General Pharmacy Practice Questions

These are two distinct factors which must be considered independently in a scenario where the pharmacy professional is both dispensing and administering a substance.

“Schedules” are included in legislation to provide details (such as lists and tables) that aren’t suitable for including in the main content of the Act or Regulation. There are four schedules in O. Reg. 256/24 under the Pharmacy Act:

In terms of scope of practice, pharmacists are authorized to administer a substance in Schedule 1 by injection, a substance in Schedule 2 by inhalation, or a vaccine in Schedule 3. (Schedule 4 relates to pharmacist prescribing and not to administration.)

Separate and distinct, O. Reg. 264/16 under the Drug and Pharmacies Regulation Act requires pharmacies to follow the conditions of sale for a drug according to the NAPRA National Drug Schedules:

  • Schedule I: Drugs require a prescription; only available from the dispensary
  • Schedule II: Drugs do not require a prescription but do require intervention from the pharmacist; available from an area of the pharmacy where there is no opportunity for patient self-selection
  • Schedule III: Drugs do not require a prescription, but a pharmacist or intern must be available for consultation; available for self-selection from the professional products area (within 10m/30ft of the dispensary)
  • Schedule U: Drugs do not require a prescription or professional supervision; available from any retail outlet

For additional information please refer to:

Having a degree in pharmacy is one of several requirements needed for a certificate of registration, in order to practice as a licensed pharmacist in Ontario. It does not, in itself, confer the right to practice pharmacy. Should an individual wish to make reference to their educational credentials, this information should be presented in a manner that is not ambiguous, confusing, or misleading to the public. OCP has not established any additional policy or guideline restricting how a degree or credential may be used, however, it must be evident whether an individual is licensed by the College and able to practice pharmacy, or not.

Pharmacy graduates who possess a PharmD (Doctor of Pharmacy) degree should be aware that use of the title “Doctor” (or an equivalent abbreviation, such as Dr.) is restricted by the Regulated Health Professions Act, Section 33. A pharmacist cannot use this title in the course of providing, or offering to provide, health care to an individual. The regulated health professionals who may use this title in practice are defined in the Act. Pharmacists should be mindful when referring to their PharmD degree of the potential for misinterpretation by a patient that the individual is, for instance, a Medical Doctor (MD).

Once registered with the College as a pharmacist, they are permitted to use the title of “Pharmacist” or an equivalent abbreviation, such as the designation “RPh” (approved by Council in 2003). Section 10 of the Pharmacy Act also restricts the use of the titles “Apothecary” and “Pharmaceutical Chemist” to registered pharmacist registrants of the College. Similarly, “Pharmacy Technician” (and its abbreviation RPhT) became a restricted title under the Pharmacy Act in December 2010. All other titles – such as Certified Pharmacy Technician (in use prior to 2008) – must no longer be used. This does not prevent someone from indicating their past achievement of passing the College’s certification exam, such as on a résumé, however the title of “Pharmacy Technician” cannot be used in practice unless they are registered as registrants of the College.

Providing a copy of the original with the transfer would be considered a best practice in the interest of patient safety. Unlike a refill, the logged prescription has never been dispensed and has not gone through the same complete checking process. This is the same reason registrants within their own practice site should be retrieving or viewing the original hardcopy before a logged prescription is dispensed.

The Code of Ethics also expects that when a patient moves from one healthcare provider to another, the relevant information is provided to the receiving healthcare provider, to ensure safe and effective transition of care

It is the professional responsibility of a pharmacist to self-assess their competency and ensure they possess sufficient knowledge, skills and judgment to safely dispense any medication. A pharmacist is expected to undertake education or training as necessary to address any knowledge gaps so that they are able to effectively assess the patient and evaluate the appropriateness of the prescribed therapy. Pharmacists are reminded that they are responsible for providing the patient with relevant and sufficient information about the medication, including how to manage potential risks associated with use, and for providing appropriate follow-up. Given the serious safety concerns identified with the use of Mifegymiso®, pharmacists should report any cases of serious or unexpected side effects to Health Canada’s MedEffect Canada adverse reaction reporting system or to the manufacturer. Additional resources are available on the Linepharma website. Also, the Canadian Pharmacists Association has published a checklist for pharmacists and the Society of Obstetricians and Gynecologists of Canada offers a training program. 

As explained in the Pharmacist Prescribing: Initiating, Adapting and Renewing Prescriptions Guideline, pharmacists have the independent authority to initiate treatment for smoking cessation with buproprion or varenicline under O. Reg 256/24 of the Pharmacy Act. 

The regulations do not require a pharmacist to complete specific training prior to initiating treatment for smoking cessation. Similarly, OCP does not require or endorse a particular program you may wish to take. As with any patient care scenario, pharmacists are relied upon to practice within the limits of their competence, and to obtain the knowledge and skills necessary to carry out their professional duties. 

However, you may be required to complete a certification course for the purposes of obtaining reimbursement for providing a specific smoking cessation service offered through a patient’s third-party insurer or the Ministry of Health. 

The federal Precursor Control Regulations sets a maximum amount of pseudoephedrine and/or ephedrine that may be sold per package*, but not a limit on the total amount or quantity of pseudoephedrine and/or ephedrine that may be sold per transaction. Nevertheless, registrants have a professional and ethical obligation to prioritize the safety and best interests of the patient and the public.

If diverted to the illicit market, pseudoephedrine or ephedrine can be used to illegally produce D-methamphetamine (“meth”, “crystal meth”), which poses a significant risk to public health and safety. Given these risks, registrants must remain vigilant and exercise professional judgment when determining the quantity to sell, considering the patient and circumstances, to prevent potential substance misuse. For example, a registrant may restrict or limit the quantity sold to an individual if the request appears inappropriate based on their assessment.

*Based on maximum amount of pseudoephedrine and/or ephedrine base per package (e.g., maximum for pseudoephedrine base is 3 grams = 3.659 grams pseudoephedrine HCL). For conversion factors, refer to: https://www.deadiversion.usdoj.gov/quotas/conv_factor/index.html.

It depends on the product’s classification at the federal level:

a) Natural Health Products (NHPs) containing pseudoephedrine and/or ephedrine (i.e., products assigned a NPN by Health Canada) are not included in the NAPRA National Drug Schedules (NDS) and therefore are not subject to the related NAPRA NDS conditions of sale. However, they are still defined as ‘drugs’ by Ontario regulations and Health Canada’s Ministerial Order sets out retail sale prohibitions for these products.

Designated Managers must ensure that these products are only available for sale while the pharmacy is in operation (i.e., when a pharmacist is physically present in the pharmacy, providing direct supervision to personnel).

Health Canada’s Order outlines the following conditions-of-sale restrictions:

  • Non-combination (“single entity”) NHPs containing only pseudoephedrine and/or ephedrine as medicinal ingredient(s) can only be sold by a pharmacist or a person working under the supervision of a pharmacist.
  • Combination NHPs containing pseudoephedrine and/or ephedrine plus one or more other NHP ingredients (substances in Schedule 1 of the Natural Health Product Regulations) can be sold only if a pharmacist is available to assist consumer prior to purchase if requested.

These restrictions also apply to remote dispensing locations (RDLs) and online sales. See related FAQ on “Can products containing pseudoephedrine or ephedrine only be sold in pharmacies?”

b) Health Canada’s Order does not apply to non-prescription drugs (NPDs) containing pseudoephedrine and/or ephedrine and other drugs (i.e., products assigned a DIN by Health Canada).

As Ontario regulations require pharmacies to follow the conditions of sale for a drug according to the NAPRA National Drug Schedules (NDS), if the NPD contains:

  • Schedule II or III drugs
    • The ingredient with the most stringent NAPRA NDS conditions for sale determines whether pharmacist intervention is required; and
    • The Supplemental Standards of Practice for Schedule II and III Drugs apply.
  • Unscheduled drug(s)
    • They are not subject to the regulations and may be sold by any retail outlet.

In any case, the Designated Manager can choose to implement procedures for a pharmacist to intervene in the sale of any NHP or NPD containing pseudoephedrine and/or ephedrine, if there are concerns about misuse or diversion.

It depends on the product’s classification at the federal level:

  1. Natural Health Products (NHPs) containing pseudoephedrine and/or ephedrine (i.e., products assigned a NPN by Health Canada) are beyond the scope of the NAPRA National Drug Schedules (NDS) and therefore are not subject to the related NAPRA NDS conditions of sale.  However, pseudoephedrine and ephedrine are still defined as ‘drugs’ by Ontario regulations, which limits their sale to accredited pharmacies in Ontario.  In addition, Health Canada’s Ministerial Order sets out retail sale prohibitions for these NHPs across the country.

Designated Managers must ensure that these products are only available for sale while the pharmacy is in operation (i.e., when a pharmacist is physically present in the pharmacy, providing direct supervision to personnel).

Health Canada’s Order outlines the following conditions-of-sale restrictions:

  • Non-combination (“single entity”) NHPs containing only pseudoephedrine and/or ephedrine as medicinal ingredient(s) cannot be accessible to the public for self-selection (e.g., must be kept behind the counter).
  • Combination NHPs containing pseudoephedrine and/or ephedrine plus one or more other NHP ingredients (substances in Schedule 1 of the Natural Health Product Regulations) can be accessible to the public in the self-selection area of the pharmacy.

These restrictions also apply to remote dispensing locations (RDLs) and online sales. See related FAQ on “Who can sell products containing pseudoephedrine or ephedrine in the pharmacy.”

  1. Health Canada’s Order does not apply to non-prescription drugs (NPDs) containing pseudoephedrine and/or ephedrine and other drugs (i.e., products assigned a DIN by Health Canada). Ontario regulations require pharmacies to follow the conditions of sale for a drug according to the NAPRA National Drug Schedules (NDS).

Therefore, if the NPD contains:

  • Schedule II or III drug(s): The ingredient with the most stringent NAPRA schedule determines its conditions for sale (e.g., if the NPD contains Schedule II and III drugs, then Schedule II applies).
  • Unscheduled (“Schedule U”) drug(s): They are not subject to the regulations and may be sold by any retail outlet.

In any case, the Designated Manager can choose to keep any NHP or NPD containing pseudoephedrine and/or ephedrine behind the counter if there are concerns about misuse or diversion.