Feedback for Proposed Changes to the DPRA regulations

Pharmacist  ·  March 12, 2015

After watching the CBC Marketplace program, it seems most pharmacies are not implementing the laws and regulations regarding the sale of schedule 2 products including sch 2 narcotics. So far no study has been published on Tylenol #1 addiction in Ontario or Canada as the sale of this product is not documented and it is impossible to do any study on this issue. I e-mailed so many researchers at CAMH and non of them was able to provide any information on Tylenol#1 addiction in Ontario or Canada. I suggest the following procedure so that CAMH or other researchers can collect data from pharmacies and determine the significance of Tylenol#1 addiction:

SALES OF SCHEDULE II DRUGS 1- When a patient comes to the dispensary requesting a Sch II medication, the PA shall direct the patient to the counseling area. 2- The pharmacist checks if the patient has a profile in the computer or not. 3- The pharmacist creates a new profile if the patient is new to the pharmacy and documents all the essential information on the profile in addition to the list of medications the patient is taking. 4- The pharmacist runs the request as a cash Rx authorized by her/him if convinced the medication will be safe and effective for the patient. 5- The Rx is processed. 6- The pharmacist checks the Rx and if needed provides further counseling to the patient. Advantages of the above procedure 1- The pharmacist is implementing the laws and regulations by being involved directly in the sale process. 2- Effectiveness and safety of the medication for the patient are assured. 3- The medication is added to the patient’s profile and can be communicated with the family physician or other prescribers if needed. 4- The pharmacist can prevent misuse or abuse of these products. 5- Research projects can be performed on the consumption of these products by collecting the data from pharmacies and this will enable regulatory authorities to take decisions or amend regulations if required. 6- Regulatory authorities will know the quantities of these products purchased by non-Canadians and transported outside Canada particularly Sch II Narcotics. 7- CAMH can analyze the data collected from pharmacies and determine the significance of addiction on Sch II Narcotics in various locations of Canada and accordingly suggest recommendations to resolve this issue.

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