- Ontario Narcotics Strategy — Questions and Answers
- Prescription Delivery Regulation (Pharmacy Connection, July/Aug 2009)
- Protecting the Cold Chain (OCP Policy)
- Designated Manager Responsibilities When Using Technology to Deliver Pharmacy Services (Pharmacy Connection, Spring 2017)
College Contact: Pharmacy Practice
The DPRA contains specific record-keeping provisions requiring that the delivery of Schedule I drugs, i.e. medications requiring a prescription, is tracked, including confirmation of both transit of the drugs and receipt by the patient. Dispensing is considered to have occurred, or to be complete, when the medication passes into the care of the patient or his or her agent. The method in which this occurs may encompass different avenues and while a drug is in the process of being delivered, it is still in the care of the pharmacy. Any drug that requires refrigeration, or cold chain protection, must be kept at the appropriate temperature during transit.
DPRA s. 152
152. (1) Subject to subsection (2), a drug listed in Schedule I shall, if sent through the mail, only be sent by registered mail or, if delivered by another method, shall be delivered in a method that is both traceable and auditable, with a receipt for the drug signed by the patient or the patient’s agent. 2007, c. 10, Sched. L, s. 16.
Exception, federal law
(2) Where a law of Canada permits a method of delivery of a drug other than provided for in subsection (1), the law of Canada prevails. 2007, c. 10, Sched. L, s. 16.
- Track delivery of Schedule I drugs:
- Registered mail where delivery by mail
- All other methods of delivery must be both traceable and auditable
- Receipt of drug must be signed by patient or patient’s agent.
Deliveries of Schedule I drugs:
- Requires a signature for receipt of the drug by patient or patient’s agent at the time of receipt
- A waiver cannot be signed in advance to request that the prescription delivery be left unattended on the premises (i.e., in a mailbox, between the doors, etc.)
- Signature is required unless there is a valid reason for not signing.
- Documentation of the circumstances leading to delivery without a signature is mandatory. Documentation should reference the identification viewed by the delivery agent, and it is permitted to have the patient sign with an ‘x’ with the delivery agent witnessing the mark. This should be the exception and not the norm.
- Specified in advance by the patient to accept and sign for their prescriptions
- Delivery person cannot be the patient’s agent as they are the agent for the pharmacy
Long distance deliveries
- Operational arrangements should be made prior to deliveries to ensure patient or agent will be available to accept delivery.
Auditable and Traceable
- Members and the pharmacy are responsible for the medication and personal health information until it is received by the patient or designated agent.
- Deliveries should be sent directly from the pharmacy to the patient. Any stops or delays along the way should be with the knowledge and approval of the pharmacist. If a delivery attempt is unsuccessful, members are responsible for the ongoing auditability, traceability, integrity, and security of drug products until the delivery reaches the patient or is returned to the pharmacy.
- Signed receipts should be returned to the pharmacy or available electronically, to ensure auditability.
- Members should ensure the authenticity of patient or agent signatures on the delivery records
- Delivery records do not need to be kept beyond 3 months and should be destroyed in a manner that protects the privacy and confidentiality of the patient
Requirements under the Narcotic Safety and Awareness Act:
- Ontario’s Narcotics Strategy FAQs
Please refer to Questions 32, 33 and 34
Delivery out of Canada
Deliveries both within and outside of Canada must meet the requirements of the DPRA.
For deliveries outside of Canada, it is recommended that members contact the delivery service to find out what documentation is required to ship prescription medications:
- Check for any restrictions that a country may have on certain drugs, e.g. if delivery service is unsure, the country’s embassy or consulate here in Canada can be contacted for information
- Advise patients there may be delays
- Ensure that the integrity of the drug is maintained, i.e. medications requiring cold chain protection must be shipped in the appropriate containers, etc.