November/December 2008 - Ontario College of Pharmacists
November/December 2008 - Ontario College of Pharmacists
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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