Dover’s powder is mentioned in the regulations as one of the preparations of opium. It would seem sufficient at first glance that Dover’s powder as a preparation, if mentioned on the label, would be all that could be required as to opium.
One of the objects of the law is to inform the consumer of the presence of certain drugs in medicines, and the above terms do not give the average person any idea as to the presence or absence of such drugs. In enumerating the ingredients, the quantity or proportion of which is required to be given upon the principal label of any medicinal preparation in which such ingredients may be present, the act uses only common names, and the permission to use any but such common names for any ingredients required to be declared upon the label is neither expressed nor implied in any part of the law.
The term used for acetanilid is “acetanilid” and not phenylacetamid. No reference is made to the use of the chemical formula in designating the presence of chemicals. The words “chloral hydrate” appear in the act, but not the chemical name trichlorethidene glycol. It can readily be seen that if the act were not closely adhered to in this connection there would soon be such a confusion and multiplicity of names and phrases that one of the objects of the act would be defeated.
The names to be employed in stating the quantity or proportion of the ingredients required by the act to appear on the label of all medicinal preparations containing same are—
First. Those used in the law for the articles enumerated; example, “alcohol,” not “spiritus rectificatus.”
Second. In the case of derivatives: (a) The name of the parent substance used in the act should constitute part of the name; example, “chloral acetone,” not “trichlorethidene dimethyl ketone.” (b) The trade-name, accompanied in parentheses by the name of the parent substance; example, “dionin (morphin derivative).”
Third. Names of preparations containing the name of some ingredient used in the act. In such cases the name used in the act should constitute the first portion of the name of the preparation. (See [F. I. D. 55].)
Fourth. Common names (such as laudanum, Dover’s powder, etc.) of preparations containing an ingredient enumerated in the law, provided such name or names are accompanied in parentheses by some such phrase as “preparation of opium” or “opium preparation,” followed by the number of minims or grains, as specified in the regulations; for instance, “laudanum (preparation of opium), 40 minims per ounce.”
James Wilson,
Secretary of Agriculture.
Washington, D. C., March 13, 1907.