Published March 31,2011
1. What is the definition of “remote dispensing location” (RDL)?
A premises where drugs are dispensed or sold by retail to the public under the supervision of a pharmacist who is not physically present and that is operated by, but not at same location as, a pharmacy whose certificate of accreditation permits its operation. A RDL can either be an automated pharmacy system or a place staffed by a regulated pharmacy technician supervised remotely by a pharmacist who is present at the accredited pharmacy.
2. Does a pharmacist need to be present when the remote location is open?
Yes, the pharmacist must be physically present in the pharmacy that operates the remote dispensing location.
3. What drugs can be sold in a remote dispensing location?
Drugs in Schedule I, II and III may be sold in a remote dispensing location. Schedule III drugs may be available either from an automated pharmacy system or from an area in the remote dispensing location to which the public does not have access. No narcotic and controlled drugs and targeted substances can be located at or available from the RDL.
4. Who can apply for a Certificate of Accreditation for an RDL?
A holder of a certificate of accreditation to operate a pharmacy can apply for an amended certificate of accreditation that permits the operation of remote dispensing location(s).
5. Can a physician or non-pharmacist business person apply for a certificate of accreditation for a RDL?
No only the holder of a certificate of accreditation can apply for an amended certificate to allow for the operation of a RDL.
Under the DPRA 142. (1) no corporation shall own or operate a pharmacy unless the majority of the directors of the corporation are pharmacists.
6. Can a pharmacy operate more than one RDL?
A pharmacy can operate multiple RDL’s but each RDL will have a specific accreditation number. Additional fees for each RDL application will be required and specific standards of accreditation must be met. As with any new store opening, an inspection will take place to ensure the standards are met prior to accreditation approval.
7. Who can operate a RDL?
Only the pharmacy whose certificate of accreditation permits the operation of the RDL can operate it at the specific location referred to in the certificate of accreditation. The operation cannot be contracted out to another pharmacy.
8. What are the size requirements of a RDL’s?
The same requirements that apply to any pharmacy must also apply to the RDL which include a dispensary. The pharmacy must be at least 18.6 sq metres and dispensary 9.3 sq metres. A RDL in which all drugs are dispensed and distributed from an automated pharmacy system is not required to have a dispensary or meet the pharmacy size requirements.
9. Where can a RDL be located?
RDL must be located in a well-lit and well-ventilated area that is appropriate for the provision of health care services and accessible to the public only during the hours that a pharmacist is physically present in the accredited pharmacy that operates the RDL. There is no restriction regarding proximity to another pharmacy.
10. What are some of the additional safety and security requirements that must be met?
- Every RDL must be designed, constructed and maintained so as to prevent unauthorized access.
- Must have an alarm system that provides immediate notification to the DM or his or her delegate of any theft or attempted theft of drugs, tampering or attempted tampering of RDL or its equipment and alternation in refrigeration temperature outside of standards
- Once the alarm system has notified the DM all dispensing at the remote dispensing location will be stopped until the DM confirms that the remote dispensing location, including any automated pharmacy system, is fully secured and operational.
As well, if the RDL has an automated dispensing system, it must:
- Be locked at all times to prevent unauthorized access and be sufficiently affixed within the RDL so that it cannot be moved by unauthorized persons.
- Use technology, such as bar-coding or micro chips, that ensures that drugs are accurately loaded and verifies that the correct drugs are selected robotically during the dispensing process and correct labels affixed to vials.
- Employ College approved technology for the creation of a digitally scanned image of a paper-based prescription
11. How can the authenticity of a prescription inserted into the automated pharmacy system be established?
In the case of an automated pharmacy system, the technology used to transmit the prescription must be approved by the College. Methods to ensure verification of physician signature and authenticity of prescriptions remain consistent with all pharmacy practices.
Currently, the College Council has approved the following APS technology:
12. What are the audio-visual link requirements?
Every RDL where a pharmacist is not physically present must be equipped with a live, two-way audio-visual link that permits dialogue and communication between the patient and a pharmacist who is physically present in the accredited pharmacy. In the event of a disruption in this link, all dispensing at the RDL must cease immediately and cannot resume until the link is restored.
13. What are the requirements for marking of containers at RDL’s?
In addition to what is required on all prescription labels, the container in which a drug is dispensed from a RDL must indicate both the name, address and telephone number of the accredited pharmacy as well as the address of the RDL including a toll-free number at which a patient may contact the accredited pharmacy. The label must include a unique identifier, attached to the prescription number that identifies that the drug was dispensed from the RDL vs. the accredited pharmacy.