Feedback for Proposed Changes to the DPRA regulations

Pharmacist  ·  March 31, 2015

The draft DPRA regulations allow for increased flexibility and adaptability as practice and standards changes in the future. I applaud the work of the College on this initiative. In addition, the inclusion of remote pharmacies for both community and hospital practice are anticipating opportunities to best service our patients in remote locations.

I noticed that in reading the posted Drug and Pharmacies Regulation Act (e-laws/Service Ontario), it indicates that a hospital pharmacy is:

Despite anything else in this Act, where drugs are compounded, dispensed or supplied for hospital patients by a hospital in premises located in a hospital, the primary location or locations in the hospital where drugs are compounded, dispensed or supplied from, together with any other location in the hospital where drugs are stored or supplied from and any other location prescribed in regulations made under subsection (2), is deemed to be a pharmacy for the purposes of the following provisions of this Act, subject to the regulations and to any necessary modifications:

Under the proposed draft DPRA regulations, there is a definition of “medications” – means drugs and other substances usually maintained in a pharmacy, including substances used in the compounding of drugs:

Is there any opportunity to have the draft DRPA Regulations have all areas that prepare/compound drugs and medications for patients under the “Pharmacy”? I am anticipating in the future that hospital may employ/contract with Regulated Health Professional such as Naturopaths, Chiropractors, TCM practitioners and it may serve in the public’s best interest if the provision of medications including natural health products or compounding of these products within the hospital setting was done with the same standards as those in the pharmacy. I would recommend the dispensing, compounding may be best under the supervision of the pharmacy and meet consistently high standards. Also, my interpretation would be that medications prepared by nursing staff on the inpatient units would need to be done to the same safe standard as those prepared in an aseptic environment (laminar flow hood) in the pharmacy.

I look forward to the implementation of the new legislation and improvement in patient care within the hospital sector.

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