Narcotic Prescription Part-Fills

March 19, 2020: Important update regarding the novel coronavirus (Covid-19) pandemic

Health Canada has issued pharmacists a temporary Controlled Drugs and Substances Act (CDSA) subsection 56(1) class exemption from the provisions of:

  • Subsection 31(1), and section 37 of the Narcotic Control Regulations (NCR)
  • Sections G.03.002 and G.03.006 of Part G of the Food and Drug Regulations (FDR)

Therefore, while this exemption is in effect pharmacists may:

  • Dispense any narcotic pursuant to a written or verbal order from a practitioner
  • Dispense a refill of a previous narcotic or controlled drug prescription pursuant to a written or verbal order from a practitioner

Pharmacists should refer to the Subsection 56(1) class exemption for patients, practitioners and pharmacists prescribing and providing controlled substances in Canada during the Coronavirus Pandemic and related Frequently Asked Questions for further information.



Published: March 2012
Revised: March 2020

Legislative References:
Additional References:

College Contact: Pharmacy Practice


The Narcotic Control Regulations (s.37) do not permit refills of narcotic drugs. The use of part fills enable a physician to prescribe narcotics for patients receiving treatment for chronic long term pain in a manner that balances the need for treatment against the necessity to monitor therapy and discourage diversion or narcotic misuse. Part fills may be applied to any prescription but the term is generally used to refer to narcotic prescriptions.

The Narcotic Control Regulations do not define refills, repeats or part fills; therefore, an interpretation of s.37 was requested.

Narcotic Control Regulations s. 37:

“A pharmacist shall not use an order or prescription, written or verbal, to dispense a narcotic after the quantity of the narcotic specified in the order or prescription has been dispensed.”

Requirements to Comply with Narcotic Control Regulations s. 37:

  1. Pharmacists may only dispense the quantity specified on the prescription;
  2. The prescription can no longer be filled (i.e. refills or repeats) once the quantity specified has been dispensed; and
  3. Applies to both written and verbal prescription narcotics.

Narcotic Part Fills:

  • Part fill is interpreted as dispensing a quantity of medication which is less than the total amount of drug specified by the prescriber;
  • Part fills are legal for narcotic drugs, while refills/repeats are not;
  • The total quantity dispensed may not exceed the authorized quantity on the original prescription; and
  • The total quantity must be written as a single figure and not as a smaller figure multiplied by a number of refills/repeats.

Narcotic Prescriptions with Refills/Repeats:

  • If a prescriber writes a prescription with a specified quantity plus a number of refills/repeats, only the original specified quantity may be filled;
  • The refills/repeats ordered by the prescriber will not be honoured by the pharmacist; and
  • After the specified quantity is dispensed, the patient will require a new prescription.


  • A prescriber may indicate a time interval between part fills of the total authorized quantity;
  • Intervals are not required for narcotics, but are recommended, especially where drug monitoring is indicated;
  • If specified, the pharmacist may only dispense the next part fill after the appropriate amount of time has passed;
  • Where patients are early on an interval, the physician must be contacted. If the physician is not available the pharmacist may use their professional judgment to dispense the next part fill. Reasons for the decision must be documented on the patient record; and
  • Interval changes ordered by the prescriber may be accepted verbally and documented.

Record Keeping:

  • All subsequent part fills must be cross-referenced to the original prescription authorization