Narcotic Reconciliation and Security
FACT SHEET – Narcotic Reconciliation and Security
The theft and diversion of controlled substances has been steadily on the rise and there is evidence that the misuse of prescription drugs is a factor in other violent and non-violent crimes. Greater awareness concerning security has been elevated at all levels of the distribution chain from the manufacturer to the pharmacy. The Narcotic Control Regulations (NCR) places the responsibility on the pharmacist to protect the narcotics in their possession; therefore, narcotic security should be a priority with every pharmacist and pharmacy owner. Where a pharmacist is shown to be negligent or careless in the management and protection of narcotics inventory, he or she is at risk of losing their narcotic privileges from Health Canada, and/or of being the subject of a College Investigation.
Narcotic Control Regulations
42. A pharmacist shall report to the Minister any loss or theft of a narcotic within 10 days of his discovery thereof.
43. A pharmacist shall take all reasonable steps that are necessary to protect narcotics on his premises or under his control against loss or theft.
Although the regulations require pharmacists to take all reasonable steps to protect the narcotics under their control, the regulations do not define what is considered reasonable. Unlike other specific requirements for purchase and sales records, general security is left open to interpretation. A pharmacist must consider a number of issues when developing policies and procedures to meet the requirements of the NCR. Narcotic security is not just about placing narcotics in a safe or locked cabinet. Narcotics can be lost through forgeries, diversion, damages, miscounts or theft, both external and internal. Pharmacists and designated managers are expected to be familiar with and have in place policies and procedures to monitor and prevent narcotic losses.
In planning the security of narcotics, the pharmacist should consider a number of factors, including, for example, the basic layout of the premises, the procedures that have been implemented to track narcotic inventory, and the systems in place to hire and screen prospective new staff. The pharmacist should be able to demonstrate what precautions have been taken to ensure that narcotics are not easily accessible by anyone entering the premises. For example, in the event that the security of the pharmacy has been breached or compromised, it would be reasonable for a member to demonstrate that they implemented more stringent security measures or sought assistance from police or security companies. Additional recommendations are provided below.
What to Consider
For additional information, please contact your local police services or refer to the Guidelines for Ensuring the Safety and Security of you and your Staff in the Pharmacy from the Ontario Pharmacists’ Association. This is located in the toolkit of the members section of the OPA website. Non-members can obtain a copy by sending a request to firstname.lastname@example.org.
Narcotic Sales Report
38. Where, pursuant to a written order or prescription, a pharmacist dispenses a narcotic, other than dextropropoxyphene or a verbal prescription narcotic, the pharmacist shall forthwith enter in a book, register or other record maintained for such purposes
(a) the name and address of the person named in the order or prescription;
(b) the name, quantity and form of the narcotic;
(c) the name, initials and address of the practitioner who issued the order or prescription;
(d) the name or initials of the pharmacist who sold or provided the narcotic;
(e) the date on which the narcotic was sold or provided; and
(f) the number assigned to the order or prescription.
Narcotic Sales Reports should be checked regularly or spot checked depending on the practice. Pharmacies with high staff turnover, large part-time staffs, or rotating staff should review the reports more often.
For additional information on the recording of purchases of controlled substances, refer to the fact sheet on Narcotic Purchase Records.
Managing Narcotic Inventory
The legislation does not specify that a pharmacist is required to maintain a narcotics inventory count; however, it is implied through the requirement that a pharmacist protect the narcotics under his or her control. Simply counting narcotics is not sufficient to protect the inventory, as an inventory count is simply a record of the amount of the stock that is present in a pharmacy at a given time. For a narcotic inventory count to be useful, it must be used as a starting point to enable narcotic reconciliations which will, in turn, pinpoint any shortages
It is recommended that narcotic inventory counts are done on a regular basis at minimum every six months with complete reconciliation (see below), in conjunction with random reconciliations on narcotics that have a high risk of diversion. The count should not be conducted by the same person who enters narcotic purchases into the purchase records. The introduction of perpetual inventory management systems in pharmacy software packages provides useful tools for facilitating the reconciliation process; however, many of these are still open to human error. When used, these systems should be reconciled against an actual physical count. Perpetual inventory counts alone should never be used for reconciliation purposes.
Additionally, inventories and reconciliations should be completed any time there is a:
OCP’s Designated Manager - Medication Procurement and Inventory Management Policy states that:
A narcotic reconciliation can only be done where there is a validated starting inventory and good record keeping processes which include retaining purchase records, filing prescriptions and maintaining narcotic sales reports. When all the systems and procedures are in place and inventories are done on a regular basis, reconciliations can be done relatively easily. Where systems are not in place, reconciliations can be time consuming.
Narcotic Reconciliation Process
Problem Solving: Shortages or Overages
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