqualified persons.
Rational dispensing practices
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Limit packaging and dosages
Smaller package sizes for drugs with overdose potential (e.g., acetaminophen)
Lower-strength formulations for OTC versions
Usage-duration caps (e.g., PPIs for max 14 days without medical review).
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Pharmacist-gatekeeping policies: Pharmacist involvement before selling certain OTC drugs, even if not prescription-only. Pharmacists can:
Ask basic screening questions
Review possible drug interactions
Educate on appropriate use and duration.
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Improved Labeling and Warnings: Mandating clearer, more prominent labels on risks like to inform consumers who may not read the fine print or consult a provider
Dependence potential
Hidden interactions (e.g., NSAIDs with blood thinners)
Maximum safe duration of use.
Training, certification, and continuous education for chemists
The Pharmacy Council of India (PCI) must establish mandatory continuing pharmacy education programs every 2–3 years for all retail pharmacy staff.
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Modules on the following should be included:
Drug classification and legal schedules
Safe dispensing practices
Patient counseling
Rational drug use and AMR
Identifying red flags for referral to a physician.
Certification examinations should be administered by the PCI or accredited universities
Digital prescription validation and sales audits
Introduction of e-prescription platforms linking doctors, pharmacists, and patients – especially for Schedule H, H1, and X drugs.
Barcode scanning and real-time verification must be implemented before selling restricted medications.
Monthly audits of sales records should be made mandatory and auditable, ideally through automated systems integrated with GST/tax software.
Public awareness campaigns on risks of self-medication
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Launching nationwide information, education, and communication (IEC) campaigns highlighting:[10]
Dangers of self-medication and irrational drug use
Dangers of antibiotic misuse and AMR
Side effects of irrational polypharmacy
Importance of seeing a doctor before starting medications whether OTC or prescription drugs.
Campaigns must be multilingual and disseminated through TV, radio, pharmacies, schools, and social media.
Stronger legal penalties for malpractice
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Amend the Drugs and Cosmetics Act to include specific penalties for:
Dispensing prescription-only drugs without valid prescriptions
Employing unregistered persons at pharmacy counters
Selling expired, substituted, or misbranded medications
State Pharmacy Councils should also maintain a blacklist of repeat violators and make it public to deter malpractice.
Incentive and recognition schemes
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Pharmacies that comply with guidelines and demonstrate ethical practices should receive:
“Rational Pharmacy” accreditation
Priority for participation in government schemes (like Jan Aushadhi)
Tax or licensing fee rebates.
Encourage involvement of professional bodies
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Associations such as the Indian Pharmaceutical Association and All India Organisation of Chemists and Druggists should play a more proactive role in:
Peer surveillance
Capacity-building workshops
Disseminating rational use guidelines.
Monitoring and evaluation
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Establish a national dashboard under CDSCO or IPC for:
Reporting violations anonymously
Tracking enforcement actions
Measuring regional trends in irrational sales and AMR resistance patterns.
Tackling irrational OTC dispensing requires systematic reform. By combining clear legal boundaries, stringent enforcement, active education, public awareness, and technological integration, India can curb dangerous dispensing practices while safeguarding accessibility. Without this structural overhaul, the country risks exacerbating the twin crises of medication misuse and AMR.
CAN DOCTORS DO PITCH IN TO THWART OTC DRUG MISUSE IN INDIA?
Prescribing rationally and clearly
Avoiding overprescription of antibiotics, steroids, sedatives, and multi-drug combinations.
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Standard guidelines for prescription writing must be strictly adhered to:[11]
Generic names (as per government norms)
Clear instructions on dose, duration, and when not to use the drug
Legible writing or digital printouts to avoid misinterpretation at pharmacies
Use prescription pads with security features (e.g., carbon copy, watermark) to discourage duplication or misuse, signatures of dispensing pharmacists with dates.
Education of patients at the point of care
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Cautioning patients against:
Reusing old prescriptions
Self-medicating when symptoms recur
Buying partial doses or shortening therapeutic regimens to save cost
Emphasizing the dangers of misuse, such as AMR, masking of serious conditions, and adverse drug reactions
Encouraging them to report any unprescribed medications offered by chemists.
Reporting of violations
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Actively reporting the chemists/pharmacies that are:
Dispensing Schedule H/H1 drugs without prescriptions
Substituting or selling inappropriate alternatives.
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Reports can be made to:
State Drug Control Administration
Local branch of pharmacy council
IPC’s pharmacovigilance cell.
Some states even allow anonymous reporting or digital filing of complaints.
Engaging in community outreach
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Doctors, particularly those in public hospitals and teaching institutions, can:
Conduct awareness sessions in villages and urban slums
Collaborate with ASHA/ANM workers to educate women and children on safe drug use
Work with NGOs or PHCs on IEC material related to rational drug use for patient use.
Collaboration with local pharmacists
Build a professional rapport with trusted local pharmacists.
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Offer training sessions or newsletters on:
Recognizing red-flag symptoms
Proper drug storage
When to refer a patient to a doctor instead of selling OTC remedies.
Form local rational drug use networks or advisory groups in districts.
Advocating for policy and structural reform
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Medical associations such as IMA, FPAI, and API can petition for:
Mandatory pharmacist presence in every pharmacy
Digital prescription tracking integration between clinics and pharmacies
Incentives for ethical pharmacy practices.
Supporting legal reforms by providing case studies and clinical evidence that link patient harm to OTC misuse.
Documentations and publications
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Case reports of:
Adverse drug reactions due to OTC misuse
Treatment failures due to antibiotic resistance from self-medication.
These can raise visibility in journals, newsletters, and health policy discussions.
Implementation of pharmacovigilance in routine healthcare
Report ADRs through the Pharmacovigilance Programme of India to help track unsafe usage trends, especially from OTC misuse.
Encourage medical interns and residents to engage in pharmacovigilance reporting as a part of clinical training.
Use technology to reinforce safe practices
Use e-prescription applications that auto-flag restricted drugs and limit refills
Suggest verified health apps or telemedicine platforms where patients can access supervised care, reducing chemist dependency.
EPILOGUE
While India’s OTC drug dispensing culture stems from a need for accessibility in a resource-limited setting, the current unregulated practices are unsustainable and hazardous. Balancing patient access with public safety requires thoughtful policymaking, robust enforcement, and systemic education. A reformed OTC framework can be a cornerstone of rational pharmacotherapy and a bulwark against the mounting threat of AMR.
Doctors must act not just as prescribers but as educators, advocates, and stewards of rational drug use. By reinforcing ethical dispensing practices and empowering patients with accurate information, clinicians can significantly reduce the misuse of OTC drugs and unregulated dispensing of prescription-only drugs in India. Their collective action can form the backbone of a culture shift toward safer, more accountable medicine use.
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