- Drug and Pharmacies Regulation Act (DPRA), s152
- Narcotics Safety and Awareness Act (NSAA), s 1(2)
- O. Reg. 381/11: GENERAL, s7
- Ontario Narcotics Strategy – Questions and Answers
- Guideline – Protecting the Cold Chain
- Policy – Faxed Transmission of Prescriptions
- Health Canada Policy – Transportation of Controlled Substances in Canada
- Article – 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 drugs in NAPRA Drug Schedule I, (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 patient or their agent takes custody of the prescription. Regardless of the delivery method used, while a drug is in the process of being delivered, it is still in the care and control of the pharmacy. Any drug that requires refrigeration, or cold chain protection, must be kept at the appropriate temperature during transit.
Provincial legislation requirements
Deliveries of Schedule I drugs:
- Registered mail if delivered by mail
- All other methods of delivery must be both traceable and auditable
- Requires a signature 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 (e.g., in a mailbox, between the doors, etc.)
- 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
- Signature by the patient or agent upon receipt is required unless there is a valid reason for not signing
- Signatures may be obtained in pen-and-ink or electronically
- Arrangements should be made prior to delivering to ensure patient or agent will be available to accept and sign for the delivery
- Documentation of the circumstances leading to delivery without a signature is mandatory
- Documentation should reference the identification viewed by the delivery agent
- If the recipient has any physical limitations, dexterity issues, etc. it is permitted to have them sign with an ‘x’ with the delivery agent witnessing the mark. This should be the exception and not the norm.
- If the recipient has or may have a disease of public health significance and close contact must be avoided, registrants should exercise professional judgement to determine the most appropriate process (e.g. place in mailbox, have delivery agent wait outside or call the recipient once the medication is dropped off to confirm they have it, provide follow-up and/or counselling by phone, etc.)
Auditable and Traceable
- The pharmacy is responsible for the security of the medication and personal health information until it is received by the patient or their agent.
- Deliveries should be sent directly from the pharmacy to the recipient. Any stops or delays along the way should be with the knowledge and approval of the pharmacist.
- If a delivery attempt is unsuccessful, the pharmacy is responsible for the ongoing auditability, traceability, integrity, and security of the medication until the delivery is successful or is returned to the pharmacy.
- The pharmacy should ensure the authenticity of patient or agent signatures on the delivery record
- Signed receipts should be returned to the pharmacy or made available electronically
- Delivery records do not need to be kept beyond 3 months
- Once the records are no longer required for audit purposes, they should be destroyed in a manner that protects confidentiality of personal health information
Requirements under the Narcotic Safety and Awareness Act:
- Ontario’s Narcotics Strategy FAQs (Please refer to Questions 32, 33 and 34)
- O. Reg 381/11, s7: Monitored drug received by agent
Delivery outside of Canada
- Deliveries both within and outside of Canada must meet the requirements of the DPRA.
- For deliveries outside of Canada, it is recommended to 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
- If delivery service is unsure, the country’s embassy, border agency, or consulate here in Canada can be contacted for information
- Advise patients there may be delays (e.g. due to weather, transportation issues, customs clearance, etc.)
- Ensure that the integrity of the drug is maintained, and that medications requiring cold chain protection must be shipped in the appropriate containers