Can a pharmacy professional administer a substance by injection if it is not listed in Schedule 1 of O. Reg. 256/24 in a potentially life-threatening situation (e.g., epinephrine, glucagon, naloxone, etc.) without a medical directive?

Yes. Administering a substance by injection is a “controlled act”, as defined in the Regulated Health Professions Act (RHPA), that may only be performed by an authorized health professional. There are, however, provisions in the RHPA that permit “a person” to perform a controlled act “in the course of rendering first aid or temporary assistance in an emergency” even if they are not an authorized health professional. 

Also, the province’s Good Samaritan Act provides protection from liability for a pharmacy professional “who provides emergency health care services or first aid assistance to a person who is ill, injured or unconscious as a result of an accident or other emergency”. 

Therefore, in the event of a medical emergency, a pharmacy professional may decide to administer a substance (that is not listed in Schedule 1 of O. Reg. 256/24) to a person, without delegation of authority (e.g., a medical directive), while waiting for emergency medical services. This should still be done in accordance with the Administering a Substance by Injection Guideline, the Code of Ethics and Standards of Practice.