Feedback deadline is: 4:00 PM on August 15, 2026
The Ontario College of Pharmacists is seeking your input on proposed amendments to the Standards of Operation for Pharmacies. The consultation closes on August 15, 2026, at 4:00 p.m. ET.
Background
The Standards of Operation for Pharmacies (‘the Standards’) outlines the requirements needed to ensure pharmacies in Ontario provide safe, effective care and comply with regulations under the Drug and Pharmacies Regulation Act, 1990 (DPRA).
As expanded scope of practice has taken shape over the last year, the College has explored various safeguards that could support its safe implementation. Some of the safeguards include ensuring registrants have access to patient health information, that physical space requirements are appropriate, and that staffing and workflow are optimized. These safeguards already exist to some extent within the Standards of Operation, however, to support the expansion of scope, and to foster consistent interpretation by pharmacy owners and operators, there is an opportunity to refine, modernize and clarify certain parts of the Standards.
Following earlier input from the Board and system partners, amendments to the Standards of Operation were formally presented to the Board in June 2026 (see pg. 184), where they were approved for a 60-day public consultation.
What Are the Proposed Amendments to the Standards of Operation?
Proposed amendments have been made to the following sections of the Standards. For details, please see Expanded Scope: Standards of Operation Proposed Changes.
- Terminology and Definitions
- Management and Employee Relations
- Pharmacy Premises
- Delivering Services
- Equipment and Technology
- Information Management
How You Can Provide Your Input
The purpose of the consultation is to understand from the profession, the public and system partners:
- Are the proposed amendments to the Standards of Operation for Pharmacies reasonable, feasible and achievable?
- What are the benefits and/or drawbacks of the proposed amendments?
- Are there additional amendments that should be considered, that would directly support the expansion of scope? If yes, please explain?
You have two ways to provide input:
1. Online consultation posting
Feedback may be provided through the usual method – by posting your comments below or emailing us at [email protected]. Please allow 1-3 business days for your feedback to be published. In accordance with our posting guidelines, the College has the right to refuse to publish or remove comments that do not meet the posting guidelines.
2. Responding to a detailed survey
To provide more targeted responses, an additional method to provide your input for this consultation is through an online survey. Responses received through the online survey will be presented in aggregate form through a survey report. The survey report will be included as part of the consultation summary, which is posted after the consultation has closed. Click here to view a PDF version of the survey questions.
Please select only one method to provide input. All comments provided as part of the consultation will be reviewed and considered in the analysis provided to the Board. These summaries will be publicly available. Feedback must be submitted by August 15, 2026, at 4:00 p.m. ET.
Next Steps
Information gathered from this consultation will be brought to a future Board of Directors meeting for discussion and consideration for final approval. A summary of the consultation responses, including those from the survey, will be publicly posted with Board materials and subsequently posted to the consultation webpage.
Helpful Links
- Draft Amended Standards of Operation for Pharmacies
- Expanded Scope: Standards of Operation Proposed Changes (Comparison and Rationale Table)
Read The Feedback
I welcome a lots of new proposed changed to the Standards of operation especially having trained staff at all times,” and “adequate time.” Last 3 to 4 years all the pharmacies where I worked, have reduced their hours by at least 30 minutes or 60 minutes and the script count has gone up at all pharmacies. There should be a separate area for counselling to maintain the patient’s privacy and lots of independent pharmacies don’t have private counselling area. Mainly counselling is done at the cash register. I request OCP to include in the Standards of practice that each pharmacies must provide a separate computer to the pharmacist and E CPS so that we can check the patient’s profile and online reference.
I am writing as a community pharmacist, pharmacy owner, and Designated Manager to express concern regarding several proposed changes to the Standards of Operation. While I support safe patient care and the evolution of pharmacy practice, I am concerned that some proposals are overly broad, subjective, and may create unintended consequences for community pharmacies, particularly independent operators. The proposed staffing and workflow requirements use terms such as “at all times,” “adequate time,” and “professional wellbeing” without clear objective criteria, potentially exposing owners and Designated Managers to inconsistent or retrospective enforcement despite unpredictable factors such as staff illness, prescription surges, complex patient needs, and workforce shortages. I am also concerned that requiring a “separate and distinct” consultation area with acoustical and visual privacy could impose costly structural changes on existing pharmacies where flexible, outcome-based privacy measures may already be effective. In addition, expanded requirements for policies, procedures, training, monitoring, documentation processes, clinical decision-support tools, equipment maintenance records, accessibility accommodations, and patient-record management may create substantial administrative and financial burdens without clear evidence that each requirement will improve patient outcomes. These cumulative obligations may disproportionately affect small and independent pharmacies that do not have the compliance departments, staffing resources, or capital available to large corporate organizations, and could ultimately cause pharmacies to limit expanded-scope services, reduce service availability, or avoid offering certain clinical activities altogether. I respectfully ask the College to withdraw or substantially revise these proposals in their current form, adopt clear and flexible risk-based standards that recognize pharmacy size, services offered, workforce availability, unexpected operational pressures, and professional judgment, avoid implied staffing ratios or subjective workload enforcement, preserve flexible approaches to patient privacy, clearly distinguish mandatory requirements from best practices, ensure requirements are proportionate to the services actually offered, and conduct a transparent financial and operational impact assessment on independent, small, and rural pharmacies before implementation. Expanded scope should improve access to care, not create uncertain regulatory obligations that increase administrative burden, reduce professional autonomy, and unintentionally threaten the sustainability of community pharmacy practice.
Trimedic’s FaStep test strips outperform the current patch-for-patch policy. Visual inspections are slow and subjective, often delaying care and limiting pharmacist decisions. Trimedic enables rapid, reliable screening of returned fentanyl patches to confirm authenticity quickly. This streamlines dispensing, improves patient access to pain relief, and strengthens diversion prevention. Safeguarding Our Communities Act needs to be amended and to be empowered by an objective screening test for the returned fentanyl patches.
Pharmacists should wear respirators, particularly when serving customers who are wearing respirators. Older patients, and those who are immune compromised deserve to receive care in a safe environment.
The OCP should amend the guidelines of Patch for Patch policy within Safeguarding Our Communities Act to protect Canadian victims from the abuse and diversion of transdermal fentanyl. This Act will continue to be defective and ineffective unless it is empowered by an objective screening test Ontario pharmacists can utilize at point of care to distinguish between authentic and counterfeit returned fentanyl patches. It’s estimated that more than 360,000 autthentic fentanyl patches are diverted yearly to the street to be abused by Canadian victims since the pharmacists are advised by the OCP guidelines to rely on visual inspection which is definitely misleading. Recently, a group of 16 community pharmacists from various locations of Ontario developed a novel screening test to detect counterfeit returned fentanyl patches. This research project was published in an American journal of addiction and addictive disorders under Rey-McIntyre et al (2025). Any pharmacist can access the manuscript on Google. Approximately 30% of the returned patches were counterfeit and were handed over to law enforcement for further investigation. Malicious actors are returning pieces of an adhesive transparent tape stamped with same printed letters and numbers on authentic fentanyl patches fooling Ontario pharmacists. Implementation of Rey-McIntyre et al rapid screening test will empower Ontario pharmacists to implement Safeguarding Our Communities Act and P4P guidelines effectively and will save lives of innocent Canadian victims. It’s an objective screening test which is more reliable than the subjective visual inspection. It is time to update the guidelines of Patch for Patch policy to Safeguarding Our Communities Act practically and effectively not theoretically. https://www.heraldopenaccess.us/openaccess/a-simple-and-rapid-test-for-screening-returned-fentanyl-patches-in-community-pharmacies
Clinical Decision Support Tools The proposed standard is a welcome addition, but without a defined minimum capability, it risks being satisfied by passive reference databases that fall short of what expanded scope activities actually demand. We recommend companion guidance that distinguishes passive reference tools from active clinical decision support e.g. tools capable of reasoning against patient-specific context and supporting clinical decisions, not simply retrieving static drug information. Documentation AI-assisted documentation tools directly address the documentation delays and inconsistencies the College is trying to solve, particularly as expanded scope increases documentation volume. We recommend companion guidance explicitly recognize AI scribes as a legitimate operational solution when operators are establishing documentation protocols.
While we appreciate the OCP commitment to advancing patient safety, accountability, and quality assurance, I am concerned that the proposed amended standards of Operation place a significant and potentially unrealistic burden on pharmacy managers. In many community pharmacy settings, the pharmacy manager is not only responsible for managerial, regulatory, quality assurance, and operational oversight duties, but is also expected to function as a staff pharmacist providing direct patient care, prescription verification, clinical services, staff supervision, and workflow management. the cumulative expectations outlined in the draft standards may be difficult to achieve consistently within the realities of current staffing levels, (as well as their shortage), workload pressures, and resource constraints. the increased administrative, documentation, monitoring, and compliance requirements could inadvertently divert pharmacists’ attention away from direct patient care and prescription review activities. this raises concerns that excessive operational obligations may contribute to workflow interruptions, increased cognitive burden, and a greater risk of dispensing errors or patient safety incidents. I encourage the College to carefully consider the practical implementation of these requirements and assess whether the expectations placed on pharmacy managers are proportionate to the resources typically available in community pharmacy practice. Additional flexibility, clearer prioritization of requirements, and recognition of staffing limitations would help ensure that the standards remain achievable while continuing to sup[port patient safety and high quality care. I believe the example of excessive regulations on Compounding Pharmacies now, resulted in many clients getting their compounded prescriptions at least 7-10 days later than the actual day that they were expected to start it. Has benefit in this case outweigh the risk? good question that I will leave it for the Public to decide. Regards,
Dear Ontario College of Pharmacists, I am writing to provide feedback regarding the proposed standards and expectations around prescription delivery, particularly the requirement to obtain a patient or agent signature at the time of delivery. As a community pharmacy operator, I fully support the importance of safe, secure, traceable, and accountable prescription delivery. However, I believe the delivery requirements should allow more discretion for the pharmacist and pharmacy, especially when serving elderly, frail, disabled, homebound, or medically vulnerable patients. In practice, many patients cannot easily come to the door, physically sign, or interact with the delivery person in the usual way. Some patients are very weak, bedbound, have mobility limitations, cognitive limitations, or rely on caregivers who may not always be present at the exact time of delivery. In these situations, the pharmacy may still be able to safely deliver the medication by placing it in a patient-approved secure location inside the home, on a table, with a caregiver, or in another location that the pharmacist has assessed as appropriate. A strict signature requirement may create unintended barriers for the very patients who depend most on pharmacy delivery services. It may also lead to unnecessary failed deliveries, delayed access to medication, repeated delivery attempts, and increased administrative burden without necessarily improving patient safety in every case. I would respectfully suggest that OCP consider a more flexible, risk-based approach. For example, the standards could allow pharmacies to develop written delivery policies that permit exceptions to signature requirements where appropriate, based on pharmacist judgment, patient circumstances, medication risk, and documentation. Possible alternatives could include: • documented verbal confirmation from the patient or caregiver; • electronic delivery confirmation; • delivery notes confirming where the medication was placed; • pharmacist-approved patient-specific delivery instructions; • confirmation by phone at the time of delivery; • documentation of why a signature could not reasonably be obtained; and • stricter requirements for higher-risk medications such as narcotics, controlled substances, refrigerated items, or expensive medications. This would still maintain accountability and traceability, while allowing pharmacies to provide practical, patient-centred care. The pharmacist should be able to use professional judgment within the framework of the pharmacy’s policies and procedures, instead of being limited to a rigid signature requirement that may not reflect real-world patient needs. I believe the goal should be safe delivery, confirmed receipt, and appropriate documentation, rather than signature collection in every circumstance. A well-documented pharmacist-approved exception process would better support patient access while still protecting the public. Thank you for the opportunity to provide feedback.
I really hope you expand the rules in lines 92-93 and add that extra language from 95-98. Honestly, I think you should go even further with the privacy requirements especially if you want. I handle all the prescriptions for my whole family including my elderly parents, my kids, my husband, and me. So its frustrating because privacy is almost nonexistent. At most places they just do the “private consultation” right there at the main counter next to the cashier. Those little plastic dividers if their even there don’t do anything. You can still hear every word and see right over them. It’s not private at all. So I don’t know how their supposed to take on these new services if they don’t even have any privacy. One pharmacy has an actual “Counseling Room” with a sign on it, but I’ve never seen a single person use it. It looks dark and depressing, like they’re just using it to store boxes. When it’s busy, which is pretty much always at this place, the line backs up and everybody’s standing way too close. I’ve overheard way too many strangers personal health stuff. It’s awkward. It’s not like that at the doctor’s office or even the dietician you get a real room with the door closed so you can talk freely. Because of this, I usually just grab my bags and go. I don’t ask the questions I need to about side effects or anything else because I’m embarrassed having everyone in line hear my family’s business.
Terminology and Definitions – we should be referred to as members (to align with legislation) Management and Employee Relations – Lunch should be mandatory; there should be a way for pharmacist on duty to take a bathroom break and eat on premises without it just being at the discretion of the employer. The pharmacy should also not require pharmacy staff to stand all day, there should be comfortable seating provided! Pharmacy Premises – consultation rooms must be private, no counselling at the cash register or within ear shot. Better verification methods for who is actually allowed to pick up for a patient – consent is not always clear. It is assumed a spouse is allowed to pick up, but rarely ever verified in practice! Delivering Services – right now, it is mandatory to sign for deliveries, however, there needs to be another way to “Digitally” sign for patients who cannot come to the door or sign due to disabilities. this practice is not inclusive Equipment and Technology – no more non-paperless software, it leads to many mistakes (working in an independent, it did feel like i was tunnel-visioned into verifying just the single rx in front of me without having the whole profile there – Clinical verification should happen prior to an rx being filled by assistants (flow on health watch is quite good for this) Information Management – pharmacies need to ban the use of whatsapp groups to discuss pharmacy notes; patient information is on everyone’s phones
The use of the terms “members” and “pharmacy professionals” is inconsistent throughout the document. GIven that “members” is the term defined in legislation I see no need to create new definitions like “pharmacy professionals” and “registrants”.
Are technicians going to be moved in to clinical, thus becoming a more respected position where wages can reflect our work?