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Medication Errors & Discipline - Ontario College of Pharmacists

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ANNUAL PHARMACY FEES DUE MAY 10, 2009<br />

Pr<strong>of</strong>ile <strong>of</strong> the Relief Pharmacist<br />

page 6<br />

<strong>Ontario</strong>’s eHealth Strategy<br />

page 8<br />

<strong>Medication</strong> <strong>Errors</strong> & <strong>Discipline</strong><br />

page 22


ontario college <strong>of</strong> pharmacists<br />

483 Huron Street, Toronto, <strong>Ontario</strong> M5R 2R4 • Tel (416) 962-4861 • Fax (416) 847-8200 • www.ocpinfo.com<br />

The mission <strong>of</strong> the <strong>Ontario</strong> <strong>College</strong> <strong>of</strong> <strong>Pharmacists</strong> is<br />

to regulate the practice <strong>of</strong> pharmacy, through<br />

the participation <strong>of</strong> the public and the<br />

pr<strong>of</strong>ession, in accordance with standards <strong>of</strong><br />

practice which ensure that pharmacists<br />

provide the public with quality<br />

pharmaceutical service and care.<br />

Council Members<br />

Council Members for Districts 1-17 are listed below according to District number. PM indicates a public member appointed by the<br />

Lieutenant-Governor-in-Council. DFP indicates the Dean <strong>of</strong> the Leslie Dan Faculty <strong>of</strong> Pharmacy, University <strong>of</strong> Toronto.<br />

DSP indicates the Director, School <strong>of</strong> Pharmacy, University <strong>of</strong> Waterloo.<br />

1 Joseph Hanna<br />

2 Elaine Akers<br />

3 Sherif Guorgui<br />

4 Tracey Phillips<br />

5 Donald Organ<br />

6 Fayez Kosa<br />

7 Tracy Wiersema<br />

8 Saheed Rashid<br />

9 Bonnie Hauser<br />

10 Gerald Cook<br />

11 Christopher Leung<br />

12 Peter Gdyczynski<br />

13 Sanjiv Maindiratta<br />

14 Stephen Clement<br />

15 Gregory Purchase<br />

16 Doris Nessim<br />

17 Shelley McKinney<br />

PM Joinal Abdin<br />

PM Thomas Baulke<br />

PM Corazon dela Cruz<br />

PM Babek Ebrahimzadeh<br />

PM David H<strong>of</strong>f<br />

PM Margaret Irwin<br />

PM Javaid Khan<br />

PM Lewis Lederman<br />

PM Aladdin Mohaghegh<br />

PM Gitu Parikh<br />

DFP Wayne Hindmarsh<br />

DSP Jake Thiessen<br />

Statutory Committees<br />

• Executive<br />

• Accreditation<br />

• Complaints<br />

• <strong>Discipline</strong><br />

• Fitness to Practice<br />

• Patient Relations<br />

• Quality Assurance<br />

• Registration<br />

Standing Committees<br />

• Communications<br />

• Finance<br />

• Pr<strong>of</strong>essional Practice<br />

Special Committees<br />

• Standards <strong>of</strong> Practice Working Group<br />

• Pharmacy Technicians Working Group<br />

<strong>College</strong> Staff<br />

Office <strong>of</strong> the Registrar and Deputy Registrar/<br />

Director <strong>of</strong> Pr<strong>of</strong>essional Development<br />

Pharmacy Connection Editor x 241<br />

ltodd@ocpinfo.com<br />

Office <strong>of</strong> the Director <strong>of</strong> Finance<br />

and Administration x 263<br />

bhsu@ocpinfo.com<br />

Office <strong>of</strong> the Director <strong>of</strong><br />

Pr<strong>of</strong>essional Practice x 236<br />

sjackson@ocpinfo.com<br />

Registration Programs x 250<br />

jsantiago@ocpinfo.com<br />

Structured Practical Training Programs x 297<br />

vgardner@ocpinfo.com<br />

Investigations and Resolutions x 274<br />

cfernandes@ocpinfo.com<br />

Continuing Education Programs and<br />

Continuing Competency Programs x 273<br />

lsheppard@ocpinfo.com<br />

Pharmacy Openings/Closings,<br />

Pharmacy Sales/Relocation<br />

ocpclientservices@ocpinfo.com<br />

Registration and Membership Information:<br />

ocpclientservices@ocpinfo.com<br />

Pharmacy Technician Programs:<br />

ocpclientservices@ocpinfo.com<br />

Publications x 229<br />

spark@ocpinfo.com


contents<br />

Pr<strong>of</strong>ile <strong>of</strong> the Relief Pharmacist 6<br />

eHealth <strong>Ontario</strong> 8<br />

Report <strong>of</strong> the Geriatric and Long Term Care<br />

Review Committee to the Chief Coroner 10<br />

ISMP - <strong>Medication</strong> Safety in Long-Term Care 18<br />

regular features<br />

President’s Message 4<br />

Editor’s Message 5<br />

Practice Q&A 14<br />

Health Canada Notices 17<br />

Pharmacy Technician Q&A 20<br />

Close up on Complaints 22<br />

Bulletin Board 23<br />

SPT Q&A 24<br />

Deciding on <strong>Discipline</strong> 25<br />

Focus on Error Prevention - Ambiguous Prescriptions 28<br />

CE Resources 29<br />

Laws & Regulations 31<br />

pharmacyconnection<br />

March/April 2009 July • August Volume 200816 • Number Volume 215 • Number 4<br />

The objectives <strong>of</strong> Pharmacy Connection are to communicate information on <strong>College</strong> activities and policies; encourage dialogue and to discuss issues <strong>of</strong><br />

interest with pharmacists; and to promote the pharmacist’s role among our members, allied health pr<strong>of</strong>essions and the public.<br />

We publish six times a year, in January, March, May, July, September and November. We welcome original manuscripts (that promote the objectives <strong>of</strong> the<br />

journal) for consideration. The <strong>Ontario</strong> <strong>College</strong> <strong>of</strong> <strong>Pharmacists</strong> reserves the right to modify contributions as appropriate. Please contact the Associate Editor<br />

for publishing requirements.<br />

We also invite you to share your comments, suggestions, or criticisms by letter to the Editor. Letters considered for reprinting must include the author’s<br />

name, address and telephone number. The opinions expressed in this publication do not necessarily represent the views or <strong>of</strong>ficial position <strong>of</strong> the <strong>Ontario</strong><br />

<strong>College</strong> <strong>of</strong> <strong>Pharmacists</strong>.<br />

Tracy Wiersema, R.Ph., B.Sc.Phm.<br />

President<br />

Deanna Williams, R.Ph., B.Sc.Phm., C.Dir., CAE<br />

Registrar<br />

Della Croteau, R.Ph., B.S.P., M.C.Ed.<br />

Editor, Deputy Registrar,<br />

Director <strong>of</strong> Pr<strong>of</strong>essional Development<br />

dcroteau@ocpinfo.com<br />

Sue Rawlinson<br />

Associate Editor<br />

srawlinson@ocpinfo.com<br />

Agostino Porcellini<br />

Production & Design / Webmaster<br />

aporcellini@ocpinfo.com<br />

Neil Hamilton<br />

Distribution<br />

nhamilton@ocpinfo.com<br />

ISSN 1198-354X<br />

© 2009 <strong>Ontario</strong> <strong>College</strong> <strong>of</strong> <strong>Pharmacists</strong><br />

Canada Post Agreement #40069798<br />

Undelivered copies should be returned<br />

to the <strong>Ontario</strong> <strong>College</strong> <strong>of</strong> <strong>Pharmacists</strong>.<br />

Not to be reproduced in whole or in part<br />

without the permission <strong>of</strong> the Editor.


president’s message<br />

Tracy Wiersema, R.Ph., B.Sc. Phm.<br />

President<br />

Advocacy vs public interest<br />

Many members <strong>of</strong> the <strong>College</strong><br />

get confused about the role<br />

<strong>of</strong> the <strong>College</strong> in advocating<br />

for the pr<strong>of</strong>ession. The <strong>College</strong> has<br />

been established through government<br />

legislation to regulate the pr<strong>of</strong>ession in<br />

the best interest <strong>of</strong> the public. As such,<br />

the privilege <strong>of</strong> self regulation requires<br />

that all decisions be guided with public<br />

safety in mind. Our respective associations<br />

for hospital and community<br />

pharmacy, CSHP (<strong>Ontario</strong> Branch)<br />

and the <strong>Ontario</strong> <strong>Pharmacists</strong> Association,<br />

on the other hand, speak on behalf<br />

<strong>of</strong>, and advocate for the pharmacist and<br />

the pr<strong>of</strong>ession. Fortunately, many decisions<br />

that are in the best interest <strong>of</strong> the<br />

public are also in the best interest <strong>of</strong> the<br />

pr<strong>of</strong>ession <strong>of</strong> pharmacy.<br />

The current Health Pr<strong>of</strong>essions<br />

Regulatory Advisory Committee<br />

(HPRAC) submissions and reports<br />

are a good example <strong>of</strong> both public and<br />

advocacy interests being met. It is in<br />

the best interest <strong>of</strong> the public for pharmacists<br />

to be able to adapt, extend,<br />

and modify prescriptions and manage<br />

medication therapy in collaboration<br />

with other health care providers. It is<br />

also in the best interest <strong>of</strong> the pharmacist<br />

to take on this expanded role,<br />

to educate ourselves to provide medication<br />

therapy management, and to<br />

expand our role beyond dispensing <strong>of</strong><br />

medications, taking responsibility for<br />

patient outcomes.<br />

The role <strong>of</strong> the <strong>College</strong> will be to set standards for<br />

education and practice, and to have a system in place<br />

to ensure that pharmacists are carrying out these new<br />

roles safely and effectively for the public...<br />

If these new expanded roles get approved<br />

by government and legislation<br />

is put in place, the roles <strong>of</strong> the <strong>College</strong><br />

and the advocacy bodies will both be<br />

important, but different. The role <strong>of</strong><br />

the <strong>College</strong> will be to set standards for<br />

education and practice, and to have a<br />

system in place to ensure that pharmacists<br />

are carrying out these new roles<br />

safely and effectively for the public,<br />

that they are documenting their decisions<br />

and working collaboratively with<br />

other health care pr<strong>of</strong>essionals. The<br />

job <strong>of</strong> the advocacy bodies will be to<br />

promote the best use <strong>of</strong> the pharmacist,<br />

encourage and facilitate their education<br />

and training, and to advocate for<br />

their role in the workplace, not only<br />

from a scope and responsibility perspective,<br />

but also from a monetary<br />

perspective. Promotion <strong>of</strong> payment <strong>of</strong><br />

the pharmacist for these new roles will<br />

be up to the advocacy bodies in hospital<br />

and community who will represent<br />

the best interests <strong>of</strong> the pharmacists.<br />

Our pr<strong>of</strong>ession is healthier with<br />

both strong regulatory and strong advocacy<br />

bodies. Many <strong>of</strong> our goals, such<br />

as excellence in pharmacy practice,<br />

are aligned but it is important that the<br />

public interest and the interest <strong>of</strong> the<br />

pr<strong>of</strong>ession be represented by separate<br />

bodies, and that these roles be clearly<br />

distinguished for all stakeholders.<br />

4 pharmacyconnection • March/April 2009


editor’s message<br />

Della Croteau, R.Ph., B.S.P., M.C.Ed.<br />

Deputy Registrar/Director <strong>of</strong> Pr<strong>of</strong>essional Development<br />

Many pharmacists tell me<br />

that when they receive<br />

Pharmacy Connection,<br />

they turn right to the discipline cases<br />

to see who was disciplined and what<br />

they did wrong.<br />

In fact, only a very small portion <strong>of</strong><br />

reports and complaints ever go to discipline<br />

(less than 10%), and there are certainly<br />

some lessons to be learned by<br />

reading the discipline cases.<br />

If you are just reading the discipline<br />

cases in Pharmacy Connection, you<br />

are really missing out on all the practice<br />

information <strong>of</strong>fered to help you continually<br />

improve your practice. In this<br />

issue, the chair <strong>of</strong> the discipline committee<br />

has written an article to educate<br />

pharmacists about medication errors,<br />

and how to manage them so that they<br />

do not go forward to discipline. The<br />

<strong>College</strong> has published several articles<br />

from the Institute for Safe <strong>Medication</strong><br />

Practices Canada (ISMP) regarding<br />

Let us know what information is valuable to you,<br />

and what other ways the <strong>College</strong> can provide you<br />

with quality improvement information that<br />

supports your practice.<br />

medication incidents and how to prevent<br />

them. As well the focus on error<br />

prevention sites common practice<br />

errors and makes recommendations<br />

about how to prevent them from happening<br />

in the workplace.<br />

You will also see a report from<br />

ISMP examining the strengths and<br />

areas for improvement in long term<br />

care pharmacy practice. This report<br />

outlines a <strong>Medication</strong> Safety Self-Assessment<br />

(MSSA) designed specifically<br />

for multidisciplinary teams in long<br />

term care practice; a tool that you can<br />

take advantage <strong>of</strong> as a quality assurance<br />

measure. There are also considerations<br />

for the relief pharmacist<br />

and the pharmacy manager to ensure<br />

continuity <strong>of</strong> patient care and safety<br />

in the absence <strong>of</strong> regular staff. All <strong>of</strong><br />

these messages are for discussion and<br />

consideration within each pharmacy<br />

practice to ensure quality assurance<br />

<strong>of</strong> the procedures that are in place<br />

for safe and effective patient care by<br />

pharmacists and the pharmacy team.<br />

Each issue <strong>of</strong> Pharmacy Connection<br />

features a Pharmacy Practice Q&A reflecting<br />

common inquiries directed to<br />

our pharmacy practice area. There are<br />

also regular alerts from Health Canada<br />

to inform pharmacists about recalls or<br />

changes which might affect your patients<br />

directly.<br />

These and other articles are provided<br />

to update you with new developments<br />

in the pr<strong>of</strong>ession such as training<br />

requirements, regulation <strong>of</strong> pharmacy<br />

technicians, introduction <strong>of</strong> e-health<br />

initiatives, and to let you know about<br />

continuing education opportunities.<br />

Consider that reading Pharmacy Connection<br />

can be your quality assurance<br />

check on how to improve your practice,<br />

prevent common errors, and be prepared<br />

for future developments. We will<br />

be sending you an on-line questionnaire<br />

in mid-March to ask for your feedback<br />

on Pharmacy Connection. Let us know<br />

what information is valuable to you,<br />

and what other ways the <strong>College</strong> can<br />

provide you with quality improvement<br />

information that supports your practice.<br />

pharmacyconnection • March/April 2009<br />

5


elief pharmacist<br />

Pr<strong>of</strong>ile <strong>of</strong> the Relief<br />

Pharmacist<br />

Nadia Sutcliffe BScPhm, R.Ph.<br />

Inspector<br />

Due to sheer number <strong>of</strong> staffing shortages<br />

in <strong>Ontario</strong>’s numerous pharmacies,<br />

more and more pharmacies are<br />

turning to agencies or independent<br />

contractors to supply temporary or relief pharmacists to<br />

cover vacations, illnesses, and requests for time <strong>of</strong>f. There<br />

was a time when it was extremely difficult to find a licensed<br />

pharmacist for this purpose and many pharmacists went<br />

to work regardless <strong>of</strong> illness or did not take vacations. Depending<br />

on who you speak to, this situation still exists today.<br />

There are many pharmacists who do only relief work as a<br />

career choice. They enjoy the independence, flexibility <strong>of</strong><br />

shifts, travel, and variety <strong>of</strong> practices. For pharmacies needing<br />

permanent staff, this leaves a smaller pool <strong>of</strong> pharmacists<br />

to hire from, which creates staffing shortages.<br />

Most relief pharmacists are very pr<strong>of</strong>essional and take<br />

pride in their work. These practitioners are highly sought<br />

after and are <strong>of</strong>ten booked months or years in advance because<br />

<strong>of</strong> their stellar reputations. Nonetheless, some pharmacies<br />

have less than optimal experiences with relief personnel.<br />

There are stories <strong>of</strong> rudeness, lengthy personal conversations<br />

conducted on cell phones during shifts, arriving<br />

late -- or not at all, refusals to work in certain practices, and<br />

failing to counsel patients. These situations may be few and<br />

far between, but can be avoided altogether if proper steps<br />

6 pharmacyconnection • March/April 2009


are taken by all parties. Both the designated manager and<br />

relief pharmacist have specific responsibilities. They are<br />

encouraged to consult the Standards <strong>of</strong> Practice for Pharmacy<br />

Managers as well as the Standards <strong>of</strong> Practice to ensure<br />

maintenance <strong>of</strong> an ideal pr<strong>of</strong>essional working environment.<br />

The designated manager is responsible for the operation<br />

<strong>of</strong> the pharmacy. The credentials and references <strong>of</strong> any<br />

pharmacist who will be working in the dispensary should<br />

be checked – including those <strong>of</strong> relief pharmacists. The<br />

Standards <strong>of</strong> Practice for Pharmacy Managers (s.5.1) states:<br />

The manager is responsible for ensuring that all staff in the<br />

pharmacy is competent to perform duties defined by their<br />

position, including specialized functions. Certification <strong>of</strong><br />

staff may be required for some specialized functions. (Standard<br />

5.1)<br />

If the pharmacy engages in a practice which is not common<br />

to most retail pharmacies, such as a methadone maintenance<br />

program or specialty compounding, it is incumbent<br />

upon the manager to inform the relief pharmacist about this,<br />

and ensure that he or she is properly trained for, and comfortable<br />

dispensing in, these situations. It would be wise to<br />

have your pharmacy’s policies and procedures in writing, including<br />

what is expected from the staff in terms <strong>of</strong> pr<strong>of</strong>essional<br />

duties; for example, mandatory patient counselling<br />

and documentation <strong>of</strong> dialogue. The manager should also<br />

determine the relief pharmacist’s experience on the store’s<br />

computer system and provide sufficient support staff to ensure<br />

that the dispensary runs smoothly.<br />

<strong>Pharmacists</strong> working relief have certain obligations. It is<br />

incumbent upon them to learn the specifics <strong>of</strong> where they<br />

will be working, such as location, hours <strong>of</strong> operation and<br />

any specialty practices in which the pharmacist would be<br />

expected to engage which require specific training, such as<br />

the provision <strong>of</strong> methadone for MMT. A name tag or lab<br />

coat should be worn to help identify them as pharmacists,<br />

especially if the patients will not know who they are. They<br />

have an obligation to the pharmacy and to the pr<strong>of</strong>ession<br />

to uphold the standards <strong>of</strong> practice. This includes proper<br />

counselling about prescription and over-the-counter medications,<br />

documentation <strong>of</strong> dialogue, and practising in a manner<br />

which puts patient safety first. The relief pharmacist<br />

should communicate with the staff any preferences he/she<br />

may have in terms <strong>of</strong> work practices in the dispensary – it<br />

is better to be up front and avoid any miscommunication.<br />

There have been anecdotal reports <strong>of</strong> an “I’m only here for<br />

the day” attitude demonstrated during interactions with patients<br />

and staff and in general behaviour. This type <strong>of</strong> behaviour<br />

reflects poorly on the entire pr<strong>of</strong>ession <strong>of</strong> pharmacy<br />

and can ruin the reputation <strong>of</strong> the pharmacy and, indeed,<br />

<strong>of</strong> the pharmacist. The relief pharmacist is an ambassador<br />

<strong>of</strong> sorts, and should do his or her best to project a positive<br />

image <strong>of</strong> the pharmacy. Being employed by the pharmacy,<br />

even for one day, mandates an obligation to uphold the standards<br />

<strong>of</strong> the pharmacy and the pr<strong>of</strong>ession.<br />

If a problem occurs, the designated manager should make<br />

every effort to address it directly with the relief pharmacist<br />

and/or their agency to inform them <strong>of</strong> the situation. The<br />

relief pharmacist should have the opportunity to learn from<br />

the experience and receive feedback, positive or negative,<br />

as would any regular staff.<br />

Relief pharmacists provide a valuable and much-needed<br />

service in our pr<strong>of</strong>ession. It is the duty <strong>of</strong> the designated<br />

manager to make available all the support that the relief person<br />

may require, and to ensure patient safety by checking<br />

the credentials <strong>of</strong> all staff in the pharmacy and setting policies<br />

and procedures which promote all the principles <strong>of</strong> our<br />

standards <strong>of</strong> practice. The relief pharmacist should act as an<br />

ambassador <strong>of</strong> the pharmacy pr<strong>of</strong>ession, remembering that<br />

the main objective is to serve the patients and ensure optimal<br />

patient care. By keeping both the standards <strong>of</strong> practice<br />

for pharmacists and the standards <strong>of</strong> practice for pharmacy<br />

managers in mind, relief pharmacists have the opportunity<br />

to uphold the pharmacy’s pr<strong>of</strong>essional image, and to ensure<br />

that patient safety and care levels remain constant, as they<br />

would with permanent pharmacy staff.<br />

pharmacyconnection • March/April 2009<br />

7


eHealth <strong>Ontario</strong><br />

The colleges <strong>of</strong> pharmacy, medicine and nursing are working with eHealth <strong>Ontario</strong> to enable two<br />

pilot projects in the province, one in Sault Ste. Marie and the other in Collingwood.<br />

<strong>Pharmacists</strong> are encouraged to subscribe to the eHealth <strong>Ontario</strong> electronic newsletter to keep<br />

informed on these pilots and other e-health initiatives which affect pharmacy practice.<br />

Visit http://www.ehealthontario.on.ca<br />

ePrescribing: A Way to Reduce Prescription<br />

<strong>Errors</strong> and Adverse Drug Events<br />

Group Health Centre in Sault Ste. Marie and Georgian<br />

Bay Family Health Team (GBFHT) in Collingwood<br />

will be participating in the Ministry <strong>of</strong> Health<br />

and Long-Term Care, eHealth Program’s ePrescribing<br />

demonstration project. ePrescribing is the electronic<br />

generation, authorization (signature) and<br />

transmission <strong>of</strong> prescriptions from doctors / prescribers<br />

to pharmacists / dispensers. Both locations<br />

are looking towards full deployment by April 2009.<br />

Dr. James Lane <strong>of</strong> the GBFHT says: “We are excited<br />

to be participating in the Early Adopters ePrescribing<br />

Project. It will insert local pharmacies and<br />

pharmacists into the circle <strong>of</strong> care and allow electronic<br />

communication <strong>of</strong> prescriptions between prescribers<br />

and pharmacists. The beneficiaries will be<br />

patients and families who will have access to better<br />

services sooner.<br />

With ePrescribing, drug prescriptions are no longer<br />

hand-written by physicians, decreasing the chance <strong>of</strong><br />

problems associated with legibility and manual data<br />

entry. This lowers the potential for dispensing errors,<br />

which can easily result in adverse drug reactions,<br />

unnecessary hospitalization and even death.<br />

In addition, pharmacists won’t need to retype paper<br />

prescriptions, eliminating another potential source for<br />

human error. As an added benefit, electronic delivery<br />

<strong>of</strong> prescriptions to pharmacists means less wait time<br />

for patients, since prescriptions may be filled before<br />

the patient even gets to the pharmacy.<br />

Informing a Provincial Solution and<br />

Regulatory Standards<br />

Each site is implementing a different solution based<br />

on their existing technology. The results and lessons<br />

learned, particularly the impact <strong>of</strong> electronic prescribing<br />

on physicians, pharmacists and patients, will<br />

be assessed and used to inform <strong>Ontario</strong>’s provincial<br />

ePrescribing solution.<br />

In addition, regulatory colleges such as the <strong>College</strong><br />

<strong>of</strong> Physicians and Surgeons <strong>of</strong> <strong>Ontario</strong>, the <strong>Ontario</strong><br />

<strong>College</strong> <strong>of</strong> <strong>Pharmacists</strong> and the <strong>College</strong> <strong>of</strong> Nurses <strong>of</strong><br />

<strong>Ontario</strong>, are being engaged to ensure participating<br />

physicians, pharmacists and nurse practitioners are<br />

able to meet their pr<strong>of</strong>essional requirements. The<br />

findings will be shared to help determine whether any<br />

changes to pr<strong>of</strong>essional practice regulations, standards<br />

and guidelines are needed.<br />

A provincial ePrescribing solution will dramatically<br />

reduce the 400,000 preventable reactions to medication<br />

estimated to occur each year in <strong>Ontario</strong>, 4,000<br />

<strong>of</strong> which result in death.<br />

Find out more about Group Health Centre at<br />

www.ghc.on.ca and Georgian Bay Family Health<br />

Team or visit their website at www.gbfht.ca.<br />

8 pharmacyconnection • March/April 2009


<strong>Ontario</strong>’s eHealth Strategy<br />

www.ehealthontario.on.ca.<br />

eHealth <strong>Ontario</strong> is a new agency that<br />

will play the leading role in harnessing<br />

technology to improve<br />

patient care and safety.<br />

We will deliver clear, measurable and transparent results<br />

for patients and will focus on excellence in customer service,<br />

which means ensuring that priority initiatives yield results for<br />

patients and that the services to support new electronic tools<br />

and information always meet customer needs.<br />

Driven and supported by the priorities <strong>of</strong> Government, the<br />

Strategy is focused on results for three clinical priorities:<br />

• Tools to control and manage diabetes more effectively to reduce<br />

associated complications and costs;<br />

• On-line management <strong>of</strong> prescription medications to minimize<br />

preventable adverse drug events; and<br />

• Reduced waits in <strong>Ontario</strong> emergency departments and the incidence<br />

<strong>of</strong> inpatients in acute care settings waiting for alternative levels <strong>of</strong> care.<br />

<strong>Pharmacists</strong>: Keep informed on the latest developments in <strong>Ontario</strong>’s ehealth strategy;<br />

subscribe to our newsletter by visiting: http://www.ehealthontario.on.ca<br />

pharmacyconnection • March/April 2009<br />

9


coroner’s report<br />

Eighteenth Annual Report <strong>of</strong> the Geriatric<br />

and Long Term Care Review Committee to the<br />

Chief Coroner for the Province <strong>of</strong> <strong>Ontario</strong><br />

SEPTEMBER 2008<br />

T<strong>of</strong> cases referred by coroners. The committee conducts<br />

he Geriatric and Long Term Care<br />

Review Committee <strong>of</strong> the Chief<br />

coroner for the Province <strong>of</strong> <strong>Ontario</strong><br />

has completed its review<br />

an independent review <strong>of</strong> the available records relevant to<br />

the specific case and prepares a final report which includes<br />

recommendations aimed towards the prevention <strong>of</strong> future<br />

deaths in similar circumstances. The recommendations<br />

are intended to promote discussion and initiate change.<br />

The following recommendations which may be relevant to<br />

pharmacy practice in geriatric and long term care are reprinted<br />

for your information; the complete report, including<br />

examples, can be found at http://www.mcscs.jus.gov.on.ca<br />

Medical / Nursing Management<br />

• Health care pr<strong>of</strong>essionals caring for elderly residents<br />

<strong>of</strong> long term care homes should be reminded that pain<br />

is one <strong>of</strong> the most common, treatable symptoms in the<br />

elderly. Some <strong>of</strong> the principles <strong>of</strong> good geriatric pain<br />

management include the following:<br />

a) Identification <strong>of</strong> the cause <strong>of</strong> the pain,<br />

b) Regular, not PRN administration <strong>of</strong> pain medications,<br />

beginning with non-narcotic medications such<br />

as Acetaminophen, followed by narcotic medications<br />

when and if the non-narcotic medications are no<br />

longer effective,<br />

c) Regular, ongoing, careful assessment <strong>of</strong> the pain, including<br />

titration <strong>of</strong> the dosage depending on the patient’s<br />

response,<br />

d) Standardized assessment <strong>of</strong> the patient’s pain including<br />

both typical (complaints <strong>of</strong> pain), and atypical<br />

(agitation, loss <strong>of</strong> appetite), symptoms and signs,<br />

e) Utilization <strong>of</strong> physiotherapists or occupational therapists<br />

on alternative positioning in chair or bed to<br />

maximize comfort.<br />

• Health care pr<strong>of</strong>essionals should be reminded that disease<br />

presentation in the elderly is frequently atypical<br />

and may vary greatly from patient to patient. A subtle<br />

change in a patient’s clinical status may well indicate that<br />

something serious is going on which may not be readily<br />

apparent. The underlying cause(s) <strong>of</strong> these atypical<br />

presentations may be missed if the investigator does not<br />

obtain an appropriate history, conduct a thorough examination,<br />

and judiciously utilize available laboratory and<br />

imaging resources.<br />

For example, the lack <strong>of</strong> fever is not uncommon in a severely<br />

septic elderly patient.<br />

• Health care pr<strong>of</strong>essionals and all long term care homes<br />

in the Province <strong>of</strong> <strong>Ontario</strong> should be reminded <strong>of</strong> the<br />

importance <strong>of</strong> providing basic care needs to ill, elderly<br />

residents no matter where the long term care home is<br />

located in the Province. This includes evidence based<br />

assessment, pain management, and management <strong>of</strong><br />

pressure ulcers. While some long term care homes located<br />

in remote northern communities may have limited<br />

resources to manage these needs, steps should be<br />

taken to ensure that the basic care needs <strong>of</strong> their residents<br />

are met.<br />

10 pharmacyconnection • March/April 2009


• Health care pr<strong>of</strong>essionals and all long term care homes<br />

in the Province <strong>of</strong> <strong>Ontario</strong> should be reminded <strong>of</strong> the<br />

importance <strong>of</strong> developing and utilizing a comprehensive<br />

care plan to prevent and manage pressure ulcers. Not<br />

only should the care plan utilize evidence based practices,<br />

but also it should include policies and procedures<br />

to systematize these practices whenever possible. The<br />

importance <strong>of</strong> involving the entire health care team, including<br />

physicians in the prevention and management <strong>of</strong><br />

pressure ulcers, cannot be overemphasized.<br />

Communication and Documentation<br />

• Health care pr<strong>of</strong>essionals should be reminded <strong>of</strong> the importance<br />

<strong>of</strong> keeping complete, comprehensive, and accurate<br />

progress notes regarding treatment decisions and<br />

assessments. Frequently, the Committee finds these<br />

notes to be absent, scanty, incomplete, irrelevant, inaccurate,<br />

and/or illegible. These notes should meaningfully<br />

reflect issues identified by all members <strong>of</strong> the health<br />

care team (including the family) and include the reason<br />

why certain treatments are/are not being done in relation<br />

to these issues.<br />

Institutions need to develop quality assurance programs<br />

in order to determine their level <strong>of</strong> compliance with these<br />

programs and to correct any deficiencies where present.<br />

• Health care pr<strong>of</strong>essionals should be reminded that family<br />

members are a vital member <strong>of</strong> the health care team.<br />

Family members’ concerns and observations should<br />

be acknowledged, taken seriously, and responded to<br />

in a timely fashion. The importance <strong>of</strong> documenting<br />

family interactions reflecting serious concerns cannot be<br />

overemphasized.<br />

• Health care pr<strong>of</strong>essionals should be reminded <strong>of</strong> the importance<br />

<strong>of</strong> good communication amongst ALL members<br />

<strong>of</strong> the health care team including family members<br />

in situations where a patient’s clinical condition suddenly,<br />

unexpectedly, and unexplainably changes, and/<br />

or when family members have expressed concerns regarding<br />

the patient’s clinical course. The importance<br />

<strong>of</strong> documenting the information communicated, and<br />

with whom the communication has occurred, cannot be<br />

overemphasized.<br />

• Health care pr<strong>of</strong>essionals should be reminded <strong>of</strong> the<br />

importance <strong>of</strong> communicating with patients, if competent,<br />

and/or family members and/or substitute decision<br />

makers, the need for various treatment modalities<br />

and what alternatives exist to the recommended<br />

treatment modalities. Documentation <strong>of</strong> the information<br />

exchange on the medical record should be<br />

mandatory.<br />

• Health care pr<strong>of</strong>essionals should be reminded <strong>of</strong> the importance<br />

<strong>of</strong> communication with families regarding severely<br />

behaviourally challenged demented elderly family<br />

members, especially about the potential risks and benefits<br />

<strong>of</strong> available treatment interventions including the use<br />

<strong>of</strong> psychotropic medications.<br />

• Health care pr<strong>of</strong>essionals and all long term care homes in<br />

the Province <strong>of</strong> <strong>Ontario</strong> should be reminded <strong>of</strong> the importance<br />

<strong>of</strong> good communication with family members<br />

during an outbreak situation when visiting restrictions<br />

are imposed. A plan <strong>of</strong> action should be in place to maximize<br />

communication during the outbreak.<br />

Use <strong>of</strong> Drugs in the Elderly<br />

• Health care pr<strong>of</strong>essionals should be reminded <strong>of</strong> the<br />

importance <strong>of</strong> ensuring that elderly patients who<br />

require opiates or other proconstipatory medications,<br />

are placed on a well defined bowel management<br />

protocol which includes careful monitoring to<br />

avoid the development <strong>of</strong> constipation and potential<br />

serious risk for the development <strong>of</strong> obstipation and<br />

obstruction.<br />

• Health care pr<strong>of</strong>essionals should be reminded that constipation<br />

is an almost always universal complication <strong>of</strong><br />

narcotic analgesics in the elderly. The development <strong>of</strong><br />

constipation should be anticipated and steps taken to<br />

prevent and manage it every time a prescription is written<br />

for a narcotic analgesic.<br />

• Health care pr<strong>of</strong>essionals should be reminded <strong>of</strong> the importance<br />

<strong>of</strong> ordering a serum albumin when assessing<br />

drug levels <strong>of</strong> highly protein bound medications such as<br />

Phenytoin Sodium.<br />

pharmacyconnection • March/April 2009<br />

11


pharmacy accreditation renewals 2009<br />

There has been no increase in Pharmacy fees for 2009<br />

Your annual pharmacy accreditation renewal fee <strong>of</strong> $810.31 * is due no later than<br />

May 10, 2009. Renewal forms will be mailed to each pharmacy by mid-March<br />

While the pharmacist annual renewal has moved online, the pharmacy accreditation renewal process remains paper-based.<br />

Why? The information on the accreditation renewal form and any changes made to it must be acknowledged, currently - by<br />

way <strong>of</strong> signature - by all Directors and the Designated Manager <strong>of</strong> each pharmacy.<br />

FEE PAYMENTS<br />

Annual Pharmacy Fees due May 10, 2009<br />

Pharmacy fees <strong>of</strong> $810.31 ($771.72 + $38.59 GST) must be<br />

received and/or postmarked no later than May 10.<br />

Paying by Cheque<br />

Make sure your cheque is signed and made payable to<br />

the <strong>Ontario</strong> <strong>College</strong> <strong>of</strong> <strong>Pharmacists</strong> or OCP in the amount<br />

<strong>of</strong> $810.31 ($771.72 + $38.59 GST). Please write your<br />

Pharmacy Accreditation number and Invoice number on<br />

the front <strong>of</strong> your cheque.<br />

NSF cheques are treated as late and incur both a late<br />

penalty fee and a $20 NSF service charge. All unsigned<br />

cheques will be returned for signature.<br />

Paying by Credit Card<br />

We accept payment by VISA, MasterCard or American<br />

Express. Enter your credit card number and the expiry date<br />

<strong>of</strong> your credit card in the box under Payment Information<br />

on your renewal form. Please be sure to sign the credit<br />

card section giving us authorization to process the credit<br />

card payment in the amount <strong>of</strong> $810.31.<br />

RECORDS UPDATE<br />

Updates are required for<br />

the following:<br />

• Which pharmacists<br />

(with and without<br />

signing authority), and<br />

technicians are practising<br />

at the pharmacy<br />

• Lock and leave practices<br />

• Methadone dispensing<br />

• Pharmacy website information<br />

• Indication <strong>of</strong> which <strong>of</strong> the <strong>College</strong>-approved Drug<br />

Information Services the pharmacy subscribes to<br />

As outlined in the Standards for Designated Managers,<br />

acknowledgement <strong>of</strong> all directors and designated<br />

managers is a requirement <strong>of</strong> every pharmacy when<br />

reporting a designated manager change. You can update<br />

this information on the renewal form or download the<br />

Acknowledgment/Change <strong>of</strong> Designated Manager form by<br />

clicking on the “college forms” link at the bottom <strong>of</strong> our<br />

home page at www.ocpinfo.com<br />

Once processed, the certificates <strong>of</strong> accreditation and<br />

income tax receipts are mailed to the Pharmacy.<br />

LATE PAYMENTS<br />

Late payments are subject to a late payment fee <strong>of</strong> $105<br />

($100 + $5 GST) (if paid within 30 days after the due date)<br />

or $157.50 (if paid more than 30 days after the due date).<br />

This includes cheques that are received early but postdated<br />

after May 10, 2009. Late payments are not processed until<br />

the late payment fee has been received.<br />

*All fees listed above include GST.<br />

For further information contact:<br />

Client Services at (416) 962-4861 Ext. 300 or by email at<br />

ocpclientservices@ocpinfo.com<br />

12 pharmacyconnection • March/April 2009


moving forward with technology<br />

With the successful launch <strong>of</strong> the Online Pharmacist Fee Renewal in January, we are<br />

monitoring member reaction to this new platform, as we continue to evaluate ways to<br />

improve <strong>College</strong> and Member processes through the use <strong>of</strong> technology.<br />

The online process has accelerated renewals significantly. We are pleased to report that<br />

as <strong>of</strong> February 19, 2009, 45% <strong>of</strong> pharmacists have completed Step 1 (the information<br />

renewal portion <strong>of</strong> their annual renewal), two thirds <strong>of</strong> which have also completed Step<br />

2 (payment). This compares very favourably to last year, when only 17% <strong>of</strong> pharmacists<br />

had completed their information renewal and payment as <strong>of</strong> the same date.<br />

Members share their first experience with<br />

the new online renewal process:<br />

“I called last week to complain about the new renewal process. I just completed it and<br />

it was really easy, so I wanted to apologize for complaining last week.”<br />

“Oh my goodness... I did it! I can’t wait to tell my grandson - he’ll be so proud <strong>of</strong> me.”<br />

“I’m uncomfortable with the new technology adopted by the college.... members should<br />

be given the choice to do their renewal online or by paper”.<br />

One member had Client Services walk him through the new online renewal process.<br />

Although he expressed his annoyance throughout the process, once he completed it, he<br />

said “This wasn’t so bad...now I’ll be able to help my wife complete her annual renewal !”.<br />

Stay tuned . . .<br />

We will continue to keep you informed about the success <strong>of</strong> this process as well<br />

as other initiatives the <strong>College</strong> is undertaking, to develop enhanced solutions<br />

through the use <strong>of</strong> technology.<br />

pharmacyconnection • March/April 2009<br />

13


practice Q&A<br />

Greg Ujiye, R.Ph., B.Sc.Phm.<br />

Pr<strong>of</strong>essional Practice Advisor<br />

QCan you clarify whether prescriptions and<br />

refills for all controlled substances expire or<br />

are no longer valid after one year, or only those for<br />

benzodiazepines and targeted substances?<br />

<strong>Pharmacists</strong> frequently ask for clarification on this issue. It<br />

is only prescriptions for benzodiazepines and targeted substances<br />

which expire or are no longer valid after one year<br />

from the date the prescription was written. In addition, refills<br />

are no longer valid if one year has elapsed from the time<br />

the prescription was written. It is important to emphasize<br />

that the year counts from the time the prescription was<br />

written by the prescriber and not from when the prescription<br />

was first dispensed.<br />

This requirement is found in s.52(c) <strong>of</strong> the Benzodiazepine<br />

and Targeted Substances Regulation. The Food and<br />

Drugs Regulation, Part G - Controlled Drugs places no such<br />

restriction or requirement on controlled drugs.<br />

QWhat is the difference between a controlled drug<br />

and a controlled substance?<br />

These terms are defined and discussed in two different<br />

Acts.<br />

A “controlled drug” is defined in the Food and Drugs Regulation,<br />

Part G – Controlled Drugs and is any drug (or preparation)<br />

listed in Parts I, II, and III <strong>of</strong> the Schedule to Part G.<br />

A “controlled substance” is defined in the Controlled<br />

Drugs and Substances Act (CDSA) and refers to any substance<br />

listed in Schedule I, II, III, IV, and V <strong>of</strong> the CDSA.<br />

These Schedules include controlled drugs, narcotics, benzodiazepines<br />

and targeted substances.<br />

The term “controlled substance” refers to all drugs and<br />

substances covered by the CDSA and encompass all activities<br />

related to the control <strong>of</strong> those drugs and substances.<br />

The definitions for “narcotic,” “benzodiazepine and targeted<br />

substance” are found in their specific regulation to<br />

the CDSA.<br />

QWe occasionally receive a notice that a physician<br />

is restricted from prescribing controlled drugs<br />

and narcotics. Does this include benzodiazepines and<br />

targeted substances?<br />

No. “Controlled drug” and “narcotic” are defined terms.<br />

In such cases the physician is restricted from prescribing<br />

controlled drugs listed in Parts I, II, and III <strong>of</strong> the Food and<br />

Drug Regulation, Part G-Controlled Drugs or narcotics found<br />

in the Schedule to the Narcotic Control Regulations. The<br />

physician is free to prescribe benzodiazepine and targeted<br />

substances. If the notice states the physician is restricted<br />

from prescribing controlled substances then the physician is<br />

not allowed to prescribe controlled drugs, narcotics, benzodiazepines<br />

or targeted substances.<br />

QWhere can I get a new narcotic register to record<br />

my controlled drug and narcotic purchases?<br />

<strong>Pharmacists</strong> can download new pages in either a PDF or<br />

Word document from the OCP website. Click on the menu<br />

bar item “<strong>College</strong> Forms” at the bottom <strong>of</strong> the webpage.<br />

Choose either the PDF or Word document <strong>of</strong> “Pharmacy<br />

Narcotic and Controlled Drug Register” on the screen that’s<br />

displayed.<br />

14 pharmacyconnection • March/April 2009


QTo fill or not to fill?<br />

To fill or not to fill? That is the question! What is the status <strong>of</strong> prescription refills when the prescribing physician is deceased<br />

or has moved away, or when the physician’s license has been suspended or revoked? The Practice Advisory staff continues<br />

to receive numerous inquiries regarding the status <strong>of</strong> prescription refills once the status <strong>of</strong> a physician’s license changes. The<br />

chart below provides some guidelines for action which may reduce confusion in the future.<br />

Physician Deceased<br />

Physician Moved<br />

Physician Retired<br />

Physician’s License<br />

Physician’s Licensed<br />

(out <strong>of</strong> Canada)<br />

Suspended<br />

Revoked<br />

• License not<br />

• License maintained<br />

maintained<br />

Refills are invalid<br />

Refills are invalid<br />

Refills valid for 1 year<br />

Refills are invalid<br />

Refills are invalid<br />

Use pr<strong>of</strong>essional<br />

Use pr<strong>of</strong>essional<br />

Any script written<br />

Any script written<br />

judgment**<br />

judgment<br />

prior to the date <strong>of</strong><br />

prior to the date <strong>of</strong><br />

suspension would be<br />

revocation would be<br />

valid.<br />

valid.<br />

Refer patient to new<br />

Refer patient to new<br />

physician or walk-in<br />

physician or walk-in<br />

Use pr<strong>of</strong>essional<br />

Use pr<strong>of</strong>essional<br />

clinic<br />

clinic<br />

judgment<br />

judgment<br />

Refer patient to new<br />

Refer patient to new<br />

physician or walk-in<br />

physician or walk-in<br />

clinic<br />

clinic<br />

• License not<br />

maintained<br />

Refills are invalid<br />

Use pr<strong>of</strong>essional<br />

judgment<br />

Refer patient to new<br />

physician or walk-in<br />

clinic<br />

** As summarized above, if the physician is deceased or if his or her license has been suspended or revoked; a pharmacist may<br />

use pr<strong>of</strong>essional judgment to determine when it is appropriate to provide a refill or direct the patient to consult another prescriber.<br />

Pr<strong>of</strong>essional judgment may be used where all reasonable options to obtain proper authorization have been exhausted. In order to<br />

ensure the continuity <strong>of</strong> patient care, and provided the patient’s condition appears stable. As always, pharmacists are accountable<br />

for their actions, and should document accordingly as per the Documentation Guidelines.<br />

pharmacyconnection • March/April 2009<br />

15


online survey<br />

Here’s your chance to<br />

Speak up about<br />

Pharmacy Connection!<br />

The Editor asks…<br />

“What do you REALLY THINK about your pr<strong>of</strong>ession’s journal?“<br />

We invite you to take a moment to complete a brief online survey to help the <strong>College</strong><br />

understand your thoughts, opinions, and reading habits <strong>of</strong> Pharmacy Connection – and your<br />

“wish list” too, as we look for ways to bring our members more practice-relevant information<br />

through this publication.<br />

Sample questions :<br />

• What articles do you find most interesting and valuable?<br />

• What topics would you like to read more about?<br />

• What improvements would you like to see in Pharmacy Connection?<br />

• Do you prefer to receive this publication in a print or electronic version?<br />

An invitation with a link to the survey will be emailed to you mid-March.<br />

Thank you –<br />

Your thoughts and suggestions will inform future editorial content, design and distribution.<br />

Survey highlights will be published in a future issue <strong>of</strong> Pharmacy Connection.<br />

16 pharmacyconnection • March/April 2009


health canada advisories & notices<br />

Feb 18, 2009<br />

Feb 17, 2009<br />

Feb. 17, 2009<br />

Jan 30, 2009<br />

Jan 13, 2009<br />

Jan 12, 2009<br />

Jan 7, 2009<br />

Jan 6, 2009<br />

Jan 5, 2009<br />

Biogen Idec Canada Inc., has updated the Tysabri product monograph with new information on Progressive<br />

Multifocal Leukoencephalopathy (PML). There have been 5 cases <strong>of</strong> PML reported in patients receiving<br />

Tysabri (natalizumab) as monotherapy.<br />

Health Canada is informing expectant mothers and women who are planning pregnancy taking the product<br />

PregVit Folic 5 and PregVit distributed by Duchesnay Inc. to check the product’s individual sealed packages.<br />

Reports related to incorrect packaging <strong>of</strong> some blister packs have been received by Health Canada; however<br />

no concerns have been raised regarding the tablets themselves.<br />

Health Canada is advising Canadian consumers and retailers to exercise caution when purchasing<br />

toothbrushes. Counterfeit toothbrushes falsely labeled as Colgate Massager, Colgate Navigator, Oral B<br />

Classic 40, Oral B Contura and Colgate 360 have been found on the Canadian market.<br />

Health Canada is advising consumers not to use 4 foreign products: Zhuang Tjar Gere, Zhixhue Capsules,<br />

Tonik Warisan Banjar and Healthily Slim. The unauthorized product Zhuang Tjar Gere, because it contains<br />

the undeclared prescription drugs sildenafil and tadalafil, and may cause serious cardiovascular side-effects.<br />

The unauthorized product Zhixhue Capsules manufactured by Vital Pharmaceutical Holdings Ltd., due to<br />

concerns <strong>of</strong> serious side- effects, including liver dysfunction. The unauthorized product Tonik Warisan<br />

Banjar, because it contains undeclared dexamethasone and may cause serious side-effects. The unauthorized<br />

product Healthily Slim, because it contains the undeclared prescription drug sibutramine, which should only<br />

be used under the supervision <strong>of</strong> a health care pr<strong>of</strong>essional.<br />

This is an update <strong>of</strong> important safety information on Botox and Botox Cosmetic (botulinum toxin type A) and<br />

the potential risk <strong>of</strong> serious adverse effects <strong>of</strong> muscle weakness remote to the site <strong>of</strong> injection, also referred<br />

to as possible distant spread <strong>of</strong> toxin.<br />

Novopharm Ltd., in consultation with Health Canada is recalling 3 lots <strong>of</strong> Dobutamine Hydrochloride<br />

Injection 250 mg/20ml, due to an error in the dosing range shown on the vial labels.<br />

Canadian healthcare pr<strong>of</strong>essionals and institutions are being provided with revised dosage conversion<br />

guidelines for switching patients from shorter acting opioid narcotics to fentanyl transdermal systems.<br />

Canadians are advised that healthcare pr<strong>of</strong>essionals and institutions have been sent the new guidelines<br />

Health Canada is reminding Canadians who are taking, or considering taking, the smoking-cessation aid<br />

Champix <strong>of</strong> important safety information for this product. Health Canada is also informing Canadians that<br />

it is in the process <strong>of</strong> further strengthening the labelling for the drug with respect to the risk <strong>of</strong> serious<br />

psychiatric adverse effects.<br />

PPC (Pharmaceutical Partners <strong>of</strong> Canada Inc.), in consultation with Health Canada is recalling Lot 7101490 <strong>of</strong><br />

Piperacillin/Tazobactam for Injection, 4.5 g/vial (DIN 02305615) due to the finding <strong>of</strong> the presence <strong>of</strong> foreign<br />

particulate matter in some vials from this lot.<br />

For complete information & electronic mailing <strong>of</strong> the Health Canada Advisories/Warnings/Notices subscribe online at:<br />

http://www.hc-sc.gc.ca/dhp-mps/medeff/index_e.html<br />

MedEffect e-Notice is the new name which replaces Health Canada’s Health_Prod_Info mailing list.<br />

The content <strong>of</strong> the e-notices you receive will remain the same and are now part <strong>of</strong> MedEffect, a new Health Canada Web site dedicated to<br />

adverse reaction information. MedEffect can be visited at www.hc-sc.gc.ca/dhp-mps/medeff/index_e.html<br />

Health Canada Notices are also linked under “Notices” on the OCP website: www.ocpinfo.com<br />

pharmacyconnection • March/April 2009<br />

17


18 pharmacyconnection • March/April 2009


continued on page 21<br />

pharmacyconnection • March/April 2009<br />

19


pharmacy technician Q&A<br />

Susan James<br />

Project Director, Pharmacy Technician Regulation<br />

QI am confused about the Bridging Education<br />

Program. I thought everyone had to complete<br />

it, but now I understand that some people will be<br />

exempted from it. How do I know if I qualify for an<br />

exemption, and how do I apply for one?<br />

The Bridging Education Program is proposed as a registration<br />

requirement for anyone who wants to become registered<br />

as a pharmacy technician and did not graduate from<br />

an education program accredited by the Canadian Council<br />

for Accreditation <strong>of</strong> Pharmacy Programs (CCAPP). Please<br />

note that CCAPP began to accredit pharmacy technician<br />

programs in 2008; therefore, graduates from any program<br />

prior to 2008 are required to complete the Bridging Program.<br />

A list <strong>of</strong> accredited schools and the dates <strong>of</strong> effectiveness<br />

are available on the OCP website under the Pharmacy<br />

Technician section. (www.ocpinfo.com>pharmacy<br />

technicians>CCAPP Accreditation)<br />

The Bridging Education Program consists <strong>of</strong> four continuing<br />

education courses: Pr<strong>of</strong>essional Practice, Pharmacology,<br />

Product Preparation and Drug Distribution, and a structured<br />

practical evaluation following the Drug Distribution<br />

course. Although each course must be completed by those<br />

required to do the Bridging Education Program, there will<br />

be a mechanism, called Prior Learning Assessment, available<br />

to allow individuals to demonstrate they already have<br />

the knowledge and skills that will be taught and evaluated in<br />

three <strong>of</strong> the four courses. Neither the Pr<strong>of</strong>essional Practice<br />

course nor the structured practical evaluation (following the<br />

Drug Distribution course) will be eligible for Prior Learning<br />

Assessment, which means that both will have to be completed<br />

by everyone.<br />

Once Prior Learning Assessment is available (it is anticipated<br />

by spring 2009), individuals will be able to review<br />

course materials to determine if they already possess<br />

the knowledge and skills needed to meet the course outcomes.<br />

Individuals who believe they have the necessary<br />

competencies will be required to register for each course,<br />

but may request a Prior Learning Assessment. The assessment<br />

will involve demonstration <strong>of</strong> the applicant’s knowledge<br />

and skills through an examination. Individuals who<br />

are successful will be considered to have met the course<br />

requirements. There is a course fee for Prior Learning Assessment,<br />

although it is typically less than a full course fee.<br />

Individuals who are unsuccessful with the assessment will<br />

be required to register and pay for the course again and successfully<br />

complete it.<br />

More details will be available as the process develops<br />

further. Be sure to sign up for e-mail notifications to stay<br />

informed. (www.ocpinfo.com > pharmacy technicians ><br />

Stay Informed)<br />

QThere are no Bridging Education Programs close<br />

to where I live. How am I supposed to complete<br />

the program when I already have a full-time job and a<br />

family to manage?<br />

The Bridging Education Program is still under development.<br />

The initial delivery <strong>of</strong> each course has been at a community<br />

college with a CCAPP-accredited pharmacy technician program;<br />

unfortunately, these are limited in number and not welldistributed<br />

across the province. As the program develops,<br />

there are two strategies that will be used to make it more<br />

accessible: satellite or affiliated delivery and on-line courses.<br />

The accredited programs will remain responsible for administration<br />

<strong>of</strong> the program, but will establish partnerships<br />

in communities throughout the province to <strong>of</strong>fer classroom<br />

delivery <strong>of</strong> the courses. Courses may be held at your local<br />

community college facility or any other setting that is suited<br />

for the course. For example, in some communities, satellite<br />

delivery has been established using classrooms at the<br />

local hospital. In all cases, registration for the course occurs<br />

through the accredited community college. A listing <strong>of</strong> the<br />

satellite and affiliated delivery sites is provided on the OCP<br />

20 pharmacyconnection • March/April 2009


website under the Bridging Program heading in the Pharmacy<br />

Technician section.<br />

Each <strong>of</strong> the courses will also be available on-line; it is anticipated<br />

by mid-2009. While most <strong>of</strong> the courses will be<br />

delivered completely on-line, at least one course (Product<br />

Preparation) will involve an on-site practical lab component.<br />

The accredited community colleges will be responsible,<br />

once again, for delivery <strong>of</strong> on-line courses and, as described<br />

above, will arrange for the practical lab component to be delivered<br />

in communities throughout the province. More details<br />

about on-line courses will be provided as they become<br />

available. Completion <strong>of</strong> the structured practical evaluation<br />

which follows the Drug Distribution course is being designed<br />

to take place at your worksite.<br />

continued from page 19<br />

pharmacyconnection • March/April 2009<br />

21


close up on complaints<br />

Do <strong>Medication</strong> <strong>Errors</strong> Result in a<br />

Referral to the <strong>Discipline</strong> Committee?<br />

TCommittee <strong>of</strong> the <strong>College</strong> and the factors that contribute to<br />

A MESSAGE FROM THE CHAIR OF THE DISCIPLINE COMMITTEE<br />

his is the first <strong>of</strong> a series <strong>of</strong> articles<br />

aimed at increasing pharmacists’<br />

understanding <strong>of</strong> the types <strong>of</strong> matters<br />

that are referred to the <strong>Discipline</strong><br />

the decision to refer a matter to discipline.<br />

In particular, this article discusses medication errors that<br />

are reported to the <strong>College</strong> as formal complaints.<br />

When a medication error is reported to the <strong>College</strong> as<br />

a formal complaint, the <strong>College</strong> investigates the matter by<br />

obtaining relevant documents from the pharmacy. The <strong>College</strong><br />

may also obtain statements from the parties named in<br />

the complaint. The <strong>College</strong> provides the pharmacist who is<br />

the subject <strong>of</strong> the complaint (“the Member”) with the opportunity<br />

to respond to the complaint by recounting their<br />

recollection <strong>of</strong> the event that resulted in the complaint.<br />

The results <strong>of</strong> the investigation, including the Member’s<br />

response, are placed before the Complaints Committee, one<br />

<strong>of</strong> two screening committees <strong>of</strong> the <strong>College</strong>. As a screening<br />

committee, the role <strong>of</strong> the Complaints Committee is to review<br />

the complaint, consider the submissions <strong>of</strong> the Member,<br />

consider or make all reasonable efforts to consider all<br />

records and documents it believes are relevant to the complaint<br />

and subsequently arrive at a disposition. The Complaints<br />

Committee in its deliberations recognizes that the<br />

cause <strong>of</strong> medication errors are <strong>of</strong>ten multi-factorial involving,<br />

but not limited to, prescription processing and dispensing<br />

procedures in place at the pharmacy, counselling issues,<br />

staff training and supervision.<br />

The Complaints Committee may arrive at a number <strong>of</strong><br />

dispositions. It may issue a written caution to the Member,<br />

require the Member to appear before it to be cautioned, suggest<br />

remediation that may assist the Member to overcome<br />

Sherif Guorgui<br />

any deficits in his or her practice or take any other action<br />

that is within its jurisdiction. The Complaints Committee<br />

may also refer a specified allegation <strong>of</strong> the Member’s pr<strong>of</strong>essional<br />

misconduct or incompetence to the <strong>Discipline</strong> Committee<br />

if the allegation is related to the complaint.<br />

Currently, the majority <strong>of</strong> complaints about medication<br />

errors are NOT referred to the <strong>Discipline</strong> Committee. As a<br />

matter <strong>of</strong> fact, in 2002, 17 <strong>of</strong> the 18 (94%) complaints about<br />

medication errors were referred to the <strong>Discipline</strong> Committee<br />

whereas between 2003 – 2008, only 7 out <strong>of</strong> a total<br />

<strong>of</strong> 42 (16%) complaints about medication errors were referred<br />

to the <strong>Discipline</strong> Committee. This change reflects a<br />

heightened desire on the part <strong>of</strong> the Complaints Committee<br />

to deal with complaints against Members about medication<br />

errors through remedial rather than punitive measures<br />

when it is satisfied the Member managed the incident<br />

in an ethical and appropriate manner that was in the best<br />

interest <strong>of</strong> the patient.<br />

Of particular interest to the Complaints Committee<br />

when it is reviewing a complaint about a medication error is<br />

whether the Member, after becoming aware that a medication<br />

error occurred, demonstrated insight into how the<br />

medication error occurred and took steps to prevent it from<br />

reoccurring. Also <strong>of</strong> interest to the Committee is whether<br />

the Member recognized his or her role in the medication<br />

error, whether the Member understood the medication involved<br />

in the error was a “red flag” drug that presented a<br />

greater risk for the commission <strong>of</strong> a medication error and,<br />

most importantly, what measures the Member took to act<br />

in the best interest <strong>of</strong> the patient to ensure that the patient<br />

did not continue to receive the wrong medication therapy.<br />

For example, when a Member deals with a medication<br />

error in a very transparent and expedient manner by taking<br />

22 pharmacyconnection • March/April 2009


measures such as calling the patient and disclosing what<br />

happened, apologizing for the error, notifying the prescriber<br />

and <strong>of</strong>fering to remedy the situation to the extent possible,<br />

the Committee is more likely to view the actions taken by<br />

the Member to be driven by a desire to act in the patient’s<br />

best interest.<br />

Conversely, when the Complaints Committee is confronted<br />

with information that suggests that the Member did<br />

not take reasonable and necessary steps to act in the best<br />

interest <strong>of</strong> the patient and may have actually taken steps<br />

or measures to “cover up” the medication error in order to<br />

protect his or her reputation or to avoid having a complaint<br />

made to the <strong>College</strong>, the Committee is likely to view the<br />

Member’s conduct as placing his or her needs ahead <strong>of</strong> the<br />

patient’s needs and a breach <strong>of</strong> trust in the therapeutic relationship.<br />

Matters containing this type <strong>of</strong> information are<br />

generally viewed by a panel <strong>of</strong> the Complaints Committee as<br />

being very serious and worthy <strong>of</strong> a referral to the <strong>Discipline</strong><br />

Committee. These referrals are generally accompanied by<br />

allegations <strong>of</strong> pr<strong>of</strong>essional misconduct against the Member<br />

characterized as being dishonest, dishonourable or unpr<strong>of</strong>essional<br />

and are commensurate with penalties that can be ordered<br />

by a panel <strong>of</strong> the <strong>Discipline</strong> Committee. <strong>Discipline</strong> proceedings<br />

are intended to serve as a specific deterrent to the<br />

Member and a general deterrent to the membership at large<br />

whereas dispositions made by the Complaints Committee<br />

are opportunities for the Member to be educated about or<br />

reminded <strong>of</strong> his or her pr<strong>of</strong>essional obligations.<br />

The Complaints Committee may also refer a matter to the<br />

<strong>Discipline</strong> Committee when it is <strong>of</strong> the opinion that a Member’s<br />

practice may place the public at risk or when the Member<br />

has been the subject <strong>of</strong> multiple complaints <strong>of</strong> a similar nature.<br />

In summary, a medication error on its own does not result<br />

in a referral to the <strong>Discipline</strong> Committee. Rather it is the<br />

failure on the part <strong>of</strong> the Member, after he or she learns <strong>of</strong><br />

the medication error, to demonstrate that he or she acted<br />

in a pr<strong>of</strong>essional, accountable and ethical manner with an<br />

understanding that the needs <strong>of</strong> the patient are primary in a<br />

pharmacist – patient relationship that may result in a referral<br />

to the <strong>Discipline</strong> Committee.<br />

bulletin board<br />

The <strong>College</strong> bid a fond farewell to Cheryl Fernandes-<br />

Stechishin, Administrative Assistant in the Investigations<br />

and Resolutions department. Cheryl had been with the <strong>College</strong><br />

since 2006 and has accepted a position in the Hearings<br />

Office with the <strong>Ontario</strong> <strong>College</strong> <strong>of</strong> Teachers.<br />

Lucy Wang, who has been providing services on a temporary<br />

basis, has recently joined the <strong>College</strong> in a permanent<br />

staff position in the Accounting department. Lucy had previously<br />

covered a maternity leave at the <strong>College</strong> and brings<br />

many years <strong>of</strong> accounting experience.<br />

Rahila Ovais recently joined the <strong>College</strong> as the part time<br />

Administrative Assistant in the Continuing Competency<br />

program. Rahila has extensive experience working in community<br />

pharmacies as a pharmacy assistant.<br />

Katryna Spadafore recently joined the <strong>College</strong> as the Administrative<br />

Assistant in the Investigations and Resolutions<br />

department. Katryna graduated with her Bachelors degree<br />

in Health Sciences and comes to us from the Alberta <strong>College</strong><br />

<strong>of</strong> Occupational Therapists where she held the position<br />

<strong>of</strong> Registration Coordinator.<br />

pharmacyconnection • March/April 2009<br />

23


structured practical training Q&A<br />

Diana Spizzirri, R.Ph., B.Sc.Phm., M.Ed.<br />

Penny Tsang, R.Ph., B.Sc.Phm.<br />

Deanna S. Yee, R.Ph., B.Sc.Phm., M.Sc.<br />

Registration Advisors<br />

QI am a Canadian pharmacy graduate about to<br />

begin an <strong>Ontario</strong> hospital pharmacy residency.<br />

Will this residency count toward the <strong>College</strong>’s<br />

internship requirement? If so, do I need to register as<br />

an intern with the <strong>College</strong>?<br />

Revision <strong>of</strong> Q&A that appeared previously in March/April<br />

2006 issue <strong>of</strong> this publication<br />

The <strong>College</strong> strongly encourages <strong>Ontario</strong> hospital residents<br />

to register as pharmacy interns during their residency<br />

program. Registration as an intern is required for<br />

residents who wish to practise in a community pharmacy<br />

or in an accredited, out-patient hospital pharmacy. Registration<br />

as an intern allows a resident to perform the controlled<br />

acts <strong>of</strong> a pharmacist, as well as to use the protected<br />

title <strong>of</strong> “intern.”<br />

Hospital residencies in <strong>Ontario</strong> are one-year, post-graduate,<br />

clinical practice programs during which pharmacy<br />

graduates must successfully complete a variety <strong>of</strong> clinical<br />

and administrative rotations. Through these rotations,<br />

residents may demonstrate entry-to-practice competencies<br />

established by the National Association <strong>of</strong> Pharmacy<br />

Regulatory Authorities (NAPRA) which form the basis <strong>of</strong><br />

the SPT internship. Therefore, the <strong>College</strong> recognizes successful<br />

completion <strong>of</strong> hospital residency rotations in <strong>Ontario</strong><br />

as meeting the minimum 12 week SPT internship requirement<br />

provided these competencies are met.<br />

To receive credit for SPT internship, the resident must<br />

• submit an internship application form and the internship<br />

application fee before beginning the residency training<br />

period that is to be counted toward the minimum 12<br />

week SPT internship. The Residency Coordinator or<br />

the Pharmacy Manager/Director is generally listed as the<br />

preceptor on the application form.<br />

• successfully complete rotations in drug distribution,<br />

pharmacy administration, drug information, and clinical<br />

practice, including the patient care activities assigned as<br />

part <strong>of</strong> the residency program in lieu <strong>of</strong> the SPT Internship<br />

activities.<br />

• complete the final SPT Internship self-assessment at the<br />

end <strong>of</strong> the rotation.<br />

The preceptor must also complete a final SPT Internship<br />

assessment and the Declaration <strong>of</strong> Completion, confirming<br />

that the resident has demonstrated his/her competency and<br />

is ready to be registered as a pharmacist.<br />

QI am an international pharmacy graduate. I<br />

completed Structured Practical Training (SPT)<br />

studentship, and then started my internship over one<br />

year ago. After completing only eight <strong>of</strong> the 16 weeks<br />

<strong>of</strong> internship training, I had to go back to my home<br />

country for personal reasons. I have now returned<br />

to <strong>Ontario</strong> to complete my internship and to become<br />

licensed as a pharmacist. Can I resume where I left<br />

<strong>of</strong>f and complete the remaining eight weeks?<br />

The amount <strong>of</strong> training you require to become registered as<br />

a pharmacist in <strong>Ontario</strong> will depend on several factors. Since<br />

you must be registered as a pharmacist within three years<br />

<strong>of</strong> beginning your SPT, staff will first check the start date<br />

<strong>of</strong> your training to see if your registration status is still valid.<br />

SPT staff will then review the assessments you and your<br />

preceptor completed and submitted during your first eight<br />

weeks <strong>of</strong> internship to determine if you have been given<br />

credit for the training you completed (i.e., two four-weeklong<br />

assessment periods). If it appears that you were at<br />

the expected level <strong>of</strong> competency, you may be required to<br />

complete a minimum <strong>of</strong> eight more weeks <strong>of</strong> SPT internship.<br />

The remaining training time could in actuality be longer,<br />

because successful completion <strong>of</strong> SPT is based on demonstration<br />

<strong>of</strong> your competency, not just length <strong>of</strong> training.<br />

Since there was a significant gap in your training, you may<br />

need more time than the minimum to re-familiarize yourself<br />

with pharmacy practice in <strong>Ontario</strong> and to demonstrate<br />

your entry-to-practice competency.<br />

OCP staff will also check the validity <strong>of</strong> your language<br />

pr<strong>of</strong>iciency test scores. Since test scores are only valid for<br />

two years, you may need to submit current, acceptable fluency<br />

test scores or other non-objective evidence <strong>of</strong> your<br />

continued fluency to a Panel <strong>of</strong> the Registration Committee.<br />

Panels would require evidence that you have maintained<br />

your English or French pr<strong>of</strong>iciency.<br />

There are factors to consider before making a decision<br />

about your remaining training time. If there are any concerns<br />

about your continued competency, your application<br />

may be referred to a Panel <strong>of</strong> the Registration Committee<br />

for a decision on your remaining training requirements.<br />

24 pharmacyconnection • March/April 2009


deciding on discipline<br />

Case 1<br />

Dispensing without authorization;<br />

record keeping discrepancies<br />

Member: Helen Huh<br />

Pharmacy: MediSystem Inc., Toronto<br />

Hearing Date: December 4, 2008<br />

Facts<br />

This case proceeded by way <strong>of</strong> Agreed<br />

Statement <strong>of</strong> Facts and Joint Submission<br />

on Penalty.<br />

Ms. Huh was the Designated<br />

Manager <strong>of</strong> MediSystem (“the Pharmacy”),<br />

which currently provides<br />

pharmacy services to approximately<br />

165 long-term care homes which have<br />

approximately 17,318 beds. At all material<br />

times, the Pharmacy was partly<br />

owned and directed by Gary Chin. Mr.<br />

Chin was the Designated Manager <strong>of</strong><br />

the Pharmacy from July 1999 to February<br />

2001.<br />

This case concerned prescription<br />

services provided to five residents <strong>of</strong><br />

<strong>College</strong> Gardens, a non-registered<br />

long-term residential care facility providing<br />

residential facilities to a small<br />

number <strong>of</strong> individuals <strong>of</strong> varying ages<br />

with mental illness. <strong>College</strong> Gardens<br />

was owned by the same individual<br />

who owned Fairview Nursing Home,<br />

a registered long-term care facility.<br />

MediSystem entered into an agreement<br />

with Fairview Nursing Home to<br />

provide pharmacy services to its residents,<br />

as well as to those <strong>of</strong> <strong>College</strong><br />

Gardens.<br />

The <strong>College</strong> received a complaint<br />

from an <strong>Ontario</strong> physician regarding<br />

her patient D.B., a 76-year-old woman<br />

diagnosed with schizophrenia. D.B.<br />

was a resident <strong>of</strong> <strong>College</strong> Gardens<br />

who had recently become a patient <strong>of</strong><br />

the physician. The physician was concerned<br />

that the Pharmacy had been<br />

dispensing prescription drugs, including<br />

Isotamine, for D.B. for approximately<br />

seven years without any apparent<br />

prescription authorization or ongoing<br />

monitoring <strong>of</strong> the patient or her use <strong>of</strong><br />

these drugs.<br />

In the course <strong>of</strong> investigating the<br />

complaint, it appeared to the <strong>College</strong><br />

that there were other dispensing<br />

irregularities in relation to other residents<br />

<strong>of</strong> <strong>College</strong> Gardens. A further<br />

investigation was therefore carried out.<br />

That investigation revealed dispensing<br />

irregularities concerning four additional<br />

<strong>College</strong> Gardens residents.<br />

If she were to testify, Ms. Huh<br />

would explain that she understood that<br />

the Pharmacy would dispense medication<br />

to residents <strong>of</strong> <strong>College</strong> Gardens<br />

in accordance with the terms <strong>of</strong> the<br />

arrangement between the Pharmacy<br />

and both Fairview Nursing Home and<br />

<strong>College</strong> Gardens. Ms. Huh would testify<br />

that she understood that residents<br />

<strong>of</strong> <strong>College</strong> Gardens would be cared for<br />

by Fairview Nursing Home’s medical<br />

director and nursing staff, and that<br />

any authorized prescriptions for residents<br />

<strong>of</strong> <strong>College</strong> Gardens would be<br />

communicated to the Pharmacy by the<br />

prescribing doctor, or a nurse acting as<br />

agent for that doctor, by telephone or<br />

facsimile.<br />

If she were to testify, Ms. Huh<br />

would explain that as a result <strong>of</strong> the<br />

terms <strong>of</strong> the Pharmacy’s arrangement<br />

with Fairview Nursing Home and <strong>College</strong><br />

Gardens, Mr. Chin’s assurances,<br />

and the random reviews she conducted<br />

<strong>of</strong> the Pharmacy’s records to ensure<br />

the Pharmacy obtained copies <strong>of</strong> any<br />

necessary documents related to the<br />

residents <strong>of</strong> <strong>College</strong> Gardens, Ms. Huh<br />

believed at all times that she and the<br />

Pharmacy were authorized to dispense<br />

the medications at issue.<br />

If she were to testify, Ms. Huh<br />

would state that any inaccuracies in<br />

the Pharmacy’s records relating to patients<br />

<strong>of</strong> <strong>College</strong> Gardens were the<br />

result <strong>of</strong> human error or technological<br />

error, both <strong>of</strong> which were beyond<br />

Ms. Huh’s control. She would further<br />

state that the prescriptions which are<br />

the subject <strong>of</strong> these allegations account<br />

for only 0.0002% <strong>of</strong> the prescriptions<br />

filled by the Pharmacy during<br />

this timeframe.<br />

If she were to testify, Ms. Huh<br />

would describe changes that have<br />

been made at the Pharmacy as a result<br />

<strong>of</strong> these proceedings to reduce the<br />

possibility that any future discrepancies<br />

might arise. These changes include<br />

reconfirming authorizations received<br />

from any rest, retirement or<br />

group home; ensuring quarterly medication<br />

reviews are conducted for all<br />

residents; and flagging three-month<br />

review dates in the Pharmacy’s computer<br />

system.<br />

Admission <strong>of</strong> Pr<strong>of</strong>essional<br />

Misconduct<br />

The Member pleaded guilty to various<br />

acts <strong>of</strong> pr<strong>of</strong>essional misconduct<br />

which occurred while she was acting as<br />

the Designated Manager <strong>of</strong> the Pharmacy,<br />

including dispensing drugs without<br />

prescriptions or other authorizations<br />

to various patients between May<br />

2004 to September 2004; dispensing<br />

Isotamine to D.B.; and discrepancies in<br />

record keeping relating to five different<br />

patients during the period May 2004 to<br />

pharmacyconnection • March/April 2009<br />

25


deciding on discipline<br />

September 2004. The Member admitted<br />

that her conduct would reasonably<br />

be regarded by members <strong>of</strong> the pr<strong>of</strong>ession<br />

as disgraceful, dishonourable<br />

and/or unpr<strong>of</strong>essional. The Panel accepted<br />

the Member’s plea to these allegations<br />

and accepted the parties’ joint<br />

submission to withdraw the remaining<br />

allegations.<br />

Decision and Reasons<br />

The Panel was presented with an<br />

Agreed Statement <strong>of</strong> Facts for Sanction,<br />

and a Joint Submission on Penalty,<br />

as well as four precedent cases.<br />

There was no case presented which<br />

was directly on point.<br />

The Panel was particularly troubled<br />

by the Member’s apparent failure to<br />

understand and/or take seriously her<br />

obligations as Designated Manager <strong>of</strong><br />

the pharmacy in question. The Panel<br />

was comforted by the fact that the<br />

Member has accepted responsibility<br />

for her actions, and co-operated fully<br />

in the <strong>College</strong>’s investigation. However,<br />

the Panel was loath for this case<br />

to be perceived as being primarily one<br />

<strong>of</strong> record keeping. The case goes much<br />

deeper than that, and had potential for<br />

real impact on patient care.<br />

The Panel was mindful <strong>of</strong> the obligations<br />

<strong>of</strong> the Member to the public<br />

in protecting public safety. The Panel<br />

found <strong>of</strong>fensive the statistic presented<br />

that the underlying problematic prescriptions<br />

constituted only 0.0002%<br />

<strong>of</strong> the total prescriptions <strong>of</strong> the Pharmacy<br />

during the timeframe <strong>of</strong> the investigation.<br />

The Member had an obligation<br />

to ensure that not a single patient<br />

was exposed to potential harm,<br />

particularly in her role as Designated<br />

Manager.<br />

Order<br />

1. A reprimand.<br />

2. Specified terms, conditions, or limitations<br />

on Ms. Huh’s Certificate<br />

<strong>of</strong> Registration requiring her to<br />

complete successfully, at her own<br />

expense, within twelve months <strong>of</strong><br />

the date <strong>of</strong> this Order, remedial<br />

training as follows:<br />

a. CPS I Module 1: Pharmaceutical<br />

Care – Applied Therapeutics<br />

Lecture Series,<br />

b. CPS I Module 3: Basic Pr<strong>of</strong>essional<br />

Practice Labs; both from<br />

the Canadian Pharmacy Skills<br />

Program <strong>of</strong>fered through the<br />

Leslie Dan Faculty <strong>of</strong> Pharmacy<br />

at the University <strong>of</strong> Toronto, and<br />

c. the Jurisprudence seminar <strong>of</strong>fered<br />

by the <strong>College</strong>.<br />

3. A suspension <strong>of</strong> Ms. Huh’s Certificate<br />

<strong>of</strong> Registration for a period <strong>of</strong><br />

three months, with two months <strong>of</strong><br />

the suspension to be remitted on<br />

condition that the Member complete<br />

the remedial training exercises<br />

specified in paragraph 2 above;<br />

4. Costs to the <strong>College</strong> in the amount<br />

<strong>of</strong> $7,500.00.<br />

Reprimand<br />

The Panel was concerned and disappointed<br />

that for a pharmacist who<br />

has over 20 years <strong>of</strong> experience, and<br />

who has accepted the role and responsibilities<br />

<strong>of</strong> the Designated Manager,<br />

there would be such ongoing failure in<br />

record keeping practices, which could<br />

have resulted in serious harm to the patients<br />

impacted.<br />

The Panel was also troubled by Ms.<br />

Huh’s explanation that the prescriptions<br />

which were the subject <strong>of</strong> this<br />

hearing accounted for only 0.0002%<br />

<strong>of</strong> the prescriptions filled by the Pharmacy<br />

during the timeframe <strong>of</strong> the investigation.<br />

The Panel hoped that the<br />

Member understands that this statistic<br />

is <strong>of</strong> no value when it comes to abiding<br />

by the standards <strong>of</strong> practice and,<br />

most importantly, to ensuring patients’<br />

safety. The attempt to use these statistics<br />

to possibly minimize the magnitude<br />

and seriousness <strong>of</strong> the matter was<br />

very disturbing.<br />

With that being said, the Panel<br />

would like to acknowledge that the<br />

Member did cooperate with the <strong>College</strong><br />

throughout the investigation, and<br />

the Panel was also pleased to hear that<br />

the Member has already made changes<br />

to her practice to reduce the possibilities<br />

<strong>of</strong> such discrepancies in the future.<br />

The Panel trusted that Ms. Huh<br />

learned a valuable lesson throughout<br />

this process and that the remedial<br />

courses she will undertake will help<br />

her realize that this case was not about<br />

poor record keeping but about ensuring<br />

patients’ safety.<br />

Case 2<br />

Dispensing error<br />

Member: George Politis<br />

Pharmacy: Peoples Drug Mart, Toronto<br />

Hearing Date: December 18, 2008<br />

Facts<br />

This case proceeded by way <strong>of</strong> Agreed<br />

Statement <strong>of</strong> Facts and Joint Submission<br />

on Penalty. It concerned a dispensing<br />

error in which the pharmacy<br />

dispensed Apo-Prednisone 50mg to a<br />

patient instead <strong>of</strong> the Prandase 50mg<br />

26 pharmacyconnection • March/April 2009


which had been prescribed on a Limited<br />

Use form. The pharmacy had dispensed<br />

Prandase to the patient on a<br />

regular basis for several years, but had<br />

not previously dispensed prednisone to<br />

the patient. The threat <strong>of</strong> patient harm<br />

in this case was significant, as the patient<br />

was an elderly person with diabetes,<br />

and prednisone could cause his<br />

blood glucose to increase.<br />

Admission <strong>of</strong> Pr<strong>of</strong>essional<br />

Misconduct<br />

The Member admitted that he checked<br />

the label against the medication inside<br />

the vial and dispensed the medication.<br />

He also counseled the patient’s spouse.<br />

However, he did not check or compare<br />

the original Limited Use Prescription<br />

with either the tablets in the vial or the<br />

label on the vial.<br />

The Member acknowledged that<br />

he dispensed prednisone 50mg instead<br />

<strong>of</strong> the Prandase 50mg that had been<br />

prescribed. He acknowledged that he<br />

failed to properly check the prescription<br />

before the drug was dispensed. He<br />

also acknowledged that he should have<br />

made further inquiries about the medication<br />

in light <strong>of</strong> the patient’s diabetes<br />

and the possible effect <strong>of</strong> prednisone on<br />

that condition. The error was reflected<br />

in the records <strong>of</strong> the pharmacy.<br />

The Member pleaded guilty to allegations<br />

that he failed to maintain the<br />

standards <strong>of</strong> practice <strong>of</strong> the pr<strong>of</strong>ession,<br />

and that he breached sections 155 and<br />

156 <strong>of</strong> the Drug and Pharmacies Regulation<br />

Act.<br />

Decision and Reasons<br />

The Panel acknowledged that there<br />

were a number <strong>of</strong> mitigating factors<br />

in this matter, including that the<br />

Member cooperated with the <strong>College</strong>;<br />

the Member accepted responsibility by<br />

entering a guilty plea; the Member has<br />

taken steps to correct practice deficiencies<br />

within the pharmacy to avoid<br />

these types <strong>of</strong> problems; and the Member<br />

has already taken the remediation<br />

courses agreed to in the Joint Submission<br />

on Penalty.<br />

Nevertheless, there are aggravating<br />

factors in this case as well. The patient<br />

had been a patient <strong>of</strong> the pharmacy for<br />

some 25 years and had prior prescriptions<br />

for Prandase dating to 2002, but<br />

had never been prescribed prednisone.<br />

The nature <strong>of</strong> the medication and daily<br />

dose dispensed (a new medication to<br />

this patient) should have raised questions<br />

in the mind <strong>of</strong> the pharmacist and<br />

resulted in additional caution, particularly<br />

given the patient’s medical history.<br />

The pharmacist is ultimately responsible<br />

to ensure that the proper medication<br />

is dispensed. Had the very basic<br />

step <strong>of</strong> checking the dispensed medication<br />

against the original prescription<br />

documentation occurred, this error<br />

would likely have been prevented.<br />

Given that the Member had been cautioned<br />

by the Complaints Committee<br />

about a separate dispensing error two<br />

months prior to the error at issue in this<br />

case, the Member should have been<br />

far more cautious in his dispensing <strong>of</strong><br />

drugs.<br />

Order:<br />

5. A reprimand.<br />

6.Specified terms, conditions, or limitations<br />

on Mr. Politis’s Certificate<br />

<strong>of</strong> Registration requiring him to<br />

complete successfully, at his own<br />

expense, within six months <strong>of</strong> the<br />

date <strong>of</strong> the Order, remedial training<br />

as follows:<br />

(a) “Confronting <strong>Medication</strong> Incidents”<br />

<strong>of</strong>fered through the <strong>Ontario</strong><br />

<strong>Pharmacists</strong>’ Association,<br />

and<br />

(b) “Root Cause Analysis” <strong>of</strong>fered<br />

through the Institute for Safe<br />

<strong>Medication</strong> Practices.<br />

7. A suspension <strong>of</strong> Mr. Politis’s Certificate<br />

<strong>of</strong> Registration for a period<br />

<strong>of</strong> two months, with one month <strong>of</strong><br />

the suspension to be remitted on<br />

condition that the Member complete<br />

the remedial training exercises<br />

specified in paragraph 2 above.<br />

8. Costs to the <strong>College</strong> in the amount<br />

<strong>of</strong> $3,000.00.<br />

Reprimand<br />

The nature <strong>of</strong> the Member’s pr<strong>of</strong>essional<br />

misconduct was cause for great<br />

concern, as it related to public safety.<br />

The Member failed to conduct the<br />

most basic <strong>of</strong> pharmaceutical functions,<br />

namely the physical checking <strong>of</strong><br />

the prepared prescription against the<br />

original document. The public relies on<br />

the pharmacist to carry out this basic<br />

function to protect them.<br />

The Panel found the circumstances<br />

around the error to be disconcerting,<br />

as the Member knew the patient and<br />

his medication history and should have<br />

acted in his best interest.<br />

In light <strong>of</strong> the previous two medication<br />

errors, the Panel was hopeful the<br />

Member had learned from this experience<br />

and would not find himself before<br />

a Panel <strong>of</strong> the <strong>Discipline</strong> Committee<br />

again. The Panel trusted that the<br />

Member would use this experience to<br />

become a more conscientious pharmacist<br />

through the course work he had already<br />

undertaken.<br />

pharmacyconnection • March/April 2009<br />

27


focus on error prevention<br />

Ian Stewart, R.Ph., B.Sc.Phm<br />

Toronto Community Pharmacist<br />

Ambiguous Prescriptions<br />

prescription, the pharmacist identified the computer entry<br />

error and corrected the instructions to read “one drop into<br />

the right eye twice daily”.<br />

Key contributing factor:<br />

Misinterpretation <strong>of</strong> the abbreviation “OD”.<br />

<strong>Pharmacists</strong> <strong>of</strong>ten receive prescriptions that may be<br />

misinterpreted due to their ambiguity. The following<br />

three cases have been reported.<br />

Case 3<br />

Case 1<br />

The above prescription was presented to a pharmacy<br />

technician at a community pharmacy. The prescription<br />

was interpreted and entered as Topicort® Cream (regular<br />

strength) to be applied twice daily. Thirty grams were then<br />

weighed, labelled and given to the pharmacist for checking.<br />

On checking the prescription, the pharmacist observed<br />

that the strength <strong>of</strong> the cream prepared was actually 0.25%<br />

desoximetasone instead <strong>of</strong> the 0.05% prescribed, which is<br />

the strength <strong>of</strong> Topicort® Mild Cream.<br />

Key contributing factor:<br />

The word “Mild” was omitted when writing the name <strong>of</strong><br />

the drug.<br />

Case 2<br />

The instructions for using the above ophthalmic drops<br />

were entered into the computer as “one drop into the affected<br />

eye once or twice daily”. However, on checking the<br />

The above prescription was initially entered into the computer<br />

as Valproic Acid. However, the pharmacist later contacted<br />

the prescriber who confirmed that he intended to<br />

prescribe divalproex sodium.<br />

Key contributing factor:<br />

The names <strong>of</strong> two different drugs that are not interchangeable<br />

were written on this prescription.<br />

Recommendations:<br />

• Always contact the prescriber to confirm/clarify prescriptions<br />

that may be misinterpreted due to ambiguity.<br />

• Use the patient’s medication history as a tool to clarify or<br />

confirm ambiguous prescriptions.<br />

• Consider the usual dosage and dosing interval <strong>of</strong> the drug<br />

being dispensed.<br />

• Educate all pharmacy staff about problematic abbreviations<br />

that may be misinterpreted. An extensive list may be<br />

accessed at http://www.ismp.org/PDF/ErrorProne.pdf .<br />

• Ensure that all staff are aware <strong>of</strong> problematic drug pairs<br />

<strong>of</strong>ten involved in medication errors.<br />

Please continue to send reports <strong>of</strong> medication errors in confidence<br />

to Ian Stewart at: ian.stewart2@rogers.com .<br />

28 pharmacyconnection • March/April 2009


CE resources<br />

Visit the <strong>College</strong>’s website: www.ocpinfo.com for a complete listing <strong>of</strong> upcoming events and/or<br />

available resources. A number <strong>of</strong> the programs listed below are also suitable for pharmacy technicians.<br />

GTA<br />

March 27-29, 2009<br />

Diabetes Certificate Program<br />

<strong>Ontario</strong> <strong>Pharmacists</strong>’ Association<br />

Toronto, ON<br />

Contact: Penny Young<br />

Email: pyoung@dirc.ca<br />

Tel: 416-441-0788 ext. 2209<br />

March 28, 2009<br />

Fundamentals <strong>of</strong> Buprenorphine<br />

Maintenance Treatment<br />

Centre for Addiction and Mental<br />

Health (CAMH)<br />

Toronto, ON<br />

Contact: Robyn Steidman @ 416-<br />

535-8501, ext. 6640<br />

Alternate Tel: 1 800 661-1111<br />

April 3, 2009<br />

Diabetes Update 2009 (course<br />

code BDC0901)<br />

Banting and Best Diabetes Centre,<br />

University <strong>of</strong> Toronto<br />

Metro Toronto Convention Centre,<br />

Toronto, ON<br />

Web: www.cme.utoronto.ca<br />

Fax: 416-946-7028<br />

April 17-19, 2009<br />

Cardiovascular Certificate<br />

Program<br />

<strong>Ontario</strong> <strong>Pharmacists</strong>’ Association<br />

Toronto, ON<br />

Contact: Penny Young<br />

Email: pyoung@dirc.ca<br />

Tel: 416-441-0788 ext. 2209<br />

April 25, 2009<br />

Obesity Level II Certificate<br />

Program<br />

<strong>Ontario</strong> <strong>Pharmacists</strong>’ Association<br />

Toronto, ON<br />

Contact: Penny Young<br />

Email: pyoung@dirc.ca<br />

Tel: 416-441-0788 ext. 2209<br />

April 25 and May 9, 2009<br />

Opioid Dependence Treatment<br />

Core Education Program<br />

CAMH Online modules and live<br />

workshop<br />

Toronto, ON<br />

Contact: Robyn Steidman @ 416 535-<br />

8501, ext. 6640<br />

Alternate Tel: 1-800-661-1111<br />

May 2, 2009<br />

Clinical Workshop – Presentation<br />

Skills<br />

Toronto, ON<br />

Contact: Penny Young<br />

Email: pyoung@dirc.ca<br />

Tel: 416-441-0788 ext. 2209<br />

May 3, 2009<br />

Clinical Workshop –<br />

Communication Skills<br />

Toronto, ON<br />

Contact: Penny Young<br />

Email: pyoung@dirc.ca<br />

Tel: 416-441-0788 ext. 2209<br />

May 23 and 24 2009<br />

Infectious Diseases Certificate<br />

Program<br />

Toronto, ON<br />

Contact: Penny Young<br />

Email: pyoung@dirc.ca<br />

Tel: 416-441-0788 ext. 2209<br />

May 25-27, 2009<br />

A Comprehensive Course on<br />

Smoking Cessation: Essential<br />

Skills and Strategies<br />

Training Enhancement in Applied<br />

Cessation Counselling and Health<br />

(TEACH Core course)<br />

Toronto, ON<br />

Contact: teach@camh.net or call<br />

416-535-8501 ext.1600<br />

May 28-29, 2009<br />

Tobacco Cessation with<br />

Aboriginal Populations<br />

Training Enhancement in Applied<br />

Cessation Counselling and Health<br />

(TEACH Specialty course)<br />

Toronto, ON<br />

Contact: teach@camh.net or call<br />

416-535-8501 ext.1600<br />

May 28-29, 2009<br />

Implementing a Systematic<br />

Approach to Tobacco Dependence<br />

Treatment for Hospitalized<br />

Smokers: The Ottawa Mode<br />

Training Enhancement in Applied<br />

Cessation Counselling and Health<br />

(TEACH Specialty course)<br />

Toronto, ON<br />

Contact: teach@camh.net or call<br />

416-535-8501 ext.1600<br />

CANADA<br />

May 5 and 6, 2009<br />

Advancing Safe <strong>Medication</strong><br />

Practices<br />

Institute for Safe <strong>Medication</strong><br />

Practices Canada<br />

Kelowna, BC<br />

Contact: conferences@ismp-canada.<br />

org<br />

Tel: 1-866-544-7672 ext. 226<br />

continued on page 30<br />

pharmacyconnection • March/April 2009<br />

29


CE resources<br />

May 30 - June 2, 2009<br />

Canadian <strong>Pharmacists</strong><br />

Association (CPhA) Annual<br />

National Conference<br />

Halifax, Nova Scotia<br />

Web: www.pharmacists.ca<br />

E-mail: meetings@pharmacists.ca<br />

Tel 1-800-917-9489 / 1-613-523-7877<br />

INTERNATIONAL<br />

asp?teleconferenceID=50<br />

High Alert <strong>Medication</strong> Series: Part<br />

II: Reducing the Risk <strong>of</strong> Patient Harm<br />

from Anticoagulant Therapy<br />

Centre for Addiction and Mental<br />

Health (CAMH): April 6, 2009<br />

http://www.camh.net/education/<br />

Online_courses_webinars/index.<br />

html :<br />

Drug Information and Research<br />

Centre (DIRC)<br />

http://www.opacti.org/<br />

Online Clinical Tobacco<br />

Interventions for Health Care<br />

Pr<strong>of</strong>essionals<br />

http://www.pharmacygateway.com<br />

On-line CE lessons<br />

May 10 – 15, 2009<br />

Clinical Pharmacy in Primary<br />

Care, Prato, Italy<br />

Contact: Maria Bystrin @<br />

416-978-8458<br />

Email: cpd.pharmacy@utoronto.ca<br />

ON-LINE/ WEBINARS<br />

Institute for Safe <strong>Medication</strong><br />

Practice (ISMP) April 2009<br />

http://www.ismp.org/<br />

teleconferences/default.<br />

-Fundamentals <strong>of</strong> Addiction<br />

-Screening for concurrent disorders<br />

-Youth & Drugs and Mental health<br />

http://www.rxcertified.ca<br />

Online fee-based certificate courses<br />

developed by the Drug Information<br />

- Diabetes Patient Care Level 1<br />

- Obesity Program<br />

- Women’s Health program<br />

http://209.200.99.173/vitamin_D<br />

Vitamin D in Osteoporosis<br />

http://www.rxbriefcase.com/<br />

On-line CE lessons<br />

http://cpha.learning.mediresource.<br />

com/select_catalog.asp<br />

CE lessons on the CPhA Home<br />

Study Online Learning Centre<br />

30 pharmacyconnection • March/April 2009


laws & regulations<br />

Drug and Pharmacies Regulation Act (DPRA) * s<br />

Amended June 4, 2008<br />

Regulations to the DPRA:<br />

DPRA R.R.O. 1990, Regulation 545 – Child Resistant Packages<br />

DPRA <strong>Ontario</strong> Regulation 297/96 Amended to O.Reg. 173/08 – General<br />

DPRA R.R.O. 1990, Regulation 551 Amended to O.Reg. 172/08 – General<br />

Drug Schedules **<br />

Summary <strong>of</strong> Laws Governing Prescription Requirements,<br />

Transfers, Refills, Prescription Drug Ordering and Records<br />

June 2007 OCP<br />

Canada’s National Drug Scheduling System –<br />

February 20, 2009 NAPRA (or later)<br />

Regulated Health Pr<strong>of</strong>essions Act (RHPA) * s<br />

Amended November 27, 2008<br />

Regulations to the RHPA:<br />

<strong>Ontario</strong> Regulation 39/02 -Certificates <strong>of</strong> Authorization Amended to<br />

O.Reg. 666/05<br />

<strong>Ontario</strong> Regulation 107/96 – Controlled Acts<br />

<strong>Ontario</strong> Regulation 59/94 – Funding for Therapy or<br />

Counseling for Patients Sexually Abused by Members<br />

Pharmacy Act (PA) & Regulations * s<br />

Amended 2007<br />

Regulations to the PA:<br />

<strong>Ontario</strong> Regulation 202/94 Amended to O.Reg. 270/04 – General<br />

<strong>Ontario</strong> Regulation 681/93 Amended to O.Reg.<br />

122/97 – Pr<strong>of</strong>essional Misconduct<br />

Standards <strong>of</strong> Practice s<br />

Standards <strong>of</strong> Practice, January 1, 2003 OCP<br />

Standards <strong>of</strong> Practice for Pharmacy Managers, July 1, 2005<br />

Drug Interchangeability and Dispensing<br />

Fee Act (DIDFA) & Regulations * s<br />

Amended June 2007<br />

Regulations to the DIDFA:<br />

R.R.O. 1990 Regulation 935 Amended to O.Reg. 354/08 – General<br />

R.R.O. 1990 Regulation 936 Amended to O.Reg. 205/96 – Notice to Patients<br />

Food and Drugs Act (FDA) & Regulations ** '<br />

Updated as <strong>of</strong> January 28, 2009<br />

Amendment 1478 & 1491 – Addition <strong>of</strong> two medicinal ingredients<br />

to Part I <strong>of</strong> Schedule F. Reg. SOR/2007-224, Oct 25/07<br />

Amendment 1476, 1502, 1511 and 1512 –<br />

Addition <strong>of</strong> nine medicinal ingredients to Part I <strong>of</strong><br />

Schedule F. Reg SOR/2007-234, Oct 25/07<br />

Regulations Amending the Food and Drug Regulations (Project 1551<br />

- Lanthanum salts) (February 7, 2008)<br />

Controlled Drugs and Substances Act (CDSA) **<br />

Current as <strong>of</strong> January 28, 2009<br />

Regulations to the Controlled Drugs<br />

and Substances Act (CDSA) **<br />

All regulations updated January 28, 2009<br />

Benzodiazepines & Other Targeted Substances Regulations<br />

Marihuana Medical Access Regulations<br />

Precursor Control Regulations<br />

Regulations Exempting Certain Precursors and<br />

Controlled Substances from the Application <strong>of</strong><br />

the Controlled Drugs and Substances Act<br />

Narcotic Control Regulations **<br />

OCP By-Laws By-Law No. 1 – September 2008 s<br />

Schedule A - Code <strong>of</strong> Ethics for Members <strong>of</strong> the<br />

<strong>Ontario</strong> <strong>College</strong> <strong>of</strong> <strong>Pharmacists</strong> - December 2006<br />

Schedule B - “Code <strong>of</strong> Conduct” and Procedures for<br />

Council and Committee Members - December 2006<br />

Schedule C - Member Fees - Effective January 1, 2009<br />

Schedule D - Pharmacy Fees - Effective January 1, 2007<br />

Schedule E – Certificate <strong>of</strong> Authorization – Jan. 2005<br />

Schedule F - Privacy Code - Dec. 2003<br />

Reference s<br />

OCP Required Reference Guide for Pharmacies<br />

in <strong>Ontario</strong>, November, 2008<br />

<strong>Ontario</strong> Drug Benefit Act (ODBA) & Regulations * s<br />

Amended 2007<br />

Regulations to the ODBA:<br />

<strong>Ontario</strong> Regulation 201/96 Amended to O.Reg. 356/08 – General<br />

* Information available at Publications <strong>Ontario</strong> (416) 326-5300 or 1-800-668-9938 www.e-laws.gov.on.ca<br />

** Information available at www.napra.org<br />

' Information available at Federal Publications Inc. Ottawa: 1-888-4FEDPUB (1-888-433-3782)<br />

Toronto: Tel: (416) 860-1611 • Fax: (416) 860-1608 • e-mail: info@fedpubs.com<br />

s Information available at www.ocpinfo.com<br />

pharmacyconnection • March/April 2009<br />

31


March/April 2009 • Volume 16, Number 2

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