Saturday, November 15, 2025

Are Small Pharma Companies Bad? The Untold Reality Behind Schedule M, Compliance & India’s Pharma Backbone


 

The Question No One Wants to Ask Aloud

“Are small pharma companies bad?”


It’s a question that floats silently in boardrooms, audit halls, regulatory meetings, and even among healthcare professionals — yet rarely spoken openly.
Why?
Because the moment a drug recall or manufacturing issue hits the headlines, the instinctive reaction is:

“It must be a small pharma company.”

This stereotype has grown so powerful that many automatically equate “small” with “unsafe”, “unprofessional”, or “non-compliant.”
But is this stigma justified?
Or have we as an industry overlooked the complex realities, the economic struggles, the regulatory burdens, and the systemic pressure placed on India’s thousands of small and medium-scale pharmaceutical manufacturers?

This article dives deep into the truth — not the sugar-coated version, but the actual on-ground reality.
We explore the role of small pharma, their challenges, the impact of the revised Schedule M, and the difference between those who are struggling and those who are truly negligent.


1. India’s Pharmaceutical Backbone: A Giant Built on Small Foundations

India is proudly known as “The Pharmacy of the World.”
A global leader in generic medicines.
A lifeline for more than 200 countries.

Yet behind this global title lies an overlooked truth:

India has over 10,500 pharmaceutical manufacturing units — and nearly 70% are small or medium-scale.

These SMEs:

  • Are family-owned

  • Operate with lean teams

  • Run with limited budgets

  • Supply affordable medicines across India

They manufacture the everyday generics used by millions:

  • Paracetamol

  • Antibiotics

  • Antacids

  • Cough syrups

  • Pediatric formulations

  • Essential tablets and capsules

They ensure that a ₹2 strip in a city is still ₹2 in a rural clinic.

Small pharma is not the fringe — it is the foundation.

Yet it carries the worst perception.


2. The Stigma: Why Small Pharma Is Often Blamed

Let’s acknowledge the stereotype:

“Small pharma units are unsafe.”
“Small companies don’t follow GMP.”
“Small units cut corners.”

These statements are repeated often — but rarely questioned.

Why?

Because the public sees outcomes, not the circumstances.
They see deviations, not the pressures that caused them.
They see a failed batch, not the economic hardship behind it.

Small pharma is blamed because:

  • Their facilities are modest

  • Their infrastructure is aging

  • Their staff strength is limited

  • Their documentation systems are still evolving

But their intent is often far better than perceived.

Most small units are not negligent — they are overburdened, underfunded, and trying to stay afloat.


3. The Harsh Economic Reality: Compliance vs. Survival

The economic challenges faced by small pharma are enormous.

3.1 DPCO Controls: Price vs. Quality

Many essential medicines fall under DPCO.
The manufacturer’s margin may be:

  • ₹0.50 to ₹1 per strip

  • Sometimes even less

This leaves little room for:

  • Upgrades

  • Modernization

  • Hiring skilled manpower

  • Investing in documentation systems

  • Funding training programs

3.2 Raw Material Price Volatility

API and excipient costs change frequently.
Contracts are often fixed.
Losses accumulate silently.

3.3 High Utility Costs

Running HVAC, purified water systems, AHUs, and QC equipment can cost lakhs monthly.

3.4 Manpower Attrition

Trained staff often move to bigger companies for better salaries.
Small pharma must constantly train new employees.

3.5 Continuous Audits

Buyer audits, loan-license audits, and regulatory inspections lead to:

  • Downtime

  • Documentation load

  • Corrective action expenditure

Small pharma isn’t choosing shortcuts.
Small pharma is fighting for survival.


4. Revised Schedule M: The Biggest Regulatory Shift in Two Decades

The revised Schedule M is essential — no doubt.
It raises the bar for quality across India.

But it also creates major challenges for small units.

Upgrading to Revised Schedule M costs ₹2–5 crore, depending on:

  • HVAC zoning

  • Area classification

  • AHU upgrades

  • Cleanroom paneling

  • Epoxy flooring

  • Water system qualification

  • Modern QMS adoption

  • Equipment qualification

  • Updated validations

  • New utilities and electrical layouts

This expense is impossible for many small units without support.

So when a regulator asks:

“Why haven’t you upgraded yet?”

The honest answer is:
They want to — but they cannot afford to.

Not immediately.
Not without assistance.


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5. Regulatory Pressure: Fear Over Guidance

Small pharma units don’t fear quality.
They fear:

  • unpredictable interpretations

  • inconsistent inspection styles

  • heavily documentation-focused audits

  • subjective expectations

One inspector may focus on HVAC.
Another on documentation accuracy.
Another on change control.
Another on trend analysis.
Another on batch record formats.

This inconsistency has created inspection anxiety, not quality culture.

Audits should inspire improvement — not fear.


6. Big Pharma’s Silent Shadow

Here’s the irony:

Small units often manufacture products for big companies under contract.

When everything goes right:

The big company gets the credit.

When something goes wrong:

The manufacturer gets the blame.

Big companies have:

  • Stronger PR teams

  • Larger legal teams

  • More influence

  • Better negotiation power

  • Greater market presence

Small pharma doesn’t.

Yet they often produce the same products under the strict SOPs of those large corporations.


7. The Unwilling Few — The Real Problem

It would be unfair to claim all small pharma units are victims.

Some are truly negligent.
These are the ones who:

  • ignore documentation

  • skip calibrations

  • reuse old batch records

  • avoid validations

  • maintain poor housekeeping

  • depend on shortcuts

These few create a negative image for everyone else.

They must be corrected, penalized, or shut down.

But they represent a small minority.


8. The Real Solution: A Graded Compliance Model

India needs a maturity model to categorize units based on their readiness and intent:

Category A — Fully Compliant

Encourage exports and expansions.

Category B — Substantially Compliant

Provide incentives for upgrades.

Category C — Non-Compliant but Willing

Offer training, mentoring, and technical support.

Category D — Persistently Unwilling

Take strict regulatory action.

This creates:

  • fairness

  • structure

  • opportunity

  • accountability


9. The Path Forward: What India MUST Do

India’s small pharma will thrive if supported through:

✔ Subsidies for modernization

✔ Soft loans for facility upgrades

✔ Digital QMS tools at affordable cost

✔ GMP Support Cells in every state

✔ Training and mentoring programs

✔ Shared QC labs in pharma clusters

✔ Recognizing improved companies

✔ Uniform interpretation of Schedule M

Support → Compliance → Better public health.


10. The Final Truth: Are Small Pharma Companies Bad?

So… are small pharma companies bad?

No.
Not even close.

Small pharma companies are:

  • the backbone of affordable healthcare

  • the first line of medicine supply in India

  • dedicated, hardworking, and essential

  • victims of financial and regulatory pressure

  • trying to maintain quality with limited resources

But yes — a small group of companies remains negligent.
They should be corrected.
Or shut down.

However, they do not represent the majority.

The majority deserve support, guidance, and recognition — not stigma.


11. A Future We Can Build — Together

Imagine an India where:

  • every small manufacturer meets WHO-GMP

  • modernization doesn’t mean closure

  • audits help instead of scare

  • documentation becomes digital and accessible

  • skilled manpower stays because the ecosystem supports them

  • state-level GMP support centres mentor SMEs

  • quality is a culture, not a compliance burden

This future is possible.
It is within reach.
And it depends on how we treat small pharma today.


12. A Message for Every Reader

If you’ve reached this point, you’re someone who cares about:

  • patient safety

  • industry fairness

  • regulatory balance

  • quality culture

So remember this:

Quality isn't built by fear. 

Compliance isn’t strengthened by intimidation. 

Industries don’t grow when we punish the willing. 

They grow when we uplift them.


🎥 Watch the Full Video — The Story Hits Harder Visually

The written article gives clarity.
The video gives emotion, visuals, and narrative depth.

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💬 What do YOU think is the biggest challenge for small pharma today?

Comment on the YouTube video — your insight could help thousands.

If you found this article valuable:

✔ Share it in WhatsApp pharma groups
✔ Share it with QA/QC teams
✔ Share it with small pharma owners
✔ Share it with regulatory professionals
✔ Share it with your LinkedIn network

Awareness breaks stigma.

Stigma blocks progress.

Progress strengthens India.

Monday, October 6, 2025

Bitter Medicine: Cough Syrup Deaths, Regulatory Failures, and India’s Quest for Safe Pharmaceuticals

 

Introduction: A Tragedy that Shocked the Nation

India has been jolted by the deaths of at least 12 children in Madhya Pradesh and Rajasthan, linked to the consumption of contaminated cough syrup. Laboratory investigations revealed the presence of diethylene glycol (DEG), a toxic chemical used in antifreeze, in concentrations as high as 48.6%—far beyond safety limits. States responded by banning the implicated product, ordering nationwide inspections, and issuing urgent advisories. The episode reignited questions about drug safety, manufacturing practices, and regulatory failures that have long plagued the sector.


_____________________________________________________________________________________

Anatomy of a Disaster

Case Details and Timeline

In early September 2025, Chhindwara district in Madhya Pradesh began to report cases of acute kidney failure in children following administration of Coldrif syrup, manufactured by Sresan Pharma. The tragedy unfolded as follows:

Multiple children developed complications within days, with the first death occurring on September 2.
A spike in fatalities forced hospitals and authorities into action.
Laboratory analysis conclusively linked the deaths to extreme DEG contamination.
State and central governments banned Coldrif, seized stocks, and extended the prohibition to other medicines from the same manufacturer.

National Alarm and Response

  • Central Drug Standards Control Organisation (CDSCO) began risk-based inspections in six states, recognizing systemic risk.
    The Union Health Ministry issued an advisory against cough and cold syrup prescriptions for children below two.
    Compensation and medical reimbursement for affected families were announced, but outrage grew as investigations pointed to deeper failures.

_____________________________________________________________________________________

How Spurious and Adulterated Drugs Proliferate

Regulatory Gaps and Fragmentation

India’s pharmaceutical sector operates under layered, often fragmented oversight: central bodies (CDSCO), state drug controllers, and district health authorities. Key weaknesses:

Insufficiently resourced state authorities, limited lab capacity, and few trained inspectors.
Disjointed record-keeping and lack of unified databases.
Delays and gaps in post-market surveillance and recall protocols.

Economic Pressures and Ethical Lapses

  • Fierce competition and price controls drive manufacturers toward cost-cutting—sometimes substituting toxic chemicals for safer ingredients (DEG for propylene glycol).
    Weak supply chain traceability lets counterfeit and substandard drugs slip through.
    Training gaps among staff—especially in small and mid-scale plants—mean SOPs aren’t always followed.

Supply Chain Weakness and Poor Pharmacovigilance

  • Medicines pass through tens of thousands of distributors with minimal batch tracing.
    India’s pharmacovigilance programme remains poorly understood, with adverse event reporting rare and enforcement patchy.

Outdated Manufacturing Infrastructure

Many small and medium enterprises operate in decades-old facilities, lacking modern equipment, interlocks, and robust safety mechanisms—making cross-contamination and process failures common.

_____________________________________________________________________________________

The Regulatory Framework—Shortfalls and Loopholes

Drugs and Cosmetics Act and Its Limits

  • The Drugs and Cosmetics Act, 1940—amended many times—remains the sector’s legal backbone, mandating product approval, batch testing, and penalties.
    Penalties for first-time or minor violations are often tiny compared to profits, making compliance a low priority.
    Lack of harmonization across states means some regions are “soft targets” for unscrupulous manufacturers.

Recalls, Testing, and Post-Market Surveillance Failures

  • Testing is often slow and limited; recalls even slower, allowing contaminated products to remain on shelves for months.
    Inspections are infrequent, often announced in advance, and affected by staff shortages.

International Fallout

India’s status as a major medicine exporter means global reputation is also at stake. Recent cough syrup incidents abroad have triggered bans and lawsuits, hurting the credibility of “Made in India” medicines.

_____________________________________________________________________________________

Accountability Across the Production Chain

The Role of Analysts

  • Drug analysts serve as gatekeepers: chemically, physically, and micro-biologically testing every batch before approval.
    If analysts neglect, falsify, or ignore problems, dangerous medication enters the market.

Production Chemists and Quality Staff

  • Production chemists maintain batch integrity, check weighing and mixing, follow SOPs, and validate final release. Their documentation and sign-off are essential.
    Quality assurance staff ensure compliance, document deviations, and trigger corrective actions.

Supervisors and Regulatory Inspectors

  • Supervisors enforce day-to-day GMP compliance, inspect documentation, and train staff.
    Regulatory agencies must audit facilities, enforce standards, and order recalls/scans as needed.

Shared Responsibility

Accountability must extend to every link. Negligence, omission, or willful non-compliance at any stage can directly cause harm. Historically, legal action focuses on management, but there is an urgent need to prosecute every complicit party—from analyst to inspector.

_____________________________________________________________________________________

Penalties and Enforcement

Current Provisions

  • Drugs and Cosmetics Act: Up to life imprisonment and multi-lakh fines for manufacturing or selling adulterated drugs causing death.
    IPC Sections 274/275: Six months imprisonment or fines for adulteration/sale; but actual deterrence is weak.

The Reality of Enforcement

  • Rare prosecution of non-management staff despite clear evidence of chain accountability and negligence.
    Most regulatory actions are limited to bans, recalls, or license cancellations.
    Experts call for stronger enforcement targeting individuals across all roles.

_____________________________________________________________________________________

Schedule M—The Imperative Reform

What is Revised Schedule M?

Revised Schedule M upgrades India’s GMP standards to global levels by mandating:

Modern facilities (clean rooms, validated equipment, proper personnel/material flow)
Strict process documentation and training
Enhanced inspection protocols

The Harm of Extensions

Despite its importance, Schedule M compliance deadlines have been routinely postponed for small and medium manufacturers, now extended to December 2025.

Every extension leaves patients exposed to substandard manufacturing processes.
Delays undercut not only domestic safety but global reputation.

No More Excuses

India must enforce Revised Schedule M across all facilities, with immediate closure or penalties for non-compliance. The new law cannot remain negotiable or optional.

_____________________________________________________________________________________

Pathways to True Accountability

Immediate Action Steps

  1. Unconditional, universal Schedule M enforcement—No further extensions. Facilities must shut down if non-compliant.
    Criminal liability across all roles—prosecution, blacklisting, and license cancellation for every complicit staff member.
    Transparent compliance reporting—publicly track audit results, recalls, and enforcement actions.
    Robust pharmacovigilance—train health workers and educate the public to report adverse events; ensure timely regulatory follow-up.
    Mandatory re-training—every staff member must undergo periodic GMP and compliance updates.

Long-Term Reforms

  • Investment in inspector training, testing labs, and digital batch tracing.
    Collaboration with global regulatory bodies for harmonized best practices.
    Incentivize ethical practices by linking compliance to market access and export privileges.

_____________________________________________________________________________________

Conclusion: Lives at Stake, Reform Cannot Wait

India stands at a crossroads. The cough syrup deaths are not isolated; they are a symptom of endemic regulatory and ethical failures. Full accountability—analyst to owner, inspector to regulator—must be enforced. The Revised Schedule M offers a clear path, but only if implemented without delay, compromise, or further extensions.

India’s children deserve safe medicine—nothing less will do.

Disclaimer:
This blog expresses the author’s personal analysis, opinions, and interpretation of the recent cough syrup tragedy and pharmaceutical regulatory issues in India. The content is intended for educational and informational purposes only, and does not constitute professional medical, legal, or regulatory advice. Readers are encouraged to consult qualified professionals for specific guidance. The author and publisher disclaim any liability arising from the use or interpretation of this material. Opinions shared here reflect the author's viewpoint based on currently available information and should not be taken as official or legally binding statements.

References:

A comprehensive list of regulatory updates, news articles, expert commentaries, and official advisories from October 2025 forms the basis of this analysis.