Narcotic Reporting of Forgeries and Losses

Published: September 21, 2012

Legislative References: Narcotic Control Regulations (NCR), s. 31, 34, 42, 43

Additional references: Health Canada: Health Concerns; Loss, Theft and Forgery

College Contact: Pharmacy Practice


Background:

Narcotics pose the highest risk to the public if they are not appropriately prescribed, dispensed and administered. For these reasons, narcotics are the most strictly regulated of all the drugs.

The NCR requires pharmacists to protect the controlled substances and precursor chemicals in their pharmacy, or otherwise under their control, against any loss or theft. The term loss broadly refers to any conceivable activity that would lead to a loss of narcotics. The most common cause of loss is theft; however, losses are also associated with other events including, for example, forgeries, expired drugs, miscounts (either dispensing or from manufacturer), damaged drugs (broken tablets), mishandling of products (dropped bottles, or poor techniques when compounding).

While all pharmacists are required to protect the narcotics in their pharmacy, the designated manager has an additional obligation to ensure that policies and procedures are in place. A physical count and reconciliation of all narcotics, controlled drugs and targeted substances is to be conducted regularly, at least once every six months. Any theft, loss or forgery related to controlled substances and precursor chemicals must be reported to police immediately, and to the Office of Controlled Substances no later than 10 days after its discovery.

Narcotic Control Regulations:

    31. (1) No pharmacist shall sell or provide narcotics except in accordance with subsections (2) and (3) and sections 34 to 36
    (b) if the pharmacist has first received a written order or prescription therefor signed and dated by a practitioner and the signature of the practitioner, where not known to the pharmacist, has been verified by him.
    34. Subject to section 39, a pharmacist may dispense a verbal prescription narcotic on receipt of a prescription or verbal order given by a person whom the pharmacist has taken reasonable precautions to determine is a practitioner.
    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.

Requirements to comply with legislative obligations:

The NCR expects pharmacists to take all reasonable precautions to ensure the validity of a narcotic prescription regardless of whether it is written or verbal. In order to reduce losses through forgeries or double doctoring, pharmacists are expected to verify the signature of the doctor where the doctor or their signature is not known to them.
The pharmacist must file a report within 10 days of the discovery of a theft, loss or forgery. The key word is “discovery”. The loss may have occurred days or even weeks prior to the discovery, for example, in the case of an inventory loss discovered during reconciliation. Reporting is required within 10 days of the discovery.

Reporting a forgery is the same as reporting a loss with one exception. A forgery must be reported even if the forged prescription was not filled. The reporting form has fields to indicate whether the forged prescription was filled or not filled, along with the required details.


Reporting of Losses:
Two separate forms are available on the Health Canada Website for reporting:

  1. Loss and Theft Reporting Form
  2. Forgery Reporting Form