Restocking of Drugs used for Medical Assistance in Dying (MAiD) during COVID-19 Policy
This policy articulates the College’s expectations regarding the restocking of injectable drugs that were previously dispensed for the purpose of providing Medical Assistance in Dying (MAiD).
This policy is in effect only for the duration of the COVID-19 public health emergency in Ontario.
Restocking: To return to inventory (“stock”) for the purpose of redispensing.
During the COVID-19 public health emergency in Ontario, given the shortage of injectable drugs dispensed for the purposes of MAiD, unused injectable MAiD drugs previously dispensed may be restocked if they are done so in accordance with the regulations outlined in the Drug and Pharmacies Regulation Act, DPRA, O. Reg. 264/16, s.32.
The DPRA, O. Reg. 264/16, s.32 permits an accredited hospital pharmacy to return to stock, resell or redispense a drug that was previously dispensed if the following stipulations are met:
- The drug is returned to the pharmacy in a sealed dosage unit or container as originally dispensed;
- The drug is returned with the labelling intact and the label includes a legible drug lot number and expiry date;
- The integrity of the drug can be verified.
In order to confirm the integrity of the drug being restocked, it is the College’s expectation that the accredited hospital pharmacy ensures each of the following:
- The drug has not left the possession of a licensed health care professional (i.e. the prescribing medical practitioner or nurse practitioner, or a licensed health professional assigned by the prescriber);
- The drug has been maintained in accordance with the manufacturer’s requirements (e.g. has been stored in accordance with required storage conditions);
- The drug is not expired.
Currently, the DPRA, O. Reg. 264/16, s.32 only permits the restocking of drugs (given the stipulations above) in an accredited hospital pharmacy environment. The DPRA, O. Reg. 264/16, s.32 prohibits an accredited community pharmacy returning to stock, reselling or redispensing a Schedule I drug that was previously sold or dispensed. The rationale for this difference is that hospitals are a closed-loop environment, allowing greater confidence that the drug integrity is maintained as it remains in the possession of healthcare providers who are able to ensure the right storage conditions.
The O. Reg 130/17 of the Pharmacy Act considers it “professional misconduct” to return to stock, resell or redispense a Schedule I drug that was previously sold or dispensed. Therefore, registrants must only engage in restocking for MAiD drugs under the authority of the accredited hospital organization where the organization has established this practice as permitted through the DPRA, O. Reg. 264/16, s.32.
DPRA, O. Reg. 264/16, s.32
Pharmacy Act, Ontario Regulation 130/17
Restocking of Drugs used for Medical Assistance in Dying (MAiD) during COVID-19 Policy: Frequently Asked Questions
Medical Assistance in Dying Guidance – Ontario College of Pharmacists
Published: June 17, 2021
Version #: 1.00
College Contact: Practice Department
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