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November/December 2008 - Ontario College of Pharmacists

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practice Q&A<br />

Greg Ujiye, R.Ph., B.Sc.Phm.<br />

Pr<strong>of</strong>essional Practice Advisor<br />

QWhat must a pharmacist report to Health Canada<br />

regarding controlled substances, specifically<br />

narcotics and controlled drugs?<br />

Both the Narcotic Control Regulations (NCR section 42)<br />

and the Regulations to the Food and Drugs Act (s.G.03.013)<br />

requires a pharmacist to report any loss or theft <strong>of</strong> these<br />

drugs within 10 days <strong>of</strong> discovering the loss.<br />

QHow do I report a loss? Are there forms to fill<br />

out?<br />

Forms can be found on the Health Canada website at:<br />

http://www.hc-sc.gc.ca/dhp-mps/substancontrol/substan/compli-conform/loss-perte/index-eng.php<br />

In addition, pharmacists can access the forms through the<br />

OCP website by clicking on the menu tab “<strong>College</strong> Forms”<br />

at the bottom <strong>of</strong> the OCP homepage, and clicking on the<br />

link “Reporting narcotic and controlled drug loss…”<br />

QWhat would be considered a loss <strong>of</strong> controlled<br />

substances?<br />

A loss can take many forms. Simply stated, a loss is anything<br />

that results in a shortage in your inventory <strong>of</strong> controlled substances.<br />

Some examples are theft or robbery, diversion or<br />

unexplained loss, spillage or wastage, damage or contamination<br />

<strong>of</strong> products, etc.<br />

QWhat about forgeries? Are they reported<br />

together with other losses?<br />

No. Although forgery is a form <strong>of</strong> loss, forgeries are reported<br />

on a separate Health Canada form. <strong>Pharmacists</strong> should<br />

download and keep copies <strong>of</strong> both the loss report and the<br />

forgery report forms with their narcotic records.<br />

QWhat if I discover a forgery that was filled in the<br />

past? Do I still need to report that?<br />

Yes. Any loss, theft or forgery must be reported within 10<br />

days <strong>of</strong> discovery.<br />

Why is it necessary to print and review the<br />

QNarcotic Sales Report?<br />

The Narcotic Sales Report is an important management<br />

tool in curbing diversion and theft, when properly reviewed.<br />

Owners and managers should use the report with the narcotic<br />

prescriptions dispensed to ensure that<br />

• all reportable narcotics and controlled drugs are properly<br />

recorded, i.e., their s<strong>of</strong>tware is up to date,<br />

• all prescriptions are accounted for, i.e., no prescription<br />

numbers are missing,<br />

• all narcotics and controlled drugs requiring a written prescription<br />

are present,<br />

• unusual patterns <strong>of</strong> drug usage are monitored or<br />

identified.<br />

QWhy is it necessary to do a narcotic inventory<br />

regularly?<br />

Narcotic inventories are necessary to provide a starting<br />

point or baseline to perform narcotic reconciliations. Narcotic<br />

inventories should be done on a regular basis, in conjunction<br />

with random reconciliations on specific narcotics.<br />

This will help to identify any shortages, possible diversion,<br />

or theft. The introduction <strong>of</strong> perpetual inventory management<br />

by s<strong>of</strong>tware providers is a useful tool for facilitating<br />

the reconciliation process.<br />

QWho do I contact to receive permission to destroy<br />

narcotics or controlled drugs in my inventory?<br />

All requests for permission to destroy narcotics must be forwarded<br />

to the Compliance, Monitoring and Liaison Division<br />

<strong>of</strong> Health Canada. No specific form is required, however<br />

all requests must be legible and include:<br />

• name <strong>of</strong> the pharmacy<br />

• name and signature <strong>of</strong> the pharmacist making the<br />

request<br />

• date <strong>of</strong> the request<br />

• detailed list with name <strong>of</strong> product, strength, dosage form<br />

and quantity as well as reason for destruction<br />

Fax your request for destruction to the Compliance,<br />

Monitoring and Liaison Division at 1-613-957-0110.<br />

For more information the <strong>of</strong>fice can be contacted by telephone<br />

at 1-613-954-1541<br />

pharmacyconnection • <strong>November</strong>/<strong>December</strong> <strong>2008</strong><br />

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