Frequently Asked Questions About Pharmacy Practice

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General Pharmacy Practice Questions

  • Who may prescribe in Newfoundland and Labrador (NL)?

    The Pharmacy Act defines a prescription to be “an instruction, directing that a drug be dispensed to or for a person or animal, given orally, in writing or by an electronic means approved by the board by a person authorized to do so by an Act of the province or by a prescriber referred to in section 26;”

    At this time, in NL, physicians, dentists, veterinarians, nurse practitioners optometrists and pharmacists all have varying authority to prescribe. To verify the current status of a prescriber in NL, you can check the relevant list linked on our Find a Health Professional page.


  • Can I legally fill a prescription written by a prescriber licensed in another province of Canada?

    Generally-speaking, the answer to this question is usually “yes.” In accordance with section 26 of the Pharmacy Act prescriptions written by prescribers licensed and practising in another province are eligible to be filled in this province.

    Having said that, there are a few conditions to consider. First, it depends on the type of prescriber and whether or not that person would have prescribing authority if they were licensed in Newfoundland and Labrador (NL). At this time, in NL, physicians, dentists, veterinarians, nurse practitioners and optometrists all have varying authority to prescribe. An out-of-province prescriber would have to belong to one of these groups for their prescription to be valid in this province. For example, a prescription from a dentist would be valid; a prescription from a chiropractor would not.

    Second to this would be what the prescription is for. If the prescription is for a narcotic or controlled drug covered by the Tamper Resistant Prescription Drug Pad Program, then the prescription MUST be written on the appropriate tamper resistant pad, regardless of whether or not the prescriber is licensed in NL. For more information on this program, visit the Department of Health and Community Services website.

    Pharmacists are also reminded that the onus is on them to verify the authenticity of any and all prescriptions and if he or she is ever in doubt as to the validity of the prescription or the licensing status of the prescriber, he or she should follow up with the prescriber directly and/or contact the relevant licensing authority.


  • Are electronic prescriptions acceptable?

    More and more prescribers are utilizing technology to manage their patient files, access information and generate prescriptions. As with all prescriptions, pharmacists and pharmacy technicians must be able to ensure the authenticity of prescriptions that have been generated electronically and also be confident that the document presented to them has not been replicated or altered.

    As such, the following are considered to be acceptable:

    • Prescriptions generated electronically by a prescriber’s password-protected electronic medical record (EMR) and faxed directly to a pharmacy.
    • Prescriptions generated electronically, printed, and faxed DIRECTLY to a pharmacy from the prescriber’s/clinic’s fax machine, in accordance with the NLPB Standards of Practice- Facsimilie Transmission of Prescriptions and Personal Health Information.
    • Prescriptions generated electronically, printed, hand-signed by the prescriber, and given to the patient to bring to their pharmacy.

    The following would NOT be acceptable:

    • Prescriptions generated electronically, with pre-printed signature images that are given to the patient to bring to their pharmacy, without being hand-signed or initialed by the prescriber.
    • Prescriptions sent via email.
    • Prescriptions for drugs referenced in section 4.(1) of the Pharmaceutical Services Regulations – i.e. the “Drugs Required to be Written on Tamper Resistant Pads”.


  • At times we are told as pharmacists to use “professional judgment.” At what point does “professional judgment” become failure to abide by regulations or standards and possibly “professional misconduct”?

    Pharmacists make hundreds of professional judgment calls every week. These judgment calls are usually decided after consideration of a number of factors that include the actual wording of regulations or standards, the spirit of those regulations or standards, our past experiences, our knowledge of this specific patient and their health history, and ultimately “the best interests of the patient.” It is important to note, however, that “the best interests of the patient” is not necessarily synonymous with what is most convenient, or easiest, or most inexpensive for the patient, or that the patient’s wishes must be accommodated regardless of all other factors.

    When faced with these types of situations, the best advice we can give is to consider if your decision is one that another pharmacist would also reasonably make if they were presented with the same circumstances. Ultimately, you should always retain documentation of the situation describing what you did or didn’t do and why.


  • How should I handle new prescriptions or requests for refills when a prescriber passes away, retires or otherwise ceases practice?

    As long as the prescriber was licensed at the time the prescription was written, it can be assumed that the prescription was written in good faith. As such, assuming the prescription is not more than a year old, it would still be considered a legal prescription. Another question to consider in these instances is whether filling or re-filling the prescription is appropriate – which needs to be assessed on case-by-case basis.

    NLPB advises pharmacists who receive such requests that it is their professional responsibility to evaluate the appropriateness of the prescription in each individual situation, considering questions related to patient assessment and the patient’s best interests. Questions to consider include, but are not limited to:

    • How long ago was the prescription written? Was it intended to be a short-term therapy?
    • Is the medication for a condition that is considered to be chronic or long term? If so, does the patient have an established stable, compliant history with the medication?
    • Is the patient unable to visit a new primary health care provider in a timely manner?
    • Is the patient at an increased risk of harm by filling or re-filling the medication? (Or conversely, is the patient at an increased risk of harm if the medication is not provided in accordance with the original prescription?)
    • If the prescriber was still practicing, would I have consulted with the prescriber for any reason before filling or refilling the medication?
    • Is there another option? Would providing an interim supply or prescription extension, be appropriate, if indicated?

    Regardless of the pharmacist’s decision, the patient should be advised to find a new or interim prescriber as soon as possible.


    Questions about Pharmacy Technician Practice

    • What is the scope of practice for a registered pharmacy technician?

      In the Spring 2017 edition of the NLPB newsletter, The Apothecary (http://nlpb.ca/media/Apothecary-Spring2017.pdf), the following table was published (to enlarge, right click on image and select “open image in new window”):

      For more information, please view the NAPRA Professional Competencies for Canadian Pharmacy Technicians at Entry to Practice and the Model Standards of Practice for Canadian Pharmacy Technicians. These are really the “gold standard” for technician practice in Canada.


    • What is a pharmacist’s responsibility when collaborating with a pharmacy technician to dispense a prescription? Does this responsibility change for refills?

      Regardless of whether the patient has presented a prescription for a new medication, a new prescription for ongoing therapy, or has requested a refill, no medication can be released to the patient without a pharmacist reviewing the patient’s medication profile, assessing the therapeutic/clinical appropriateness of the drug therapy, and providing patient counselling, as required.

      Pharmacists and pharmacy technicians cannot assume that a clinical check performed for the first fill of a prescription fulfills the required clinical check by a pharmacist for subsequent refills (including those in compliance packages). A patient’s circumstances and health can change between the time of the first prescription and subsequent refills – especially if the medication is prescribed long-term. Over time, patients age, may lose or gain weight, receive new diagnoses, have changes to their medications, become pregnant, or experience other health-related changes that could impact the continued suitability of a prescribed medication. As such, there is an expectation for on-going clinical review of the medication profile by the pharmacist.

      Pharmacy technicians can assess the currency, authenticity, and completeness of prescriptions as well as be accountable and responsible for the technical aspects of prescriptions such as ensuring the right:

      • Patient
      • Drug, Dosage Form, Route, Dose and Quantity
      • Directions
      • Prescriber
      • Container/Packaging/Labelling

      However, pharmacists remain responsible for ensuring:

      • the prescription is appropriate / still appropriate for the condition being treated
      • the dosage is safe and appropriate / still safe and appropriate for the patient based on patient-specific factors such as age, weight, organ function, pregnancy or lactation status, etc.
      • the medication is compatible / still compatible with current medical conditions and allergies
      • the medication is compatible / still compatible with other medications being taken

      The responsibilities noted above are outlined in section 3.1 of the Standards of Pharmacy Operation – Community Pharmacy, and section 3.3 of the Standards of Pharmacy Operation – Hospital Pharmacy. In addition, sections 1.11-1.14 of the Standards of Practice for Canadian Pharmacists, state:

      Pharmacists, when providing patient care as part of the care provided when dispensing medications or medication therapies:

      • 1.11 assess the appropriateness of providing a refill of a medication requested by a patient by collecting and interpreting relevant patient information to ensure:
        • there are no significant drug interactions, contraindications or adverse effects, and
        • the medication is still required, and
        • the dose and instructions for use of the medication are correct, and
        • that the patient is receiving appropriate monitoring for this medication and disease.
      • 1.12 manage patient’s requests for refills of medications which pose risks to the patient by:
        • making changes to the prescription in accordance with authorities granted to pharmacists by laws / regulations / policies / guidelines, and/or
        • contacting a prescriber to recommend changes in the prescription, and/or
        • refusing to dispense the medication.
      • 1.13 assess patient’s compliance when providing refills for medications for treatment of chronic disease.
      • 1.14 address problems with compliance that pose risks to the patient or can affect the efficacy of the medication by:
        • educating the patient, and
        • making changes to their medications and/or medication therapies in accordance with authorities granted to pharmacists by laws / regulations / policies / guidelines, or
        • contacting a prescriber to recommend changes in therapy.

      Additionally, in accordance with section 3.8 of the Standards of Pharmacy Operation – Community Pharmacy, pharmacists are also expected to assess the need for patient counselling for refills by asking questions regarding changes to dosage regimens, compliance, efficacy, and the presence of adverse effects and then counsel accordingly, if necessary.

      And finally, in accordance with section 3.5 of the Standards of Pharmacy Operation – Community Pharmacy, each dispensing record must also contain documentation of:

      • i) any interactions that were detected, how they were addressed, and who addressed them;
      • ii) the identity of all staff members involved in the dispensing and checking processes; and
      • iii) the name of the pharmacist who delivered patient counselling and the date and time the counselling was given.



    Questions about Pharmacy Intern Practice

    • Do I need a preceptor during an extended registration as an intern?

      No, once the NLPB Pharmacist Internship is completed, you do not need a specified preceptor, but you will need to be working under the supervision of a pharmacist at all times.

      When you apply to extend your registration as an intern, a pharmacist who has agreed to be responsible for your supervision will also need to sign this form to indicate to NLPB that they have accepted and understand this responsibility. You do not necessarily need to practice with this pharmacist at all times–the supervising pharmacist may delegate another pharmacist to supervise and support you while they are not there.

      Accountability for a pharmacy intern’s practice is shared between them and the supervising pharmacist.

      • The supervising pharmacist is accountable/responsible for ensuring that the appropriate level of supervision is provided to an intern, based on ongoing assessment of the individual intern’s competence. It is important that the supervising pharmacist understands they are ultimately accountable/responsible for an intern’s practice regardless of the level of independence granted-there must be appropriate oversight, checks, and balances in place at all times.
      • As a pharmacy intern, you are accountable/responsible for your own practice and should only engage in an activity when competent to do so. It is an intern’s responsibility to seek assistance from the supervising pharmacist, as needed.


    • What can I do as an intern–what is my scope?

      As per the Act, a pharmacy intern may perform most duties within the scope of practice of a pharmacist, as long as they are under the supervision of a pharmacist.

      The requirement for “supervision” in this case is more open-ended than the requirement for “direct supervision” of pharmacy students. Supervision is not a one-size-fits-all approach, and calls for the active engagement of all participants to ensure a quality learning environment while maintaining the best possible patient care.

      When determining the appropriate level of supervision required, the supervising pharmacist must assess the intern individually by considering the intern’s level of education and experience, and evaluating the intern’s competence in relevant areas of practice.

      Once the supervising pharmacist is comfortable with allowing some independence, they and the pharmacy intern should come to a shared understanding of the types of activities that can be performed independently and the extent to which these activities can be performed without the direct observation of the supervising pharmacist.

      When providing indirect supervision, the supervising pharmacist must be readily available for consultation and, if necessary, for providing hands-on assistance to the intern and ensure the intern complies with established standards, policies and procedures.

      The scope of activities an intern is comfortable with and the level of independence required when carrying out pharmacist duties may vary from intern to intern. It will depend on previous practice experiences and the amount of time practicing with the supervising pharmacist and their team.


    • Are there specific things I am not permitted to do?

      Certain NLPB Standards of Practice require authorization from NLPB in order for pharmacists to be able to participate in that practice. These practices include the following:

      • administering an inhalation or injection
      • participating in Opioid Agonist Maintenance Treatment (OAMT)
      • prescribing

      Authorizations for these practice areas are only available to pharmacists. As such, interns cannot be authorized until they are registered as pharmacists and meet the established criteria. An intern cannot independently perform these activities under any circumstance; however, interns can assist pharmacists who have a given practice authorization with services if they have the appropriate training and under direct supervision. Pharmacy interns are encouraged to complete the necessary education, training and orientation programs associated with these specific practice areas so they can get the most of their learning experience.

      With regards to administering injections in accordance with the NLPB Practice Policy–Pharmacy Students/Interns Administering Inhalations or Injections, a pharmacy intern may administer drug therapy by inhalation or injection under the following conditions. The pharmacy intern must:

      • be registered with the NLPB (including maintaining appropriate professional liability insurance);
      • have successfully completed an education and training program on the administration of injections that has received CCCEP competency-based (stage 2) accreditation OR all education and training on the administration of injections are part of the pharmacy program core curriculum;
      • have current certification in CPR Level C or HCP and Emergency or Standard First Aid from a recognized provider (e.g. St. John Ambulance, the Canadian Red Cross); and,
      • be under the direct supervision of a pharmacist who has received authorization from the NLPB to administer drug therapy by inhalation or injection.


    • I completed my injection training during pharmacy school. By the time I am able to submit an application for authorization, it will be more than one year since I completed my training–will I be required to take a refresher course?

      The Standards for the Safe and Effective Administration of Drug Therapy by Inhalation or Injection require applications for authorization to administer injections to be submitted within one year of successful completion of the required education program.

      NLPB will make an exception to this requirement for those who have extended their registration as an intern, providing that they:

      • apply for injection authorization at the earliest opportunity;
      • demonstrate continued injection competence by submitting an injection log that indicates they have properly administered injections under a supervision of an authorized pharmacist while practicing as an intern and in the timeframe leading up to the application date; and,
      • meet all other injection authorization requirements, including proof of current certification in CPR Level C or HCP and Emergency or Standard First Aid from a recognized provider (e.g. St. John Ambulance, the Canadian Red Cross).


    • Can an intern be independently accountable for the clinical verification or final product check of a prescription?

      As per the Act, a pharmacy intern may perform most duties within the scope of practice of a pharmacist as long as they are under the supervision of a pharmacist. Regardless of the level of independence deemed appropriate by the supervising pharmacist and the intern–the supervising pharmacist still holds a level of accountability for the role the intern plays in the dispensing of each prescription.

      Section 3.1 a) of the Standards of Pharmacy Operation (SOPO) identifies the professional responsibilities of a pharmacist as follows:

      Before a prescription is dispensed or a Schedule II medication is provided to a patient, it is the pharmacist’s responsibility to review the patient profile and patient medication profile and to take appropriate action, where applicable, with respect to:

      • i) appropriateness of drug therapy;
      • ii) drug interactions;
      • iii) allergies, intolerances or adverse drug reactions;
      • iv) therapeutic duplication;
      • v) correct dosage, route, frequency and duration of administration and dosage form;
      • vi) contraindicated drugs;
      • vii) patient adherence issues; and
      • viii) any other potential drug-related problems.


      Pharmacists will have to determine whether or not they feel they have met their professional responsibilities if they delegate certain duties to an intern and will need to be prepared to take accountability for that decision. On the other hand, it is an intern’s responsibility to self-govern and only agree to perform duties that are within their competence. This decision will be at the discretion of both parties and will likely depend on the intern’s experience and professional relationship with the pharmacist.

      The SOPO also requires documentation identifying the pharmacy team members involved in each stage of the dispensing process. The pharmacist-in-charge and the supervising pharmacist (if different) will need to consider how interns will be integrated into dispensing processes and how to document the intern and supervising pharmacist’s involvement in each prescription. This could potentially involve changes to pharmacy workflow, development of new documentation processes and/or practice management system software changes.

      Other factors that should be considered when assessing how to integrate an intern into the dispensing process include:

      • the need for a pharmacist to be associated with the medication dispense in the electronic health record
      • the acceptability of a pharmacy intern “sign off” to third party payers
      • any limitations to the intern’s liability insurance coverage (in terms of practicing independently)

      Pharmacists-in-charge, supervising pharmacists, and interns will need to do an assessment of the above and determine what they are collectively comfortable with.




    Questions About Narcotics and Controlled Drugs

    • Is there a way to easily differentiate the requirements for Narcotics and Controlled Drugs?

      Yes, we have published a convenient summary of Narcotic, Controlled Drug and Benzodiazepine Regulations applicable to Newfoundland and Labrador which can be found on our Legislation page or by clicking here.


    • Can I legally fill a prescription for a narcotic or controlled drug if it was written by a prescriber licensed in another province of Canada?

      If the drug is included on the Schedule of Drugs for the Tamper Resistant Prescription Drug Pad (TRPP) Program, then the answer to this question will be usually be “no”, since all prescriptions for these drugs MUST be written on the approved tamper resistant pad, and these pads are rarely given to prescribers from outside the province. For more information on this program, visit the Department of Health and Community Services website.

      If the drug is not included on the Schedule of Drugs for the TRPP Program, or if the prescriber has been issued the approved pad, then the answer would be “yes” so long as that person would have prescribing authority if they were licensed in Newfoundland and Labrador (NL). At this time, in NL, physicians, dentists, veterinarians, nurse practitioners and optometrists all have varying authority to prescribe. An out-of-province prescriber would have to belong to one of these groups for their prescription to be valid in this province. For example, a prescription from a dentist would be valid; a prescription from a chiropractor would not.

      Pharmacists are also reminded that the onus is on them to verify the authenticity of any and all prescriptions and if he or she is ever in doubt as to the validity of the prescription or the licensing status of the prescriber, he or she should follow up with the prescriber directly and/or contact the relevant licensing authority.


    • How do I request an emergency supply of a narcotic or a controlled drug from another pharmacy?

      Since the Narcotic Control Regulations only allow for one pharmacist to provide a narcotic or controlled drug to another pharmacist to fulfill an emergency need, this means only the minimum amount necessary to fill an actual prescription may be provided (i.e. 26 tablets of Atasol 30 to make up a total quantity of 30 for a prescription but not 100 tablets, just in case).

      • When requesting a product, the pharmacist should a sign and date a written request that includes the product and the quantity needed as well as the pharmacy to where the product is going.A copy of this request should be retained by the pharmacy.
      • When such a request is received by a pharmacy, they should record the provision in their perpetual inventory and retain the written request with their narcotic and controlled drug prescription files.
      • When the requesting pharmacy receives the product, they should record the receipt in their perpetual inventory and file the written request along with any other documentation with their purchase records.

    • What do I need to do before I destroy Narcotics and Controlled Drugs?

      Health Canada recently published two guidelines on the destruction of narcotics and other controlled substances:


    • What is going on with Cannabis for Medical and Non-Medical Purposes?

      The Government of Canada has introduced legislation that would legalize non-medical cannabis use in the country. If passed, this legislation is expected to come into effect in July, 2018. For now, there is no change to access cannabis for medical purposes. Access will continue to follow the Access to Cannabis for Medical Purposes Regulations. Additional information on how a patient accesses cannabis can be found on Health Canada’s website – Accessing Cannabis for Medical Purposes.

      In addition to the federal legislation, the province will be establishing guidelines and making decisions related to where non-medical cannabis can be sold, who may purchase it, and whether certain laws should be updated or changed in the interests of public safety and health.

      Recognizing that the landscape around cannabis is evolving rapidly, the national organization for pharmacy regulators, NAPRA, has released its position statement on cannabis and the role of pharmacy practitioners which can be found at http://napra.ca/policies-and-positions/cannabis-position-statement.



    Questions about Prescribing by Pharmacists

    • What activities are covered by the Standards of Practice – Prescribing by Pharmacists

      In NL, authorized pharmacists may:

      • Prescribe Schedule I, II, III or Unscheduled Drugs for a Minor Ailment
      • Prescribe Schedule I, II, III or Unscheduled Drugs for a Preventable Disease
      • Prescribe Schedule II, III or Unscheduled Drugs for Other Purposes
      • Prescribe an Interim Supply
      • Extend a Prescription
      • Adapt a Prescription
      • Make a Therapeutic Substitution


    • Can all pharmacists prescribe?

      Only pharmacists authorized by NLPB as outlined in the Standards of Practice – Prescribing by Pharmacists (available on the Standards, Guidelines and Policies page) are authorized to prescribe.

      Pharmacists who wish to be authorized to prescribe must complete a mandatory orientation program (available through the NLPB Online Learning Portal) and then apply to NLPB by submitting a completed Application for Authorization to Prescribe, found on the Registration and Authorization page, with the supporting documentation and associated fee.

      Pharmacists will be notified by email once the application has been reviewed and approved. Pharmacists are to refrain from prescribing until this approval has been received.


    • Are there limitations on Pharmacists’ Prescribing?

      Yes, pharmacists must adhere to the following limitations:

      • A pharmacist may not prescribe Narcotics, Controlled Drugs or Targeted Substances, including benzodiazepines.
      • A pharmacist may not prescribe a drug included on the list of drugs referenced in section 4.(1) of the Pharmaceutical Services Regulations – i.e. the “Drugs Required to be Written on Tamper Resistant Pads”.
      • A pharmacist may not prescribe for an animal.
      • A pharmacist may not prescribe for themselves.
      • A pharmacist may not provide an interim supply, extend a prescription, make a therapeutic substitution or adapt a prescription where the original prescription bears a specific indication otherwise.
      • A pharmacist should not prescribe for a family member or someone of a “close personal or emotional relationship” unless there is no alternative. If a pharmacist prescribes in these circumstances, it should be appropriately documented.
      • Pharmacists must limit their prescribing activities to those situations covered by the Standards of Practice.


    • What is informed consent?

      Informed consent has two basic components:

      • patients have a right to determine what happens to their bodies; and
      • health professionals have an inherent duty to provide patients with enough information to make an informed decision.

      Patients must be provided with sufficient information specific to the circumstances to allow him/her to make an informed decision. When dealing with prescribing, this includes but is not necessarily limited to the condition being treated, the drug therapy being prescribed, any expected benefits and risks of the drug therapy, among other elements as detailed in the Standards.

      To ensure understanding and that suitable information has been provided, the patient or his or her agent should be provided with an opportunity to ask questions.


    • Is there a list of drugs pharmacists can prescribe for the minor ailments?

      No, once a pharmacist has determined from their assessment that the condition to be treated is one of the approved minor ailments, he or she is expected to follow best practices and clinical guidelines to choose the best treatment for the patient. The only restriction on this decision would be with regard to the limitation on prescribing narcotics, controlled drugs, benzodiazepines or targeted substances.

      For pharmacists who are looking for the most recent best practices and clinical guidelines, we would suggest referring to:

      • The Compendium of Therapeutics for Minor Ailments (https://www.pharmacists.ca/products-services/) – a required reference under the Standards that is a compilation of assessment and treatment algorithms, pathophysiology, pharmacological and nonpharmacological therapies and patient information for a wide variety of minor ailments.
      • The website RxFiles (www.rxfiles.ca) – an academic detailing program providing objective, comparative drug information to clinicians through newsletter reviews, Q&As, Trial Summaries, and up-to-date drug comparison charts.
      • The website MedSask (https://medsask.usask.ca/professional-practice/minor-ailment-guidelines.php) – the drug information centre in Saskatchewan (the first province to move forward with prescribing for minor ailments). They have developed treatment guidelines for a number of minor ailments, including mild acne, allergic rhinitis, cold sores and hemorrhoids.


    • What if I am not sure of the correct therapy or have some doubts as to the diagnosis?

      Again, there is no obligation for a pharmacist to prescribe. If you have determined that there is insufficient information or added risks to the patient, you should not prescribe. In these cases, pharmacists should refer the patient back to their primary health care provider or another appropriate health care professional.


    • Should pharmacists have their own prescription pads? If so, is there a standardized format for the pad?

      While there is no specific requirement in the Standards for pharmacists to have their own prescription pad, it is a best practice to help standardize the information on the prescription. This is especially important if the patient is taking the prescription to be filled elsewhere. In these cases, the pharmacist at the dispensing pharmacy must be able to be confident in the validity of the prescription as well as to contact the prescribing pharmacist if there are questions or issues.

      With regard to the format of the pad, the forms should be large enough to contain complete information for each prescription and should be difficult to photocopy or otherwise duplicate (utilizing a watermark or other security features). The prescriber’s name, practice address and telephone number should be preprinted on the prescription form. Pharmacists should always sign their prescriptions, and include their registration number if it is not pre-printed on the pad.


    • When I add an exempted codeine product to a patient’s profile, is this prescribing?

      No, adding an exempted codeine product (ECP) to a patient’s profile for the purposes of meeting the record-keeping requirements of the Standards of Practice – The Sale of Exempted Codeine Products in Community Pharmacies is not considered to be prescribing.

      In order to be considered prescribing, in accordance with the Standards of Practice – Prescribing by Pharmacists, a pharmacist would have to be:

      • 1. initiating a prescription for a Schedule I, II, III or Unscheduled product to treat a Minor Ailment or
      • 2. initiating a prescription for a Schedule II, III or Unscheduled product to facilitate adherence or to facilitate coverage through the patient’s third party drug benefit plan

      While it could be argued that a pharmacist could prescribe an ECP for mild headache or minor joint pain under #1 above, at this time, the Prescribing Regulations and Standards specifically limit pharmacists from prescribing Narcotics, Controlled Drugs, Benzodiazepines and Other Targeted Substances.


    • The Standards of Pharmacy Operation require me to document the provision of all Schedule II products on the patient’s profile – is this considered prescribing?

      No, adding a Schedule II product to a patient’s profile for the purposes of meeting the record-keeping requirements of the Standards of Pharmacy Operation – Community Pharmacy is not considered to be prescribing.

      In order to be considered prescribing, in accordance with the Standards of Practice – Prescribing by Pharmacists, a pharmacist would have to be:

      • 1. initiating a prescription for a Schedule I, II, III or Unscheduled product to treat a Minor Ailment or
      • 2. initiating a prescription for a Schedule II, III or Unscheduled product to facilitate adherence or to facilitate coverage through the patient’s third party drug benefit plan



    Questions about Administering Drug Therapy by Inhalation or Injection

    • Are all pharmacists authorized to administer drug therapy by inhalation or injection?

      Only pharmacists authorized by NLPB as outlined in the Standards for the Safe and Effective Administration of Drug Therapy by Inhalation or Injection (available on the Standards, Guidelines and Policies page) are authorized to administer drugs by inhalation or injection. The requirements for obtaining this authorization and the applicable authorization form can be found on the Registration and Authorization Information for Registrants page.


    • Do I need a private counselling room to administer drug therapy by inhalation or injection to a patient?

      In accordance with the Standards, pharmacists are expected administer drug therapy in a private patient care environment that is clean, safe, and comfortably furnished for the
      patient. This does not necessarily have to be a “counselling room” – it may be an office in the pharmacy, a clinic office or even an off-site location.

      Having said that, whatever location is utilized for injections, the location must still allow for suitable post-therapy observation and be equipped with all necessary emergency support equipment and supplies that may be required. If the injections are being provided off-site, the pharmacist would be expected to bring this equipment and supplies with them.

      In addition, even if injections are provided off-site, all assessment, documentation and follow-up requirements must still be met.


    • What types of supplies should I have on hand?

      A pharmacist must have ready access to all necessary supplies for the administration of injections as well as the drugs and supplies that would be required to treat emergencies or adverse reactions associated with the administration of drug therapy. Information on this is provided during the education and training program, as well as in the Canadian Immunization Guide. In Part 2 of this guide, under “Early vaccine reactions including anaphylaxis”, it gives a list of recommended items in an anaphylaxis management kit. Based on this list, as well as other resources, the following is recommended as a minimum:

      • Anaphylaxis treatment guidelines
      • Laminated table of dosage recommendations for epinephrine and diphenhydramine hydrochloride by weight and by age
      • Vials of aqueous epinephrine 1:1000
      • Vial of injectable diphenhydramine hydrochloride
      • A range of autoinjectors of epinephrine labelled by age and weight
      • 1 cc syringes with attached needles 25 gauge,1 inch needle and 25 gauge, 5/8 inch needle)
      • One extra 25 gauge, 5/8 inch needle only
      • Two extra 25 gauge, 1 inch and 1.5 inch needles only (for larger adults)
      • Ice or cold compress
      • Resuscitator bag / equipment to maintain airways


    • What reporting is expected in the event of an adverse reaction to an immunization?

      The Public Health Agency of Canada require that all health professionals report any major or moderate adverse events that occur following the administration of an immunization, using the Adverse Events Following Immunization Guidelines and reporting form (available at http://www.phac-aspc.gc.ca/im/aefi-essi-form-desc-eng.php). Once completed, the form is to be submitted to the Division of Communicable Disease Control at the Department of Health and Community Services. More information on this division can be found on the Department of Health and Community Services website.


    • Can the Inhalation or Injection Administration Documentation & Notification Form found in Appendix II of the Standards be modified?

      Yes, this form is provided as a template so it may be modified to suit the purposes of the pharmacy. Having said that, all information on the template MUST also be included on the customized form(s).


    • How should I file the documentation and notification forms afterwards?

      There are several ways this could be accomplished but the main thing you must ensure is that they are retrievable, if needed. An appropriate way to handle these forms would be to file them in sequential order along with your other prescriptions, since each instance of administration will likely generate a prescription/transaction number. You could then attach your computer “hard copy” to the form and file it. Pharmacies that have scanning technology can also scan these forms and attach them to the patient’s file for future reference.


    • Can pharmacy students or interns administer drugs by inhalation or injection?

      Yes, as long as they meet certain criteria set out by NLPB:

      The pharmacy student or intern MUST:

      • be registered with the NLPB (including maintaining appropriate professional liability insurance);
      • have successfully completed either an education and training program on the administration of injections that has received CCCEP competency-based (stage 2) accreditation OR all education and training on the administration of injections are part of the pharmacy program core curriculum;
      • have current certification in CPR Level C or HCP and Emergency or Standard First Aid from a recognized provider (e.g. St. John Ambulance, the Canadian Red Cross); and
      • be under the direct supervision of a pharmacist who has received authorization from the NLPB to administer drug therapy by inhalation or injection.
      • In this context, when providing “direct supervision”, the pharmacist or must be present when the activity is being performed and be able to observe and promptly intervene and stop or change the actions of the individual being supervised.

        For reference, this policy is posted to the Standards, Guidelines and Policies page of the NLPB website.

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