Delivery of Prescriptions Fact Sheet

A fact sheet is a plain-language explanation of the legislation that forms the foundation of certain pharmacy practices. It provides useful information and references to help pharmacy professionals understand a particular topic. A fact sheet is an informational resource and is not considered legal advice. Always refer to the legislation for full context.

Legislative References

Additional References

Protecting the Cold Chain Guideline
Article – Designated Manager Responsibilities When Using Technology to Deliver Pharmacy Services (Pharmacy Connection, Spring 2017)

Definitions

Controlled substance: A substance set out in Schedules I, II, III, IV, or Part 1 of V of the

federal Controlled Drug and Substances Act (CDSA). Where applicable, this resource applies to the substances named in Schedule 1 (narcotics), Schedule 2 (controlled drugs) and Schedule 3 (targeted substances) under the Controlled Substances Regulations.

Monitored drug: A controlled substance as defined above, an opioid that is not listed under the CDSA, and any drug product designated by the Minister of Health as per the Narcotics Safety and Awareness Act, 2010.

Background

The authority and requirements for delivering a prescription drug are outlined in the provincial Drug and Pharmacies Regulation Act, 1990 (DPRA) and Narcotics Safety and Awareness Act, 2010 (NSAA), and the federal Controlled Substances Regulations (CSR).

Importantly, dispensing is considered to have occurred, or to be complete, when the patient or their agent takes custody of the prescription. Regardless of the method used, while a drug is in the process of being delivered, it is still in the care and control of the pharmacy.

Provincial Requirements

The DPRA contains specific provisions requiring that the delivery of drugs in NAPRA Drug Schedule I, (i.e., prescription drugs), is traceable and auditable, including confirmation of both transit of the drugs and receipt by the patient or their agent. If the delivery is for a monitored drug or controlled substance, additional requirements apply (described below).

Delivery of Schedule I drugs:

Registered mail if delivered by mail
All other methods of delivery must be both traceable and auditable
Requires a signature by patient or patient’s agent at the time of receipt
- A waiver cannot be signed in advance to request that the prescription delivery be left unattended on the premises (e.g., in a mailbox, post office box, between the doors, etc.)
Arrangements should be made prior to delivering to ensure the patient or agent will be available to accept and sign for the delivery

For patients requiring accommodation for a disability (as defined in the Accessibility for Ontarians with Disabilities Act (AODA) s2), procedures should be guided by the College’s Human Rights Policy:

Pharmacy professionals are required to follow the Ontario Human Rights Code (OHRC), which has primacy and takes precedence over other legislation in Ontario.
Section 38 of AODA states that, if two laws conflict with one another, the law that provides a higher level of accessibility must be followed.

Patient’s Agent

Specified in advance by the patient to accept and sign for their prescriptions.
- This is the patient’s choice and does not need to be someone they know personally.
A person providing delivery service for the pharmacy cannot be the patient’s agent because they are acting as an agent of the pharmacy. However, a patient may use an independent delivery service as their agent to pick up and deliver their prescription.

Documentation

Signature by the patient or agent upon receipt is required by law.
Signatures may be “wet” (obtained in pen-and-ink) or electronic.
- Be mindful that some couriers may allow their customers to decline any signature for deliveries. These preferences cannot be applied to prescription deliveries.
If obtaining a signature is not possible and an alternative approach is in the patient’s best interest, documentation of these circumstances is mandatory.
- This exception should only be used in rare situations, as registrants are expected to make every reasonable effort to comply with legislative requirements.

Examples of exceptional circumstances might include:

The recipient has physical limitations, dexterity issues, etc. They may sign with an ‘x’ witnessed by the delivery agent, use biometric confirmation, or another method that achieves the same purpose.
The recipient has or may have a disease of public health significance and close contact must be avoided. Registrants should exercise professional judgment to determine the most appropriate process (e.g., place in a secure location and have delivery agent wait outside or call the recipient to confirm patient receipt).
If applicable, document the patient’s request for an accommodation and how that accommodation was met.

Auditable and Traceable

The pharmacy is responsible for the security of the medication and personal health information until it is received by the patient or their agent; all reasonable measures must be taken.
For controlled substances, the pharmacist or pharmacy technician must use a method of delivery that ensures the tracking of the prescription until the patient or their agent receives it.
Deliveries should be sent directly from the pharmacy to the recipient.
- Any stops or delays along the way (aside from the pharmacy’s other prescription deliveries) should be with the knowledge and approval of the pharmacist.
If a delivery attempt is unsuccessful, the pharmacy is responsible for the ongoing auditability, traceability, integrity, and security of the medication until the delivery is successful or is returned to the pharmacy.

Record Keeping

The pharmacy should ensure the authenticity of patient or agent signatures on the delivery record.
Signed receipts should be returned to the pharmacy or made available electronically.
Delivery records for prescription drugs do not need to be kept for a specific time period, except for records related to controlled substances (see below).
- Once the records are no longer required for audit purposes, they should be destroyed in a manner that protects confidentiality of personal health information.

Monitored Drugs

Pharmacy professionals must adhere to the applicable Ontario Ministry of Health’s requirements under the Narcotics Safety and Awareness Act (NSAA) and its regulations (O. Reg. 381/11) when a patient uses an agent to receive their monitored drug on their behalf. In these situations, the pharmacy professional must:

Verify the name and address of the agent before dispensing the monitored drug.
Keep a record of the following:
- Agent’s name and address
- Form of identification provided by the agent that verifies their name and address
- Distinguishing number on the form of identification

For further details, refer to Ontario’s Narcotics Strategy FAQs (Questions 32, 33 and 34) and Ontario Drug Programs reference manual (Section 15.3 for Ministry-approved forms of identification).

Additional Federal Requirements for Controlled Substances

The Controlled Substances Regulations require the pharmacy professional responsible for the delivery of a controlled substance prescription to record:

Their name (or the name of the pharmacy’s delivery agent)
The pharmacy’s name and municipal address
The patient’s name (for an animal patient, also the owner’s name)
- If being delivered to the patient’s agent, the name of their agent and, if applicable, title
The destination address
The date of delivery
The means of transportation
For the controlled substance, its name, form, strength, the number of containers dispensed and quantity in each container
- If applicable, the brand name and drug identification number (DIN)

Documents pertaining to controlled substances must be retained for two years after the day on which the last entry is recorded in the document.

For more information refer to the Health Canada Policy – Transportation of Controlled Substances in Canada.

Additional Considerations

Cold Chain

Drugs must be kept in the appropriate temperature range during transit.
- Medications requiring a cold chain or other specific logistics should be shipped in the appropriate (i.e., validated) containers and/or temperature-controlled vehicles, considering the time and distance expected to complete the delivery and the possibility of unforeseen delays.
Having procedures in place to manage delivery delays and temperature excursions is encouraged, and for cold chain drugs, required.

Prescription Lockers

While drugs may be delivered or mailed, provincial legislation (DPRA) does not permit Schedule I drugs to be available at a location other than the dispensary of a pharmacy, which (by definition) cannot be accessible to the public.
- Lockers are not feasible delivery options in Ontario, unless they are designed to interface with the dispensary and access is restricted to the pharmacy’s operating hours when a pharmacist is on duty.
A patient’s agent must be a natural person.
- A locker cannot act as a patient’s agent, even if a “signature” or proof of receipt can be obtained.

Delivery Outside of Canada

Must meet the requirements of the DPRA.
It is recommended to contact the delivery service to find out what documentation is required to send prescription medications to another country:
- Check for any restrictions that a country may have on certain drugs
- Check for personal importation rules for the patient
- If delivery service is unsure, the country’s embassy, border agency, or consulate here in Canada can be contacted for information
Advise patients there may be delays (e.g., due to weather, transportation issues, customs clearance).
Ensure that the packaging and method of transportation safeguard the integrity of the drug.

Delivery to a licensed dealer

If a controlled substance is being delivered to a licensed dealer for destruction, the container must be sealed and tamper-evident (i.e., cannot be opened without breaking the sea)l an marked in a manner sufficient to identify the container.

Refer to the Controlled Substances: Destruction of Unserviceable Stock and Post-Consumer Returns Fact Sheet for further details.

Delivery between Pharmacies, Hospitals, and Drug Preparation Premises

The requirements for prescription delivery to patients applies to deliveries of prescription drugs and controlled substances between pharmacies, hospitals, and drug preparation premises (DPPs).

Examples include:

Delivery of prepared prescriptions from a central fill pharmacy to the patient’s pharmacy.
Transportation of medication between hospital sites or from pharmacy to patient care areas.
Delivery of compounded preparations from a DPP to a pharmacy or practitioner. In particular:
They must be auditable and traceable, having procedures for recording pertinent information.
The integrity and security of the medication and, if applicable, security of personal health information, is maintained.
Transportation of controlled substances must meet the legislated requirements outlined above.

Published: October 2026
Version: 3.0

Revision History

Version #	Date	Action
1.0	September 2013	Published as Prescription Delivery Fact Sheet
2.0	March 2020	Added guidance for delivery to patients with a disease of public health significance
3.0	October 2026	Added requirements for controlled substances, accessibility, and additional considerations for other delivery situations.