Overview
Direct purchase and shipment of narcotics and other controlled substances by registrants is a professional privilege. All registrants are responsible for the controlled drugs they use for their patients and should work with the designated registrant and practice staff to ensure these drugs are managed safely and securely.
Under the federal Controlled Drugs and Substances Act (CDSA), registrants are considered practitioners. For veterinary practitioners, the most relevant regulations include the Narcotic Control Regulations and the Benzodiazepines and Other Targeted Substances Regulations.
Proper management of controlled drugs is essential to public and staff safety.Any discrepancy between the amount present and the amount expected should be investigated promptly. Significant unexplained losses must be reported to Health Canada and the College, and may also need to be reported to police. The reporting requirements are outlined below.
Reporting Requirements
Lost or Stolen Controlled Drugs
Under the CDSA, the practitioner (that is, the registrant) must report a significant loss, including theft, to Health Canada. Depending on the nature and amount of the loss, reporting to local law enforcement may also be required. The designated registrant is responsible for reporting any significant loss to the College. For narcotics, controlled drugs, and targeted substances, practitioners should report to police based on best practices and submit the report to Health Canada within 10 calendar days of discovery.
Health Canada provides guidance on how to report a loss or theft of controlled substances or precursors, including how to submit a report through the Health Canada E-Services Portal.
Health Canada also provides guidance on which incidents are reportable and the timeframes that apply.
CVBC Bylaw 3.6(9) requires the designated registrant to report the loss to the College. Failure to comply with the Professional Practice Standard on Management and Disposal of Controlled Drugs could result in direction of an inspection, and/or referral to the Investigation Committee. More importantly, poor controlled-drug management can create significant risk for staff and the public.
The designated registrant may submit the Controlled Drug Loss Form to facilities@cvbc.ca to notify the College of a loss of controlled drugs.
Summary of steps
Lost or Stolen Prescription Pads
If prescription pads are missing, lost, or stolen, the registrant must contact PharmaNet. Please review the College of Pharmacists of British Columbia Controlled Prescription Program for information about lost or stolen prescription pads. For replacement prescription pads, contact reception@cvbc.ca.
Resources for Controlled Drug Management
The Practice Facility Accreditation Committee (PFAC) emphasizes the importance of proper logging and auditing of controlled drugs, as outlined in the following resources:
There is no single management approach that will suit every practice. The goal is to develop a controlled-drug management program that fits the practice team and supports consistent tracking of products entering the facility and being dispensed. This enables routine audits to confirm that the amount expected from the logs matches the amount physically present. Unexplained losses must be investigated and reported. Secure, safe and logged disposal of these drugs is also important.
A Resource on creating a Controlled Drug Management Program can be adapted to the needs of each practice.
The CVBC office is often asked for approved templates. The templates below are samples only and are intended as guides that can be adapted to each practice’s needs. A practice or facility may also develop its own forms and logs, provided they meet the accreditation standards in Schedule D.
The College of Veterinarians of Ontario also provides controlled-drug management resources that may be useful to registrants and their teams.