Scope of Practice – Pharmacy Technicians Practice Topic

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. 

Yes. A pharmacy professional may decide to administer a substance that is not listed in Schedule 2 of O. Reg. 256/24 to a patient via the intranasal route, without needing delegation of authority (e.g., a medical directive). Refer to Appendix A of the Administering a Substance by Inhalation Guideline as it explains that “intranasal” administration of a substance is not a controlled act and therefore is not restricted to health professionals or require enabling regulations. 

With inhalation, the drug is intended to be delivered to the epithelium lining the lower respiratory tract. With intranasal administration, the drug is intended to be delivered to the mucous membranes lining the nasal passages. If a pharmacy professional decides to administer a substance by the intranasal route, this should still be done in accordance with the Administering a Substance by Inhalation Guideline, Code of Ethics and Standards of Practice. 

For example, can they check and sign for blister packs independently, or does that still require a pharmacist to cosign the hard copies? Also, are they able to process, fill and sign for a repeat prescription independently or does it have to be cosigned by a pharmacist as well? My assumption is that they would be able to do these things since the original therapeutic check was already done by a pharmacist who checked and signed the original prescription and they would be just refilling it?

The legislation (O. Reg. 256/24) states “Every certificate of registration as a pharmacy technician is subject to the following terms, conditions and limitations: 1. The member shall only engage in the practice of pharmacy (…) when practising in a pharmacy to which the Drug and Pharmacies Regulation Act applies, other than a remote dispensing location, while under the direct supervision of a member holding a certificate of registration as a pharmacist…” 

A pharmacy technician can check any/all prescriptions for technical accuracy and completeness. Every prescription – new and refill, regardless of how they are packaged – must have both the technical and therapeutic check completed prior to release to the patient. Please refer to the integrating pharmacy technicians into the dispensing workflow webpage for more details; note that the term “co-signing” is not used, as each registrant is performing an independent “check” for different purposes. 

A suitable method for documenting both “checks” for a given prescription may be signatures (or some other identifying mechanism) from both registrants on every hardcopy. However, other methods may be suitable to document the respective actions and associated responsibilities in the dispensing process. As software, workflow, personnel, etc. can vary from pharmacy to pharmacy, the information presented on our website is not meant to be entirely prescriptive for how a pharmacy achieves the desired end result, which is to ensure the patient receives a prescription that is both technically accurate and therapeutically appropriate. 

Ultimately, registrants remain accountable for their respective roles in dispensing a prescription, and documentation on the patient record should reliably demonstrate that every prescription – new and refill – has been reviewed for both technical and therapeutic aspects before it is dispensed. It should be readily retrievable, auditable, and be unambiguous. When and how these functions occur, and what form they take (i.e., operational procedures) are at the discretion of the pharmacist and technician in consultation with the Designated Manager. 

Additional Resource 

• Article: Fall 2016 – Pharmacy Technicians – Professional Responsibilities and Standards of Practice 

The College’s Opioid Policy expects pharmacists providing Opioid Agonist Treatment (OAT) to practice in accordance with CAMH’s Opioid Agonist Maintenance Treatment: A Pharmacist’s Guide to Methadone and Buprenorphine for Opioid Use Disorder and the Standards of Practice. 

When dispensing methadone, the pharmacist is responsible for the therapeutic check of the prescription, assessing the patient, and witnessing the administration and ingestion of observed doses. These functions cannot be delegated to a pharmacy technician by the pharmacist. 

Part A pharmacy technicians have the independent authority to check the accuracy of the technical components of methadone prescriptions. Pharmacy technicians may also be responsible for other tasks in the workflow that fall within their competencies such as checking the prescription for technical accuracy, dose preparation, assisting with documentation and inventory management, etc. 

Additional resource 

• E-Learning Module: Pharmacy Technician Scope of Practice 

The Pharmacy Act and Ontario Regulation 256/24 define Scope of Practice and authorized acts for all pharmacy professionals. The steps involved in conducting a BPMH, such as gathering patient records from various sources and identifying discrepancies, are not necessarily governed by legislation. However, the regulation does set out Terms, Conditions and Limitations on a pharmacy technician’s certificate of registration, and pharmacy technicians cannot provide information or education relating to drug use which requires therapeutic knowledge, clinical analysis or assessment (s18.4). 

Pharmacy technicians responsible for performing a BPMH must have the appropriate knowledge, skills and training to meet the Standards of Practice for Pharmacy Technicians outlined in #9-#12. When collaborating to provide patient care, technicians are expected to document their decisions and actions in the patient’s health record, including the relevant health and drug information they’ve obtained and their interpretation of this information. 

The Pharmacy Manager/Administrator should establish policies and procedures for conducting medication reconciliations, outlining the respective roles for pharmacy technicians and pharmacists. OCP resources to consult include the Hospital Pharmacy Assessment Criteria, Standards of Operation, and the Pharmacy Technician Practice Assessment Criteria. External resources are also available from organizations such as the Canadian Society of Hospital Pharmacists (CSHP), ISMP Canada, the Canadian Patient Safety Institute (CPSI), etc. Collaborating with peers at other hospitals to share operational advice and best practices is also encouraged. 

Pharmacy technicians can gather and document relevant health information from the patient and conduct a Best Possible Medication History to inform the pharmacist’s patient assessment and support their decision-making. They can also assist the pharmacist in documenting and notifying the patient’s primary care provider about the minor ailment service and, if one is issued, the details of the prescription.  

The Designated Manager should have processes in place to incorporate pharmacy technicians into the workflow for minor ailment services and to support registrants in practicing to their full scope. Pharmacy technicians cannot “provide information or education relating to drug use, either to or for a patient, where the provision of the information requires therapeutic knowledge, clinical analysis or clinical assessment” due to the terms, limitations, and conditions on their certificate of registration. 

No. “Pharmacy Technician” (and its abbreviation “RPhT”) became restricted titles under section 10 of 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 the individual is registered with the College.