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Controlled Drugs Policy Clinical Policy CL060 - NHS County Durham

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Version Number:<br />

<strong>Controlled</strong> <strong>Drugs</strong> <strong>Policy</strong><br />

<strong>Clinical</strong> <strong>Policy</strong> <strong>CL060</strong><br />

Version 3, 13 th November 2009<br />

Issued date: 9 December 2009<br />

Review date: 9 December 2011<br />

Sponsoring Director: Director of <strong>Clinical</strong> Quality<br />

Prepared by: Senior Pharmaceutical Advisor<br />

Consultation Process: <strong>Drugs</strong> & Therapeutics Committee<br />

<strong>Policy</strong> Development Group<br />

Formally approved: December 2009<br />

<strong>Policy</strong> adopted from: National Prescribing Centre Guide to Good<br />

Practice in the Management of <strong>Controlled</strong> <strong>Drugs</strong><br />

in Primary Care (England)<br />

Approval given by: Director of <strong>Clinical</strong> Quality<br />

<strong>Drugs</strong> & Therapeutics Committee<br />

<strong>Policy</strong> Development Group<br />

POLICY VALIDITY STATEMENT<br />

This policy is due for review on the latest date shown above.<br />

After this date, policy and process documents may become invalid.<br />

<strong>Policy</strong> users should ensure that they are consulting the currently valid<br />

version of the documentation.


Document Information<br />

Document Title: <strong>Controlled</strong> <strong>Drugs</strong> <strong>Policy</strong><br />

Initial Issue: Version 1: 13 March 2008<br />

Document history<br />

Version Date Significant Changes<br />

2 30 June 2009 <strong>Policy</strong> has been significantly re-drafted<br />

3 13 Nov 2009 Contact names, SOPs and Audits updated<br />

Equality impact assessments:<br />

Date Issues<br />

18 August 2009<br />

There are no specific equality and diversity issues which arise within this policy<br />

document.


<strong>Controlled</strong> <strong>Drugs</strong> <strong>Policy</strong><br />

Contents<br />

Section Title Page<br />

1<br />

2<br />

3<br />

4<br />

5<br />

6<br />

7<br />

8<br />

9<br />

INTRODUCTION<br />

DEFINITIONS<br />

POLICY DETAIL<br />

DUTIES AND RESPONSIBILITIES<br />

IMPLEMENTATION<br />

TRAINING<br />

DOCUMENTATION<br />

MONITORING, REVIEW AND ARCHIVING<br />

IMPACT ASSESSMENTS<br />

Appendices to the <strong>Policy</strong><br />

1<br />

2<br />

3<br />

4<br />

5<br />

Relevant acts of parliament and regulations<br />

Accountable officer<br />

Monitoring and auditing the management and use of controlled<br />

drugs<br />

Possession of controlled drugs<br />

Purchasing and supply of controlled drugs<br />

6<br />

7<br />

7<br />

8<br />

9<br />

9<br />

9<br />

10<br />

11<br />

14<br />

18<br />

20<br />

24<br />

25<br />

2


6<br />

7<br />

8<br />

9<br />

10<br />

11<br />

12<br />

13<br />

14<br />

15<br />

16<br />

17<br />

18<br />

19<br />

20<br />

21<br />

22<br />

Preparation and administration of controlled drugs<br />

Prescribing of controlled drugs<br />

Prescribing in instalments<br />

Private prescriptions<br />

Prescriptions for prisoners and other agency agreements for <strong>NHS</strong><br />

services<br />

Storage of controlled drugs<br />

Dispensing of controlled drugs<br />

Recording of controlled drugs<br />

Transportation of controlled drugs<br />

Administration of controlled drugs<br />

Nurses working in the community<br />

Palliative care<br />

Self-medication<br />

Patients travelling overseas<br />

Destruction of controlled drugs 56<br />

Standard Operating Procedures 59<br />

Patient information<br />

28<br />

30<br />

35<br />

37<br />

39<br />

40<br />

43<br />

47<br />

50<br />

51<br />

52<br />

53<br />

54<br />

55<br />

60<br />

3


A<br />

B<br />

C<br />

D<br />

E<br />

F<br />

G<br />

H<br />

I<br />

J<br />

K<br />

L<br />

M<br />

N<br />

Appendices of Procedures<br />

List of <strong>Controlled</strong> <strong>Drugs</strong> and Their Schedules 61<br />

Summary of legal requirements of the possession and supply of<br />

<strong>Controlled</strong> <strong>Drugs</strong>.<br />

Relevant Contact Details regarding <strong>Controlled</strong> <strong>Drugs</strong><br />

Information Sharing Code in respect of the operation of the <strong>County</strong><br />

<strong>Durham</strong> and Darlington Local Intelligence Network for <strong>Controlled</strong><br />

<strong>Drugs</strong> governance<br />

<strong>Controlled</strong> <strong>Drugs</strong> Practice Declaration and Self Assessment Audit<br />

for GP Practices 2009/10<br />

<strong>Controlled</strong> Drug Personal Declaration and Self Assessment Audit<br />

for GP‘s 2009/10<br />

<strong>Controlled</strong> <strong>Drugs</strong> Practice Declaration and Self Assessment Audit<br />

for Dental Practices 2009/10<br />

<strong>Controlled</strong> Drug Personal Declaration and Self Assessment Audit<br />

for Dentist‘s 2009/10<br />

<strong>Controlled</strong> Drug : Practice Audit by PCT Pharmacist<br />

<strong>Controlled</strong> Drug : Personal Audit by PCT Pharmacist<br />

<strong>Controlled</strong> Drug : OOH/UCC/Dispensing Doctor Audit<br />

<strong>Controlled</strong> Drug : Community Hospital Audit<br />

<strong>Controlled</strong> Drug : Prison Audit<br />

Useful External Contacts<br />

62<br />

64<br />

66<br />

82<br />

92<br />

103<br />

113<br />

124<br />

133<br />

140<br />

148<br />

155<br />

172<br />

4


O<br />

P<br />

Q<br />

R<br />

S<br />

T<br />

Table of <strong>Controlled</strong> <strong>Drugs</strong> and Indications allowed to be prescribed<br />

by Nurse Independent Prescriber‘s<br />

Methods of Destruction of <strong>Controlled</strong> <strong>Drugs</strong><br />

Standard Operating Procedure for witnessing destruction of<br />

<strong>Controlled</strong> drugs by a delegated PCT Pharmacist<br />

<strong>Controlled</strong> Drug Destruction Record Form<br />

Summary of <strong>Controlled</strong> Drug guidance for GP‘s<br />

Guidance on Standard Operating Procedures<br />

176<br />

177<br />

180<br />

189<br />

190<br />

194<br />

5


1. Introduction<br />

<strong>Controlled</strong> <strong>Drugs</strong> <strong>Policy</strong><br />

<strong>NHS</strong> <strong>County</strong> <strong>Durham</strong> and <strong>NHS</strong> Darlington aspires to the highest standards of<br />

corporate behaviour and clinical competence, to ensure that safe, fair and equitable<br />

procedures are applied to all organisational transactions, including relationships<br />

with patients their carers, public, staff, stakeholders and the use of public resources.<br />

In order to provide clear and consistent guidance, <strong>NHS</strong> <strong>County</strong> <strong>Durham</strong> and <strong>NHS</strong><br />

Darlington will develop documents to fulfil all statutory, organisational and best<br />

practice requirements and support the principles of equal opportunity for all.<br />

This document gives guidance on the requirements of The Misuse of <strong>Drugs</strong> Act<br />

1971, the Misuse of <strong>Drugs</strong> Safe Custody Regulations 1973, and the<br />

recommendations resulting from the Fourth Report of the Shipman Inquiry and<br />

associated amendments to the Misuse of <strong>Drugs</strong> Regulations 2001.<br />

The Misuse of <strong>Drugs</strong> Act and Misuse of <strong>Drugs</strong> Regulations govern the<br />

circumstances under which controlled drugs (CDs) may be manufactured,<br />

possessed, supplied, imported and exported. Full details of the relevant legislation<br />

are in Appendix 1.<br />

1.1 Status<br />

This policy is a <strong>Clinical</strong> policy.<br />

1.2 Purpose and scope<br />

This document aims to<br />

� Develop good practice in the management of controlled drugs in primary care in line<br />

with current legislation.<br />

� Identify robust systems for obtaining, storing, supplying, recording, monitoring and<br />

safe disposal of CDs, whilst at the same time ensuring appropriate and convenient<br />

access for those patients that require them.<br />

This policy is applicable to Health Care Providers within Co <strong>Durham</strong> and Darlington<br />

PCT‘s, including independent contractors and directly managed services and staff<br />

where controlled drugs are handled, prescribed or used, including: -<br />

GP and Dental Practices<br />

Pharmacies<br />

Midwifery Services<br />

Out of Hours/ Urgent Care/Walk in Centre Services<br />

Patients own homes<br />

Care Homes<br />

Community Hospitals<br />

6


Community Nursing Services<br />

Community Palliative Care Services<br />

Substance Misuse Services<br />

Hospices<br />

Prison Services<br />

2. Definitions<br />

There are no specific definitions applicable to this policy<br />

3. General <strong>Policy</strong> Statement<br />

Co <strong>Durham</strong> and Darlington PCT‘s have an obligation to comply with legislation<br />

outlined in Appendix 1 and with the Health Care Commission Standards for Better<br />

Health: Core Standard : C4 D in that organisations keep patients, staff and visitors<br />

safe by having systems to ensure that medicines are handled safely.<br />

Each practice (GP, Dental etc), pharmacies, services and PCT directly managed<br />

services and staff, are required to have clear practice standard operating<br />

procedures (SOP‘s) covering issues relating to the prescribing, receipt, storage,<br />

supply, recording, monitoring, administration and disposal of controlled drugs.<br />

These SOPs should provide a full audit trail to track the movement of CDs in<br />

primary care from acquisition to administration.<br />

As designated bodies Co <strong>Durham</strong> and Darlington PCT‘s have a duty under the<br />

Health Act 2006 to : -<br />

Appoint an Accountable Officer and describe the duties and responsibilities of<br />

the officer to improve the safe management of CDs. The regulations specify who<br />

may be appointed as an Accountable Officer.<br />

Share intelligence on CD issues with other local and national agencies.<br />

Have the power of entry and inspection for the police and other nominated<br />

people to enter premises to inspect stocks and records of CDs.<br />

Specific procedures applicable to this policy are shown in Appendices 3-22<br />

The Care Quality Commission is responsible for overseeing the Regulation of the<br />

management of CDs by the PCT.<br />

7


4. Duties and Responsibilities<br />

Trust board:<br />

The Trust Board has overall responsibility within each Trust for setting the strategic<br />

context in which organisational process documents are developed, and for<br />

establishing a scheme of governance for the formal review and approval of such<br />

documents.<br />

Chief Executive<br />

The Chief Executive has overall responsibility for the strategic direction and<br />

operational management, including ensuring that Trust process documents comply<br />

with all legal, statutory and good practice guidance requirements.<br />

Director of <strong>Clinical</strong> Quality<br />

The director of clinical quality is the sponsoring director for this document and is<br />

responsible for ensuring that:<br />

The document is drafted, approved and disseminated in accordance with the<br />

<strong>Policy</strong> for the Development and Approval of Policies.<br />

The necessary training or education needs and methods required to<br />

implement this policy are identified and resourced or built into the delivery<br />

planning process.<br />

Mechanisms are in place for the regular evaluation of the implementation<br />

and effectiveness of this policy.<br />

<strong>Controlled</strong> <strong>Drugs</strong> Accountable Officer<br />

The duties of the Accountable Officer are shown in Appendix 2<br />

All staff<br />

All staff, including temporary and agency staff, are responsible for:<br />

Compliance with relevant process documents. Failure to comply may<br />

result in disciplinary action being taken.<br />

Co-operating with the development and implementation of policies and<br />

procedures and as part of their normal duties and responsibilities.<br />

Identifying the need for a change in policy or procedure as a result of<br />

becoming aware of changes in practice, changes to statutory requirements,<br />

revised professional or clinical standards and local/national directives, and<br />

advising their line manager accordingly.<br />

Identifying training needs in respect of policies and procedures and bringing<br />

them to the attention of their line manager.<br />

Attending training / awareness sessions when provided.<br />

8


5. Implementation<br />

This policy will be available to all Staff, in particular the staff listed in Section 1.2 of<br />

the policy for the circumstances described there.<br />

All directors and managers are responsible for ensuring that relevant staff within<br />

their own directorates and departments have read and understood this document<br />

and are competent to carry out their duties in accordance with the procedures<br />

described.<br />

It may be necessary to develop specific implementation plans.<br />

6. Training Implications<br />

The sponsoring director will ensure that the necessary training or education needs<br />

and methods required implementing the policy or procedure(s) are identified and<br />

resourced or built into the delivery planning process. This may include identification<br />

of external training providers or development of an internal training process.<br />

It has been determined that there are no specific training requirements associated<br />

with this policy/procedure.<br />

7. Documentation<br />

7.1 Other related policy documents.<br />

Safe and Secure Handling of Medicines (2008)<br />

7.2 Legislation and statutory requirements<br />

Misuse of <strong>Drugs</strong> Act 1971<br />

Misuse of Drug Regulations 2001 (2001 Regulations)<br />

Misuse of <strong>Drugs</strong> (Safe Custody) Regulations 1973<br />

Misuse of <strong>Drugs</strong> (Supply to Addicts) Regulations 1997<br />

Medicines Act 1968<br />

Health Act 2006<br />

Dangerous <strong>Drugs</strong>, England, Scotland: The <strong>Controlled</strong> <strong>Drugs</strong><br />

(Supervision of Management and Use) Regulations Health Act 2006<br />

7.3 Best practice recommendations<br />

National Prescribing Centre Guide to Good Practice in the Management of<br />

<strong>Controlled</strong> <strong>Drugs</strong> in Primary Care (England) 2 nd Edition February 2007<br />

9


7.4 References<br />

The major references consulted in preparing this document are described above.<br />

8. Monitoring, Review and Archiving<br />

Monitoring<br />

The director of clinical quality as sponsor director, will agree with the policy<br />

manager a method for monitoring the dissemination and implementation of this<br />

policy. Monitoring information will be recorded in the policy database.<br />

Review<br />

The sponsoring director will ensure that each policy document is reviewed in<br />

accordance with the timescale specified at the time of approval. No policy or<br />

procedure will remain operational for a period exceeding three years without<br />

a review taking place.<br />

Staff who become aware of changes in practice, changes to statutory requirements,<br />

revised professional or clinical standards and local/national directives that affect, or<br />

could potentially affect policy documents, should advise the sponsoring director as<br />

soon as possible, via line management arrangements. The sponsoring director will<br />

then consider the need to review the policy or procedure outside of the agreed<br />

timescale for revision.<br />

If the review results in changes to the document, then the initiator should inform the<br />

policy manager who will renew the approval and re-issue under the next ―version‖<br />

number. If, however, the review confirms that no changes are required, the title<br />

page should be renewed indicating the date of the review and date for the next<br />

review and the title page only should be re-issued.<br />

For ease of reference for reviewers or approval bodies, changes should be noted<br />

on the ―Document history‖ table on page 2 of this document.<br />

NB: If the review consists of a change to an appendix or procedure document,<br />

approval may be given by the sponsor director and a revised document may be<br />

issued. Review to the main body of the policy must always follow the original<br />

approval process.<br />

Archiving<br />

The <strong>Policy</strong> Manager will ensure that archived copies of superseded policy<br />

documents are retained in accordance with Records Management: <strong>NHS</strong> Code of<br />

Practice 2006.<br />

10


9 Audit / Impact Assessment Statements<br />

EQUALITY IMPACT ASSESSMENT FORM<br />

Please refer to the corporate checklist for further information.<br />

Name of function/strategy/policy/service: <strong>Controlled</strong> <strong>Drugs</strong> <strong>Policy</strong><br />

Date of Review: 18 August 2009<br />

a) Please provide a brief description of the function/strategy/policy/service:<br />

This document gives guidance on the requirements of The Misuse of <strong>Drugs</strong> Act<br />

1971, the Misuse of <strong>Drugs</strong> Safe Custody Regulations 1973, and the<br />

recommendations resulting from the Fourth Report of the Shipman Inquiry and<br />

associated amendments to the Misuse of <strong>Drugs</strong> Regulations 2001.<br />

The Misuse of <strong>Drugs</strong> Act and Misuse of <strong>Drugs</strong> Regulations govern the<br />

circumstances under which controlled drugs (CDs) may be manufactured,<br />

possessed, supplied, imported and exported.<br />

b) What Type of positive and negative equality & diversity implications are you<br />

aware of that arise from your function/strategy/policy/service?<br />

There are no specific equality and diversity issues which arise within this policy document.<br />

c) In line with our statutory duty under equality legislation do your<br />

functions/strategies/policies/services make reference to equality wherever relevant?<br />

In line with the Race Equality Duty to<br />

eliminate discrimination, harassment,<br />

promoting equality of opportunity and good<br />

relations between people of different racial<br />

groups<br />

In line with the Disability Equality Duty to<br />

promote positive attitudes towards<br />

disabled persons and encourage<br />

participation by disabled people<br />

<strong>NHS</strong> <strong>County</strong> <strong>Durham</strong> aspires to the highest<br />

standards of corporate behaviour and clinical<br />

competence, to ensure that safe, fair and<br />

equitable procedures are applied to all<br />

organisational transactions, including relationships<br />

with patients their carers, public, staff,<br />

stakeholders and the use of public resources. In<br />

order to provide clear and consistent guidance,<br />

<strong>NHS</strong> <strong>County</strong> <strong>Durham</strong> will develop documents to<br />

fulfil all statutory, organisational and best practice<br />

requirements and support the principles of equal<br />

opportunity for all.<br />

Applied equally to all employees<br />

11


In line with the Gender Equality Duty to<br />

eliminate unlawful discrimination and<br />

harassment & promote equality of<br />

opportunity between men and women<br />

Other relevant equality legislation/best<br />

practice?<br />

Applied equally to all employees<br />

d) What relevant groups have a legitimate interest in the<br />

function/strategy/policy/service?<br />

Does it impact differently on particular minority groups?<br />

If Yes – Which Groups are affected, and how are they affected?<br />

Group Impact<br />

All Trust<br />

employees<br />

This policy is appropriate and applicable to those staff identified in Section<br />

1.2.<br />

e) Please outline below any work you have carried out to assess, monitor, address and review<br />

the equality implications of your function/strategy/policy/service and identify additional work<br />

that needs to be carried out to meet requirements of our statutory duties.<br />

Area of Work<br />

Consultation<br />

Monitoring & Target<br />

Setting<br />

Access to<br />

Information/Services<br />

Marketing &<br />

promotion<br />

Work already<br />

carried out /<br />

Measures in Place<br />

<strong>Drugs</strong> &<br />

Therapeutics<br />

Committee<br />

Work Required Timescales<br />

Management Group<br />

to approve<br />

Review June 2011<br />

Available to staff via<br />

the Intranet and hard<br />

copy of policy.<br />

Signpost access to<br />

services and support.<br />

All staff informed of<br />

approval and<br />

publication of the<br />

policy.<br />

June 2011<br />

Following approval<br />

Following approval<br />

12


Training/Briefing<br />

staff<br />

Employment Issues<br />

Review and<br />

Evaluation<br />

N/A<br />

Review June 2011<br />

June 2011<br />

WHERE APPROPRIATE, ACTIONS AND TARGETS DESCRIBED HERE SHOULD BE<br />

EVIDENT IN SERVICE AREA PLANS<br />

13


RELEVANT ACTS OF PARLIAMENT AND REGULATIONS<br />

1.1 Misuse of <strong>Drugs</strong> Act 1971<br />

Appendix 1<br />

The Act establishes a series of criminal offences for the unauthorised use, possession,<br />

supply, importation and unlawful production of drugs considered ‗dangerous or<br />

otherwise harmful‘, with potential for diversion and misuse.<br />

<strong>Drugs</strong> controlled under this act are divided into 3 classes – A, B & C in order to<br />

determine the penalties for offences committed under the act. The class of drug<br />

reflects its relative harm when misused. The maximum penalties for offences of<br />

possession and supply of the main CDs within each class are outlined in the table<br />

below.<br />

Drug Class Penalties for Penalties for<br />

Class A<br />

possession supply<br />

Diamorphine (heroin), Cocaine (Crack), Up to seven years Up to life<br />

MDA (Ecstasy, lysergic acid diethylamide imprisonment or an imprisonment or an<br />

(LSD), methamphetamine, cocaine, more unlimited fine or unlimited fine or<br />

potent opioid analgesics e.g. methadone both<br />

both<br />

Class B<br />

Up to five years Up to 14 years<br />

Amphetamine, barbiturates, Cannabis *, less imprisonment or an imprisonment or an<br />

potent opioids e.g. codeine<br />

unlimited fine or unlimited fine or<br />

both<br />

both<br />

Class C<br />

Up to two years Up to 14 years<br />

Benzodiazepines (and zolpidem), ketamine, imprisonment or an imprisonment or an<br />

anabolic steroids and gamma-<br />

unlimited fine or unlimited fine or<br />

hydroxybutyrate (GBH)<br />

both<br />

both<br />

NB: Any class B drug in an injectable form is treated as Class A.<br />

* The Advisory Council on the Misuse of <strong>Drugs</strong> reviews and advises Ministers in<br />

the United Kingdom on measures that deal with social problems caused by drug<br />

misuse. Therefore the above summary may change, for up to date and detailed<br />

information contact The Home Office.<br />

1.2 Misuse of Drug Regulations 2001 (2001 Regulations)<br />

These regulations<br />

Authorise and govern certain activities which would otherwise be illegal under<br />

the Misuse of <strong>Drugs</strong> Act.<br />

Identify those Health Care Professionals who may legitimately posses and<br />

supply CDs.<br />

Establish a regime of control around prescribing, administration, safe custody,<br />

dispensing, record keeping and destruction or disposal.<br />

The 2001 regulations divide CDs into 5 schedules, which dictate the degree to<br />

which a CDs use is regulated, which in turn depends upon the therapeutic<br />

benefit versus harm when misused.<br />

Schedule 1 CDs are subject to the highest level of control whereas Schedule 5<br />

CDs are subject to a much lower level of control.<br />

Regulations are subject to amendments: full details are available from the Home<br />

Office and the Office of Public Sector information website. www.opsi.gov.uk


1.2.1 Schedule 1 (CD Licence)<br />

These drugs have no recognised medicinal use, although Sativex® (a cannabis based<br />

product) can be supplied on a named patient basis under Home Office Licence.<br />

Examples: cannabis, coca leaf, mescaline, ecstasy, hallucinogens (e.g. LSD) and raw<br />

opium.<br />

Only certain people licensed by the Home Office may possess Sch 1 drugs for<br />

research or other special purposes Practitioners and pharmacists may not lawfully<br />

possess Sch 1 drugs except under licence from the home office.<br />

1.2.3 Schedule 2 (CD)<br />

Includes more than 100 drugs such as the opiates, the major stimulants, secobarbital<br />

and amphetamine.<br />

Sch 2 CDs (except quinalbarbitone) are subject to safe custody requirements (under<br />

the Misuse of <strong>Drugs</strong> Safe Custody Regulations 1973).They must be stored in a locked<br />

receptacle, such as an appropriate CD cabinet or approved safe, which can be opened<br />

by the person in lawful possession of the CD or a person authorised by them.<br />

Quinalbarbitone is exempt from safe custody requirements but is it considered good<br />

practice to store with other CDs.<br />

A licence is required to import and export drugs in Sch 2. They may be manufactured<br />

or compounded by a licence holder, a practitioner, a pharmacist or a person lawfully<br />

conducting a retail pharmacy business acting in their capacity as such.<br />

A pharmacist may only supply Sch 2 CDs to a patient only on the authority of a<br />

prescription in the required form issued by an appropriate prescriber.<br />

A pharmacist may only supply Sch 2 CDs for the purpose of stock in primary care on<br />

the authority of a requisition in the required form issued by an appropriate person.<br />

SCH2 CDs may be administered to a patient by a doctor or dentist or by any person<br />

acting in accordance with the directions of an appropriately qualified prescriber.<br />

Nurse independent prescriber‘s are permitted to prescribe, administer or direct anyone<br />

to administer some CDS for specific conditions and routes of administration. Full<br />

details are given at www.doh.gov.uk/nonmedicalprescribing<br />

A CD register must be kept for Sch 2 CDs and this must comply with the requirements<br />

of the 2001 regulations.<br />

The destruction of Sch 2 CDs stock must only take place in the presence of an<br />

appropriately authorised person. Patient returns do not currently have to be witnessed<br />

but good practice would deem that another person should witness their destruction.<br />

1.2.4 Schedule 3 (CD No Register)<br />

Sch 3 includes a small number of minor stimulant drugs and others which are less<br />

likely to be misused than Sch 2.<br />

The majority of Sch 3 drugs are exempt from safe custody requirements. Exceptions<br />

are: Flunitrazepam, Temazepam, Buprenorphine, Diethylpropion, which must be<br />

stored in a locked receptacle, such as an appropriate CD cabinet or approved safe,<br />

which can be opened by the person in lawful possession of the CD or a person<br />

authorised by them.<br />

A pharmacist may only supply Sch 3 CDs for the purpose of stock in primary care on<br />

the authority of a requisition in the required form issued by an appropriate person.<br />

Page 15 of 196


Certain prescription requirements apply.<br />

There is no legal requirement to record transactions of Sch 3 CDs in a CD register<br />

The requirements for destruction do not apply unless the CDs are manufactured by the<br />

individual.<br />

Sch 3 drugs are subject to full import and export control.<br />

1.2.5 Schedule 4 (CD Benzodiazepines and CD Anabolic steroids)<br />

Sch 4 is split into 2 parts<br />

Part 1 (CD Benzodiazepines) contains most of the benzodiazepines, plus eight<br />

other substances including zolpidem, fencamfamin and mesocarb.<br />

Part 2 (CD Anabolic steroids) contains most of the anabolic and androgenic<br />

steroids such as testosterone, together with clenbuterol and growth hormones.<br />

There is no restriction on the possession of a Sch 4 Part 2 (CD Anabolic<br />

steroids) drug when it is in the form of a medicinal product.<br />

Possession of a drug from Sch 4 Part 1 (CD Benzodiazepines) is an offence without<br />

the authority of a prescription in the required form. Possession, by practitioners and<br />

pharmacists acting in their professional capacities, is authorised.<br />

<strong>Drugs</strong> in Part 1 (CD Benzodiazepines) are subject to full import and export control and<br />

a Home Office licence is also required for importation and exportation of Part 2<br />

Anabolic Steroids unless the substance is in the form of a medicinal product and is for<br />

personal use/ administration.<br />

All substances from Sch 4 are exempt from safe custody requirements with destruction<br />

only applying to importers, exporters and manufacturers.<br />

Prescription-writing requirements set out in the 2001 Regulations for these CDs do not<br />

apply, except those requirements laid down in the Medicines Act 1968.<br />

CD registers do not need to be kept for Sch 4 drugs, although records should be kept if<br />

such CDs are compounded.<br />

1.2.6 Schedule 5 (CD Invoice)<br />

Schedule 5 contains preparations of certain CDs e.g. codeine, pholcodine, morphine,<br />

which are exempt from full control when present in medicinal products of low strength,<br />

as their risk of misuse is reduced.<br />

There is no restriction on the import, export, possession, administration or destruction<br />

of these preparations and safe custody Regulations do not apply.<br />

The Misuse of <strong>Drugs</strong> Regulations have been amended so that preparations containing<br />

more than 0.1% cocaine are no longer exempt from prohibitions on import, export and<br />

possession.<br />

A practitioner or pharmacist acting in his capacity as such, or a person holding an<br />

appropriate licence, may manufacture or compound any CD in schedule 5.<br />

Appendix A contains a list of the most commonly used controlled drugs and their<br />

Schedules.<br />

Appendix B contains a summary of the legal requirements, possession and supply.<br />

Page 16 of 196


1.3 Misuse of <strong>Drugs</strong> (Safe Custody) Regulations 1973<br />

These regulations impose controls on the storage of CDs. The degree of control<br />

depends on the premises where the drugs are stored.<br />

All Schedule 2 and some Schedule 3 CDs should be stored securely in accordance<br />

with the safe custody regulations. These regulations state that such CDs must be<br />

stored in a cabinet or safe, locked with a key. It should be made from metal, with<br />

suitable hinges and fixed to a wall or floor with rag bolts that are not accessible from<br />

outside the cabinet.<br />

1.4 Misuse of <strong>Drugs</strong> (Supply to Addicts) Regulations 1997<br />

These regulations prohibit doctors from prescribing, administering or supplying<br />

diamorphine, cocaine or dipipanone for the treatment of addiction or suspected<br />

addiction except under a Home Office Licence. A licence is not required with such<br />

drugs for the treatment of organic disease or injury.<br />

1.5 Medicines Act 1968<br />

This Act sets out the requirements for a valid prescription. It also allows Midwives to<br />

possess and administer diamorphine, morphine, pethidine or pentazocine.<br />

A number of Health Care Professionals are permitted to supply or administer<br />

medicines in accordance with a patient group direction under medicines act legislation.<br />

Some of these professional groups, but not all, are permitted to supply or administer<br />

CDs in accordance with a PGD under Misuse of <strong>Drugs</strong> legislation.<br />

1.6 Health Act 2006<br />

See section 2.2<br />

1.7 Dangerous <strong>Drugs</strong>, England, Scotland: The <strong>Controlled</strong> <strong>Drugs</strong><br />

(Supervision of Management and Use) Regulations 2006 Health Act 2006<br />

These regulations set out the requirements for certain <strong>NHS</strong> bodies and independent<br />

health care bodies to appoint an Accountable Officer and describe the duties and<br />

responsibilities of Accountable Officers to improve the safe management and use of<br />

CDs.<br />

The regulation requires specific bodies to co-operate with each other, including with<br />

regard to sharing of information, about concerns about the use and management of<br />

CDs, and set out arrangements relating to powers of entry and inspection.<br />

Page 17 of 196


ACCOUNTABLE OFFICER<br />

Page 18 of 196<br />

Appendix 2<br />

2.1 Appointment of Accountable Officer<br />

As designated bodies, Co <strong>Durham</strong> <strong>NHS</strong> and Darlington <strong>NHS</strong> have a duty to appoint an<br />

Accountable Officer. The Health Act 2006 specifies who may be appointed as an<br />

Accountable Officer.<br />

The Accountable Officer cannot be a person who routinely supplies, administers or<br />

disposes <strong>Controlled</strong> <strong>Drugs</strong> as part of their duties.<br />

The PCT must notify the Head of Operations at the Care Quality Commission of the<br />

nomination or appointment of their Accountable Officer, and also the removal or<br />

change of an Accountable Officer.<br />

These notifications can be made via the Accountable Officer notification form available<br />

via the Care Quality Commission Website.<br />

www.cqc.org.uk/guidanceforprofessionals/healthcare/allhealthcarestaff/managingrisk/c<br />

ontrolleddrugs/accountabl/accountableofficernotificationform.cfm<br />

The Care Quality Commission is required to publish a list of Accountable Officers in<br />

England and an up to date list is available via their website.<br />

Contact details for Co <strong>Durham</strong> <strong>NHS</strong> and Darlington <strong>NHS</strong> Accountable Officer see<br />

Appendix C<br />

2.2 Roles and Responsibilities of the Accountable Officer<br />

The Accountable Officer is responsible for ensuring the safe and effective use and<br />

management of controlled drugs within Co <strong>Durham</strong> and Darlington PCT.<br />

The Accountable Officer must have regard to best practice in relation to the<br />

management of controlled drugs;-<br />

Secure the safe management and use of CDs in particular<br />

Establish and ensure appropriate arrangements to comply with Misuse of <strong>Drugs</strong><br />

Legislation.<br />

Ensure adequate and up to date Standard Operating Procedures are in place in<br />

relation to the management of CDs.<br />

Ensure adequate destruction and disposal arrangements for CDs<br />

Ensure monitoring and auditing of the management and use of CDs<br />

Ensure relevant individuals receive appropriate training<br />

Maintain a record of concerns regarding relevant individuals<br />

Assess and investigate concerns<br />

To take appropriate action if there are well founded concerns<br />

To establish arrangements for sharing information<br />

The PCT Accountable Officer has the authority to inspect CD registers, premises and<br />

general drug control procedures in practices and nominate certain designated PCT<br />

personnel to facilitate this or perform inspection on their behalf.<br />

The PCT Accountable Officer is responsible for arranging periodic inspections of<br />

premises which are used in connection with controlled drugs and are not subject to


inspection by the Care Quality Commission or the Royal Pharmaceutical Society<br />

Inspectors (RPSGB). Advanced notification of the inspection does not have to be<br />

provided.<br />

2.3 Local Intelligence Network<br />

Local Agencies required by legislation to share information include: Health Care<br />

organisations, the police, social services and relevant inspectorates, Care Quality<br />

Commission and RPSGB.<br />

Responsibility for establishing the Local Intelligence Network lies with the PCT<br />

Accountable Officer. The network will enable agencies that have cause for concern<br />

about the activities of any Healthcare professional to share them as soon as possible<br />

with other local agencies who may be affected or who may have complimentary<br />

information.<br />

Full details can be found in the Information Sharing Code for <strong>Durham</strong> and Darlington<br />

Local Intelligence Network. Appendix D<br />

Page 19 of 196


Page 20 of 196<br />

Appendix 3<br />

MONITORING AND AUDITING THE MANAGEMENT AND USE OF CONTROLLED<br />

DRUGS<br />

3.1 <strong>Controlled</strong> drugs declaration statement and self assessment<br />

All organisations providing clinical services are required to complete a declaration (at<br />

least every two years) on whether or not their organisation keeps stocks of CDs.<br />

Those that do hold stocks of CDs will be required to complete a self assessment of<br />

their management of CDs.<br />

The self assessment will inform other monitoring and inspection activities.<br />

A declaration and self assessment questionnaire will be sent by the PCT Medicines<br />

Management Team to GPs on Co <strong>Durham</strong> and Darlington performers list, registered<br />

dentists on Co <strong>Durham</strong> and Darlington performers lists and PCT /CHS services.<br />

Appendix E, F, G, H for details of the forms.<br />

The forms should be returned to Co <strong>Durham</strong> and Darlington PCT Medicines<br />

Management Team.<br />

Co <strong>Durham</strong> and Darlington PCTs will be required to complete the Health Care<br />

Commission Annual Health Check Core Standards Assessment.<br />

3.2 Routine Inspections<br />

Inspection remains a useful tool to check physical arrangements for the storage,<br />

record keeping and management of CDs, to support individual and organisational<br />

development and to identify and investigate concerns.<br />

The Health Act has created power of entry and inspection for the police and other<br />

nominated people to enter premises to inspect stocks and records of CDs. See table<br />

below<br />

The PCT Accountable Officer is responsible for authorising PCT personnel, as a<br />

nominated person, to carry out these duties on his behalf, completing the PCT Audit<br />

Tool. See Appendix I, J, K, L and M.<br />

This delegation excludes premises subject to inspection by the Care Quality<br />

Commission or the Royal Pharmaceutical Society Inspectors (RPharmSGB).<br />

The PCT inspecting body is the Care Quality Commission, however, routine<br />

inspections of PCT /CHS services will also be performed by authorised PCT staff in<br />

order to support development and identify concerns.<br />

3.3 Inspection Responsibilities<br />

Area Inspecting Body<br />

GP Practices<br />

PCTs. Inspection will be announced and<br />

<strong>NHS</strong> dentists<br />

may be combined with other visits.<br />

Community Pharmacies The Royal Pharmaceutical Society<br />

PCTs Care Quality Commission


PCT Prisons<br />

PCT Community Hospitals<br />

PCT Services/clinics etc.<br />

PCT<br />

PCT<br />

PCT<br />

<strong>NHS</strong> Trusts Care Quality Commission<br />

Independent Healthcare sector<br />

including GPs in private practice<br />

Care Quality Commission<br />

Care Homes Care Quality Commission<br />

3.3.1 Standards for Inspection<br />

A small number of routine inspections of a random sample (about 10%) must be<br />

performed on an annual basis. The Head of Medicines Management or the<br />

Accountable Officer for the PCT will determine the number and frequency of routine<br />

monitoring visits.<br />

Routine inspections will be performed by designated PCT pharmacists. Pharmacists<br />

who perform monitoring must not do so in practices or services where they work or are<br />

registered as a patient.<br />

To ensure consistency common guidelines will be followed: -<br />

<strong>Controlled</strong> drugs: Monitoring and inspection guidelines - Core activities for CD<br />

monitoring and inspection work - Primary care : Department of Health - Publications<br />

Inspections will comply with the ten principles of inspection set out in the government‘s<br />

policy on Inspection of Public Services.<br />

http://archive.cabinetoffice.gov.uk/opsr/documents/pdf/policy.pdf<br />

Those involved in monitoring and inspection are required to complete the mandatory<br />

PCT training and the National Prescribing Centre competency framework.<br />

http://www.npc.co.uk/pdf/CDI_Competency_Framework.pdf<br />

Notification will be given prior to a routine inspection. Unannounced inspections may<br />

only be carried out under specific directions from the Accountable Officer.<br />

3.4 Monitoring <strong>Controlled</strong> Drug Prescribing and Requisitions<br />

The PCT Medicines Management team will monitor <strong>NHS</strong> and private prescribing and<br />

requisitions of Schedule2 and 3 controlled drugs via ePACT data on a quarterly basis.<br />

These reports will inform other monitoring and inspection activities to determine<br />

whether any further action is needed. Currently there is no facility to monitor <strong>NHS</strong><br />

dentist prescribing by this method.<br />

ePACT data is available for a rolling 60-month historical period only therefore local<br />

historical data will be archived and stored securely and via designated spread sheets,<br />

as this information may be required as evidence by other bodies.<br />

The PCT Pharmaceutical Advisers will use the reports generated to:<br />

Identify GP practices, private practice, non medical prescriber‘s and services,<br />

with a higher than average cost or frequency of CD prescribing/requisitions<br />

compared with the PCT average.<br />

Prescribing/ordering of excessive quantities.<br />

Prescribing for drug addicts<br />

Identify where prescriptions/ requisitions were dispensed or supplied from.<br />

Page 21 of 196


This will enable monitoring of prescribing and ordering patterns to determine<br />

specific medicines and quantities prescribed.<br />

These techniques do not detect inappropriate, fraudulent or criminal behaviour or<br />

identify individual patients; it identifies prescriber‘s/services with unusual<br />

prescribing/requisition patterns for these drugs.<br />

When unusual and/or excessive prescribing or ordering is identified from these reports<br />

the PCT Pharmaceutical Advisers may contact the prescriber or service lead. The<br />

prescriber or service lead may use this information to identify patients receiving<br />

unusual or excessive quantities and take action or identify a legitimate reason or raise<br />

concerns. Where a legitimate reason is identified the advisers should be informed so<br />

this can be logged onto the database.<br />

If anomalies or abnormal prescribing patterns are picked up and no legitimate reason<br />

is identified, the PCT Pharmaceutical Advisers will seek guidance and expert help via<br />

the <strong>Clinical</strong> Governance Leads and the Accountable Officer will be notified.<br />

If concerns are raised about controlled drugs, by any Healthcare Professional, from the<br />

ePACT data, these should be reported. There are a number of mechanisms for this –<br />

See Reporting concerns section 13.6<br />

3.5 Information Sharing<br />

In sharing information the PCT will have regard to the Data Protection Act 1998 and<br />

the codes of practice on confidentiality, in particular the Caldecott principles.<br />

The Local Intelligence Network code of conduct on information sharing will be followed.<br />

Wherever possible, information will be anonymous. In exceptional circumstances the<br />

PCT may determine that it is in the public interest to share patient/ practitioner<br />

identifiable information or that they are required to do so by statute. The patients/<br />

practitioners consent should be sought or they should be notified of the disclosure<br />

unless such action would prejudice an investigation.<br />

3.6 Reporting Concerns<br />

In addition to concerns arising from routine monitoring and inspection, concerns may<br />

be raised by individuals.<br />

The Public Interest Disclosure Act 1998 protects employees who are worried about<br />

wrongdoing in their place of work and want to raise concerns,<br />

The Act applies to all <strong>NHS</strong> employees and includes all self-employed <strong>NHS</strong><br />

Professionals (i.e. doctors, dentists, opticians, optometrists, and pharmacists).<br />

For the purpose of the Act, the employer of a self employed <strong>NHS</strong> Professional is<br />

deemed to be the relevant PCT or Strategic Health Authority.<br />

Other relevant policies are the<br />

PCT Whistleblower <strong>Policy</strong><br />

PCT Incidents Reporting <strong>Policy</strong><br />

Concerns may be raised by following the above policies or reporting direct to any of<br />

the relevant personnel or regulatory authorities listed in Appendix C and N.<br />

Page 22 of 196


3.7 <strong>Controlled</strong> Drug Review<br />

Information from declaration and self assessment, routine monitoring and other<br />

sources will be reviewed to decide whether any further action is needed<br />

The review will assess the organisation/practitioners clinical standards in the<br />

prescribing, supply, administration, storage, record keeping and disposal of CDs and<br />

assure compliance with the Misuse of <strong>Drugs</strong> Act 2001 and associated Regulations,<br />

medicines legislation and any relevant professional codes of practice.<br />

Page 23 of 196


POSSESSION OF CONTROLLED DRUGS<br />

Page 24 of 196<br />

Appendix 4<br />

Unlawful possession of any CD in Schedule 2 to 4 (part1) is a criminal offence.<br />

Persons who can legally possess CDs include:-<br />

Medical Practitioners (this includes doctors and dentists)<br />

Pharmacists or a person lawfully conducting a retail pharmacy business<br />

Supplementary Prescriber‘s where CDs form part of a clinical management plan<br />

Nurse Independent prescriber‘s, but restricted to specific CDs for specific<br />

indications<br />

Any person administering under the directions of a doctor or dentist<br />

Midwives acting in their capacity as such (restrictions apply)<br />

Paramedics acting in their capacity as such (restrictions apply)<br />

Health Professionals supplying or administering CDs under a PGD (restrictions<br />

apply)<br />

Persons in charge of a hospital or care home with nursing<br />

Someone who is transferring, with permission, a CD to another person who is<br />

lawfully allowed to have it in their possession. This permission may be granted<br />

by the person authorised to possess and should be in writing<br />

Someone who has legally been prescribed a CD<br />

Someone who has found a CD and is immediately taking it to a person who may<br />

lawfully possess it. E.g. a pharmacist for a medicinal product, a police officer for<br />

illicit drugs<br />

Someone who has removed a CD from someone else to stop them offending<br />

and is immediately taking it to a person who may lawfully possess it.<br />

Other categories (not applicable to primary care) are allowed, for full details refer to the<br />

Misuse of <strong>Drugs</strong> Act.


PURCHASING AND SUPPLY OF CONTROLLED DRUGS<br />

Page 25 of 196<br />

Appendix 5<br />

A requisition is required for purchase of Schedule 2 and 3 controlled drugs.<br />

The requisition must contain the following information<br />

Name and address and profession or occupation of the recipient<br />

Purpose for which drug supplied<br />

Name form and strength of the drug and quantity to be supplied<br />

Date on which supplied<br />

Faxed or other electronically transmitted requisitions are not currently permitted.<br />

Invoices should be retained for a minimum of two years. It is good practice to keep<br />

records for longer as any investigations take longer than 2 years.<br />

5.1 Supply from community pharmacy (FP10CDF forms)<br />

<strong>Controlled</strong> drugs ordered from a community pharmacy should be made using the<br />

dedicated CD Requisition Form (FP10CDF).<br />

FP10CDF forms are available from the service which supplies other controlled<br />

stationary e.g. prescription forms.<br />

PCT shared services office which supplies other controlled stationery (i.e.FP10).<br />

Contact: -<br />

The Office Services Manager<br />

John Snow House<br />

Telephone 0191 3011300<br />

Independent Hospitals, Out of Hours, Community Hospitals etc will be provided with an<br />

organisation code and/or a practice code for the purpose of ordering controlled drugs<br />

from a community pharmacy. Please contact the PCT Medicines Management Team<br />

for more details.<br />

FP10CD forms are controlled stationery, with unique numbers, and should be stored<br />

securely with access limited to authorised personnel. The minimum number of forms<br />

should be held (i.e. 1 form per GP at any one time).To order controlled drugs all fields<br />

of the form Part B to D should be completed. The person ordering the CDs should sign<br />

the requisition by hand, all other parts of the form may be printed or completed by<br />

another designated person.<br />

If a messenger is sent to collect the CD they must carry a bearer‘s note, signed and<br />

dated by the prescriber, stating that they are authorised to collect the CD. The<br />

pharmacy may retain the bearers note for a minimum of 2 years.<br />

Dispensing Doctors should not supply controlled drugs ordered on a requisition as they<br />

are not permitted to carry out a wholesale function unless they have a wholesalers<br />

licence.<br />

Pharmacies who supply the CD must record their name and address on the forms and<br />

submit these to the Prescription Pricing Division (PPD) of the <strong>NHS</strong> Business Services<br />

Authority (BSA).<br />

5.2 Supply of controlled drugs from a wholesaler or <strong>NHS</strong> Hospital Trust<br />

Supply of controlled drugs from a wholesaler or <strong>NHS</strong> Trust should be made via a<br />

written requisition, containing all the details as per the FP10CDF.<br />

Pharmacists and doctors may order controlled drugs, for their dispensary,<br />

electronically from wholesalers; however, doctors must provide a written requisition on


eceipt of the controlled drugs. Pharmacists do not need to issue a signed order when<br />

purchasing from a pharmaceutical wholesaler, however, this does not apply to support<br />

pharmacist prescriber function.<br />

5.3 GP Practices<br />

Previous recommendations were that the practice holds a central stock under the care<br />

of a designated person for distribution to individual GP for their bags.<br />

The introduction of designated controlled drug requisition forms in 2008 and the<br />

subsequent monitoring of these now make this recommendation obsolete.<br />

GP practices who wish to continue to hold a central stock of CDs should ensure a full<br />

auditable trail is available from ordering to administration and overseen by a<br />

designated member of staff.<br />

The FP10CDF requisition to replenish bags or stock should be completed by the<br />

doctor who requires the stock for their bag.<br />

There is a distinction between supplies of CDs prescribed for individual patients on a<br />

prescription and those obtained by practitioners for stock or bags for home visits etc.<br />

Medicines prescribed for an individual patient must be supplied to, and used by, that<br />

patient only.<br />

Practitioners must NOT use patient specific CD prescriptions to replace or top up their<br />

bags for home visits, etc, or practice stock, even if the stock was used for that patient<br />

initially. This could be considered as a potential offence under the Theft Act 1968 and<br />

might be seen as a means of obtaining CDs by deception.<br />

GPs can claim the cost of injectable controlled drugs, purchased by the practice, which<br />

have been administered to patients. To do this the GP should generate an FP10 and<br />

submit this to the Prescription Pricing Division (PPD) of the <strong>NHS</strong> Business Services<br />

Authority (BSA) at the end of the month along with other personally administered<br />

claims on form FP34D or FP34PD for dispensing doctors. For more information<br />

contact the PPD on 0845 6101171.<br />

5.4 Urgent Supplies (GPs)<br />

A practitioner who requires a Sch 2 or 3 CD urgently and who is unable to supply a<br />

signed requisition (FP10CDF) can request the drugs to be supplied in an emergency.<br />

The practitioner may be supplied with the CD provided he/she gives an undertaking to<br />

supply the completed requisition (FP10CDF) within 24 hours. Failure to do this is a<br />

criminal offence on the part of the practitioner.<br />

5.5 ACQUISITION OF CONTROLLED DRUGS BY OTHER HEALTHCARE<br />

PROFESSIONALS<br />

In addition to the legal requirements and good practice described previously, the<br />

following applies when other healthcare professionals acquire CDs.<br />

5.5.1 Midwives<br />

Community Midwives should obtain controlled drugs for stock in accordance with their<br />

employing authority policies and procedures. For more details on the regulations and<br />

midwives refer to the National Prescribing Centre Guidance : - NPC - Home Page<br />

Alternatively, a prescription can be written by a doctor e.g. a GP if that patient is under<br />

their care. The patient obtains the prescribed CD from a pharmacy and keeps it in their<br />

home until it is required for administration by the midwife.<br />

Page 26 of 196


5.5.2 Paramedics<br />

Ambulance paramedics can supply and / or administer under PGD all drugs listed in<br />

schedule 4 and 5. Under separate exemptions and a group authority, <strong>NHS</strong> ambulance<br />

paramedics serving at any approved ambulance station are able to administer<br />

diazepam and/or morphine sulphate injection (to a max of 20mg) for immediate<br />

necessary treatment of sick or injured persons.<br />

Out of Hours, Urgent Care, Walk in Centres etc. are not approved ambulance stations<br />

therefore registered paramedics who are required to administer diazepam or<br />

midazolam in the course of their duties must do so under an approved Patient Group<br />

Direction (PGD). Currently administration of schedule 2 controlled drugs (i.e. morphine,<br />

diamorphine) are not allowed via PGD for use in trauma.<br />

5.5.3 Hospices, community hospitals and independent hospitals<br />

Where a hospice, community hospital or private hospital does not employ a<br />

pharmacist, the person or acting person in charge may obtain CDs via a requisition<br />

signed by a doctor or dentist employed or engaged there.<br />

If supplies are obtained from a community pharmacy the FP10CDF requisition form<br />

must be used. A designated organisation code and/or practice code will be issued by<br />

the PCT and PPD for the specific purpose of ordering controlled drugs from community<br />

pharmacies via FP10CDF requisitions.<br />

If supplies are requested via a wholesaler or the pharmacy department of an <strong>NHS</strong><br />

Trust with whom a service level agreement (SLA) is in place a written requisition form<br />

should be used which complies with the regulations set out above. (FP10CDF forms<br />

do not apply).<br />

5.5.4 Out of Hours premises<br />

At out of hour‘s premises, as long as the ordering, supply or dispensing of CDs is<br />

undertaken by a doctor or pharmacist, CD stock can be ordered as in section15.5.3<br />

above.<br />

Acquisition may be undertaken by anyone else i.e. office manager of the Out of Hours<br />

Provider – under these circumstances a Home Office licence is required.<br />

Page 27 of 196


PREPARATION AND ADMINISTRATION OF CONTROLLED DRUGS<br />

6.1 Legal Framework<br />

Any person may legally administer a schedule 5 CD to any other person<br />

Page 28 of 196<br />

Appendix 6<br />

Administration of CDs via PGD applies to the specified healthcare professional in the<br />

PGD, this cannot be delegated to another person.<br />

Doctors and dentists and any person acting in accordance with the directions of a<br />

doctor or dentist may administer Sch 2, 3 or 4 CD from stock.<br />

Nurse independent prescriber‘s or any person acting in accordance with their<br />

directions can administer a limited range of controlled drugs. See Appendix O<br />

Some professional groups, not all, are permitted to supply or administer controlled<br />

drugs in accordance with a PGD.<br />

A carer/relative, can, with consent, administer a CD that has been individually<br />

prescribed for a third party. As CDs are included within the legal category of<br />

prescription only medicines (POM), home carers who are competent to administer<br />

medicines should also be competent to administer CDs.<br />

Midwives may possess those CDs which they may also lawfully administer (i.e.<br />

diamorphine, morphine, pethidine and pentazocine)<br />

Ambulance paramedics see section 15 above<br />

6.2 Good Practice<br />

Except in exceptional circumstances, the person prescribing the CD should not also<br />

personally undertake all of the following tasks: preparation, dispensing, transportation<br />

and administration of the CD.<br />

A record of each administration should be kept in the relevant patient clinical notes.<br />

This record should specify the date, time, strength, presentation and form of<br />

administration, dose administered as well as the name and occupation of the person<br />

administering it.<br />

There should be policies and procedures that define safe medicine practice for the<br />

preparation and administration of injections including CDs that comply with the<br />

National Patient Safety Alerts: Promoting safer use of injectable medicines. Further<br />

details can also be found in the PCT Safe and Secure Handling of Medicines <strong>Policy</strong><br />

and the PCT Syringe driver policy.<br />

6.3 Naloxone<br />

Naloxone injection, an antidote to opiate-induced respiratory depression, should be<br />

available in all clinical locations where diamorphine and morphine injections are stored<br />

and administered, including GPs bags; as per the National Patient Safety Agency<br />

alerts <strong>NHS</strong> to risks with high dose morphine and diamorphine injections<br />

6.4 Extemporaneous preparation of methadone<br />

If a licensed product is available, methadone mixture should only be prepared<br />

extemporaneously if the quantity of methadone dispensed on a regular basis is large<br />

enough to preclude storage of sufficient quantities of the licensed product.<br />

SOPs must be in place for the extemporaneous preparation of methadone


It is essential that robust standards and systems are in place to ensure the quality of<br />

the prepared methadone so that patient care is not compromised.<br />

Full guidance can be found at http://www.rpsgb.org/pdfs/coepsgssmeds.pdf<br />

Page 29 of 196


7.1 Medical practitioners<br />

PRESCRIBING OF CONTROLLED DRUGS<br />

Page 30 of 196<br />

Appendix 7<br />

Doctors and dentists may prescribe all CDs in Schedules 2 to 5 for organic disease.<br />

Doctors are only able to prescribe diamorphine, dipipanone and cocaine to substance<br />

misusers for the treatment of addiction if they hold a licence issued by the Home Office. All<br />

doctors may prescribe such drugs for patients, including substance misusers, for the relief<br />

of pain due to organic disease or injury without a specific licence.<br />

(Note: supplementary prescriber‘s working within agreed patient specific management plans<br />

who prescribe for substance misusers for the treatment of addiction are not currently able to<br />

apply for a licence from the Home Office: currently licences are restricted to doctors; this<br />

may be subject to change in the future).<br />

7.2 Non-medical prescriber‟s<br />

7.2.1 Community practitioner nurse prescriber‟s<br />

Community practitioner nurse prescriber‘s may only prescribe those products and<br />

medicines specified in the Nurses Prescriber‘s‘ Formulary for community practitioners. No<br />

CDs are included in this formulary.<br />

7.2.2 Nurse independent prescriber‟s<br />

Nurse independent prescriber‘s are permitted to prescribe, administer, or direct anyone to<br />

administer certain CDs solely for specific medical conditions.<br />

7.2.3 Pharmacist independent prescriber‟s<br />

Pharmacist independent prescriber‘s cannot currently prescribe CDs, although community<br />

pharmacists can advise on and sell Schedule 5 CDs from a pharmacy.<br />

7.2.4 Supplementary prescriber‟s<br />

Registered nurses, pharmacists and Registered midwives, chiropodist / podiatrist, physio-<br />

therapist, radiographer and optometrist supplementary prescriber‘s may now prescribe any<br />

CD as long as it is within the <strong>Clinical</strong> Management Plan specific to that patient and agreed<br />

between the independent prescriber (doctor or dentist), supplementary prescriber and the<br />

patient.<br />

7.2.5 Midwives<br />

Midwives may also train as nurse independent prescriber‘s. Midwives who are not trained<br />

as nurse independent prescriber‘s may administer CDs under Exemption Orders under<br />

medicines regulations.<br />

7.3 Patient Group Directions<br />

The supply and administration of the following CDs is currently allowed under PGDs:<br />

Diamorphine, but only for the treatment of cardiac pain by nurses working in<br />

coronary care units or hospital accident and emergency departments.<br />

Midazolam. (This is the only Sch 3 CD allowed under a PGD)<br />

All drugs listed in Schedule 4 of the Regulations except:<br />

The anabolic steroids in part 2 of that Schedule<br />

Injectable formulations for the purpose of treating a person who is addicted to a<br />

drug


All drugs listed in Schedule 5 of the Regulations.<br />

The amended Regulations allow nurses, midwives, pharmacists, optometrists, chiropodists,<br />

radiographers, orthoptists, physiotherapists, ambulance paramedics, occupational<br />

therapists, orthotists and prosthetists to supply or administer CDs in Schedule 4 and 5.<br />

7.4 Exemptions<br />

Midwives, who are not trained as nurse independent prescriber‘s may administer some<br />

specific named CDs under Exemption Orders under medicines legislation.<br />

7.5 PRESCRIPTION REQUIREMENTS<br />

7.5.1 Schedule 2 and 3 controlled drugs (except temazepam)<br />

A prescription for Schedule 2 and 3 CDs (with the exception of temazepam and<br />

preparations containing it) must:<br />

Contain the following details, written so as to be indelible, e.g. written by hand,<br />

typed or computer-generated:<br />

The patient‘s full name, address and, where appropriate, age<br />

The name and form of the drug, even if only one form exists<br />

The strength of the preparation, where appropriate<br />

The dose to be taken (Take as directed or as required are not acceptable)<br />

The total quantity of the preparation, or the number of dose units, to be<br />

supplied in both words and figure<br />

Be signed by the prescriber with their usual signature (this must be handwritten)<br />

and dated by them (the date does not have to be handwritten)<br />

The address of the prescriber must be stated on the prescription and must be within<br />

the UK. (NB: the UK does NOT include the Channel Islands or the Isle of Man)<br />

Dentists: prescriptions issued by a dentist must contain the words ‗for dental<br />

treatment only‘.<br />

7.5.2 Temazepam and Schedule 4 and 5 controlled drugs<br />

Prescriptions for temazepam and for Schedule 4 and 5 CDs are exempt from the specific<br />

prescription requirements, however, they must still comply with the general prescription<br />

requirements.<br />

7.5.3 Quantity supplied on prescription<br />

The quantity of drug prescribed on each prescription should be appropriate for the clinical<br />

need of the patient. Careful consideration should be given to the quantities prescribed, both<br />

to anticipate requirements, e.g. over a weekend, and to reduce the amount of excess CDs<br />

stored in the patient‘s home.<br />

Although not a legal requirement, there is a strong recommendation that prescriptions for<br />

Schedule 1, 2, 3 and 4 CDs are limited to a quantity necessary for up to 30 days clinical<br />

need.<br />

7.5.4 Prescribing more than 30 days supply<br />

In exceptional circumstances where the prescriber believes a supply of more than 30 days<br />

medication is clinically indicated and would not pose an unacceptable threat to patient<br />

safety the prescriber:<br />

Should make a note of the reasons for this in the patient‘s notes<br />

Be ready to justify his / her decision if required<br />

Page 31 of 196


7.5.5 Repeat prescribing<br />

Current legislation does not allow Schedule 2 and 3 CDs to be prescribed as repeat<br />

prescriptions (i.e. to be part of the repeat prescribing system within a practice, or part of a<br />

repeat dispensing system).<br />

7.5.6 <strong>NHS</strong> repeat dispensing scheme<br />

Schedule 4 and 5 CDs may be ordered on prescriptions issued under the repeat dispensing<br />

scheme. For Schedule 4 CDs, the first prescription must be dispensed within 28 days.<br />

Currently Schedule 2 and 3 CDs are not permitted on prescriptions issues under repeat<br />

dispensing schemes.<br />

7.5.7 Dispensing more than 30 days supply<br />

It is not illegal for a pharmacist to dispense a prescription for more than 30 days<br />

supply, but they must satisfy themselves as to the clinical appropriateness of the<br />

prescription before doing so<br />

A pharmacist does not need to contact the prescriber each time they receive a prescription<br />

requesting a supply in excess of 30 days of a Schedule 2-4CD. There may be<br />

circumstances where there is a genuine need to prescribe more than 30 days supply and<br />

pharmacists should exercise their professional judgement and assess both the prescription<br />

and the situation to check the suitability for the patient. Where there is concern that the<br />

prescription is not appropriate the prescriber should be contacted.<br />

7.5.8 Good practice (general)<br />

All prescriptions for Schedule 2 and 3 CDs should include the patients <strong>NHS</strong> number where<br />

possible so that the usage of CDs by individual patients can be audited.<br />

The professional registration number and the profession of the person who signs the<br />

prescription should be added to the CD prescriptions they write, to assist with any future<br />

audit. The prescriber‘s full name, address, telephone number and the PCT in which they are<br />

working should also be included on the prescription. This information is generally preprinted<br />

on the prescription.<br />

Dosages and frequencies for all CDs should normally be presented in full by the prescriber,<br />

to aid administration by nurses and carers. (i.e. Take one tablet up to four times a day when<br />

required for pain relief). Particular care should be taken to ensure clarity of dosage<br />

instructions where systems such as syringe drivers are being used.<br />

Any space on the prescription form that has not been written on must be blanked off,<br />

e.g. by drawing a line through it to reduce the opportunity for fraud.<br />

CDs have the potential to be diverted to the illicit market. For this reason, when a patient<br />

presents a CD prescription for an acute condition, more than two/three weeks after the<br />

prescription was issued, it would be prudent to check with the patient and/or prescriber that<br />

the supply of the CD is still warranted before dispensing the item.<br />

Computer systems should be used, wherever feasible, as an additional method to record<br />

and audit the prescribing of CDs. If a prescriber makes a domiciliary visit, and a CD is<br />

administered or a handwritten prescription for a CD is issued, it is good practice to make a<br />

note of this on the patient‘s computer record as soon as possible after the event. The doctor<br />

should also record the administration of a CD to a patient<br />

Page 32 of 196


7.5.9 Validity of prescriptions<br />

The validity period of <strong>NHS</strong> and private prescriptions for Schedule 1, 2, 3 and 4 CDs has<br />

been restricted to 28 days. This means that the prescription should not be dispensed if<br />

more than 28 days have elapsed since it was signed and dated by the prescriber, or if the<br />

prescription has a later start date, not more than 28 days from this date.<br />

In the case of a prescription containing a Schedule 2 or 3 CD, which directs that specified<br />

instalments of the total amount may be supplied at stated intervals, the first instalment must<br />

be supplied no later than 28 days after the ‗appropriate date‘.<br />

See the following website for further details The Misuse of <strong>Drugs</strong> (Amendment No. 2)<br />

Regulations 2006<br />

7.5.10 Technical errors on a prescription<br />

Pharmacists are able to supply Schedule 2 and 3 CDs except temazepam (which is exempt<br />

from CD prescription requirements), against some prescriptions that have a minor technical<br />

error but where the prescriber‘s intention is clear.<br />

The only errors that pharmacists may amend are:<br />

Minor typographical errors or spelling mistakes<br />

Where the total quantity of the preparation of the CD or the number of dosage units<br />

as the case may be is specified in either words or figures but not both (i.e. they may<br />

add the words or the figures to the CD prescription if they have been omitted).<br />

As a safeguard to these changes the pharmacist must satisfy two pre-conditions before<br />

amending the prescription and supplying the CD:<br />

He must be satisfied on reasonable grounds, having exercised due diligence that the<br />

prescription is genuine and that he is supplying the drug in accordance with the<br />

intention of the prescriber<br />

Any correction must be marked so as to be attributable to the pharmacist to ensure it<br />

is readily identifiable, for the purpose of the audit.<br />

Additional guidance is available at www.rpsgb.org.uk<br />

7.5.12 Prescribing to self and family<br />

Other than in emergencies, no prescriber should prescribe any drug for themselves<br />

or anyone with whom they have a close personal or emotional relationship.<br />

There may be some cases, such as in an emergency situation in which prescribing for<br />

family, friends or self is immediately necessary to:<br />

Save life<br />

Avoid significant deterioration in the patients health<br />

Alleviate uncontrollable pain<br />

And that no other person with the legal right to prescribe is available to assess the patient‘s<br />

clinical condition and to delay prescribing would put the patient‘s health at risk, or cause<br />

unacceptable pain.<br />

The British Medical Association (BMA) and the General Medical Council (GMC) advise<br />

doctors against prescribing for themselves, family, friends and colleagues. There is a risk<br />

that doctors who self-treat may ignore or deny serious health problems. There is also a risk<br />

that self-prescribing could lead to drug abuse or addiction.<br />

Page 33 of 196


The RPSGB and Nursing and Midwifery Council (NMC) also advise against self prescribing,<br />

and prescribing for friends, family and colleagues. See NMC ‗Standards of Proficiency to<br />

prescribe‘ www.nmc-uk.org and RPSGB ‗Code of Ethics‘ www.rpsgb.org.uk<br />

7.5.13 Security of Prescription pads<br />

There are regulations covering security measures to prevent users unlawfully obtaining<br />

supplies of drugs and syringes; prescription pads; and headed notepaper from<br />

premises.<br />

<strong>NHS</strong> Security Management Service; Security of Prescription Forms Guidance 2008<br />

and the PCT Guidance on security of prescriptions pads must be followed.<br />

Do not leave blank prescription pads lying around unattended.<br />

Blank prescription pads should never be pre-signed<br />

Pads should always be locked away at night in case of unlawful entry<br />

Prescriber‘s must never use blank or out of date prescription pads as spare notepads<br />

Prescription forms for Schedule 2 & 3 CDs should not routinely be sent to the patient‘s<br />

pharmacy via the postal system, but should be collected by a healthcare professional,<br />

a member of their staff, the patient or their representative.<br />

Prescriptions for the treatment of drug addiction may be sent to pharmacies when it is<br />

not practical for the pharmacists to collect prescriptions from the premises i.e. due to<br />

distance and it is not always desirable for the patient to be handed the prescription.<br />

It is good practice to keep a record of controlled drug prescription forms awaiting<br />

collection in the practice (including prescriptions for drug addiction). Also for the<br />

person collecting the prescription to date and sign for receipt of the prescription form.<br />

Care must be taken to ensure other prescriptions for the patient are also collected at<br />

the same time.<br />

Page 34 of 196


PRESCRIBING IN INSTALMENTS<br />

Page 35 of 196<br />

Appendix 8<br />

Some CDs can be dispensed to substance misusers in instalments providing they are<br />

prescribed using specific <strong>NHS</strong> prescription forms. FP10 (MDA)<br />

A prescriber writing a private prescription can also ask for the prescription to be dispensed<br />

in instalments.<br />

8.1 FP10 (MDA)<br />

The form FP10 (MDA) is used to prescribe in instalments Schedule 2 CDs, buprenorphine<br />

(Schedule 3) or diazepam (Schedule 4) for drug addiction. This form must not be used for<br />

any other purpose. E.g. when the total quantity needs to be dispensed at one time – in this<br />

case the normal FP10 form must be used.<br />

Hospital or clinical-based prescriber‘s use a variation of this form – FP10 (MDA) SS that is<br />

overprinted with the words ‗HOSPITAL PRESCRIBER‘. The SS forms are intended to be<br />

used for computer-generated prescriptions although they can be handwritten as well.<br />

8.1.2 Details to be specified<br />

If a CD prescription is to be dispensed in instalments, e.g. daily, then the prescription must<br />

specify the following details:<br />

1. The number of instalments<br />

2. The intervals to be observed between instalments; if necessary, instructions for<br />

supplies at weekends or bank holidays should be included<br />

3. The total quantity of CD that will provide treatment for a period not exceeding<br />

14 days.<br />

4. The quantity to be supplied in each instalment<br />

Points 1, 2 and 3 are required by the <strong>NHS</strong> (General Medical Services Contract) Regulations<br />

2004. Points 2 and 4 are required under the Misuse of <strong>Drugs</strong> Regulations 2001, Regulation<br />

15.<br />

8.2 Collection of instalments<br />

The prescription must be dispensed on the date on which it is due. If the client does not<br />

collect an instalment when it is due that supply is no longer valid. The client cannot collect<br />

that supply the following day.<br />

If a prescriber has ordered several days‘ instalments to be collected on one day and the<br />

client does not come in on the specified day, then he loses the complete instalment; he<br />

cannot have the remainder of the instalment. Pharmacists should endorse the prescription<br />

‗NOT DISPENSED‘ for that instalment and, if possible, notify the prescriber.<br />

However, guidance from the Home Office has indicated that the use of specific wording will<br />

enable those supplying CDs to issue the remainder of an instalment prescription when the<br />

person has failed to collect the instalment on the specified day. The wording below can be<br />

used if a prescription does not contain such wording the Regulations only permit the supply<br />

to be made in accordance with the prescriber‘s instalment direction. Further guidance can<br />

be found at:-<br />

www.pharmj.com/Editorial/20050430/society/ethics.hmtl.<br />

‗Supervised consumption of daily dose specified days; the remainder of supply<br />

to take home. If an instalment prescription covers more than one day and is not<br />

collected on the specified day, the total amount prescribed less the amount<br />

prescribed for the days used may be supplied‘


‗Unsupervised consumption; instalment prescriptions covering more than one day<br />

should be collected on the specified day; if this collection is missed the remainder of<br />

the instalment (i.e. the instalment less the amount prescribed for the days missed)<br />

may be supplied.‘<br />

8.3 <strong>NHS</strong> forms issued to substance misusers<br />

Issued by / in Type of form Region What is allowed<br />

GPs<br />

Hospital or clinic<br />

based prescriber‘s<br />

Nurse independent<br />

prescriber‘s<br />

Supplementary prescriber‘s<br />

FP10(MDA) or<br />

FP10(MDA) SS<br />

FP10(MDA) SS<br />

FP10(MDA) or<br />

FP10(MDA) SS<br />

FP10(MDA) SS<br />

FP10(MDA) SP<br />

England<br />

England<br />

England<br />

England<br />

Schedule 2 CDs, buprenorphine,<br />

diazepam, plus single supplies of<br />

water for injection as necessary<br />

Schedule 2 CDs, buprenorphine,<br />

diazepam, plus single supplies of<br />

any other medication allowed on<br />

FP10<br />

Diazepam for treatment of initial<br />

or acute withdrawal symptoms<br />

caused by the withdrawal of<br />

alcohol from persons habituated<br />

to it.<br />

Schedule 2 CDs, provided this is<br />

agreed by a doctor in the patient‘s<br />

<strong>Clinical</strong> Management Plan.<br />

8.4 Good Practice<br />

On FP10 (MDA) prescriptions, it is good practice for the duration of the instalments to be<br />

set out on the prescription, e.g. dispense daily for five days starting on x date.<br />

The client should collect the CD in person. If he or she is unable to collect prescriptions<br />

personally, the client may arrange for a representative to collect it. The representative<br />

should bring a suitable note on each occasion to ensure they have authority to collect.<br />

The requirements to see identification on collection only apply to the first dispensing of an<br />

instalment prescription.<br />

8.5 Prescribing controlled drugs for addiction<br />

Only doctors are able to prescribe diamorphine, dipipanone or cocaine to substance<br />

misusers for treatment of addiction, but only if they hold a licence, issued by the Home<br />

Office. Prescriber‘s can prescribe such drugs for patients, including substance misusers, for<br />

relief of pain due to organic disease or injury, without a specific licence.<br />

Page 36 of 196


PRIVATE PRESCRIBING<br />

Page 37 of 196<br />

Appendix 9<br />

Besides reviewing the current legal framework, this document helps to establish good<br />

practice for the management of CDs. Although this is presented in the form of guidance for<br />

the <strong>NHS</strong>, this is equally applicable to professionals providing health care in non-<strong>NHS</strong><br />

settings. The law relating to prescribing applies to all <strong>NHS</strong> and non-<strong>NHS</strong> settings and good<br />

governance is equally applicable to Non <strong>NHS</strong> organisations.<br />

The term ‗private prescriber‘ is used to describe the situation when a private prescription is<br />

written, either by <strong>NHS</strong> or non-<strong>NHS</strong> practitioners, in either <strong>NHS</strong> or non-<strong>NHS</strong> settings.<br />

9.1 Legal framework<br />

When writing private prescriptions, prescriber‘s must comply with all legal requirements,<br />

including appropriate record keeping, when ordering, prescribing, dispensing, administering<br />

and destroying CDs.<br />

Registerable private doctors and independent clinics, as defined under section 2 of the<br />

Care Standards Act 2000, are required to be registered with the Healthcare Commission, as<br />

laid out in the Health and Social Care (Community Health and Standards) Act (2003) and<br />

Private and Voluntary Health Care (England) Regulations 2001. *There is a need to<br />

demonstrate safe systems of handling and prescribing CDs in meeting the National<br />

Minimum Standards for Independent Healthcare<br />

www.dh.gov.uk/assetRoot/04/07/83/67/04078367.pdf<br />

Normally, private prescriptions can allow a prescriber to request that the prescription is<br />

repeatable ** for a specified number of times. However, this is not permitted for Schedule 2<br />

and 3 CDs. It is possible to prescribe Schedule 4 and 5 CDs on a repeat basis, both<br />

privately and under <strong>NHS</strong> repeat dispensing arrangements.<br />

* It is an offence under the Care Standards Act 2000 section 11 to carry on or manage a<br />

registerable service without first being registered to do so. Failure to apply for registration<br />

could render the practitioner liable to prosecution and could lead to the refusal of the<br />

application to register.<br />

** The repeat method is where a private prescription is written for a specified quantity of<br />

drugs and the prescriber endorses the prescription with the number of times the prescription<br />

should be repeated. The pharmacist is then able to make the specified number of<br />

dispensing transactions from that prescription.<br />

9.2 Standardised private prescription form<br />

All private prescriptions for human use of Schedule 1, 2 and 3 CDs (including temazepam)<br />

that are presented for dispensing in the community (not the hospital) must be written on a<br />

standard prescription form which must include the private prescriber‘s unique (six digit)<br />

identification number issued specifically for the private prescribing activity.<br />

There are two types of forms available:<br />

Personalised FP10 (PDC) NC – These contain the prescriber‘s details already printed.<br />

Non personalised forms FP10 (PCD) SS – These allow private prescriber‘s to print private<br />

CD prescriptions, including their private prescriber details, using their practice computer<br />

systems.


Private prescriber‘s should obtain stocks of private prescription forms via their designated<br />

PCT.<br />

9.3 Private prescriber identification number<br />

Prescriber‘s who issue private prescriptions for Schedule 2 and 3 CDs that will be<br />

dispensed by community pharmacists must have a unique prescriber identification number.<br />

Any prescriber requiring a private prescriber identification number should apply via local<br />

PCT. A number will be then issued by the PPD of the <strong>NHS</strong> Business Services Authority. It<br />

will be different from the prescriber‘s <strong>NHS</strong> prescriber code if they have one. A prescriber<br />

who practices in the <strong>NHS</strong> and privately will, therefore have two identifier numbers (one <strong>NHS</strong><br />

and one private).<br />

Prescriber‘s working in private practice in a hospital should inform patients that private<br />

prescriptions not written on the standard form can only be dispensed in a hospital<br />

pharmacy.<br />

9.4 Submission of prescription<br />

The original or a copy of each prescription for a Schedule 1, 2 or 3 CD should be submitted<br />

after dispensing (community pharmacists or dispensing doctors) to the relevant National<br />

Health Service Agency (<strong>NHS</strong> Business Services Authority for England) along with a CD<br />

submission form (FP34PCD). Until the Miscellaneous Provisions Regulations are amended<br />

a copy needs to be submitted.<br />

9.5 Good practice<br />

The National <strong>Clinical</strong> Assessment Service (NCAS) and the <strong>NHS</strong> <strong>Clinical</strong> Governance<br />

Support Team have suggested the following good practice for private prescriber‘s:<br />

Private prescriber‘s should produce their own guidance for use in their services with respect<br />

to:<br />

Treatment, prescribing and review policies<br />

<strong>Clinical</strong> governance systems<br />

Training and continuing professional development (CPD)<br />

This guidance should be rooted in any relevant national good practice guidance,<br />

Including ‗Drug misuse and dependence: guidelines on clinical management‘<br />

published by DH.<br />

Private prescriber‘s should, in most circumstances and with the patient‘s agreement,<br />

contact the patient‘s private or <strong>NHS</strong> GP before initiating treatment and during the course of<br />

treatment.<br />

Private prescriber‘s should, in most circumstances, liaise as appropriate with other health<br />

care professionals involved in the care of the patient. This should include the pharmacist/<br />

dispensing doctor.<br />

Private prescriber‘s should indicate on the prescription when prescribing for a non-UK<br />

resident. Several of the points here are included in Regulation under the Health and Social<br />

Care (Community Health and Standards) Act (2003), and private and Voluntary Health Care<br />

(England) Regulations 2001.<br />

Page 38 of 196


Page 39 of 196<br />

Appendix 10<br />

Prescriptions for prisoners and other agency agreements for <strong>NHS</strong> services<br />

In England, the <strong>NHS</strong> provides prescriptions for prisoners and some other patients under<br />

SLA‘s with other organisations. Traditionally, this has been treated for administrative<br />

convenience in the same way as private work in order to prevent submission to and<br />

reimbursement by the relevant <strong>NHS</strong> agency. However, the new standardised private<br />

prescription forms should not be used for such patients as this is classed as <strong>NHS</strong> activity.


STORAGE OF CONTROLLED DRUGS<br />

Page 40 of 196<br />

Appendix 11<br />

This section covers the legal and good practice issues for the storage of CDs. It does not<br />

cover any clinical or drug stability issues, which should be addressed separately.<br />

All Schedule 2 (except quinalbarbitone) and Schedule 3 CDs (except Buprenorphine,<br />

Diethylpropion, Flunitrazepam and Temazepam) are subject to safe custody requirements<br />

and must be kept in a locked receptacle, which is so constructed and maintained to prevent<br />

unauthorised access to drugs.<br />

In residential and healthcare settings it is recommended that the specifications of cabinets<br />

and safes set out in Schedule 2 of the Safe Custody Regulations should be regarded as a<br />

minimum standard for the storage of CDs.<br />

11.1 <strong>Controlled</strong> drug cabinets/safes<br />

Requirements and/or recommendations are that:<br />

The receptacle should consist of a locked safe/cabinet preferably of steel, with<br />

suitable hinges, fixed to a wall or the floor with rag bolts (these bolts should not be<br />

accessible from outside the cabinet)<br />

Ideally the safe/cabinet should be within a cupboard or in such a position as to avoid<br />

easy detection by intruders.<br />

Nothing should be displayed outside to indicate that CDs are kept within the<br />

container.<br />

The room containing the safe/cabinet should be lockable and tidy to avoid drugs<br />

being misplaced.<br />

This room should not normally be accessible to patients, nor should the keys<br />

required for access. However, if patients do have to enter the area where CDs are<br />

stored, it is good practice that they should be continuously supervised until such time<br />

as they leave the area.<br />

The walls of the room should be constructed to a suitable thickness using suitable<br />

materials.<br />

The locked receptacle must only be opened by the person in lawful possession of the<br />

CDs or a person authorised by him/her.<br />

Stock should be kept to a minimum and the cabinet should not contain anything other than<br />

the drugs, or the drugs and register. (The register does not have to be kept locked with the<br />

drugs).<br />

The CD register should be stored safely outside the CD container but near to it but not<br />

easily visible or accessible.<br />

Items such as money should not be stored in the CD cabinet.<br />

Tamper evident manufacturer seals must be left in tact on receipt of the CD and only<br />

opened at time of administration/supply.<br />

All services/practices must have SOP in place for management of CD stock held on the<br />

premises.<br />

One designated person within the premises should take overall responsibility for the<br />

management of controlled drugs including keys/codes. The number of sets of keys to the<br />

container, and who holds them, or who has access to the codes for digital key pads, must


e known at all times by the designated person. The keys should always be kept separate<br />

from the container and should never be accessible to unauthorised persons. The container<br />

should only be opened by the designated person, or by the person authorised by them, e.g.<br />

a locum. The designated person remains ultimately accountable for the management of the<br />

CDs.<br />

Other drugs that are liable to misuse can be locked in the container if this is deemed<br />

appropriate by the relevant health care professional.<br />

<strong>Drugs</strong> in Schedules 4 and 5 can also be a target for substance misusers. Dispensary areas<br />

are required to be secure enough to prevent unauthorised access, but additional<br />

precautions, such as keeping these items out of sight of patients, may be advisable.<br />

All CDs should be stored out of sight and reach of children<br />

11.2 <strong>Controlled</strong> drugs in a „doctor‟s bag‟<br />

A‘ doctor‘s bag‘ is a locked bag, box or case for home visits, etc. which should be kept<br />

locked at all times, except when in immediate use. The person in lawful possession of this<br />

bag, or an individual authorised by them, must always retain the keys.<br />

Legal precedent holds that such a bag is regarded, once locked, as a suitable receptacle for<br />

storing CDs, but a locked car is not. Bags containing CDs should not be left in a vehicle<br />

overnight, or in a vehicle left unattended for long periods of time.<br />

For a bag for home visits, etc. a digital combination lock on a case is often the most<br />

practical and convenient solution and avoids problems with keys.<br />

The stock levels held in this bag should be kept to a minimum and informed by previous<br />

requirements.<br />

Normally, only one strength of each CD should be kept in a bag for home visits, etc. in order<br />

to minimise the risk of confusion, error and inappropriate administration.<br />

Oral preparations of CDs would not routinely be considered essential items to be carried in<br />

such a bag.<br />

The doctor, or a delegated member of staff, should undertake a monthly stock check of CDs<br />

held within each bag for home visits and a record made that this has been done. This<br />

process also provides a good opportunity to check for any out-of-date (or ‗soon to expire‘)<br />

stock. This needs to be included in an SOP.<br />

When a bag for home visits, etc. containing CDs is in the practice, it should be stored in a<br />

safe place away from patient areas in a locked room. This location should be determined by<br />

carrying out a risk assessment.<br />

A separate CD register should be kept for the CD stock held within the bag and a running<br />

balance maintained.<br />

Restocking of a bag for home visits, etc. from FP10CDF or practice stock should be<br />

witnessed by another member of the practice staff, as should the appropriate entries into<br />

the CD register.<br />

Where a prescription is written by a doctor following administration of a CD to a patient, the<br />

doctor should endorse the form with the words ‗administered‘ and then date it. This process<br />

Page 41 of 196


aims to avoid unauthorised individuals attempting to reuse such prescriptions to obtain CDs<br />

illegally<br />

When a drug from the doctor‘s bag is administered to a patient, an entry must be made in<br />

the CD register for that bag. Personal administration should also be recorded in the<br />

patient‘s notes/computer record.<br />

Each professional should also assess the risks and benefits in relation to where they store<br />

CDs and registers in relation to each other. A balance has to be achieved between having<br />

the CD register readily available to make an entry at the time of administration, and the<br />

possibility of the bag and the register both being stolen, with the consequent loss of both<br />

the CDs and the audit trail.<br />

If CDs kept in a bag for home visits, etc. expire, they should be returned to the central<br />

practice stock for future destruction in the presence of an authorised individual. If the<br />

practice does not hold central stock, then the CDs need to be destroyed directly from the<br />

bag, witnessed by an authorised individual and appropriate records made in the CD<br />

register.<br />

A small number of GPs continue to provide their own personal service in the out-of-hours<br />

period, and would therefore use their own bag in the same way as they do during normal<br />

hours. However, the majority of GPs delegate responsibility to an organised provider of outof-hours<br />

services e.g. a GP Co-operative or a deputising service.<br />

In terms of good practice when managing CDs out-of-hours, reference should be made to<br />

the following DH guidance ‗Securing proper access to medicines in the out-of-hours period‘<br />

www.out-of-hours.info/downloads/short_medicines_guidance.pdf and the accompanying<br />

practical guide:<br />

www.out-of-hours.info/downloads/medicines_supply_guidance_a_practical_guide.pdf.<br />

Page 42 of 196


DISPENSING OF CONTROLLED DRUGS<br />

Page 43 of 196<br />

Appendix 12<br />

12.1. General<br />

In this context, the term ‗dispense‘ means to assemble and to supply a medicine<br />

(please note ‗dispense‘ is not defined in legislation).<br />

A second person should check the quantity/volume and strength of a CD being<br />

dispensed, although this may not be practiced in all situations.<br />

All CDs should normally be dispensed in child-resistant containers, or with childresistant<br />

closures.<br />

As with all dispensed medicinal products (except unlicensed medicines), it is a legal<br />

requirement to provide a manufacturer‘s patient information leaflet.<br />

Details of supplies of Schedule 2 CDs must be entered into the CD register as soon as<br />

possible and at the latest the next day following the day of supply.<br />

The date entered in the CD register should be the date of supply (i.e. the date on<br />

which the CD is handed to the patient/carer/representative) and not the date when it is<br />

assembled.<br />

The pharmacist/dispensing doctor must endorse prescriptions for Schedule 2 and 3<br />

CDs with the date of supply to the patient.<br />

Advice to patients, their representatives or carers should include safe and secure<br />

storage at home, especially out of sight and reach of children, and safe disposal by<br />

returning any unused CDs to a pharmacy.<br />

If a prescription for a CD is handed in for dispensing, but is not due to be collected until<br />

a future date or time, the prescription can be assembled in advance. However, details<br />

should not be entered in the CD register until after the CD has been supplied to the<br />

patient/carer/representative.<br />

Patients, or other people collecting Schedule 2 and 3 drugs on their behalf, should sign<br />

for them. This applies to both <strong>NHS</strong> and private prescriptions; there is space on the<br />

back of the form for this purpose. See below for details on proof of identity for<br />

Schedule 2 CDs.<br />

12.2 Dispensing against instalment prescriptions FP10 (MDA)<br />

For instalment prescriptions of Schedule 2 CDs, each supply must be entered, on the<br />

day of supply, into the relevant section of the CD register. This task must not be left<br />

until the end of the prescription period or carried out in advance.<br />

Instalments must only be supplied on the day that they are due, as specified on the<br />

prescription.<br />

Medical Services Contract) Regulations 2004 specify only a sufficient quantity of<br />

drugs as will provide treatment for not more than 14 days can be prescribed on <strong>NHS</strong><br />

instalment prescriptions.


Prescriptions are valid for 28 days. The 28 day period starts on the applicable date<br />

entered on the prescription form. This date will be the date of signing or a start date<br />

specified by the prescriber on the form. The first instalment must be dispensed within<br />

the 28-day limit, with the remainder instalments dispensed in accordance with<br />

instructions.<br />

Where appropriate, shared care arrangements for the prescribing and dispensing of<br />

CDs for substance misusers, should be developed<br />

If an instalment prescription for a CD is presented, then it should be stamped with the<br />

pharmacy/dispensing practice address at the time of the first dispensing. This is to<br />

prevent the possibility of future misdirection of the prescription.<br />

In practice, methadone prescriptions are often made up in advance, to ensure<br />

substance misusers can be dealt with in a proactive and timely manner when they<br />

present for their medicine. The pre-assembled methadone must be stored in a cabinet<br />

which meets the legal requirements, or be under the direct personal supervision of the<br />

pharmacist/doctor.<br />

If the patient does not collect the instalment, it can be returned to stock, provided it is<br />

labelled appropriately as stock, e.g. with batch number and expiry date. Where CDs<br />

are assembled in advance for instalment dispensing and not collected, the patient<br />

medication record should be amended and the prescription annotated to reflect the fact<br />

that the supply was not collected.<br />

Guidance on instalments prescribing and pharmacy closures can be found at<br />

www.rpsgb.org.uk/pdfs/LEBapprovwordinginstalprescs.pdf<br />

Pharmacists dispensing CDs to substance misusers should liaise with the prescriber<br />

regarding collection/non-collection of the CDs by these clients<br />

Patients receiving methadone, diazepam and buprenorphine may require supervision<br />

of consumption by a pharmacist. This should ideally be carried out in a quiet area of<br />

the pharmacy. This area should not normally be the dispensary, or involve taking the<br />

patient through the dispensary.<br />

Particular care should be exercised when a third party collects a CD for a patient being<br />

treated for addiction. RPSGB guidance states that third party collection of CDs for addicts<br />

should only occur in exceptional circumstances. A letter of authority from the patient should<br />

be obtained on every occasion that the representative collects the prescription and this<br />

letter should be retained in the pharmacy. If a patient regularly sends a third party to collect<br />

a supply, it may be necessary for the pharmacist to notify either the clinic where the<br />

substance misuser is being treated, or the prescriber.<br />

12.3 „Owing‟ prescriptions for controlled drugs<br />

If the pharmacist/dispensing doctor are unable to supply the total quantity of the drug<br />

requested, the entry made in the CD register must only be for the quantity of the drug<br />

actually supplied. A further entry must be made when the balance is supplied. If the patient<br />

no longer requires the balance of the prescription, the prescription should be endorsed with<br />

the amount dispensed. It is good practice to record the reason why the remainder was not<br />

dispensed, e.g. the patient has died.<br />

Page 44 of 196


Dispensed items or Owings for Schedule 2, 3 or 4 CDs cannot be supplied more than 28<br />

days after the appropriate date on the prescription.<br />

Where the prescriber has written on the prescription that it must be supplied on a specific<br />

date, as in the case for instalment prescriptions, those instructions must be complied with.<br />

Where a prescription requires a specific quantity of CDs to be dispensed on a specific date,<br />

the dispenser may not dispense a part of this quantity and then rest at a later date, as this<br />

would deviate from the prescriber‘s instructions. The stock initially held in the dispensary,<br />

plus the balance remaining, can be dispensed to the patient, as long as it is done during the<br />

same calendar day.<br />

12.4 Emergency supplies to patients<br />

Under no circumstances may an emergency supply of a schedule 2 or 3 CD be made to a<br />

patient. The only exception to this rule is phenobarbital for the treatment of epilepsy. An<br />

emergency supply of Schedule 4 or 5 CDs may be made as long as the other conditions for<br />

the supply of a POM medicine are satisfied, taking into consideration the abuse potential of<br />

these drugs.<br />

12.5 Dispensing doctors<br />

It is lawful for a dispensing doctor to delegate the act of dispensing medicines for their<br />

patients to employed staff.<br />

Practice and partners carry vicarious liability for errors made, or for the breach of the law. A<br />

dispenser or other dispensing doctor employee would not normally be expected to dispense<br />

a Schedule 2 or 3 CD without first checking the dispensed items with a doctor. The<br />

Dispensing Doctor‘s Association‘s Guidelines for dispensing doctors state that ‗the doctor<br />

should check all prescriptions for CDs‘.<br />

Updated guidance on managing the use of CDs is available from the Dispensing Doctor‘s<br />

Association www.dispensingdoctor.org/.<br />

12.6 Proof of Identity; Prescriptions for Schedule 2 controlled drugs<br />

Patients or their representatives may require evidence of identity when collecting Schedule<br />

2 CDs.<br />

Persons asked to supply Schedule 2 CDs on prescription must seek to establish whether<br />

the person collecting the drug is the patient, the patient‘s representative or a health care<br />

professional acting in his professional capacity on behalf of the patient.<br />

Where the person is the patient or the patient‘s representative, e.g. a friend, neighbour, etc.,<br />

the dispenser<br />

May request evidence of that person‘s identity, and<br />

May refuse to supply the drug if he is not satisfied as to the identity of that person<br />

Where the person collecting the prescription is a health care professional acting in his<br />

professional capacity on behalf of the patient, the dispenser:<br />

Must obtain the person‘s name and address<br />

Must, unless he is acquainted with that person, request evidence of that person‘s<br />

identity; but<br />

May supply the drug even if he is not satisfied as to the identity of that person.<br />

Page 45 of 196


Any strengthening of controls has been balanced with ensuring that patients have access to<br />

medicines they need and have been prescribed for them. The new requirement placed on<br />

the dispenser therefore allows them:<br />

Discretion not to ask patients or patient representatives for proof of identity if for<br />

example they have concerns that to do so may compromise patient confidentiality or<br />

deter patients from having their medicine dispensed.<br />

It is a requirement to record the following information in the CD register for Schedule 2 CDs<br />

supplied on prescription:<br />

Whether the person who collected the drug was the patient, the patient‘s<br />

representative or a health care professional acting on behalf of the patient.<br />

If the person who collected the drug was a health care professional acting on behalf<br />

of the patient, that person‘s name and address.<br />

If the person collected the drug was the patient or their representative, whether<br />

evidence of identity was requested (as a matter of good practice a note as to why the<br />

dispenser did not ask may be included but this is not mandatory).<br />

And whether evidence of identity was provided by the person collecting the drug.<br />

RPSGB have issued professional guidance ‗Changes in the management of CDs affecting<br />

pharmacists (England, Scotland and Wales)‘ for their members on what forms of<br />

identification may be considered suitable and advice on circumstances where discretion<br />

should be exercised. This guidance is available from the following website:<br />

www.rpsgb.org.uk/pdfs/cdmanagechguid.pdf<br />

It is good practice to record information to support the proof of identity requirements<br />

outlined.<br />

As a matter of good practice, the form of identification for health care professionals should<br />

be their professional registration number.<br />

Page 46 of 196


RECORDING OF CONTROLLED DRUGS<br />

Page 47 of 196<br />

Appendix 13<br />

This section applies to all CD registers, whether held by a doctor, a pharmacist or other<br />

health care professional (personally or as part of the activities of an organisation).<br />

Records for Schedule 2 CDs must be kept in a CD register. This is not a legal requirement<br />

for Schedule 3, 4 or 5 CDs.<br />

All health care professionals who hold personal CD stock must keep their own CD register,<br />

and they are personally responsible for keeping this accurate and up-to-date.<br />

13.1 <strong>Controlled</strong> Drug Registers<br />

Currently the register must:<br />

Be bound (not loose-leaved) or a computerised system which is in accordance with best<br />

practice guidance<br />

Contain class sections for each individual drug<br />

Have the name of the drug specified at the top of each page<br />

Have the entries in chronological order and made on the day of the transaction or<br />

the next day<br />

Have the entries made in ink or otherwise so as to be indelible or in a computerised<br />

form in which every such entry is attributable and capable of being audited and is in<br />

accordance with the best practice guidance endorsed by the Secretary of State<br />

under Section 2 of the <strong>NHS</strong> Act 1977.<br />

Not have cancellations, obliterations or alterations: corrections must be made by a<br />

signed and dated entry in the margin or at the bottom of the page.<br />

Be kept at the premises to which it relates and be available for inspection at any<br />

time. A separate register must be kept for each set of premises (for example, not just<br />

the main surgery)<br />

Be kept for a minimum of two years after the date of the last entry, once completed<br />

Not be used for any other purpose<br />

13.2 Computerised controlled drug registers<br />

If the CD register is held in computerised form it must be attributable and capable of being<br />

audited the following should be put in place:<br />

Safeguards should be incorporated in the software to ensure the author of each entry<br />

is identifiable<br />

Entries cannot be altered at a later date<br />

A log of all data entered is kept and can be recalled for audit purposes<br />

Full details see www.opsi.gov.uk/si/si2005/20052864.htm<br />

13.4 Record keeping requirements<br />

For CDs received into stock the following details must be recorded in the CD register:<br />

The date on which the CD was received<br />

The name and address of the supplier, e.g. wholesaler, pharmacy<br />

The quantity received<br />

The name, form and strength of the CD<br />

For CDs supplied to patients (via prescriptions), or to practitioners (via requisitions),<br />

or personally administered the following details must be recorded in the CD register<br />

The date on which the supply/ administration was made


The name and address of the patient or practitioner receiving the CD<br />

Particulars of the authority of person who prescribed or ordered or administered the<br />

CD<br />

The quantity supplied/administered<br />

The name, form and strength in which the CD was supplied/administered<br />

The 2001 Regulations were amended in July 2006 to make clear that the record keeping<br />

requirements of the CD Regulations are a minimum and do not prevent any person required<br />

to keep a CD register from including additional related information.<br />

It is good practice to record the batch number and expiry date of the CD, time of<br />

administration and maintain a running balance.<br />

13.5 Prescriber and dispenser details<br />

CD registers are allowed but not required to include:<br />

The prescriber identification number (six digit private prescriber code or the <strong>NHS</strong><br />

prescriber code) and or professional registration number of the prescriber where<br />

known<br />

The name and professional registration number of the pharmacist or dispensing<br />

doctor<br />

As the dispensing of a prescription can involve several pharmacists, it should be the<br />

pharmacist who makes the supply of CDs to a patient or his/her representative whose name<br />

and professional number are entered in the CD register.<br />

13.6 Maintaining a running balance of stock<br />

Pharmacists and other health care professionals who supply CDs should maintain a running<br />

balance of stock in their CD registers as a matter of good practice. The aim of maintaining<br />

running balances in CD registers is to ensure irregularities are identified as quickly as<br />

possible.<br />

The running balance of drug remaining should be calculated and recorded after each<br />

transaction and balances should be checked with the physical amount of stock at regular<br />

intervals. Guidance on this can be found on the RPSGB website<br />

www.rpsgb.org.uk/pdfs/cdrunningbalanceguid.pdf<br />

Accountability for maintaining the running balance of CD stock and dealing with any<br />

discrepancies lies with the health care professional in charge and not with the person to<br />

whom they may delegate day-to-day responsibility under defined SOPs.<br />

13.7 Physical reconciliation with stock levels<br />

The running balance recorded in the CD register should be checked with the physical<br />

amounts of stock at regular intervals, at least once a month is recommended for infrequent<br />

users (i.e. GP practices) or weekly where there is a high usage or turnover of staff (i.e.<br />

OOH)<br />

Wherever possible, two members of staff should check all stock received or removed, and<br />

both individuals should initial the entry in the CD registers, or a record made that the stock<br />

balance has been checked.<br />

It is good practice for a health care professional/registered manager or registered provider,<br />

when first taking over accountability for premises that hold CD stock, and where they will be<br />

in regular attendance, to ensure the CD stock levels are correct. This primarily applies to:-<br />

Page 48 of 196


GP practices holding CD stock in the surgery<br />

Pharmacies<br />

Dispensing doctor practices<br />

Care homes, community hospitals and hospices<br />

Independent health care establishments, hospitals and community hospitals without<br />

a pharmacy.<br />

Where changeover of responsibility occurs very frequently, e.g. when multiple locums are<br />

required within community pharmacies, out-of-hours providers or GP practices, it would be<br />

impractical to carry out stock checks at every changeover. SOPs for the reconciliation of<br />

physical stock with balances should define how often this task takes place; as a minimum it<br />

should take place weekly. If usage of CDs is high, e.g. in drug and alcohol units, palliative<br />

care establishments, etc., then stock checks should be carried out more frequently and by<br />

different, suitably trained members of staff. The day-to-day responsibility for this task can be<br />

delegated under SOPs, to another appropriate, suitably trained, member of staff who is<br />

routinely present at the premises.<br />

The accountability for maintaining the correct balance of CD stock lies with the professional<br />

in charge and not with the person to whom they may delegate the day-today responsibility.<br />

13.8 Preservation of records<br />

Registers, requisitions and orders for CDs must be preserved for two years. It is<br />

recommended that records are preserved for longer as this may be required as evidence if<br />

an untoward incident occurs and investigations may take longer than 2 years<br />

13.9 Dealing with discrepancies<br />

SOPs should clearly define the action to be taken if a discrepancy arises. Once resolved,<br />

a note should be made in the CD register correcting the discrepancy in the balance. It is<br />

also advisable to keep appropriate records of the action taken when discrepancies arise.<br />

If the source of the discrepancy cannot be identified during the stock check, then a<br />

nominated member of the relevant organisation should be informed and a formal internal<br />

investigation undertaken. This process may include discussion with the relevant<br />

professional body, or other inspectors. If this still does not resolve the issue satisfactorily<br />

then the police should be informed. The Accountable Officer should be informed of any<br />

concerns in relation to the management and use of CDs.<br />

Page 49 of 196


TRANSPORTATION OF CONTROLLED DRUGS<br />

Page 50 of 196<br />

Appendix 14<br />

All health care professionals in legal possession of a CD have a professional duty of care to<br />

take all reasonable steps to maintain safe custody of that CD at all times.<br />

Nurses, midwives, doctors, pharmacists, pharmacy staff and other health care<br />

professionals, plus formal carers and patients‘ representatives, are legally allowed to<br />

transport CDs to a patient, provided the CDs have been prescribed, by an appropriate<br />

prescriber, for the patient.<br />

Any nominated individual is also allowed to return CDs from the patient to the pharmacy, or<br />

the practice for destruction.<br />

The person authorised to possess may grant permission, and it should be in writing.<br />

Community pharmacies and GP practices must not accept waste medicines, including CDs,<br />

from care homes providing nursing care.<br />

Health care professionals involved in the delivery of patient care should not routinely<br />

transport a patient‘s own CDs to and from the patient‘s home. Where this is essential, part<br />

of an organised service, or where pharmacies operate collection and delivery schemes to<br />

the household and other needy patients, it is good practice to keep the CDs out of view<br />

during transit.<br />

CDs should not generally be transported via mail, taxi services or equivalent. However, in<br />

exceptional circumstances, where urgent clinical need dictates, dispensed CDs can be sent<br />

to a patient, or stock CDs to premises, via such routes. Where the mail route is used, the<br />

CD should always be sent as a special delivery item to ensure the pathway is auditable.<br />

If transport of CDs or CD prescriptions via mail, taxi services or equivalent has to be used<br />

an SOP should be developed which reflects a risk management assessment.


ADMINISTRATION OF CONTROLLED DRUGS<br />

Page 51 of 196<br />

Appendix 15<br />

A record of administration should be made in the patient‘s records which detail dose, form<br />

and route, site of injection, expiry date, time of administration and if records require this the<br />

batch number and expiry date.<br />

If the patient has nursing records for administration of medicines, (i.e. palliative care,<br />

residential care homes and hospices) these should be completed by the person<br />

administering the medicine, (this also applies to the patient, carer, visiting doctor etc) so a<br />

full record is made to avoid accidental overdose.<br />

Also, if the patients nursing records have a running balance of the patients own controlled<br />

drugs this should be maintained by all visiting healthcare professionals.


NURSES WORKING IN THE COMMUNITY<br />

Page 52 of 196<br />

Appendix 16<br />

16.1 Transportation<br />

Nurses should not routinely transport CDs. This should only be undertaken in<br />

circumstances where there is no other reasonable mechanism available. CDs should be<br />

kept out of sight during transportation.<br />

16.2 Administration<br />

Nurse may administer CDs to a patient in their care, as long as they are acting in<br />

accordance with the directions of a doctor or dentist or in accordance with an approved<br />

Patient Group Direction.<br />

Nurse independent prescriber‘s, or nurses acting under the directions of a nurse<br />

independent prescriber, can administer the CDs listed in the table in Appendix O but solely<br />

for the medical conditions specified.<br />

Midwives may administer diamorphine, morphine, pentazocine and pethidine to their<br />

patients, acting on their own professional judgement.<br />

Any CD that is administered by a nurse must be recorded in the nurse‘s and patient‘s notes,<br />

stating the medicine and dose administered, the date of administration, the method of<br />

administration and the person who administered it.<br />

For CDs stored in a patient‘s home, the nurse should keep a running balance. Any<br />

discrepancy must be investigated and reported to the nurse manager, the Head of<br />

Medicines Management and an incident form completed.<br />

16.3 Administration on a verbal instruction<br />

The NMC has published ‗Guidelines for the administration of medicines‘, which includes<br />

guidance on CDs, and is available at:<br />

www.nmc-uk.org/aFrameDisplay.aspx?DocumentID=610<br />

16.4 Disposal of controlled drugs<br />

Prescribed drugs including CDs are the property of the patient and remain so even after<br />

death. However, it is illegal to possess CDs that have not been prescribed for you. In the<br />

first instance the patient/patient‘s relatives should be advised that all CDs no longer<br />

required should be returned to a pharmacy for safe destruction.<br />

It should not normally be the responsibility of the community nurses to become involved in<br />

the disposal of unwanted CDs. However, there may be occasions when it is appropriate for<br />

nursing staff to become involved in recovery/disposal of CDs.<br />

A possible staged approach would be:<br />

If return by relatives/next of kin is not practical or possible then the following action<br />

could be taken<br />

Nurse with another member of the nursing team acting as a witness disposes of CD<br />

in an appropriate and safe manner. This should be within an agreed local SOP and<br />

should include appropriate record keeping in patient‘s notes. See Appendix P and Q<br />

for details on safe disposal of controlled drugs.<br />

Or<br />

Nurse could take CDs to local community pharmacy who would be asked to<br />

countersign patient nursing record.<br />

Appendix 17


PALLIATIVE CARE<br />

17.1 Good Practice<br />

It is good practice to only prescribe quantities of CDs that are needed by the patient for<br />

effective symptom control. This can include CDs for regular dosage, plus a quick-acting CD<br />

at an appropriate dose for breakthrough pain. The good practice principles for managing<br />

CDs described earlier in these guidelines apply equally to the palliative care situation.<br />

Where prescriber‘s are prescribing high doses CDs for palliative care, it is recommended<br />

that the specialist palliative care team are contacted for advice and support, wherever<br />

feasible. Any actions resulting from such a contact should be recorded in the patient‘s<br />

notes.<br />

If a prescriber is prescribing high doses of CDs for a patient, particularly where prolonged<br />

use is expected, then it is recommended that this is reported to the Medicines Management<br />

team at the PCT to aid the interpretation of routine ePACT data.<br />

Palliative care patients may obtain CD prescriptions from more than one source, e.g. GPs,<br />

hospices, hospitals, out-of-hours services and specialist palliative care teams. In such<br />

circumstances, one professional in the locality, could take on a co-ordinating role to avoid<br />

over-supply and to help maintain patient and public safety.<br />

Additional sources of information:<br />

Cancer Care Alliance www.cancernorth.nhs.uk or www.cancercarealliance.nhs.uk<br />

Liverpool Care Pathway www.lep-mariecurie.org.uk<br />

<strong>NHS</strong> End of Life Programme www.endoflifecare.nhs.uk<br />

National Council for Palliative Care www.ncpc.org.uk<br />

PCT Syringe Driver <strong>Policy</strong> http://intranet/PCTServices/2041.htm<br />

17.2 Out-of-hours palliative care<br />

There are sometimes problems encountered with the availability of medicines for palliative<br />

care patients in the community during the out-of-hours period. To maintain effective<br />

symptom control in patients choosing to be treated at home, or in other care environments,<br />

it is important that health care professionals ensure sufficient quantities of appropriate<br />

palliative care drugs, including CDs, are available to anticipate deterioration in the patient‘s<br />

condition. The potential needs of deteriorating conditions need to be balanced with the<br />

safety risk of increased quantities of CDs left in the domiciliary/care setting.<br />

For specific recommendations about the manner in which a patient-centred, high quality<br />

palliative care service can be provided out-of-hours, please refer to ‗Securing proper access<br />

to medicines in the out-of-hours period‘<br />

www.out-of-hours.info/downloads/short_medicines_guidance.pdf<br />

and the accompanying practical guide<br />

www.out-of-hours.info/downloads/medicines_supply_guidance_a_practical_guide.pdf.<br />

And the<br />

PCT Syringe Driver <strong>Policy</strong> – http://intranet/PCTServices/2041.htm<br />

Page 53 of 196


SELF-MEDICATION<br />

Page 54 of 196<br />

Appendix 18<br />

If patients are self-medicating, whether in a hospice or hospital, their CDs should be kept in<br />

a locked metal receptacle immediately adjacent to their bed, or in their bedside locker. The<br />

receptacle should not be readily portable. In order to prevent unauthorised access, each<br />

receptacle should have an individual key, with a master key kept by the person in charge<br />

(on duty).<br />

Where a patient is being treated in their own home, professional advice and supporting<br />

information should be provided in a timely way, by the most appropriate professional, to<br />

ensure safety and efficacy is maintained.


PATIENTS TRAVELLING OVERSEAS<br />

Page 55 of 196<br />

Appendix 19<br />

Travellers carrying prescribed drugs controlled under Schedules 1, 2, 3 and 4 Part I to The<br />

Misuse of <strong>Drugs</strong> Regulations 2001 may require a personal licence.<br />

Persons travelling for over three months either abroad or to the United Kingdom<br />

will need to have a personal licence.<br />

If a person is staying outside their resident country for a period exceeding 3 months<br />

they are advised to register with a doctor in the country they are visiting for the<br />

purpose of receiving further prescriptions.<br />

Persons travelling for three months or fewer will not need a personal export/import<br />

licence.<br />

Applications should be made at least 10 days prior to travel.<br />

Licences are normally issued with an expiry date of one week after the expected return to<br />

the UK.<br />

A personal licence has no legal standing outside the UK and is intended to allow travellers<br />

to pass through the UK customs unhindered.<br />

Other countries may have their own import regulations for controlled drugs.<br />

Travellers should check this with the UK-based representative(s) of the<br />

country/countries to which they are travelling.<br />

Further details and Personal licence application forms can be downloaded from Personal<br />

licences | Home Office - Tackling <strong>Drugs</strong> Changing Lives<br />

It is good practice for CDs to be carried in original packaging in hand luggage with a letter<br />

from the prescribing doctor confirming the carriers name, destination, drug details and<br />

amount.


DESTRUCTION OF CONTROLLED DRUGS<br />

20.1 Stock controlled drugs (including doctor‟s bags)<br />

Stock refers to CDs that have not been issued/dispensed to a patient.<br />

Page 56 of 196<br />

Appendix 20<br />

When Schedule 2 CDs plus temazepam, flunitrazepam, buprenorphine and diethylpropion<br />

pass their expiry date, they should be stored in the CD cabinet/safe or doctors bag (if no<br />

central stock held in practice) until destruction. They should be segregated and clearly<br />

marked as ‗date-expired‘ stock to prevent them being issued in error to patients.<br />

20.1.1 Authorised witnesses<br />

Destruction of obsolete, expired and unwanted Schedule 2 CD stock must be witnessed by<br />

an authorised person.<br />

The following classes of people are currently authorised by the Secretary of State for Health<br />

and the Home Secretary to witness the destruction of CDs: -<br />

Chief dental officer of the DH or a senior dental officer to whom authority has been<br />

delegated<br />

Supervisors of midwives appointed by the Local Supervising Authority<br />

Senior officers in an <strong>NHS</strong> Trust who report directly to the Trust Chief Executive and<br />

who have responsibility for health and safety, security or risk management matters in<br />

the Trust<br />

Chief Executives of <strong>NHS</strong> Trusts<br />

A PCT chief pharmacist or pharmaceutical/prescribing adviser who reports directly to<br />

the chief executive or to a director of the PCT<br />

A registered medical practitioner who has been appointed to the PCT Professional<br />

Executive Committee or equivalent<br />

The PCT board executive member with responsibility for clinical governance or risk<br />

management<br />

Medical director of a PCT<br />

Inspectors of the RPSGB<br />

Police constables<br />

Holders of specific roles within the independent health care sector, for example,<br />

registered managers of independent hospitals.<br />

Public limited companies operating retail pharmacies nominated persons for their<br />

own stock of CDs<br />

Persons in charge or acting person in charge of private hospitals providing palliative<br />

care or hospices wholly or mainly maintained by a public authority out of public funds<br />

or by a charity or by voluntary subscription.<br />

Persons or class of persons authorised by the Accountable Officer<br />

For <strong>County</strong> <strong>Durham</strong> and Darlington PCTs Authorised persons see Appendix Q.<br />

Stock CDs from GP practices, dentists, vets, midwives, community hospitals, Out of<br />

Hours/Urgent Care centres or nursing homes should not be sent to a pharmacy for<br />

destruction. Practices should contact an authorised witness.<br />

An authorised person cannot witness the destruction of CDs that have been supplied to<br />

them or by them – there must be an appropriate separation of roles and responsibilities.


Anyone directly involved with a GP practice, or who is authorised to supply CDs from the<br />

GP practice, e.g. a PCT clinical governance lead working in their own practice, or practice<br />

based pharmacists, must not be asked to witness the destruction of CDs in that GP<br />

practice, even if they are included within the authorised groups.<br />

Home Office <strong>Drugs</strong> Licensing is responsible for the processing of applications for<br />

authorisation to witness the destruction of CDs under Regulation 27(1) of the Misuse of<br />

<strong>Drugs</strong> Regulations 2001. These authorisations cover the holders of specified jobs and<br />

locations within the private sector, e.g. regional managers of major retail pharmacy chains.<br />

For further information, contact the Home Office <strong>Drugs</strong> Licensing on 0207 035 0483 or<br />

email Licensing enquiry. aadu@homeoffice.gsi.gov.uk.<br />

Accountable Officers should not be designated as authorised people to witness destruction<br />

as one of the criteria for Accountable Officers is their independence from day-to-day<br />

management of CDs.<br />

20.1.2 Recording<br />

When a CD is destroyed, details of the drug must be entered into the CD register. This<br />

should include: the name of the drug; form; strength and quantity; the date it was destroyed;<br />

and the signature of the authorised person who witnessed the destruction and the<br />

professional destroying it (i.e. two signatures)<br />

20.2 „Patient-returned‟ controlled drugs<br />

‗Patient-returned‘ CDs are those that have been prescribed for, and dispensed to, a named<br />

patient and then returned unused or part-used for destruction.<br />

<strong>Controlled</strong> <strong>Drugs</strong> (Supervision of Management and Use) Regulations 2006 require SOPs to<br />

be in place for maintaining a record of Schedule 2 drugs that have been returned by the<br />

patients.<br />

It is good practice for pharmacists and doctors to keep a separate book to record all CDs<br />

returned by patients. Although it is not a legal requirement to witness destruction of ‗patientreturned‘<br />

CDs by an authorised witness, good practice would recommend that they are<br />

witnessed by another member of staff and the signature of both the person witnessing and<br />

the person destroying should be entered in a separate book set aside for this purpose<br />

Medicines returned from patient stocks should NOT be re-issued or used to treat other<br />

patients.<br />

For pharmacists, the RPSGB Code of Ethics prevents pharmacists reusing patient returns.<br />

A breach of this requirement could form the basis of disciplinary action.<br />

Community pharmacies can accept CDs returned by patients from their own homes and<br />

from care homes (personal care) for safe destruction and onward disposal even if they did<br />

not originally dispense them.<br />

Pharmacists are not able to accept waste medicines, including CDs, from care homes<br />

(nursing), unless the pharmacy holds a waste management licence. It should be noted<br />

that the definition of ―care services‖ may exclude certain <strong>NHS</strong> premises.<br />

Under the Waste Management Regulations, a pharmacy does not require a Waste<br />

Management Licence to store its own unwanted expired stock, pending disposal. There is<br />

also an exemption in the Waste Management Licence Regulations for the secure storage at<br />

a pharmacy, pending disposal, of waste medicines, which have been returned to the<br />

Page 57 of 196


pharmacy from households or by individuals. This includes waste medicines from a<br />

patient‘s own home or a care home providing residential care, but NOT from a care home<br />

providing nursing care (this is classed as industrial waste).<br />

20.3 Methods of destruction<br />

CDs can be placed into waste containers only after the CD has been rendered irretrievable<br />

(i.e. by denaturing). See Appendix P and Q.<br />

The RPSGB issues guidance on the methods of destruction/denaturing that meet the<br />

requirements of the Misuse of <strong>Drugs</strong> Regulations 2001 and the health and safety needs of<br />

people undertaking the role.<br />

20.4 Environment Agency Regulations and permissions on waste<br />

The destruction and disposal of CDs are also subject to Waste Management Licensing<br />

Regulations 1994. Having considered the risks posed by destruction of CDs in a pharmacy,<br />

the Environment Agency (EA). Which covers England and Wales, has decided that it does<br />

not believe it is in the public interest to expect pharmacies to obtain a waste management<br />

licence for denaturing CDs and this is seen by the EA as a ‗low risk‘ activity. The EA<br />

emphasises, however, that it may amend or revoke its position at any time and will continue<br />

enforcement in all circumstances where activity has or is likely to cause pollution or harm to<br />

health.<br />

For further information on Waste Management Regulation visit the following website:<br />

www.environmentagency.gov.uk.<br />

Guidance on The Hazardous Waste Regulations 2005 can be found on the RPSGB<br />

website:<br />

www.rpsgb.org/pdfs/hazwastehospphguid.pdf. Since the guidance was published, the EA<br />

has agreed that pharmacists may de-blister and otherwise treat waste CDs in a pharmacy<br />

without the need to obtain a licence. Further information on this may be found on the EA<br />

website: www.environment-agency.gov.uk<br />

Page 58 of 196


STANDARD OPERATING PROCEDURES<br />

Page 59 of 196<br />

Appendix 21<br />

Standards for Better Health Core Standard 4d requires each service and practice to have<br />

clear practice policy covering issues relating to the prescribing, ordering, receipt, storage,<br />

monitoring and disposal of controlled drugs. This policy should ensure that there is a full<br />

audit trail for the movement of controlled drugs in primary care form acquisition to<br />

administration and disposal.<br />

Standard operating procedures must be developed which describes the responsibilities and<br />

procedures to provide clarity and consistency for all staff handling controlled drugs within<br />

agreed working practices and current legislation.<br />

Each service should have a designated person responsible for the management of<br />

controlled drugs on the premises.<br />

Each Nursing team should have procedures in place to ensure the safe handling of<br />

controlled drugs in the domiciliary and educational setting.<br />

Baseline information which should be contained in an SOP can be found in Appendix T.


Page 60 of 196<br />

Appendix 22<br />

PATIENT INFORMATION<br />

<strong>NHS</strong> Direct<br />

The <strong>NHS</strong> direct website has developed a Common Health Question about CDs specifically<br />

to inform the public and is available from What is a controlled drug (medicine)? - Health<br />

Questions - <strong>NHS</strong> Direct<br />

Medicines Guides for patients<br />

Medicines guides provide a source of information for members of the public who are looking<br />

for information about individual medicines. Guides for CDs that have been published can be<br />

found at Medicine Guides - Welcome


Appendix A – List of <strong>Controlled</strong> <strong>Drugs</strong> and their Schedules<br />

This list is not exhaustive: it covers the most common drugs encountered in general<br />

practice. Practice computer system may be able to help for specific examples not listed<br />

below. Brand names are not listed except where no generic name exists, or is not<br />

commonly used.<br />

Schedule 1 CDs are drugs with virtually no medical uses, such as cannabis and<br />

hallucinogens. Possession and supply of these drugs is limited to persons granted a special<br />

licence by the Home Office except for Sativex spray. It is not a requirement for a prescribing<br />

doctor or dispensing pharmacist to contact the Home Office in relation to obtaining a licence<br />

to prescribe or supply Sativex spray. The Home Office has also lifted the record-keeping<br />

requirements and, therefore, pharmacists do not need to record Sativex in their CD<br />

registers.<br />

<strong>Controlled</strong> drug<br />

Schedule<br />

<strong>Controlled</strong> drug<br />

Schedule<br />

Amobarbital (Sodium<br />

Amytal<br />

3 Fentanyl 2<br />

Anabolic Steroids 4 (part 2) Flunitrazepam 3<br />

Benzodiazepines<br />

Hydromorphone 2<br />

(Except temazepam,<br />

midazolam,<br />

flunitrazepam)<br />

4 (part 1)<br />

Buprenorphine 3 Kaolin & Morphine<br />

Mixture & tablets<br />

5<br />

Chlordiazepoxide 4 (part 1) Meprobamate 3<br />

Cocaine 2 Methadone 2<br />

Co-codamol 5 Midazolam 3<br />

Codeine<br />

2<br />

Morphine * 2<br />

Oral codeine max<br />

strength


Appendix B Summary of Legal Requirements of the Possession and Supply of CDs<br />

Prescription requirements<br />

Handwriting requirements<br />

Requisitions necessary<br />

Records to be kept in CD register<br />

Emergency supplies allowed<br />

Safe Custody<br />

Date of supply to marked on<br />

prescription<br />

Address of prescriber to be within<br />

the UK<br />

Stock destruction to be witnessed<br />

Validity of prescription<br />

Invoices to be kept for 2 years<br />

Import / export licence required<br />

Yes<br />

No<br />

Yes<br />

Yes<br />

No<br />

Yes<br />

Yes<br />

Yes<br />

Yes<br />

28 days<br />

No<br />

Yes<br />

Schedule 2: CD<br />

Secobarbital<br />

Yes<br />

No<br />

Yes<br />

Yes<br />

No<br />

No<br />

Yes<br />

Yes<br />

Yes<br />

28 days<br />

No<br />

Yes<br />

Yes<br />

No<br />

Yes<br />

No<br />

No<br />

No<br />

Yes<br />

Yes<br />

No<br />

28 days<br />

Yes<br />

Yes<br />

Phenobarbital<br />

Yes<br />

No<br />

Yes<br />

No<br />

Yes<br />

No<br />

Yes<br />

Yes<br />

No<br />

28 days<br />

Yes<br />

Yes<br />

Schedule 3: CD No Reg<br />

Temazepam<br />

No<br />

No<br />

Yes<br />

No<br />

No<br />

Yes<br />

Yes<br />

Yes<br />

No<br />

28 days<br />

Yes<br />

Yes<br />

Diethylpropion<br />

Flunitrazepam<br />

(Rohypnol)<br />

Yes<br />

No<br />

Yes<br />

No<br />

No<br />

Yes<br />

Yes<br />

Yes<br />

No<br />

28 days<br />

Yes<br />

Yes<br />

Buprenorphine<br />

(Subutex)<br />

Yes<br />

No<br />

Yes<br />

No<br />

No<br />

Yes<br />

Yes<br />

Yes<br />

No<br />

28 days<br />

Yes<br />

Yes<br />

Schedule 4:<br />

CD Benz and<br />

CD Anab<br />

No<br />

No<br />

No<br />

No<br />

Yes<br />

No<br />

No<br />

No<br />

No<br />

28 days<br />

Yes<br />

Yes<br />

Schedule 5:<br />

CD Inv<br />

No<br />

No<br />

No<br />

No<br />

Yes<br />

No<br />

No<br />

No<br />

No<br />

6 months<br />

Yes<br />

Yes


Appendix C<br />

Relevant Contact Details Re: <strong>Controlled</strong> <strong>Drugs</strong><br />

Contact Title Email Telephone<br />

Dr. Hilton Accountable hilton.dixon@nhs.net<br />

0191 3011300<br />

Dixon Officer for<br />

<strong>County</strong> <strong>Durham</strong><br />

and Darlington<br />

PCTs<br />

Kate<br />

Huddart<br />

Vicki<br />

Vardy<br />

Alison<br />

Hopkins<br />

Paul<br />

Errington<br />

Senior<br />

Pharmaceutical<br />

Adviser for<br />

<strong>County</strong> <strong>Durham</strong><br />

and Darlington<br />

PCTs<br />

<strong>Controlled</strong> Drug<br />

Accountable<br />

Officer Support<br />

and Data<br />

Manager for<br />

<strong>County</strong> <strong>Durham</strong><br />

and Darlington<br />

PCTs<br />

RPSGB<br />

Professional<br />

Standards<br />

Inspector<br />

<strong>Controlled</strong> Drug<br />

and Chemical<br />

Liaison Officer<br />

Kate.huddart@nhs.net 01388 825687<br />

Vicki.vardy@nhs.net 01388 825680<br />

Alison.hopkins@rpsgb.org<br />

020 75722557<br />

Paul.errington@durham.pnn.police.uk 0191 3752626


Appendix D<br />

Information Sharing Code in respect of the operation of the <strong>County</strong> <strong>Durham</strong> and<br />

Darlington Local Intelligence Network for controlled drugs governance<br />

Disclaimer<br />

The contents should not be used as expert opinion, legal or otherwise.<br />

Professional advice should be sought where appropriate. Any liability arising<br />

from action taken in relation to the contents of the Protocol is excluded.<br />

Version 3 November 2009<br />

Page 64 of 196


Information Sharing Code in respect of the operation of the <strong>County</strong> <strong>Durham</strong> and<br />

Darlington Local Intelligence Network for controlled drugs governance<br />

Contents<br />

Section 1 – Background and scope of the Code<br />

Section 2 – Purposes for sharing information<br />

Section 3 – Information to be shared<br />

Section 4 – Arrangements for sharing information<br />

Section 5 – Access and security<br />

Section 6 – Dissemination, monitoring and review<br />

Section 7 – Advice and guidance<br />

Appendices<br />

Appendix 1 – Data Protection and Caldicott principles<br />

Appendix 2 –<strong>County</strong> <strong>Durham</strong> and Darlington Local Intelligence Network<br />

Appendix 3 – Specialist advice and guidance<br />

Page 65 of 196


Section 1<br />

Background and scope of the Code<br />

1.1 Background<br />

Legislation, guidance and Government policy all emphasise the importance of<br />

confidentiality and the protection of personal information. Strong emphasis is also<br />

placed on the need to share information in order to provide effective, integrated<br />

services.<br />

The Heath Act 2006 includes a legal duty of collaboration for local agencies to share<br />

information, within certain constraints, about the use of controlled drugs in the health<br />

and social care sectors. The active duty of collaboration should be manifested through<br />

the operation of a Local Intelligence Network (LIN) through which information can be<br />

shared, analysed and acted upon.<br />

Within the Department of Health Safer Management of controlled drugs: (1) guidance<br />

on strengthened governance arrangements published in January 2007 it states:-<br />

Care should also be taken with sharing information about identifiable health and social<br />

care professional and where possible, they should be made aware of concerns raised<br />

about them. Intelligence networks may wish to agree a code on information-sharing<br />

and nominate a person to be responsible for ensuring the code is followed.<br />

This Information Sharing Code (ISC) has been drawn up by the LIN to assist the<br />

appropriate sharing of information, some of which may be personal information, about<br />

the use of controlled drugs.<br />

The code is intended to reinforce current working practices, give guidance to staff and<br />

be a training resource for new members of staff. It defines the information which will be<br />

transferred between the organisations listed and arrangements for assisting<br />

compliance with relevant legislation and guidance including the Data Protection Act,<br />

1998.<br />

1.2 Framework for confidentiality and information sharing<br />

Four key documents provide the main national framework for information sharing:<br />

Data Protection Act 1998 – This Act provides the main legislative framework for<br />

confidentiality and information sharing issues. The Act stipulates eight principles<br />

(see Appendix 1) that must be followed when personal information is ―processed‖<br />

by organisations. (“Processing” refers to any work done with personal information<br />

including obtaining, recording, viewing, listing, disclosing and destroying.) The Act<br />

stipulates the conditions under which information may be shared i.e. the legal<br />

justifications.<br />

Human Rights Act 1998 – This Act incorporates Article 8 of the European<br />

Convention of Human Rights which provides that everyone has the right to respect<br />

for their private and family life, home and correspondence.<br />

Caldicott Guidance – The Caldicott Committee produced their report on the<br />

―Review of Patient Identifiable Information‖ in December 1997. Caldicott guidance<br />

applies to all <strong>NHS</strong> organisations and local authority Social Services Departments.<br />

Guidance is based on six key principles (see Appendix 1). Organisations are<br />

required to appoint Caldicott Guardians to oversee the confidentiality / information<br />

sharing process.<br />

Page 66 of 196


The <strong>NHS</strong> Confidentiality Code of Practice – The Code of Practice was issued in<br />

July 2003 and applies to all <strong>NHS</strong> organisations. It is a guide to required practice on<br />

confidentiality, security and disclosure of personal information.<br />

The health and social care agencies in <strong>County</strong> <strong>Durham</strong> and Darlington have developed<br />

this Information Sharing Agreement to formalise good practice guidelines for sharing<br />

information with regard to controlled drugs.<br />

1.3 Members of LIN that will work within the code<br />

� <strong>County</strong> <strong>Durham</strong> Primary Care Trust<br />

� Darlington Primary Care Trust<br />

� <strong>County</strong> <strong>Durham</strong> and Darlington Foundation Trust<br />

� Tees, Esk and Wear Valley <strong>NHS</strong> Trust<br />

� Woodlands Hospital, Darlington<br />

� St Cuthbert‘s Hospice<br />

� St Theresa‘s Hospice<br />

� Willowburn Hospice<br />

� The Inspectorate of the Royal Pharmaceutical Society of Great Britain (RPSGB)<br />

� Care Quality Commission<br />

� <strong>Durham</strong> Constabulary<br />

� <strong>County</strong> <strong>Durham</strong> Social Services.<br />

� Darlington Social Services<br />

� North East <strong>NHS</strong> (Strategic Health Authority)<br />

� North East Ambulance Service (NEAS)<br />

� <strong>NHS</strong> Counter Fraud and Security Management<br />

� <strong>Durham</strong> DAAT<br />

� Darlington DAAT<br />

� Prison Cluster representation<br />

As the Local Intelligence Network matures it may be necessary to include any other<br />

responsible body (as defined within the CD regulations) located in <strong>County</strong> <strong>Durham</strong> and<br />

Darlington with a legal obligation to appoint an Accountable Officer and associated<br />

duty to collaborate on issues relating to controlled drugs.<br />

1.4 Approval of the Code<br />

The local intelligence network member‘s representative of the list in Para 1.3 will be<br />

asked to approve the final draft of the code at a LIN meeting, in particular to:<br />

Facilitate the sharing of information on the basis detailed in the code;<br />

Support staff and new members of the local intelligence network in the<br />

implementation of the code through the provision of training, advice and guidance;<br />

Provide relevant information to facilitate monitoring and review.<br />

Page 67 of 196


Section 2<br />

Purposes for sharing information<br />

The purpose of this code is to provide a framework for the sharing of data,<br />

information and knowledge relating to the use, handling, prescribing or<br />

management of controlled drugs (CD) in order to achieve the following:<br />

Section 3<br />

Review or analysis of trends in CD use<br />

Interpretation of CD data in relation to local influences<br />

Identification of persons or groups of people who are managing, using,<br />

prescribing or handling CDs inappropriately or illegally<br />

Identifying “best practice” in the management of CDs (with the exception<br />

of best clinical practice)<br />

Identifying poor systems of control for the management of CDs<br />

Raising concerns relating to any of the above.<br />

Information to be shared<br />

The <strong>Controlled</strong> <strong>Drugs</strong> (Supervision of Management and Use) Regulations 2006 state<br />

that there is an active duty to share any information that<br />

―[An organisation that is party to this agreement] may disclose to any other<br />

[organisation that is party to this agreement] any information in its possession or<br />

control which it reasonably considers it should share with that body for the purposes<br />

of—<br />

(a) identifying cases in which action may need to be taken in respect of matters arising<br />

in relation to the management or use of controlled drugs by a relevant person;<br />

(b) the consideration of issues relating to the taking of action in respect of such<br />

matters;<br />

(c) the taking of action in respect of such matters.‖<br />

Such information may include but is not restricted to data extracted from:<br />

Prescribing reports (e-PACT) for GPs, Dentists, Nurse prescribers and private<br />

prescribers of CDs<br />

Records of ordering , receipt and dispensing of CD‘s<br />

Records of administration of CDs within hospitals and hospices<br />

Records of the destruction of CDs in any setting<br />

e-PACT reports generated that detail the dispensing of controlled drugs by<br />

pharmacies<br />

Records of the supply of ward CD stationary<br />

Records of supply of FP10PCD prescriptions to private prescribers<br />

Records of supply of CDs from wholesalers<br />

Records of issues to wards and departments from the JAC system or similar<br />

stock management system in hospitals<br />

Routine stock checks of CDs held in wards and departments in hospitals and<br />

hospices<br />

Records of Drug Testing and Treatment Orders<br />

Records of arrests for drug related crime<br />

Information discerned from any of the above that will provide:<br />

Page 68 of 196


Patterns or trends in the prescribing, ordering, receipt, dispensing,<br />

administration or destruction of controlled drugs on an individual practitioner,<br />

collection of practitioners or population basis.<br />

Details of anomalies within the prescribing, ordering, receipt, dispensing,<br />

administration or destruction of controlled drugs on an individual practitioner,<br />

collection of practitioners or population basis.<br />

Details of CDs, the whereabouts of which cannot be ascertained.<br />

Identification of areas or activities for which record keeping is not adequate<br />

Patterns or trends in activities relating to the enforcement of controlled drugs<br />

legislation.<br />

Information or knowledge regarding causes for concern relating to CD use or<br />

management, actual or suspected, derived from:<br />

A complaint or the analysis of complaints<br />

An incident report or the analysis of incident reports<br />

The conduction or results of an investigation into an incident or complaint<br />

―Whistle-blowing‖ or other report of a concern relating to professional conduct or<br />

performance.<br />

Confiscation of controlled drugs that have been possessed illegally.<br />

The report or investigation of an alleged or actual criminal act relating to<br />

controlled drugs<br />

A report resulting from an inspection carried out by the RPSGB, CSCI, HCC or<br />

PCT.<br />

Communications from <strong>NHS</strong> Counter Fraud & Security Management Services<br />

(<strong>NHS</strong> CF&SMS).<br />

Where a concern has been raised information may be shared that includes any of the<br />

above in addition to or contained within the following:<br />

―Occurrence Reports‖ (as defined in the 2006 regulations)<br />

Reports of a concern where evidence or information has been collated.<br />

The agenda, minutes and reports of a LIN incident panel.<br />

Letters of referral to regulatory, indemnifying or representative bodies.<br />

Referrals to the police or <strong>NHS</strong> CF&SMS<br />

Minutes of meetings of the LIN<br />

Personal information may include:<br />

The person‘s name, and or any aliases they live under<br />

The person‘s address(s)<br />

The person‘s occupation<br />

The person‘s age and date of birth.<br />

The person‘s sex<br />

Information about the person‘s social circumstances (which may include<br />

references to ethnicity)<br />

Information about the person‘s health or healthcare<br />

Information relating to the person‘s alleged or proven, past or present criminal<br />

offences<br />

The person‘s movements, habits, conduct or practises.<br />

Page 69 of 196


Section 4<br />

Arrangements for sharing information<br />

4.1 Provision of information<br />

Information which is not personally identifiable information will be shared in any<br />

of the following formats:<br />

Face to face & telephone conversation<br />

Post<br />

Fax<br />

e-mail<br />

Where information identifies an organisation or practice (or similar collective)<br />

information will be shared in the following ways:<br />

Face to face & telephone conversation<br />

Post using recorded/special delivery<br />

Secure fax (or secure faxing method)<br />

e-mail using a password protected file<br />

Where information identifies an individual or could be used to identify an<br />

individual the following methods will be used:<br />

Face to face & telephone conversation conducted in privacy<br />

Post using recorded delivery<br />

Safe Haven Fax or secure faxing method<br />

4.2 Consent from service users<br />

4.2.1 Sharing with Consent<br />

If an organisation wishes to disclose information under this code that contains person<br />

identifiable information but this information is not required for the purposes of<br />

identifying cases in which action may need to be taken, the organisation must remove<br />

the person identifiable information. If this is not possible or the organisation considers it<br />

necessary to disclose person identifiable information, the organisation must, where<br />

practicable, obtain the consent of the patient to whom the information relates. In such<br />

cases only the minimum amount of person identifiable information will be disclosed.<br />

4.2.2 Other Justifications for Sharing<br />

Where it is not appropriate to use consent as the basis for sharing information, the<br />

following justifications may be applicable:<br />

Information shared for medical purposes between health professionals<br />

Information can be shared if it is for medical purposes and is shared between<br />

health professionals. The terms ―medical purposes‖ and ―health professionals‖<br />

are defined in the Data Protection Act.<br />

Serious harm<br />

It may be justified to share information where there is evidence that serious<br />

harm would be caused to the service user, (or another person) if this was not<br />

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done. This may arise for example in relation to child, adult or public protection<br />

issues.<br />

Vital interests<br />

Information may be shared where this is in the ―vital interests‖ of the service<br />

user or another person. This refers to life or death circumstances.<br />

Prevention or detection of crime<br />

Personal information may be provided to the Police where this is necessary for<br />

the prevention or detection of crime. This is a power not an obligation. A<br />

judgement needs to be made in each case as to whether it is appropriate to<br />

release information taking into account the following criteria. Advice should be<br />

sought if there is uncertainty about interpreting these criteria. Information should<br />

only be disclosed where:<br />

- without disclosure the task of preventing or detecting crime would be<br />

prejudiced;<br />

- information shared is limited to what is strictly relevant to a specific<br />

investigation;<br />

- there are satisfactory undertakings that the information will not be used for<br />

any other purpose than the specific investigation.<br />

It may also be appropriate to disclose information under Section 29 of the Data<br />

Protection Act in response to investigations by the <strong>NHS</strong> Counter Fraud and<br />

Security Management Service (CF&SMS). Service Users should not be<br />

informed about information disclosed unless the appropriate officer of the<br />

CF&SMS concurs.<br />

Court Order<br />

Information must be shared where the service is instructed to do so by a Court<br />

(including a Coroner‘s Court.)<br />

Wherever possible and appropriate service users should be informed if their<br />

information is to be shared without consent.<br />

4.2.3 Confidentiality<br />

The right to confidentiality is extended to all persons including clinicians, unless an<br />

organisation considers that disclosure is necessary for:<br />

(a) identifying cases in which action may need to be taken in respect of matters arising<br />

in relation to the management or use of controlled drugs by a relevant person;<br />

(b) the consideration of issues relating to the taking of action in respect of such<br />

matters;<br />

(c) the taking of action in respect of such matters<br />

The sharing of information relating to the management of controlled drugs is facilitated<br />

by the operation of the Local Intelligence Network. The framework under which the LIN<br />

operates is provided in Appendix 2<br />

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Section 5<br />

Access and security<br />

5.1 Need to know<br />

All the members of the LIN may be privy to information as detailed in section 3.<br />

Sharing of the information detailed in section 3 that has been made available to the<br />

LIN within a recipient organisation will be restricted to those persons who need the<br />

information to carry out their duties in relation to the investigation of a concern. In such<br />

circumstances the organization will be bound by its own information governance or<br />

confidentiality policy as well as the Data Protection Act 1998.<br />

5.2 Secure storage and transfer of personal information<br />

Steps should be taken by all members of LIN to ensure that personal information is<br />

held and transmitted securely. Organisations should ensure that their staff have<br />

access to their policies on Confidentiality and Information Security and <strong>NHS</strong> staff have<br />

access to the <strong>NHS</strong> Confidentiality Code of Practice. (See Appendix 3 for details).<br />

Guidance on security issues is given in the Procedures Section B of the Information<br />

Sharing Protocol.<br />

5.3 Retention of records<br />

Files relating to an individual‘s controlled drugs management will remain active for the<br />

duration of time practitioners continue to practice within the <strong>County</strong> <strong>Durham</strong> and<br />

Darlington LIN area. The files will be archived once practitioners cease to practice in<br />

the <strong>County</strong> <strong>Durham</strong> and Darlington LIN area and retained for a period of 25 years to<br />

provide evidence if required in any future litigation which may be brought.<br />

Each organisation that is party to this agreement has responsibility for retaining<br />

information that relates to practitioners within their scope of responsibility.<br />

Files of information that arise from an investigation of a LIN incident panel will be<br />

retained by the PCT Accountable Officer or his/her deputy until such time as the<br />

concern is resolved. Once resolution is achieved the files will be transferred to the<br />

most appropriate organisation to be kept with the practitioner‘s individual file.<br />

CD files relating to individual practitioners may be passed on to other Accountable<br />

Officers at their request should a practitioner move from the area covered by the LIN<br />

into another LIN area.<br />

The Accountable Officer of each organisation or for organisations without an<br />

Accountable Officer the LIN member will act as the data controller for shared data<br />

originating in their respective organisation.<br />

Section 6<br />

Dissemination, monitoring and review of the Code<br />

LIN Members will make copies of the code and the protocol available to all<br />

relevant staff and on request to service users. Partners will ensure that<br />

appropriate training is provided to all relevant staff.<br />

LIN Members should ensure they are familiar with the requirements of The<br />

<strong>Controlled</strong> <strong>Drugs</strong> (Supervision of Management and Use) Regulations 2006 and<br />

with their internal policies relating to the implementation of these regulations.<br />

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Section 7<br />

LIN Members should investigate any breaches of the code and ensure that<br />

problems are addressed as promptly as possible within their partner<br />

organisations.<br />

The code will be reviewed every twelve months. Changes to the code will not be<br />

considered during this period unless they are required urgently.<br />

As part of the review process all LIN members will be asked about use of the<br />

code, any proposals they may have for addressing specific problems and any<br />

amendments they feel are necessary.<br />

Advice and guidance<br />

Sources of advice about confidentiality and information sharing issues are included in<br />

Appendix 3 of the agreement.<br />

Details of relevant additional guidance are given in Appendix 3.<br />

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Appendix 1 of Information sharing Code - Key principles<br />

The eight principles of the Data Protection Act:<br />

1.Fair and lawful: Personal data shall be processed fairly and lawfully and, in<br />

particular, shall not be processed unless certain conditions are met, also the<br />

processing must adhere to the fair processing code.<br />

2. Use for specified purposes: Personal data shall be obtained only for one or more<br />

specified purposes, and shall not be further processed in any manner incompatible<br />

with that purpose or purposes.<br />

3. Adequate, relevant and not excessive: Personal data shall be adequate, relevant<br />

and not excessive in relation to the purpose.<br />

4. Accurate and up to date: Personal data shall be accurate and, where necessary,<br />

kept up to date.<br />

5. Don‟t keep longer than necessary: Personal data processed for any purpose or<br />

purposes shall not be kept longer than is necessary for that purpose or those<br />

purposes.<br />

6. Rights given under the act: Personal data shall be processed in accordance with<br />

the rights of the data subject under this act‖.<br />

7. Security: Appropriate and organisational measures shall be taken against<br />

unauthorised or unlawful processing of personal data and against accidental loss or<br />

destruction of, or damage to, personal data.<br />

8. Disclosure outside Europe: Personal data shall not be transferred to a country<br />

outside the European Economic area, without adequate protection.<br />

The six Caldicott Principles:<br />

1. Define Purposes: Every proposed use or transfer of patient-identifiable information<br />

within or from an organisation should be clearly defined and scrutinised, with<br />

continuing uses regularly reviewed, by an appropriate guardian.<br />

2. Use anonymised information if possible: Patient-identifiable information items<br />

should not be included unless it is essential for the specified purpose. The need for<br />

patients to be identified should be considered at each stage of satisfying the purpose.<br />

3. Use the minimum information necessary: The minimum amount of identifiable<br />

information should be transferred or made accessible that is necessary for a given<br />

function to be carried out.<br />

4. Access to personal information on a need to know basis: Only those individuals<br />

who need access to patient-identifiable information should have access to it, and they<br />

should only have access to the information items that<br />

they need to see. This may mean introducing access controls or splitting information<br />

flows where one information flow is used for several purposes.<br />

5. Staff must be aware of their responsibilities: Action should be taken to ensure<br />

that those handling patient-identifiable information – both clinical and non-clinical staff<br />

– are made fully aware of their responsibilities and obligations to respect patient<br />

confidentiality.<br />

6. Use only when lawful: Every use of patient-identifiable information must be lawful.<br />

Page 74 of 196


Appendix 2 of Information Sharing Code<br />

Framework for a <strong>Controlled</strong> <strong>Drugs</strong> Local Intelligence<br />

Network.<br />

Introduction<br />

The Heath Act 2006 includes a legal duty of collaboration for local agencies to share<br />

information, within certain constraints, about the use of controlled drugs in the health<br />

and social care sectors. The duty of collaboration should be manifested through the<br />

operation of a local intelligence network through which information can be shared,<br />

analysed and acted upon.<br />

Remit<br />

The remit of the group is twofold:<br />

1. To comply with the duty of collaboration as defined by the Health Act 2006 (and<br />

related regulations) with regard to identifying and resolving issues of<br />

a. poor management of controlled drugs<br />

b. poor clinical/professional handling or use of controlled drugs.<br />

2. To act as a forum for the dissemination of best practice in the 2006 (and related<br />

regulations) with regard to identifying and resolving management of controlled<br />

drugs.<br />

Area of operation<br />

The local intelligence network covers the people living or working in the geographical<br />

area of <strong>County</strong> <strong>Durham</strong> and Darlington<br />

Membership of the network<br />

The Accountable Officers of healthcare organisations within the defined boundaries. (A<br />

named and fully informed deputy of the accountable officer may be nominated in place<br />

of the organisations Accountable Officer)<br />

Named representatives from the organisations below:<br />

� Care Quality Commission (CQC)<br />

� The inspectorate of the Royal Pharmaceutical Society of Great Britain (RPSGB)<br />

� The Healthcare Commission<br />

� The Police<br />

� Local Authority provided Social Services Department<br />

� North East <strong>NHS</strong> (Strategic Health Authority)<br />

A non-executive director who will offer lay representation.<br />

In addition the network should include input from the following where such expertise is<br />

not already found in the group:<br />

� Chief pharmacists<br />

� Medical directors<br />

� Nursing directors,<br />

� Social care providers and<br />

� <strong>Clinical</strong> governance leads of the healthcare organisations<br />

� Representatives of local wholesale dealers<br />

The network will be chaired by the PCT Accountable Officer who will have the<br />

additional responsibility of liaising with representatives of neighbouring local<br />

intelligence networks.<br />

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It remains the duty of each organisation to ensure full clinical engagement in the<br />

management of controlled drugs within its area of responsibility.<br />

Meeting Arrangements<br />

Regular communication will be necessary to share information of non-specific trends<br />

(for example an increase or decrease in the number of patients receiving palliative<br />

care) and to advise the network of any issues relating the quality or effectiveness of<br />

the information that is available for monitoring purposes. This will predominantly be<br />

done using teleconferencing or e-mail.<br />

Initially the members of the network will meet formally four times a year.<br />

On occasions where concerns are raised ad-hoc meetings are to be called, by the<br />

responsible Accountable Officer, that includes only those members of the network on<br />

whom the concern will impact. It will remain the duty of the responsible accountable<br />

officer to escalate the concern to the full network if they consider this to be necessary<br />

and co-ordinate the necessary meetings.<br />

Contact Management<br />

For use when causes of concern require rapid sharing of information to safeguard the<br />

public, the network maintains a list of emergency contacts for each organisation which<br />

can be used when the member of the group (or the relevant accountable officer) is not<br />

contactable (e.g. during annual leave). Wherever possible an out-of-hours contact will<br />

also be maintained.<br />

The PCT Accountable Officer is responsible for maintaining this list and testing its<br />

operation.<br />

Information sharing<br />

An information sharing agreement will be developed and subsequently adopted by<br />

each responsible organisation that will enable collaboration as outlined below.<br />

Each organisation should decide what information is shared routinely and the<br />

frequency in which this information is produced or updated based upon the validity and<br />

reliability of the data.<br />

Only information that is useful to partner organisations should be shared. Such<br />

information may be useful by means of providing context to the interpretation of other<br />

data, complimenting other data, direct addition to other data or increasing the pool of<br />

collective knowledge.<br />

Data may include:<br />

� Complaints<br />

� Incident reports<br />

� Whistle blowing<br />

� Reports from visits or inspections<br />

� Self declarations from CD holders<br />

And where there is good validity and reliability:<br />

� Concerns raised during performance review<br />

� Analysis of prescribing trends<br />

� Analysis of dispensing trends<br />

And in the future<br />

� Wholesaler/supply chain reports<br />

� Records of administration<br />

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Other information or knowledge may include:<br />

� Interpretation of data<br />

� Changes to clinical practice<br />

� Police activity<br />

� Reasonable suspicion, conjecture, speculation and predictions.<br />

The network recognises that in the course of implementing better management of<br />

controlled drugs areas of practice which do not comply with the letter of the law will be<br />

uncovered. Where an undertaking is made by the professional concerned to remedy<br />

the problems and such problems are considered not to be due to an unsafe disregard<br />

for the law or to malicious intent, such discrepancies do not automatically require<br />

raising as a concern to the network.<br />

The body of data to be routinely collated will be developed over time as systems are<br />

devised that allow the production of a consistent data set. A centralised secure<br />

repository of information will be established once a technological solution can be<br />

found. It will remain the responsibility of the producing organisation to securely store<br />

and archive the information it produces.<br />

During the course of responding to a concern each organisation will make available<br />

data or information in an open and timely manner on the request of a member of the<br />

network.<br />

In the process for raising a concern to the local intelligence network each organisation<br />

continues to be responsible for monitoring use of controlled drugs by its staff, patients<br />

and clients. The tools that the organisations use should be operated in such a manner<br />

that the threshold that any anomaly has to cross before an enquiry is made is very low.<br />

This low threshold will trigger enquiries that in the most part will be explained by the<br />

normal variation in practice. Any anomalies that are not sufficiently accounted for, or<br />

leave room for doubt will be highlighted to the local intelligence network. When an<br />

anomaly is first highlighted to the local intelligence network it should be anonymous<br />

unless the cause for concern is proven and serious. Anonymous reports will be<br />

compared for patterns or similarities and only if a pattern or similarity is observed will<br />

identifying details be exchanged.<br />

Confidentiality rules should be maintained at all times and this is the responsibility of<br />

the organisational lead. When sharing this becomes essential to take an investigation<br />

further then all other parties are bound by the same rules.<br />

Where concerns have been dealt with without the need to involve the whole network<br />

the responsible accountable officer should circulate a report of the concern and its<br />

subsequent resolution to inform the whole network.<br />

Administrative Support<br />

The PCT hosts administrative support that:<br />

� Co-ordinates the meetings and activities of the network,<br />

� Acts as a librarian for shared data and information and<br />

� Collates and analyses data and information in response to a concern being<br />

raised and elevated to include the whole network.<br />

All other administrative support remains the responsibility of the organisations within<br />

the network.<br />

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Appendix 3<br />

Additional guidance and key contacts<br />

Guidance<br />

The <strong>Controlled</strong> <strong>Drugs</strong> (Supervision of Management and Use) Regulations 2006:<br />

www.opsi.gov.uk/si/si2006/20063148.htm<br />

The Data Protection Act 1998 can be accessed via the Information<br />

Commissioner‘s website at www.informationcommissioner.gov.uk<br />

The <strong>NHS</strong> Confidentiality Code of Practice is available at<br />

www.dh.gov.uk/ipu/confiden<br />

Caldicott requirements are available at www.dh.gov.uk<br />

Specialist advice: contact details<br />

In relation to controlled drugs governance and management:<br />

Kate Huddart<br />

Senior Pharmaceutical Adviser<br />

Medicines Management (Commissioning)<br />

<strong>County</strong> <strong>Durham</strong> and Darlington Primary Care Trusts<br />

Merrington House<br />

Merrington Lane Industrial Estate<br />

Spennymoor<br />

<strong>County</strong> <strong>Durham</strong><br />

DL16 7UT<br />

Tel: 01388 82 5687<br />

Email: kate.huddart@nhs.net<br />

In relation to information sharing and the Data Protection Act<br />

Kevin Garrigan<br />

Information Governance Manager<br />

Tel: 0191 301 3820<br />

Email: kevin.garrigan@nhs.net<br />

Page 78 of 196


Appendix E<br />

<strong>Controlled</strong> <strong>Drugs</strong> Practice Declaration & Self Assessment audit for<br />

GP Practices 2009/2010<br />

Please complete the form below:<br />

Name of organisation/Practice<br />

Address of organisation/Practice<br />

Telephone Number<br />

Name of person completing form (Please<br />

print name)<br />

PPA Practice Code i.e. A12345<br />

Please indicate which applies to you: (please tick box)<br />

GP Nurse Practice Manager Other<br />

Please complete the relevant parts of the questionnaire below. This questionnaire relates to activities,<br />

since October 2008 and relates to schedule 2 and 3 <strong>Controlled</strong> <strong>Drugs</strong> (CDs) including Midazolam &<br />

Temazepam, as they are subject to a higher level of control.<br />

Area of activity Yes/No If answer is YES<br />

Question 1 Does the practice write/print<br />

prescriptions for CDs?<br />

Question 2 Does the practice supply or<br />

dispense CDs?<br />

Question 3 (i) a. Are CDs stocked either on the<br />

premises or off site? E.g. in<br />

doctor‘s bag/Emergency box.<br />

(ii)<br />

Question 4 Do you destroy or dispose of CDs<br />

(patient returns/stock) in the<br />

practice?<br />

Page 79 of 196<br />

Please complete<br />

TABLE A and<br />

SECTION 1<br />

Please complete<br />

TABLE A and<br />

SECTION 2<br />

Please complete<br />

TABLE A and<br />

SECTION 3<br />

Please complete<br />

TABLE A and<br />

SECTION 4


<strong>Controlled</strong> <strong>Drugs</strong> Practice Declaration Statement for GP Practices 2009/2010<br />

In ALL cases please delete as applicable and sign the declaration below:<br />

a) I declare to the best of my knowledge and belief that the organisation/practice does not handle,<br />

use or manage Schedule 2 or 3 CDs on any premises from which I provide clinical services.<br />

OR<br />

b) I declare that to the best of my knowledge and belief that I do/do not comply (please delete as<br />

appropriate) with the provisions of the Misuse of <strong>Drugs</strong> Act 1971 and the associated Regulations in its<br />

handling, use, prescribing and management of schedule 2 and 3 CDs.<br />

Signature*<br />

Name and registration number<br />

Date of Signing<br />

* This form must be signed by appropriately authorised personnel, who have responsibility for the management<br />

and use of CDs within the organisation/Practice.<br />

Please note that you must notify us of any material changes to the answers to questions 1 to 4 within 14<br />

days of change.<br />

Please return your completed <strong>Controlled</strong> Drug Declaration to:<br />

Vicki Vardy<br />

<strong>Controlled</strong> Drug Accountable Support & Data Manager<br />

<strong>NHS</strong> <strong>County</strong> <strong>Durham</strong><br />

Merrington House<br />

Merrington Lane Ind estate<br />

Spennymoor<br />

CO. <strong>Durham</strong><br />

DL16 7UT<br />

Telephone number; 01388 285680<br />

Vicki.vardy@nhs.net<br />

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TABLE A: General Information; Please complete in ALL cases<br />

Does the practice have written standard<br />

operating procedures or written policies<br />

covering the handling and management<br />

of CDs, appropriate to the activities<br />

carried out at the premises?<br />

Does the practice have in place a local<br />

procedure for dealing with a significant<br />

event* involving CDs?<br />

Does the practice have appropriate<br />

procedures for the initial and continuing<br />

training or development of all staff<br />

involved in the prescribing, handling,<br />

supply and administration of CDs?<br />

Are there any specific restrictions (iii) that<br />

have been applied that would affect the<br />

handling/prescribing/supply/administration<br />

of CDs by any of the healthcare<br />

professionals involved with your practice?<br />

Yes/No Details<br />

* Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

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Section one:<br />

Prescribing of CDs<br />

Have there been any patient or carer<br />

complaints* involving the prescribing of<br />

CDs by your practice?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about unusual,<br />

excessive or inappropriate prescribing of<br />

CDs by your practice?<br />

Have there been any significant events (iv) **<br />

involving the prescribing of CDs within<br />

your practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

* This includes complaints about failing to prescribe appropriate doses and/or appropriate medicines<br />

** Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

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Section Two:<br />

Supply/Dispensing of CDs<br />

Does the practice supply/dispense CDs<br />

as part of substance misuse treatment?<br />

If so, are the drugs checked against the<br />

prescription by a GP when<br />

supplying/dispensing?<br />

Does the practice supply/dispense CDs<br />

against private prescriptions:<br />

a) For or from substance misuse<br />

services?<br />

b) Elsewhere?<br />

Does the practice supply CDs against (v) a<br />

signed order:<br />

a) To doctors?<br />

b) To others (not including patients)?<br />

From where does your practice obtain (vi)<br />

stocks of CDs?<br />

Does your practice provide advice (vii) to<br />

patients on the safekeeping and disposal<br />

of unwanted CDs within your practice?<br />

Are patient returned medicines ever (viii) reused<br />

in the practice?<br />

Are patient information leaflets supplied (ix)<br />

to all patients supplied/dispensed CDs by<br />

the practice?<br />

Have there been any patient or carer<br />

complaints involving the<br />

supply/dispensing of CDs in your<br />

practice?<br />

(x)<br />

Have there been any concerns expressed (xi)<br />

by colleagues, police, drugs misuse<br />

service or others about CDs<br />

supply/dispensed from the organisation<br />

/practice?<br />

Have there been any significant events* (xii)<br />

involving the supply/dispensing of CDs<br />

from your practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

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Section Three:<br />

3.1) Security and safe custody of CDs on premises<br />

Does the practice store CDs in:<br />

a) A central store? (e.g. A single<br />

cupboard that holds all CD stocks for the<br />

practice)<br />

b) Doctors bags?<br />

c) Other places (please details)?<br />

Are all CDs (including patient returned<br />

CDs or unwanted/obsolete CDs) are kept<br />

locked in a cupboard that complies with<br />

BS2881 (a metal cupboard with an<br />

internal locking system)?<br />

Is access to CDs controlled within (xiii) your<br />

practice?<br />

e.g. Keys held only by appropriate staff<br />

If yes, then who?<br />

Do you utilise the CD storage facilities (xiv)<br />

for storage of anything other than CDs?<br />

If so, please state<br />

How often does date checking of (xv) CD<br />

stock take place in your practice?<br />

Give details of date checking procedures<br />

How often does date checking of (xvi) CD<br />

stock in Doctors bags take place?<br />

(where applicable)<br />

Please give details of date checking<br />

procedures<br />

Are all stock CDs kept in the original (xvii)<br />

manufacturers pack within the practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

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If a dispensing practice,are dispensed<br />

patients medicines appropriately labelled<br />

in the practice?<br />

Are different strengths of the same<br />

medicine segregated in any way?<br />

Do you have out of date or obsolete<br />

stock CDs currently stored in the<br />

practice?<br />

Are out of date/obsolete/patient returned (xviii)<br />

CDs segregated from other in date CDs<br />

in the practice?<br />

If Yes, where?<br />

Are patient returned medicines (xix) ever<br />

reused in the practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

3.2) Security and Safe custody of CDs in transport<br />

Do you transport or are you responsible<br />

for the transport of CDs (this includes<br />

sending CDs using third party carriers<br />

such as delivery drivers and postal<br />

system) to other sites?<br />

If NO, please move on to section 3.3<br />

What procedure do you have in place for<br />

the transport of CDs in the practice?<br />

Are CDs routinely kept under lock and<br />

key during transport?<br />

If No, then please provide details.<br />

What records are maintained of CDs in<br />

transport?<br />

Yes/No or<br />

N/A<br />

Details<br />

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3.3) Security and Safe custody of CD registers<br />

Yes/No or Details<br />

N/A<br />

Do you keep an up to date CD register in<br />

the practice?<br />

Do you keep running balances of stock<br />

CDs held?<br />

If yes:<br />

a) Do you audit your running totals?<br />

(state how often and date of last<br />

audit)<br />

b) Are the running totals audited by<br />

an independent 3 rd party (i.e. PCT<br />

staff)? (state how often and date of<br />

last audit)<br />

Have you identified any discrepancies<br />

between running totals and actual CD<br />

balances, since October 2008 in the<br />

practice?<br />

If yes:<br />

a) What was the explanation for the<br />

discrepancy?<br />

b) What action was taken?<br />

Do you maintain records of all receipts<br />

and supplies of CDs within your practice?<br />

If yes, for how long do you keep records?<br />

Have there been any patient or carer<br />

complaints involving the storage,<br />

transport or record keeping of CDs in the<br />

practice?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about the storage,<br />

transport or record keeping of CDs in the<br />

practice?<br />

Have there been any significant events*<br />

involving the storage, transport or<br />

recording keeping of CDs?<br />

Page 86 of 196


Section Four:<br />

Destruction and Disposal of CDs<br />

Patients Returned CDs<br />

What records do you keep of CDs<br />

returned to you by patients for disposal<br />

within the practice? (Where applicable)<br />

Do you routinely destroy patients old or<br />

obsolete CDs in the practice?<br />

What arrangements do you have in place<br />

to dispose of patients old or obsolete CDs<br />

in the practice?<br />

Is the destruction of patients old or<br />

obsolete CDs witnessed in the practice?<br />

If yes, by whom?<br />

Do you keep records of the destruction of<br />

patients old or obsolete CDs in the<br />

practice?<br />

Stock CDs (if applicable)<br />

How often do you aim to destroy out of<br />

date or obsolete stock CDs in the<br />

practice?<br />

Do you have any out of date or obsolete<br />

stock CDs currently awaiting destruction?<br />

Who usually witnesses your stock CDs<br />

destruction?<br />

When was the last witnessed CD stock<br />

destroyed?<br />

Are records of stock destruction kept in<br />

the CD register within the practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 87 of 196


Have there been any patient or carer<br />

complaints involving the destruction or<br />

disposal of CDs in the practice?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about the destruction<br />

or disposal of CDs in the practice?<br />

Have there been any significant events*<br />

involving the destruction or disposal of<br />

CDs in the practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

* Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Please return your completed self assessment audit to:<br />

Vicki Vardy<br />

<strong>Controlled</strong> Drug Accountable Support & Data Manager<br />

<strong>NHS</strong> <strong>County</strong> <strong>Durham</strong><br />

Merrington House<br />

Merrington Lane Ind estate<br />

Spennymoor<br />

CO. <strong>Durham</strong><br />

DL16 7UT<br />

Telephone Number; 01388 825680<br />

Vicki.vardy@nhs.net<br />

Page 88 of 196


Appendix F<br />

<strong>Controlled</strong> <strong>Drugs</strong> Personal Declaration & Self Assessment audit for<br />

individual GPs 2009/2010<br />

Please complete the form below:<br />

Name of Clinician<br />

Address of main workplace<br />

Telephone Number<br />

Name (Please print name)<br />

GMC Number<br />

Please indicate which applies to you: (please tick box)<br />

Partner GP Salaried GP Locum GP Other<br />

Please complete the relevant parts of the questionnaire below. This questionnaire relates to activities<br />

since October 2008 and relates to schedule 2 and 3 <strong>Controlled</strong> <strong>Drugs</strong> (CDs) including Midazolam &<br />

Temazepam, as they are subject to a higher level of control.<br />

Question 1<br />

Question 2<br />

Question 3<br />

Area of activity Yes/No If the answer is YES<br />

Do you prescribe CDs? Please complete TABLE A<br />

and SECTION 1<br />

Do you supply CDs? Please complete TABLE A<br />

and SECTION 2<br />

Do you administer CDs (or<br />

supervise or assist patients own<br />

administration)?<br />

Question 4 (xx) a. Do you keep a stock of CDs?<br />

(xxi) e.g. In doctor‘s bag.<br />

(xxii) b. Do you keep patients CDs?<br />

Question 5 Do you destroy or dispose of CDs<br />

(patient returns/stock)?<br />

Please complete TABLE A<br />

and SECTION 3<br />

Please complete TABLE A<br />

and SECTION 4<br />

Please complete TABLE A<br />

and SECTION 5<br />

Page 89 of 196


<strong>Controlled</strong> <strong>Drugs</strong> Personal Declaration Statement for individual GPs<br />

2009/2010<br />

In ALL cases please delete as applicable and sign the declaration below:<br />

c) I declare to the best of my knowledge and belief that I do not handle, use or manage<br />

Schedule 2 or 3 CDs.<br />

OR<br />

d) I declare that to the best of my knowledge and belief that I do/do not comply (please delete as<br />

appropriate) with the provisions of the Misuse of <strong>Drugs</strong> Act 1971 and the associated Regulations in its<br />

handling, use, prescribing and management of schedule 2 and 3 CDs.<br />

Signature*<br />

Name and registration number<br />

Date of Signing<br />

Please note that you must notify us of any material changes to the answers to questions 1 to 5 within 14<br />

days of change.<br />

Please return your completed declaration to:<br />

Vicki Vardy<br />

<strong>Controlled</strong> Drug Accountable Support & Data Manager<br />

<strong>NHS</strong> <strong>County</strong> <strong>Durham</strong><br />

Merrington House<br />

Merrington Lane Ind estate<br />

Spennymoor<br />

CO. <strong>Durham</strong><br />

DL16 7UT<br />

Telephone Number; 01388 825680<br />

Vicki.vardy@nhs.net<br />

Page 90 of 196


TABLE A: General Information; Please complete in ALL cases<br />

Do you have written standard operating<br />

procedures or written policies covering<br />

the handling and management of CDs,<br />

appropriate to the activities carried out at<br />

the premises?<br />

Do you have in place a procedure for<br />

dealing with a significant event* involving<br />

CDs?<br />

Do you have appropriate arrangements in<br />

place, for ongoing personal<br />

development/training<br />

CDs?<br />

with regards to<br />

Are there any specific restrictions (xxiii) that<br />

have been applied that would affect the<br />

handling/prescribing/supply/administration<br />

of CDs by yourself?<br />

Yes/No Details<br />

* Significant event include any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Page 91 of 196


Section one:<br />

Prescribing of CDs<br />

Have there been any patient or carer<br />

complaints* involving the prescribing of<br />

CDs by you?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about unusual,<br />

excessive or inappropriate prescribing of<br />

CDs by you?<br />

Have there been any significant events (xxiv) **<br />

involving the prescribing of CDs by you?<br />

Yes/No or<br />

N/A<br />

Details<br />

* This includes complaints about failing to prescribe appropriate doses and/or appropriate medicines<br />

** Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Page 92 of 196


Section Two:<br />

Supply of CDs<br />

Do you supply CDs as part of substance<br />

misuse treatment?<br />

If so, are the drugs checked against your<br />

prescription by someone other than<br />

yourself, when being supplied?<br />

Do you supply CDs to patients against<br />

private prescriptions written by:<br />

c) Other doctors?<br />

d) Yourself?<br />

Do you supply CDs against a signed (xxv)<br />

order:<br />

c) Other doctors?<br />

d) To others (not including patients)?<br />

e) Yourself?<br />

From where do you obtain your stocks (xxvi) of<br />

CDs?<br />

Do you provide advice to patients on (xxvii) the<br />

safekeeping and disposal of unwanted<br />

CDs?<br />

Are patient returned medicines ever (xxviii) reused<br />

by you?<br />

Are patient information leaflets supplied (xxix)<br />

to all patients receiving CDs directly from<br />

you?<br />

Have there been any patient or carer (xxx)<br />

complaints involving the supply of CDs by<br />

you?<br />

Have there been any concerns expressed (xxxi)<br />

by colleagues, police, drugs misuse<br />

service or others about the supply of CDs<br />

by you?<br />

Have there been any significant events* (xxxii)<br />

involving the supply of CDs by you?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 93 of 196


Section Three:<br />

Administration of CDs (This excludes supervision of CDs consumed by addicts)<br />

The CDs used for administration are:<br />

a) Stock CDs?<br />

b) Patients own CDs?<br />

c) Both a) and b)<br />

Do you maintain records of<br />

administration:<br />

If Yes, where? (Register, MAR charts etc)<br />

Is administration of CDs witnessed?<br />

If not, what risk management policies are<br />

in place to cover administration?<br />

Have there been any patient or carer (xxxiii)<br />

complaints involving the administration of<br />

CDs by you?<br />

Have there been any concerns expressed (xxxiv)<br />

by colleagues, police, drugs misuse<br />

service or others about the administration<br />

of CDs by you?<br />

Have there been any significant events* (xxxv)<br />

involving the administration of CDs by<br />

you?<br />

Yes/No or<br />

N/A<br />

Details<br />

* Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Page 94 of 196


Section Four:<br />

4.1) Security and safe custody of CDs on premises<br />

Do you store CDs in:<br />

d) A central store (e.g. a single cupboard<br />

that holds all CD stocks for your use)?<br />

e) Doctors bags?<br />

f) Other places (please details)?<br />

Are all CDs (including patient returned<br />

CDs or unwanted/obsolete CDs) are kept<br />

locked in a cupboard that complies with<br />

BS2881 (a metal cupboard with an<br />

internal locking system)?<br />

Is access to CDs controlled? (xxxvi)<br />

E.g. keys held by appropriate staff?<br />

If yes, then how?<br />

Do you utilise the CD storage facilities (xxxvii)<br />

for storage of anything other than CDs?<br />

If so, please state<br />

How often does date checking of (xxxviii) CD<br />

stock take place?<br />

Give details of date checking procedures<br />

How often does date checking of (xxxix) CD<br />

stock in Doctors bags take place?<br />

(where applicable)<br />

Please give details of date checking<br />

procedures<br />

Are all stock CDs kept in the original (xl)<br />

manufacturers pack?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 95 of 196


Are dispensed patients medicines<br />

appropriately labelled by you?<br />

Are different strengths of the same<br />

medicine segregated in any way?<br />

Do you have out of date or obsolete<br />

stock CDs currently stored?<br />

Are out of date/obsolete/patient returned (xli)<br />

CDs segregated from other in date CDs?<br />

Are patient returned medicines (xlii) ever<br />

reused by you?<br />

Yes/No or<br />

N/A<br />

Details<br />

4.2) Security and Safe custody of CDs in transport<br />

Do you transport or are you responsible<br />

for the transport of CDs (this includes<br />

sending CDs using third party carriers<br />

such as delivery drivers and postal<br />

system)?<br />

If NO, please move on to section 4.3<br />

What procedure do you have in place for<br />

the transport of CDs?<br />

Are CDs routinely kept under lock and<br />

key during transport?<br />

If No, then please provide details.<br />

What records are maintained of CDs in<br />

transport?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 96 of 196


4.3) Security and Safe custody of CD registers<br />

Yes/No or Details<br />

N/A<br />

Do you keep an up to date CD register by<br />

yourself?<br />

Do you keep running balances of stock<br />

CDs held?<br />

If yes:<br />

c) Do you audit your running totals?<br />

(state how often and date of last<br />

audit)<br />

d) Are the running totals audited by<br />

an independent 3 rd party (i.e. PCT<br />

staff)? (state how often and date of<br />

last audit)<br />

Have you identified any discrepancies<br />

between running totals and actual CDs<br />

held in the last 12 months?<br />

If yes:<br />

a) What was the explanation for the<br />

discrepancy?<br />

b) What action was taken?<br />

Do you maintain records of all receipts<br />

and supplies of CDs?<br />

If yes, for how long do you keep records?<br />

Have there been any patient or carer<br />

complaints involving the storage,<br />

transport or record keeping of CDs by<br />

you?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about the storage,<br />

transport or record keeping of CDs by<br />

you?<br />

Have there been any significant events*<br />

involving the storage, transport or<br />

recording keeping of CDs by you?<br />

* Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Page 97 of 196


Section Five:<br />

Destruction and Dispose of CDs<br />

Patient returned CDs<br />

What records do you keep of CDs<br />

returned to you by patients for disposal<br />

(where applicable)?<br />

Do you routinely destroy patients old or<br />

obsolete CDs?<br />

What arrangements do you have in place<br />

to dispose of patients old or obsolete<br />

CDs?<br />

Is the destruction of patients old or<br />

obsolete CDs witnessed?<br />

If yes, by whom?<br />

Do you keep records of the destruction of<br />

patients old or obsolete CDs?<br />

Stock CDs (if applicable)<br />

How often do you aim to destroy out of<br />

date or obsolete stock CDs?<br />

Do you have any out of date or obsolete<br />

stock CDs currently awaiting destruction?<br />

Who usually witnesses your stock CDs<br />

destruction?<br />

When was the last witnessed CD stock<br />

destroyed?<br />

Are records of stock destruction kept in<br />

the CD register by you?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 98 of 196


Have there been any patient or carer<br />

complaints involving the destruction or<br />

disposal of CDs by you?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about the destruction<br />

or disposal of CDs by you?<br />

Have there been any significant events*<br />

involving the destruction or disposal of<br />

CDs by you?<br />

Yes/No or<br />

N/A<br />

Details<br />

* Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Please return your completed CD Declaration & self assessment audit to:<br />

Vicki Vardy<br />

<strong>Controlled</strong> Drug Accountable support & Data Manager<br />

<strong>NHS</strong> <strong>County</strong> <strong>Durham</strong><br />

Merrington House<br />

Merrington Lane Ind estate<br />

Spennymoor<br />

CO. <strong>Durham</strong><br />

DL16 7UT<br />

Telephone Number; 01388 825680<br />

Vicki.vardy@nhs.net<br />

Page 99 of 196


Appendix G<br />

<strong>Controlled</strong> <strong>Drugs</strong> Practice Declaration & Self Assessment for Dental<br />

Practices 2009/2010<br />

Please complete the form below:<br />

Name of organisation/Practice<br />

Address of organisation/Practice<br />

Telephone Number<br />

Name of person completing form (Please<br />

print name)<br />

Please indicate which applies to you: (please tick box)<br />

Dentist Nurse Practice Manager Other<br />

Please complete the relevant parts of the questionnaire below. This questionnaire relates to activities<br />

since October 2008 and relates to schedule 2 and 3 <strong>Controlled</strong> <strong>Drugs</strong> (CDs) including Midazolam &<br />

Temazepam, as they are subject to a higher level of control.<br />

Area of activity Yes/No If the answer is YES<br />

Question 1 Does the practice write/print<br />

prescriptions for CDs?<br />

Question 2 Does the practice supply or<br />

dispense CDs?<br />

Question 3 (xliii) a. Are CDs stocked either on the<br />

premises or off site? E.g. in<br />

dentist‘s bag/emergency box.<br />

(xliv)<br />

Question 4 Do you destroy or dispose of CDs<br />

(patient returns/stock) in the<br />

practice?<br />

Page 100 of 196<br />

Please complete TABLE<br />

A and SECTION 1<br />

Please complete TABLE<br />

A and SECTION 2<br />

Please complete TABLE<br />

A and SECTION 3<br />

Please complete TABLE<br />

A and SECTION 4


<strong>Controlled</strong> <strong>Drugs</strong> Practice Declaration Statement for Dental Practice 2009/2010<br />

In ALL cases please delete as applicable and sign the declaration below:<br />

e) I declare to the best of my knowledge and belief that the organisation/practice does not handle,<br />

use or manage Schedule 2 or 3 CDs on any premises from which I provide clinical services.<br />

OR<br />

f) I declare that to the best of my knowledge and belief that I do/do not comply (please delete as<br />

appropriate) with the provisions of the Misuse of <strong>Drugs</strong> Act 1971 and the associated Regulations in its<br />

handling, use, prescribing and management of schedule 2 and 3 CDs.<br />

Signature*<br />

Name and registration number<br />

Date of Signing<br />

* This form must be signed by appropriately authorised personnel, who have responsibility for the management<br />

and use of CDs within the organisation/practice.<br />

Please note that you must notify us of any material changes to the answers to questions 1-4 within 14<br />

days of change.<br />

Please return your completed <strong>Controlled</strong> Drug Declaration to:<br />

Vicki Vardy<br />

<strong>Controlled</strong> Drug Accountable Support & Data Manager<br />

<strong>NHS</strong> <strong>County</strong> <strong>Durham</strong><br />

Merrington House<br />

Merrington Lane Ind estate<br />

Spennymoor<br />

CO. <strong>Durham</strong><br />

DL16 7UT<br />

Telephone number; 01388 285680<br />

Vicki.vardy@nhs.net<br />

Page 101 of 196


TABLE A: General Information; Please complete in ALL cases<br />

Does the practice have written standard<br />

operating procedures or written policies<br />

covering the handling and management<br />

of CDs, appropriate to the activities<br />

carried out at the premises?<br />

Does the practice have in place a local<br />

procedure for dealing with a significant<br />

event* involving CDs?<br />

Does the practice have appropriate<br />

procedures for the initial and continuing<br />

training or development of all staff<br />

involved in the prescribing, handling,<br />

supply and administration of CDs?<br />

Are there any specific restrictions (xlv) that<br />

have been applied that would affect the<br />

handling/prescribing/supply/administration<br />

of CDs by any of the healthcare<br />

professionals involved in your practice?<br />

Yes/No Details<br />

* Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Page 102 of 196


Section one:<br />

Prescribing of CDs<br />

Have there been any patient or carer<br />

complaints* involving the prescribing of<br />

CDs by your practice?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about unusual,<br />

excessive or inappropriate prescribing of<br />

CDs by your practice?<br />

Have there been any significant events (xlvi) **<br />

involving the prescribing of CDs within<br />

your practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

* This includes complaints about failing to prescribe appropriate doses and/or appropriate medicines<br />

** Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Page 103 of 196


Section Two:<br />

Supply/Dispensing of CDs<br />

Are drugs checked against your<br />

prescription by someone other than<br />

yourself, when being supplied?<br />

Does the practice supply/dispense CDs<br />

against private prescriptions:<br />

e) For or from substance misuse<br />

services?<br />

f) Elsewhere?<br />

Does the practice supply CDs against (xlvii) a<br />

signed order:<br />

f) To doctors?<br />

g) To others (not including patients)?<br />

From where does your practice obtain (xlviii)<br />

stocks of CDs?<br />

Does your practice provide advice (xlix) to<br />

patients on the safekeeping and disposal<br />

of unwanted CDs within your practice?<br />

Are patient returned medicines ever (l) reused<br />

in the practice?<br />

Are patient information leaflets supplied (li)<br />

to all patients supplied/dispensed CDs by<br />

the practice?<br />

Have there been any patient or carer<br />

complaints involving the<br />

supply/dispensing of CDs in your<br />

practice?<br />

(lii)<br />

Have there been any concerns expressed (liii)<br />

by colleagues, police, drugs misuse<br />

service or others about CDs<br />

supply/dispensed from the<br />

organisation/practice?<br />

Have there been any significant events* (liv)<br />

involving the supply/dispensing of CDs<br />

from your practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 104 of 196


Section Three:<br />

3.1) Security and safe custody of CDs on premises<br />

Does the practice store CDs in:<br />

g) A central store?(e.g. a single<br />

cupboard that holds all CD stocks for the<br />

practice)<br />

h) Dentist bags?<br />

i) Other places (please details)?<br />

Are all CDs (including patient returned<br />

CDs or unwanted/obsolete CDs) are kept<br />

locked in a cupboard that complies with<br />

BS2881 (a metal cupboard with an<br />

internal locking system)?<br />

Is access to CDs controlled within (lv) your<br />

practice?<br />

E.g. keys held only by appropriate staff<br />

If yes, then how?<br />

Do you utilise the CD storage facilities (lvi)<br />

for storage of anything other than CDs?<br />

If so, please state<br />

How often does date checking of (lvii) CD<br />

stock take place in your practice?<br />

Give details of date checking procedures<br />

How often does date checking of (lviii) CD<br />

stock in medical bags take place?<br />

(where applicable)<br />

Please give details of date checking<br />

procedures<br />

Are all stock CDs kept in the original (lix)<br />

manufacturers pack within the practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 105 of 196


Are dispensed patients medicines<br />

appropriately labelled in the practice?<br />

Are different strengths of the same<br />

medicine segregated in any way?<br />

Do you have out of date or obsolete<br />

stock CDs currently stored in the<br />

practice?<br />

Are out of date/obsolete/patient returned (lx)<br />

CDs segregated from other in date CDs<br />

in the practice?<br />

Are patient returned medicines (lxi) ever<br />

reused in the practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

3.2) Security and Safe custody of CDs in transport<br />

Do you transport or are you responsible<br />

for the transport of CDs (this includes<br />

sending CDs using third party carriers<br />

such as delivery drivers and postal<br />

system)?<br />

If NO, please move on to section 3.3<br />

What procedure do you have in place for<br />

the transport of CDs in the practice?<br />

Are CDs routinely kept under lock and<br />

key during transport?<br />

If No, then please provide details.<br />

What records are maintained of CDs in<br />

transport?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 106 of 196


3.3) Security and Safe custody of CD registers<br />

Yes/No or Details<br />

N/A<br />

Do you keep an up to date CD register in<br />

the practice?<br />

Do you keep running balances of stock<br />

CDs held?<br />

If yes:<br />

e) Do you audit your running totals?<br />

(state how often and date of last<br />

audit)<br />

f) Are the running totals audited by<br />

an independent 3 rd party (i.e. PCT<br />

staff)? (state how often and date of<br />

last audit)<br />

Have you identified any discrepancies<br />

between running totals and actual CD<br />

balance since October 2008 in the<br />

practice?<br />

If yes:<br />

a) What was the explanation for the<br />

discrepancy?<br />

b) What action was taken?<br />

Do you maintain records of all receipts<br />

and supplies of CDs within your practice?<br />

If yes, for how long do you keep records?<br />

Have there been any patient or carer<br />

complaints involving the storage,<br />

transport or record keeping of CDs in the<br />

practice?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about the storage,<br />

transport or record keeping of CDs in the<br />

practice?<br />

Have there been any significant events*<br />

involving the storage, transport or<br />

recording keeping of CDs?<br />

Page 107 of 196


Section Four:<br />

Destruction and Dispose of CDs<br />

Patient returned CDs<br />

What records do you keep of CDs<br />

returned to you by patients for disposal<br />

within the practice? (Where applicable)<br />

Do you routinely destroy patients old or<br />

obsolete CDs in the practice?<br />

What arrangements do you have in place<br />

to dispose of patients old or obsolete CDs<br />

in the practice?<br />

Is the destruction of patients old or<br />

obsolete CDs witnessed in the practice?<br />

If yes, by whom?<br />

Do you keep records of the destruction of<br />

patients old or obsolete CDs in the<br />

practice?<br />

Stock CDs (if applicable)<br />

How often do you aim to destroy out of<br />

date or obsolete stock CDs in the<br />

practice?<br />

Do you have any out of date or obsolete<br />

stock CDs currently awaiting destruction?<br />

Who usually witnesses your stock CDs<br />

destruction?<br />

When was the last witnessed CD stock<br />

destroyed?<br />

Are records of stock destruction kept in<br />

the CD register within the practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 108 of 196


Have there been any patient or carer<br />

complaints involving the destruction or<br />

disposal of CDs in the practice?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about the destruction<br />

or disposal of CDs in the practice?<br />

Have there been any significant events*<br />

involving the destruction or disposal of<br />

CDs in the practice?<br />

Yes/No or<br />

N/A<br />

Details<br />

* Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Please return your completed CD Declaration & self assessment audit to:<br />

Vicki Vardy<br />

<strong>Controlled</strong> Drug Accountable Support & Data Manager<br />

<strong>NHS</strong> <strong>County</strong> <strong>Durham</strong><br />

Merrington House<br />

Merrington Lane Ind estate<br />

Spennymoor<br />

CO. <strong>Durham</strong><br />

DL16 7UT<br />

Telephone Number; 01388 825680<br />

Vicki.vardy@nhs.net<br />

Page 109 of 196


Appendix H<br />

<strong>Controlled</strong> <strong>Drugs</strong> Personal Declaration & Self-Assessment Audit for<br />

Dentists 2009/2010<br />

Please complete the form below:<br />

Name of Clinician<br />

Address of main workplace<br />

Telephone Number<br />

Name (Please print name)<br />

GDC Number<br />

Please indicate which applies to you: (please tick box)<br />

Dentist Other<br />

Please complete the relevant parts of the questionnaire below. This questionnaire relates to activities<br />

since October 2008 and relates to schedule 2 and 3 <strong>Controlled</strong> <strong>Drugs</strong> (CDs) including Midazolam &<br />

Temazepam, as they are subject to a higher level of control.<br />

Area of activity Yes/No If the answer<br />

is YES<br />

Question 1 Do you prescribe CDs? Please complete<br />

TABLE A and<br />

Question 2 Do you supply CDs?<br />

SECTION 1<br />

Please complete<br />

TABLE A and<br />

SECTION 2<br />

Question 3 Do you administer CDs (or supervise or<br />

Please complete<br />

assist patients own administration)?<br />

TABLE A and<br />

SECTION 3<br />

Question 4 (lxii) a. Do you keep a stock of CDs? E.g. in<br />

Please complete<br />

dentist‘s bag/Emergency box.<br />

TABLE A and<br />

(lxiii) b. Do you keep patients CDs?<br />

SECTION 4<br />

Question 5 Do you destroy or dispose of CDs (patient<br />

Please complete<br />

returns/stock)?<br />

TABLE A and<br />

SECTION 5<br />

Page 110 of 196


<strong>Controlled</strong> <strong>Drugs</strong> Personal Declaration Statement for Dentist‟s<br />

2009/2010<br />

In ALL cases please delete as applicable and sign the declaration below:<br />

g) I declare to the best of my knowledge and belief that I do not handle, use or manage<br />

Schedule 2 or 3 CDs.<br />

OR<br />

h) I declare that to the best of my knowledge and belief that I do/do not comply (please delete as<br />

appropriate) with the provisions of the Misuse of <strong>Drugs</strong> Act 1971 and the associated Regulations in its<br />

handling, use, prescribing and management of schedule 2 and 3 CDs.<br />

Signature*<br />

Name and registration number<br />

Date of Signing<br />

Please note that you must notify us of any material changes to the answers to questions 1-5 within 14<br />

days of change.<br />

Please return your completed declaration to:<br />

Vicki Vardy<br />

<strong>Controlled</strong> Drug Accountable Support & Data Manager<br />

<strong>NHS</strong> <strong>County</strong> <strong>Durham</strong><br />

Merrington House<br />

Merrington Lane Ind estate<br />

Spennymoor<br />

CO. <strong>Durham</strong><br />

DL16 7UT<br />

Telephone Number; 01388 825680<br />

Vicki.vardy@nhs.net<br />

Page 111 of 196


TABLE A: General Information; Please complete in ALL cases<br />

Do you have written standard operating<br />

procedures or written policies covering<br />

the handling and management of CDs,<br />

appropriate to the activities carried out at<br />

the premises?<br />

Do you have in place a procedure for<br />

dealing with a significant event* involving<br />

CDs?<br />

Do you have appropriate arrangements in<br />

place for ongoing personal<br />

development/training with regards CDs?<br />

Are there any specific restrictions (lxiv) that<br />

have been applied that would affect the<br />

handling/prescribing/supply/administration<br />

of CDs by yourself?<br />

Yes/No Details<br />

* Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Page 112 of 196


Section one:<br />

Prescribing of CDs<br />

Have there been any patient or carer<br />

complaints* involving the prescribing of<br />

CDs by you?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about unusual,<br />

excessive or inappropriate prescribing of<br />

CDs by you?<br />

Have there been any significant events (lxv) **<br />

involving the prescribing of CDs by you?<br />

Yes/No or<br />

N/A<br />

Details<br />

* This includes complaints about failing to prescribe appropriate doses and/or appropriate medicines<br />

** Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Page 113 of 196


Section Two:<br />

Supply of CDs<br />

Are drugs checked against your<br />

prescription by someone other than<br />

yourself, when being supplied?<br />

Do you supply CDs to patients against<br />

private prescriptions written by:<br />

g) Other dentist‘s?<br />

h) Yourself?<br />

Do you supply CDs against a signed (lxvi)<br />

order:<br />

h) Other dentist‘s?<br />

i) To others (not including patients)?<br />

j) Yourself<br />

From where do you obtain your stocks (lxvii) of<br />

CDs?<br />

Do you provide advice to patients on (lxviii) the<br />

safekeeping and disposal of unwanted<br />

CDs?<br />

Are patient returned medicines ever (lxix) reused<br />

by you?<br />

Are patient information leaflets supplied (lxx)<br />

to all patients receiving CDs directly from<br />

you?<br />

Have there been any patient or carer (lxxi)<br />

complaints involving the supply of CDs by<br />

you?<br />

Have there been any concerns expressed (lxxii)<br />

by colleagues, police, drugs misuse<br />

service or others about the supply of CDs<br />

by you?<br />

Have there been any significant events* (lxxiii)<br />

involving the supply of CDs by you?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 114 of 196


Section Three:<br />

Administration of CDs (This excludes supervision of CDs consumed by addicts)<br />

Are the CDs used for administration:<br />

d) Stock CDs?<br />

e) Patients own CDs?<br />

f) Both a) and b)<br />

Do you maintain records of<br />

administration:<br />

If Yes, where? (Register, MAR charts etc)<br />

Is administration of CDs witnessed?<br />

If not, what risk management policies are<br />

in place to cover administration?<br />

Have there been any patient or carer (lxxiv)<br />

complaints involving the administration of<br />

CDs by you?<br />

Have there been any concerns expressed (lxxv)<br />

by colleagues, police, drugs misuse<br />

service or others about the administration<br />

of CDs by you?<br />

Have there been any significant events* (lxxvi)<br />

involving the administration of CDs by<br />

you?<br />

Yes/No or<br />

N/A<br />

Details<br />

* Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Page 115 of 196


Section Four:<br />

3.1) Security and safe custody of CDs on premises<br />

Do you store CDs in:<br />

j) A central store?(e.g. a single<br />

cupboard that holds all CDs)<br />

k) Dentist‘s bags?<br />

l) Other places (please details)?<br />

Are all CDs (including patient returned<br />

CDs or unwanted/obsolete CDs) are kept<br />

locked in a cupboard that complies with<br />

BS2881 (a metal cupboard with an<br />

internal locking system)?<br />

Is access to CDs controlled? (lxxvii)<br />

E.g. Keys held only by appropriate staff<br />

If yes, then how?<br />

Do you utilise the CD storage facilities (lxxviii)<br />

for storage of anything other than CDs?<br />

If so, please state<br />

How often does date checking of (lxxix) CD<br />

stock take place?<br />

Give details of date checking procedures<br />

How often does date checking of (lxxx) CD<br />

stock in medical bags take place?<br />

(where applicable)<br />

Please give details of date checking<br />

procedures<br />

Are all stock CDs kept in the original (lxxxi)<br />

manufacturers pack?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 116 of 196


Are dispensed patients medicines<br />

appropriately labelled by you?<br />

Are different strengths of the same<br />

medicine segregated in any way?<br />

Do you have out of date or obsolete<br />

stock CDs currently stored?<br />

Are out of date/obsolete/patient returned (lxxxii)<br />

CDs segregated from other in date CDs?<br />

Are patient returned medicines (lxxxiii) ever<br />

reused?<br />

Yes/No or<br />

N/A<br />

Details<br />

3.2) Security and Safe custody of CDs in transport<br />

Do you transport or are you responsible<br />

for the transport of CDs (this includes<br />

sending CDs using third party carriers<br />

such as delivery drivers and postal<br />

system)?<br />

If NO, please move on to section 3.3<br />

What procedure do you have in place for<br />

the transport of CDs?<br />

Are CDs routinely kept under lock and<br />

key during transport?<br />

If No, then please provide details.<br />

What records are maintained of CDs in<br />

transport?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 117 of 196


3.3) Security and Safe custody of CD registers<br />

Do you keep an up to date CD register?<br />

Do you keep running balances of stock<br />

CDs held?<br />

If yes:<br />

g) Do you audit your running totals?<br />

(state how often and date of last<br />

audit)<br />

h) Are the running totals audited by<br />

an independent 3 rd party (i.e. PCT<br />

staff)? (state how often and date of<br />

last audit)<br />

Have you identified any discrepancies<br />

between running totals and actual CD<br />

balances since October 2008?<br />

If yes:<br />

a) What was the explanation for the<br />

discrepancy?<br />

b) What action was taken?<br />

Do you maintain records of all receipts<br />

and supplies of CDs?<br />

If yes, for how long do you keep records?<br />

Have there been any patient or carer<br />

complaints involving the storage,<br />

transport or record keeping of CDs by<br />

you?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about the storage,<br />

transport or record keeping of CDs by<br />

you?<br />

Have there been any significant events*<br />

involving the storage, transport or<br />

recording keeping of CDs by you?<br />

Yes/No or<br />

N/A<br />

Details<br />

* Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Page 118 of 196


Section Five:<br />

Destruction and Dispose of CDs<br />

Patient returned CDs<br />

What records do you keep of CDs<br />

returned to you by patients for disposal<br />

(where applicable)?<br />

Do you routinely destroy patients old or<br />

obsolete CDs?<br />

What arrangements do you have in place<br />

to dispose of patients old or obsolete<br />

CDs?<br />

Is the destruction of patients old or<br />

obsolete CDs witnessed?<br />

If yes, by whom?<br />

Do you keep records of the destruction of<br />

patients old or obsolete CDs?<br />

Stock CDs (if applicable)<br />

How often do you aim to destroy out of<br />

date or obsolete stock CDs?<br />

Do you have any out of date or obsolete<br />

stock CDs currently awaiting destruction?<br />

Who usually witnesses your stock CDs<br />

destruction?<br />

When was the last witnessed CD stock<br />

destroyed?<br />

Are records of stock destruction kept in<br />

the CD register?<br />

Yes/No or<br />

N/A<br />

Details<br />

Page 119 of 196


Have there been any patient or carer<br />

complaints involving the destruction or<br />

disposal of CDs by you?<br />

Have there been any concerns expressed<br />

by colleagues, police, drugs misuse<br />

services or others about the destruction<br />

or disposal of CDs by you?<br />

Have there been any significant events*<br />

involving the destruction or disposal of<br />

CDs by you?<br />

Yes/No or<br />

N/A<br />

Details<br />

* Significant event includes any action or omission resulting in patient(s) being harmed or any action or<br />

omission that nearly happened but did not (near miss)<br />

Please return your completed CD Declaration & self assessment audit to:<br />

Vicki Vardy<br />

<strong>Controlled</strong> Drug Accountable support & Data Manager<br />

<strong>NHS</strong> <strong>County</strong> <strong>Durham</strong><br />

Merrington House<br />

Merrington Lane Ind estate<br />

Spennymoor<br />

CO. <strong>Durham</strong><br />

DL16 7UT<br />

Telephone Number; 01388 825680<br />

Vicki.vardy@nhs.net<br />

Page 120 of 196


Appendix I<br />

Practice Name<br />

Practice Address<br />

<strong>Controlled</strong> <strong>Drugs</strong>: Practice Audit by PCT Pharmacist<br />

Practice Representative (Print<br />

Name)<br />

Practice Representative<br />

(Signature)<br />

PCT Pharmacist (Print Name)<br />

PCT Pharmacist (Signature)<br />

Date of Visit<br />

Personnel Prescribing CDs<br />

1.<br />

2.<br />

3.<br />

4.<br />

5.<br />

6.<br />

Personnel with access to CD<br />

receptacle<br />

1.<br />

2.<br />

3.<br />

4.<br />

Overall responsibility for CDs rests<br />

with:<br />

7.<br />

8.<br />

9.<br />

10.<br />

11.<br />

12.<br />

5.<br />

6.<br />

7.<br />

8.<br />

Page 121 of 196


Section 1: Obtaining <strong>Controlled</strong> <strong>Drugs</strong><br />

Main Supplier of CDs:<br />

Orders authorised by:<br />

Person authorised to receive<br />

CDs at premises:<br />

Is there a written standard operating procedure in place for<br />

ordering CDs?<br />

Is a record of orders kept for a minimum of 2 years?<br />

Are CD orders authorised?<br />

Is there a written standard operating procedure in place for<br />

the receipt of CDs?<br />

Is there a written standard operating procedure in place for<br />

the receipt of CDs delivered via transport systems?<br />

Is the level of stock held to a minimum and reviewed<br />

annually?<br />

YES NO<br />

Page 122 of 196


Section 2: Supply of <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you supply CDs to addicts?<br />

Do you supply CDs against private<br />

prescriptions:<br />

(a) From addiction services?<br />

(b) Elsewhere?<br />

Do you supply CDs:<br />

(a) To doctors?<br />

(b) To others (excluding patients)<br />

Do you provide advice to patients on the<br />

safekeeping and disposal of unwanted CDs?<br />

Are patient information leaflets supplied to all<br />

patients receiving CDs?<br />

Are patient returned medicines ever reused?<br />

Have there been any patient or carer<br />

complaints involving the supply of CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the supply of CDs from the<br />

organisation?<br />

Have there been any significant events<br />

involving the supply of CDs relating to the<br />

organisation?<br />

Yes No Details<br />

Page 123 of 196


Section 3: Administration of <strong>Controlled</strong> <strong>Drugs</strong><br />

Are CDs which are administered:<br />

(a) Stock CDs?<br />

(b) Patient‘s own CDs?<br />

Do you maintain records of administration?<br />

(If yes, where? E.g. Register, MAR chart etc.)<br />

Is the administration of CDs witnessed?<br />

If administration is not witnessed, do you have<br />

risk management policies in place?<br />

Have there been any patient or carer<br />

complaints involving the administration of<br />

CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the administration of CDs from<br />

the organisation?<br />

Have there been any significant events<br />

involving the administration of CDs relating to<br />

the organisation?<br />

Yes No Details<br />

Yes No Details<br />

Page 124 of 196


Section 4a: Storage of <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you have any current Chief Constable<br />

exemption certificates in operation for your<br />

CD storage facilities?<br />

Are Schedule 2 CDs stored in a locked,<br />

secure, non-portable receptacle?<br />

Is the receptacle permanently affixed to an<br />

internal wall?<br />

Is the receptacle used only for CDs?<br />

Are all stock CDs kept in their original<br />

containers?<br />

Are different strengths of the same medicines<br />

segregated?<br />

Are there any patient‘s own medicines stored<br />

in the CD receptacle?<br />

Are out of date/returned medicines/out of date<br />

stock segregated?<br />

Are patient returned medicines ever reused?<br />

Is there a written standard operating<br />

procedure which details routine date checking<br />

of stock CDs?<br />

How often does routine date checking take<br />

place?<br />

Is the room containing the CD receptacle<br />

lockable?<br />

Is the room containing the CD receptacle kept<br />

locked?<br />

Does the room containing the CD receptacle<br />

have limited access?<br />

Is there a named person detailed in a written<br />

standard operating procedure, with<br />

responsibility for the CD receptacle and a list<br />

of the current key holder(s)?<br />

Is there a clear daily audit trail for key holders<br />

(i.e. keys signed in and out, and not stored in<br />

a drawer)?<br />

Do you store naloxone in the practice?<br />

Yes No Details<br />

Page 125 of 196


Section 4b: Security and safe custody of <strong>Controlled</strong> <strong>Drugs</strong> in transport<br />

Do you transport or are you responsible for<br />

the transport of CDs (this includes sending<br />

CDs using third party carriers)?<br />

Do you have written standard operating<br />

procedures in place for the transport of CDs?<br />

Are CDs kept in a locked receptacle during<br />

transport?<br />

Are records maintained of CDs in transport?<br />

Section 4c: Register of <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you maintain a controlled drug register?<br />

Are the controlled drugs kept at more than<br />

one surgery site?<br />

Is there a separate register for each area<br />

where the CDs are stored?<br />

Is the CD register stored safely, near to, but<br />

outside the CD receptacle?<br />

Are all records, registers and invoices kept for<br />

a minimum of 2 years?<br />

Have there been any patient or carer<br />

complaints involving the storage, transport or<br />

record keeping of CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the storage, transport or<br />

record keeping of CDs?<br />

Have there been any significant events<br />

involving the storage, transport or record<br />

keeping of CDs?<br />

Yes No Details<br />

Yes No Details<br />

Page 126 of 196


Section 4c: Paper based CD registers<br />

The following table may be used to identify which procedures are being followed and the number of<br />

registers in current use. Tick the box to indicate whether the criteria are being followed in the practice.<br />

Criterion Register Comments<br />

1. Format of register<br />

1.1 Bound book<br />

1.2 Separate section per drug<br />

1.3 Separate section per presentation with<br />

name and strength at top of each page<br />

2. Entries<br />

2.1 In ink<br />

2.2 Chronological order<br />

2.3 Entries within 24 hours<br />

3. Errors and corrections<br />

3.1 As margin/foot notes<br />

3.2 Corrections dated<br />

3.3 Corrections initialled<br />

4. Record of receipt<br />

4.1 Date of receipt<br />

4.2 Name and address of supplier<br />

4.3 Amount obtained<br />

4.4 Form and strength obtained<br />

4.5 Running balance<br />

4.6 Signature<br />

4.7 Process for discrepancies<br />

5. Record of supply<br />

5.1 Date of supply<br />

5.2 Name and address of person supplied<br />

5.3 Authority to supply<br />

5.4 Amount supplied<br />

5.5 Form and strength supplied<br />

5.6 Running balance<br />

5.7 Signature<br />

Criterion Register Comments<br />

5.8 Collected by<br />

6. Record of administration<br />

6.1 Date of administration<br />

6.2 Name and address of person<br />

administered to (where appropriate)<br />

6.3 Name and authority of person<br />

administering<br />

6.4 Amount administered<br />

6.5 Form administered<br />

6.6 Time of administration<br />

6.7 Running balance<br />

6.8 Signature and witness where appropriate<br />

6.9 Procedure if pack contents incorrect<br />

7. Stock check<br />

7.1 Evidence of appropriate stock check e.g.<br />

monthly<br />

7.2 Stock checked and correct<br />

7.3 Different people carrying out stock check<br />

Page 127 of 196


Section 5: Destruction of <strong>Controlled</strong> <strong>Drugs</strong><br />

Are CDs destroyed using recommended<br />

methods?<br />

Are there any CDs awaiting destruction in the<br />

CD receptacle?<br />

Is date expired CD stock clearly labelled?<br />

Is date expired CD stock clearly segregated?<br />

Have there been any patient or carer<br />

complaints involving the destruction of CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the destruction of CDs?<br />

Have there been any significant events<br />

involving the destruction of CDs?<br />

Destruction of stock controlled drugs<br />

Is there a written standard operating<br />

procedure for the destruction of controlled<br />

drugs?<br />

Is destruction of stock CDs witnessed by an<br />

authorised person?<br />

Is the authorised person NOT directly involved<br />

with CD supply in the practice?<br />

Is the name, form, strength and quantity of the<br />

drug destroyed, entered into the CD register?<br />

Is the date of destruction entered into the<br />

register?<br />

Is the signature of the witness entered into the<br />

register?<br />

Is there a written standard operating<br />

procedure for the destruction of expired stock<br />

from doctor‘s bags?<br />

Destruction of patient returned controlled<br />

drugs<br />

Are records made of patient returned CDs in a<br />

separate book (not the CD register)?<br />

Does this book record:<br />

The date received?<br />

Name and address of the patient prescribed<br />

CD?<br />

Pharmacy/practice where originally<br />

dispensed?<br />

Name, quantity, form of CD?<br />

Role of person returning CD?<br />

Name and signature of staff receiving CD?<br />

Name and signature of staff destroying CD<br />

and date?<br />

Destruction of patient returned controlled<br />

drugs<br />

Does this book record:<br />

Name and signature of witness to destruction<br />

and date?<br />

Yes No Details<br />

Yes No Details<br />

Page 128 of 196


Are patient returned CDs destroyed as soon<br />

as possible?<br />

Is the patient returns process audited?<br />

Page 129 of 196


Section 6: General<br />

Do all staff know who to contact at the<br />

Primary Care Organisation regarding<br />

concerns about other colleagues in relation to<br />

CDs?<br />

Comments<br />

Yes No Details<br />

It is good practice to keep all audit records for 7 years<br />

Revision Date: August 2010<br />

Page 130 of 196


Appendix J<br />

GP Name<br />

GP Address<br />

GP Signature<br />

<strong>Controlled</strong> <strong>Drugs</strong>: Personal Audit by PCT Pharmacist<br />

PCT Pharmacist (Print Name)<br />

PCT Pharmacist (Signature)<br />

Date of Visit<br />

Section 1: Obtaining <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you obtain controlled drugs from your local pharmacist?<br />

Do you obtain controlled drugs by signed requisition?<br />

Do you use practice headed paper for your signed<br />

requisition?<br />

Do you obtain controlled drugs using an FP10<br />

Do you obtain controlled drugs from patients who have died?<br />

Is there a written standard operating procedure in place for<br />

ordering CDs?<br />

Is a record of orders kept for a minimum of 2 years?<br />

Is there a written standard operating procedure in place for<br />

the receipt of CDs?<br />

Is there a written standard operating procedure in place for<br />

the receipt of CDs delivered via transport systems?<br />

Is the level of stock in your bag held to a minimum and<br />

reviewed annually?<br />

Section 2: Supply of <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you supply CDs to addicts?<br />

Do you supply CDs against private<br />

prescriptions:<br />

(c) From addiction services?<br />

(d) Elsewhere?<br />

Do you supply CDs:<br />

(c) To doctors?<br />

(d) To others (excluding patients)<br />

Do you provide advice to patients on the<br />

YES NO<br />

Yes No Details<br />

Page 131 of 196


safekeeping and disposal of unwanted CDs?<br />

Are patient information leaflets supplied to all<br />

patients receiving CDs?<br />

Are patient returned medicines ever reused?<br />

Have there been any patient or carer<br />

complaints relating to you involving the supply<br />

of CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others relating to you about the supply of<br />

CDs from the organisation?<br />

Have there been any significant events<br />

involving the supply of CDs relating to you?<br />

Section 3: Administration of <strong>Controlled</strong> <strong>Drugs</strong><br />

Are CDs which are administered:<br />

(c) Stock CDs?<br />

(d) Patient‘s own CDs?<br />

Do you maintain records of administration?<br />

(If yes, where? E.g. Register, MAR chart etc.)<br />

Is the administration of CDs witnessed?<br />

If administration is not witnessed, do you have<br />

risk management policies in place?<br />

Have there been any patient or carer<br />

complaints involving the administration of CDs<br />

by you?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the administration of CDs by<br />

you?<br />

Have there been any significant events<br />

involving the administration of CDs relating to<br />

you?<br />

Section 4a: Storage of <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you store controlled drugs in a locked<br />

doctors‘ bag?<br />

Do you store controlled drugs in your car?<br />

If you store controlled drugs in your car are<br />

they stored in a locked container?<br />

If you store controlled drugs in your car, is the<br />

car locked?<br />

If you store controlled drugs in your car, are<br />

they stored in a locked boot?<br />

When would you store controlled drugs in<br />

your car?<br />

Yes No Details<br />

Yes No Details<br />

Page 132 of 196


Would controlled drugs be left overnight in<br />

your car?<br />

Are out of date/returned medicines/out of date<br />

stock segregated?<br />

Are patient returned medicines ever reused?<br />

Is there a written standard operating<br />

procedure which details routine date checking<br />

of stock CDs?<br />

How often does routine date checking take<br />

place?<br />

Where is your bag, containing controlled<br />

drugs stored out of hours?<br />

Is the room containing the CDs kept locked?<br />

Does the room containing the CDs have<br />

limited access?<br />

Do you carry naloxone in your bag?<br />

Do you store naloxone in your practice?<br />

Section 4b: Security and safe custody of <strong>Controlled</strong> <strong>Drugs</strong> in transport<br />

Do you transport or are you responsible for<br />

the transport of CDs (this includes sending<br />

CDs using third party carriers)?<br />

Do you have written standard operating<br />

procedures in place for the transport of CDs?<br />

Are CDs kept in a locked receptacle during<br />

transport?<br />

Are records maintained of CDs in transport?<br />

Section 4c: Register of <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you maintain a controlled drug register?<br />

Is the CD register kept with the controlled<br />

drugs?<br />

Are all records, registers and invoices kept for<br />

a minimum of 2 years?<br />

Have there been any patient or carer<br />

complaints involving the storage, transport or<br />

record keeping of CDs regarding you?<br />

Have there been any concerns regarding you<br />

expressed by colleagues, police, substance<br />

Yes No Details<br />

Yes No Details<br />

Page 133 of 196


misuse services or others about the storage,<br />

transport or record keeping of CDs?<br />

Have there been any significant events<br />

regarding you involving the storage, transport<br />

or record keeping of CDs?<br />

Section 4c: Paper based CD registers<br />

The following table may be used to identify which procedures are being followed and<br />

the number of registers in current use. Tick the box to indicate whether the criteria are<br />

being followed in the practice.<br />

Criterion Register Comments<br />

1. Format of register<br />

1.1 Bound book<br />

1.2 Separate section per drug<br />

1.3 Separate section per presentation with<br />

name and strength at top of each page<br />

2. Entries<br />

2.1 In ink<br />

2.2 Chronological order<br />

2.3 Entries within 24 hours<br />

3. Errors and corrections<br />

3.1 As margin/foot notes<br />

3.2 Corrections dated<br />

3.3 Corrections initialled<br />

4. Record of receipt<br />

4.1 Date of receipt<br />

4.2 Name and address of supplier<br />

4.3 Amount obtained<br />

4.4 Form and strength obtained<br />

4.5 Running balance<br />

4.6 Signature<br />

4.7 Process for discrepancies<br />

Criterion Register Comments<br />

5. Record of supply<br />

5.1 Date of supply<br />

5.2 Name and address of person supplied<br />

5.3 Authority to supply<br />

5.4 Amount supplied<br />

5.5 Form and strength supplied<br />

5.6 Running balance<br />

5.7 Signature<br />

5.8 Collected by<br />

6. Record of administration<br />

6.1 Date of administration<br />

6.2 Name and address of person<br />

administered to (where appropriate)<br />

6.3 Name and authority of person<br />

administering<br />

6.4 Amount administered<br />

6.5 Form administered<br />

Page 134 of 196


6.6 Time of administration<br />

6.7 Running balance<br />

6.8 Signature and witness where appropriate<br />

6.9 Procedure if pack contents incorrect<br />

7. Stock check<br />

7.1 Evidence of appropriate stock check e.g.<br />

monthly<br />

7.2 Stock checked and correct<br />

Section 5: Destruction of <strong>Controlled</strong> <strong>Drugs</strong><br />

Are CDs destroyed using recommended<br />

methods?<br />

Are there any CDs awaiting destruction in the<br />

GP bag<br />

Is date expired CD stock clearly labelled?<br />

Is date expired CD stock clearly segregated?<br />

Have there been any patient or carer<br />

complaints involving the destruction of CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the destruction of CDs?<br />

Have there been any significant events<br />

involving the destruction of CDs?<br />

Destruction of stock controlled drugs<br />

Is the out of date stock from your emergency<br />

bag destroyed by a GP?<br />

Is destruction of stock CDs witnessed by an<br />

authorised person?<br />

Is the authorised person NOT directly involved<br />

with CD supply in the practice?<br />

Is the name, form, strength and quantity of the<br />

drug destroyed, entered into the CD register?<br />

Is the date of destruction entered into the<br />

register?<br />

Is the signature of the witness entered into the<br />

register?<br />

Is there a written standard operating<br />

procedure for the destruction of expired stock<br />

from doctor‘s bags?<br />

Destruction of patient returned controlled<br />

drugs<br />

What do you do when Sch 2 controlled drugs<br />

that are no longer required by your patient for<br />

use in their home e.g. terminal care? Are the<br />

Yes No Details<br />

Yes No Details<br />

Page 135 of 196


drugs:<br />

Returned by you to a community<br />

pharmacy?<br />

Returned by others to a community<br />

pharmacy?<br />

Added to your own emergency bag<br />

stock?<br />

Destroyed by you?<br />

Destroyed by a District Nurse?<br />

Destroyed by patient‘s relatives?<br />

Destroyed by an authorised person?<br />

Are records made of patient returned CDs in a<br />

separate book (not the CD register)?<br />

Does this book record:<br />

The date received?<br />

Name and address of the patient prescribed<br />

CD?<br />

Pharmacy/practice where originally<br />

dispensed?<br />

Name, quantity, form of CD?<br />

Role of person returning CD?<br />

Name and signature of staff receiving CD?<br />

Name and signature of staff destroying CD<br />

and date?<br />

Name and signature of witness to destruction<br />

and date?<br />

Are patient returned CDs destroyed as soon<br />

as possible?<br />

Is the patient returns process audited?<br />

Section 6: General<br />

Do all staff know who to contact at the<br />

Primary Care Organisation regarding<br />

concerns about other colleagues in relation to<br />

CDs?<br />

Comments<br />

Yes No Details<br />

It is good practice to keep all audit records for 7 years<br />

Revision Date: August 2010<br />

Page 136 of 196


Appendix K<br />

OOH/UCC/Practice Name<br />

<strong>Controlled</strong> <strong>Drugs</strong>: OOH/UCC/Dispensing Doctors Audit<br />

OOH/UCC/Practice Address<br />

OOH/UCC/Practice<br />

Representative (Print Name)<br />

OOH/UCC/Practice<br />

Representative (Signature)<br />

PCT Pharmacist (Print Name)<br />

PCT Pharmacist (Signature)<br />

Date of Visit<br />

Personnel Prescribing CDs<br />

1.<br />

2.<br />

3.<br />

4.<br />

5.<br />

6.<br />

Personnel with access to CD<br />

receptacle<br />

1.<br />

2.<br />

3.<br />

4.<br />

Overall responsibility for CDs rests<br />

with:<br />

7.<br />

8.<br />

9.<br />

10.<br />

11.<br />

12.<br />

5.<br />

6.<br />

7.<br />

8.<br />

Page 137 of 196


Section 1: Obtaining <strong>Controlled</strong> <strong>Drugs</strong><br />

Main Supplier of CDs:<br />

Orders authorised by:<br />

Person authorised to receive<br />

CDs at premises:<br />

Is there a written standard operating procedure in place for<br />

ordering CDs?<br />

Is a record of orders kept for a minimum of 2 years?<br />

Are CD orders authorised?<br />

Is there a written standard operating procedure in place for<br />

the receipt of CDs?<br />

Is there a written standard operating procedure in place for<br />

the receipt of CDs delivered via transport systems?<br />

Is the level of stock held to a minimum and reviewed<br />

annually?<br />

Section 2: Supply of <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you supply CDs to addicts?<br />

Do you supply CDs against private<br />

prescriptions:<br />

(e) From addiction services?<br />

(f) Elsewhere?<br />

Do you supply CDs:<br />

(e) To doctors?<br />

(f) To others (excluding patients)<br />

Are the drugs checked against the<br />

prescription by a GP when dispensing<br />

schedule 2 and 3 controlled drugs?<br />

Do you provide advice to patients on the<br />

safekeeping and disposal of unwanted CDs?<br />

Are patient information leaflets supplied to all<br />

patients receiving CDs?<br />

Are patient returned medicines ever reused?<br />

Have there been any patient or carer<br />

complaints involving the supply of CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the supply of CDs from the<br />

organisation?<br />

Have there been any significant events<br />

involving the supply of CDs relating to the<br />

organisation?<br />

YES NO<br />

Yes No Details<br />

Page 138 of 196


Section 3: Administration of <strong>Controlled</strong> <strong>Drugs</strong><br />

Are CDs which are administered:<br />

(e) Stock CDs?<br />

(f) Patient‘s own CDs?<br />

Do you maintain records of administration?<br />

(If yes, where? E.g. Register, MAR chart etc.)<br />

Is the administration of CDs witnessed?<br />

If administration is not witnessed, do you have<br />

risk management policies in place?<br />

Have there been any patient or carer<br />

complaints involving the administration of<br />

CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the administration of CDs from<br />

the organisation?<br />

Have there been any significant events<br />

involving the administration of CDs relating to<br />

the organisation?<br />

Section 4a: Storage of <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you have any current Chief Constable<br />

exemption certificates in operation for your<br />

CD storage facilities?<br />

Are Schedule 2 CDs stored in a locked,<br />

secure, non-portable receptacle?<br />

Are Schedule 3 CDs stored in a locked,<br />

secure, non-portable receptacle?<br />

Is the receptacle permanently affixed to an<br />

internal wall?<br />

Is the receptacle used only for CDs? (i.e. is<br />

there a separate CD cupboard?)<br />

Are all stock CDs kept in their original<br />

containers?<br />

Are different strengths of the same medicines<br />

segregated?<br />

Are there any patient‘s own medicines stored<br />

in the CD receptacle?<br />

Are out of date/returned medicines/out of date<br />

stock segregated?<br />

How are out of date/returned medicines/out of<br />

date stock segregated?<br />

Are patient returned medicines ever reused?<br />

Is there a written standard operating<br />

Yes No Details<br />

Yes No Details<br />

Yes No Details<br />

Page 139 of 196


procedure which details routine date checking<br />

of stock CDs?<br />

How often does routine date checking take<br />

place?<br />

Is the room containing the CD receptacle<br />

lockable?<br />

Is the room containing the CD receptacle kept<br />

locked?<br />

Does the room containing the CD receptacle<br />

have limited access?<br />

Is there a named person detailed in a written<br />

standard operating procedure, with<br />

responsibility for the CD receptacle and a list<br />

of the current key holder(s)?<br />

Is there a clear daily audit trail for key holders<br />

(i.e. keys signed in and out, and not stored in<br />

a drawer)?<br />

Do you store naloxone in the practice?<br />

Section 4b: Security and safe custody of <strong>Controlled</strong> <strong>Drugs</strong> in transport<br />

Do you transport or are you responsible for<br />

the transport of CDs (this includes sending<br />

CDs using third party carriers)?<br />

Do you have written standard operating<br />

procedures in place for the transport of CDs?<br />

Are CDs kept in a locked receptacle during<br />

transport?<br />

Are records maintained of CDs in transport?<br />

Section 4c: Register of <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you maintain a controlled drug register?<br />

Are the controlled drugs kept at more than<br />

one surgery site?<br />

Is there a separate register for each area<br />

where the CDs are stored?<br />

Is the CD register stored safely, near to, but<br />

outside the CD receptacle?<br />

Are all records, registers and invoices kept for<br />

a minimum of 2 years?<br />

Have there been any patient or carer<br />

complaints involving the storage, transport or<br />

record keeping of CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

Yes No Details<br />

Yes No Details<br />

Page 140 of 196


or others about the storage, transport or<br />

record keeping of CDs?<br />

Have there been any significant events<br />

involving the storage, transport or record<br />

keeping of CDs?<br />

Section 4c: Paper based CD registers<br />

The following table may be used to identify which procedures are being followed and<br />

the number of registers in current use. Tick the box to indicate whether the criteria are<br />

being followed in the practice.<br />

Criterion Register Comments<br />

1. Format of register<br />

1.1 Bound book<br />

1.2 Separate section per drug<br />

1.3 Separate section per presentation with<br />

name and strength at top of each page<br />

2. Entries<br />

2.1 In ink<br />

2.2 Chronological order<br />

2.3 Entries within 24 hours<br />

2.4 Are entries dated, timed and signed by<br />

two practitioners<br />

3. Errors and corrections<br />

3.1 As margin/foot notes<br />

3.2 Corrections dated<br />

3.3 Corrections initialled<br />

4. Record of receipt<br />

4.1 Date of receipt<br />

4.2 Name and address of supplier<br />

4.3 Amount obtained<br />

4.4 Form and strength obtained<br />

4.5 Running balance<br />

4.6 Signature<br />

4.7 Process for discrepancies<br />

5. Record of supply<br />

5.1 Date of supply<br />

5.2 Name and address of person supplied<br />

5.3 Authority to supply<br />

5.4 Amount supplied<br />

5.5 Form and strength supplied<br />

5.6 Running balance<br />

5.7 Signature<br />

Criterion Register Comments<br />

5.8 Collected by<br />

6. Record of administration<br />

6.1 Date of administration<br />

6.2 Name and address of person<br />

administered to (where appropriate)<br />

6.3 Name and authority of person<br />

administering<br />

6.4 Amount administered<br />

Page 141 of 196


6.5 Form administered<br />

6.6 Time of administration<br />

6.7 Running balance<br />

6.8 Signature and witness where appropriate<br />

6.9 Procedure if pack contents incorrect<br />

7. Stock check<br />

7.1 Evidence of appropriate stock check e.g.<br />

monthly<br />

7.2 Stock checked and correct<br />

7.3 Different people carrying out stock check<br />

Section 5: Destruction of <strong>Controlled</strong> <strong>Drugs</strong><br />

Are CDs destroyed using recommended<br />

methods?<br />

Are there any CDs awaiting destruction in the<br />

CD receptacle?<br />

Is date expired CD stock clearly labelled?<br />

Is date expired CD stock clearly segregated?<br />

Have there been any patient or carer<br />

complaints involving the destruction of CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the destruction of CDs?<br />

Have there been any significant events<br />

involving the destruction of CDs?<br />

Destruction of stock controlled drugs<br />

Is there a written standard operating<br />

procedure for the destruction of controlled<br />

drugs?<br />

Is destruction of stock CDs witnessed by an<br />

authorised person?<br />

Is the authorised person NOT directly involved<br />

with CD supply in the practice?<br />

Is the name, form, strength and quantity of the<br />

drug destroyed, entered into the CD register?<br />

Is the date of destruction entered into the<br />

register?<br />

Is the signature of the witness entered into the<br />

register?<br />

Is there a written standard operating<br />

procedure for the destruction of expired stock<br />

from doctor‘s bags?<br />

Destruction of patient returned controlled<br />

drugs<br />

Are records made of patient returned CDs in a<br />

separate book (not the CD register)?<br />

Does this book record:<br />

The date received?<br />

Name and address of the patient prescribed<br />

CD?<br />

Destruction of patient returned controlled<br />

Yes No Details<br />

Page 142 of 196


drugs<br />

Does this book record:<br />

Pharmacy/practice where originally<br />

dispensed?<br />

Name, quantity, form of CD?<br />

Role of person returning CD?<br />

Name and signature of staff receiving CD?<br />

Name and signature of staff destroying CD<br />

and date?<br />

Name and signature of witness to destruction<br />

and date?<br />

Are patient returned CDs destroyed as soon<br />

as possible?<br />

What methods are used to destroy patient<br />

returned controlled drugs? (Dispensing<br />

Doctors)<br />

Is the patient returns process audited?<br />

Section 6: General<br />

Do all staff know who to contact at the<br />

Primary Care Organisation regarding<br />

concerns about other colleagues in relation to<br />

CDs?<br />

Can the nurse/ECP/dispenser in charge<br />

explain protocol/policy if a vial/tablet is:<br />

Broken<br />

Unaccounted for<br />

Out of date<br />

No longer required by the patient after<br />

dispensing<br />

Yes No Details<br />

Page 143 of 196


Comments<br />

It is good practice to keep all audit records for 7 years<br />

Revision Date: August 2010<br />

Page 144 of 196


Appendix L<br />

Community Hospital Name<br />

Community Hospital Address<br />

Community Hospital<br />

Representative (Print Name)<br />

Community Hospital<br />

Representative (Signature)<br />

PCT Pharmacist (Print Name)<br />

PCT Pharmacist (Signature)<br />

Date of Visit<br />

Personnel Prescribing CDs<br />

Personnel with access to CD<br />

receptacle<br />

<strong>Controlled</strong> <strong>Drugs</strong>: Community Hospital Audit<br />

Page 145 of 196


Overall responsibility for CDs rests<br />

with:<br />

Section 1: Obtaining <strong>Controlled</strong> <strong>Drugs</strong><br />

Main Supplier of CDs:<br />

Orders authorised by:<br />

Person(s) authorised to receive<br />

CDs at premises:<br />

Is there a written standard operating procedure in place for<br />

ordering CDs?<br />

Is a record of orders kept for a minimum of 2 years?<br />

Are CD orders authorised?<br />

Is there a written standard operating procedure in place for<br />

the receipt of CDs?<br />

Is there a written standard operating procedure in place for<br />

the receipt of CDs delivered via transport systems?<br />

Is the level of stock held to a minimum and reviewed<br />

annually?<br />

Section 2: Supply of <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you provide advice to patients on the<br />

safekeeping and disposal of unwanted CDs?<br />

Are patient information leaflets supplied to all<br />

patients receiving CDs?<br />

Are patient returned medicines ever reused?<br />

Have there been any patient or carer<br />

complaints involving the supply of CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the supply of CDs from the<br />

organisation?<br />

Have there been any significant events<br />

involving the supply of CDs relating to the<br />

organisation?<br />

Section 3: Administration of <strong>Controlled</strong> <strong>Drugs</strong><br />

Are CDs which are administered:<br />

(g) Stock CDs?<br />

(h) Patient‘s own CDs?<br />

Do you maintain records of administration?<br />

(If yes, where? E.g. Register, drug cardex<br />

YES NO<br />

Yes No Details<br />

Yes No Details<br />

Page 146 of 196


etc.)<br />

Is the administration of CDs witnessed?<br />

If administration is not witnessed, do you have<br />

risk management policies in place?<br />

Have there been any patient or carer<br />

complaints involving the administration of<br />

CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the administration of CDs from<br />

the organisation?<br />

Have there been any significant events<br />

involving the administration of CDs relating to<br />

the organisation?<br />

Section 4a: Storage of <strong>Controlled</strong> <strong>Drugs</strong><br />

Are Schedule 2 CDs stored in a locked,<br />

secure, non-portable receptacle?<br />

Is the receptacle permanently affixed to an<br />

internal wall?<br />

Is the receptacle used only for CDs?<br />

Are all stock CDs kept in their original<br />

containers?<br />

Are different strengths of the same medicines<br />

segregated?<br />

Are there any patient‘s own medicines stored<br />

in the CD receptacle?<br />

Are out of date/returned medicines/out of date<br />

stock segregated?<br />

Are patient returned medicines ever reused?<br />

Is there a written standard operating<br />

procedure which details routine date checking<br />

of stock CDs?<br />

How often does routine date checking take<br />

place?<br />

Is the room containing the CD receptacle<br />

lockable?<br />

Is the room containing the CD receptacle kept<br />

locked?<br />

Does the room containing the CD receptacle<br />

have limited access?<br />

Is there a named person detailed in a written<br />

standard operating procedure, with<br />

Yes No Details<br />

Page 147 of 196


esponsibility for the CD receptacle and a list<br />

of the current key holder(s)?<br />

Is there a clear daily audit trail for key holders<br />

(i.e. keys signed in and out, and not stored in<br />

a drawer)?<br />

Do you store naloxone in the department?<br />

Section 4b: Security and safe custody of <strong>Controlled</strong> <strong>Drugs</strong> in transport<br />

Do you have written standard operating<br />

procedures in place for the transport of CDs?<br />

Are CDs kept in a locked receptacle during<br />

transport?<br />

Are records maintained of CDs in transport?<br />

Section 4c: Register of <strong>Controlled</strong> <strong>Drugs</strong><br />

Do you maintain a controlled drug register?<br />

Is the CD register stored safely, near to, but<br />

outside the CD receptacle?<br />

Are all records, registers and invoices kept for<br />

a minimum of 2 years?<br />

Have there been any patient or carer<br />

complaints involving the storage, transport or<br />

record keeping of CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the storage, transport or<br />

record keeping of CDs?<br />

Have there been any significant events<br />

involving the storage, transport or record<br />

keeping of CDs?<br />

Section 4c: Paper based CD registers<br />

Yes No Details<br />

Yes No Details<br />

Yes No Details<br />

The following table may be used to identify which procedures are being followed and<br />

the number of registers in current use. Tick the box to indicate whether the criteria are<br />

being followed in the practice.<br />

Criterion Register Comments<br />

1. Format of register<br />

1.1 Bound book<br />

1.2 Separate section per drug<br />

1.3 Separate section per presentation with<br />

name and strength at top of each page<br />

2. Entries<br />

2.1 In ink<br />

Page 148 of 196


2.2 Chronological order<br />

2.3 Entries within 24 hours<br />

3. Errors and corrections<br />

3.1 As margin/foot notes<br />

3.2 Corrections dated<br />

3.3 Corrections initialled<br />

4. Record of receipt<br />

4.1 Date of receipt<br />

4.2 Name and address of supplier<br />

4.3 Amount obtained<br />

4.4 Form and strength obtained<br />

4.5 Running balance<br />

4.6 Signature<br />

4.7 Process for discrepancies<br />

5. Record of supply (discharge/return of<br />

patient‟s own drugs)<br />

5.1 Date of supply<br />

5.2 Name and address of person supplied<br />

5.3 Authority to supply<br />

5.4 Amount supplied<br />

5.5 Form and strength supplied<br />

5.6 Running balance<br />

5.7 Signature<br />

5.8 Collected by<br />

6. Record of administration<br />

6.1 Date of administration<br />

6.2 Name of person administered to (where<br />

appropriate)<br />

6.3 Name and authority of person<br />

administering<br />

6.4 Amount administered<br />

6.5 Form administered<br />

6.6 Time of administration<br />

6.7 Running balance<br />

6.8 Signature and witness where appropriate<br />

6.9 Procedure if pack contents incorrect<br />

7. Stock check<br />

7.1 Evidence of appropriate stock check e.g.<br />

monthly<br />

7.2 Stock checked and correct<br />

7.3 Different people carrying out stock check<br />

Section 5: Destruction of <strong>Controlled</strong> <strong>Drugs</strong><br />

Are CDs destroyed using recommended<br />

methods?<br />

Are there any CDs awaiting destruction in the<br />

CD receptacle?<br />

Is date expired CD stock clearly labelled?<br />

Is date expired CD stock clearly segregated?<br />

Yes No Details<br />

Page 149 of 196


Have there been any patient or carer<br />

complaints involving the destruction of CDs?<br />

Have there been any concerns expressed by<br />

colleagues, police, substance misuse services<br />

or others about the destruction of CDs?<br />

Have there been any significant events<br />

involving the destruction of CDs?<br />

Destruction of stock controlled drugs<br />

Is there a written standard operating<br />

procedure for the destruction of controlled<br />

drugs?<br />

Is destruction of stock CDs witnessed by an<br />

authorised person?<br />

Is the authorised person NOT directly involved<br />

with CD supply in the practice?<br />

Is the name, form, strength and quantity of the<br />

drug destroyed, entered into the CD register?<br />

Is the date of destruction entered into the<br />

register?<br />

Is the signature of the witness entered into the<br />

register?<br />

Destruction of patient returned controlled<br />

drugs<br />

Are records made of patient‘s own CDs in a<br />

separate book (not the stock CD register)?<br />

Does this book record:<br />

The date received?<br />

Name and address of the patient prescribed<br />

CD?<br />

Pharmacy where originally dispensed?<br />

Name, quantity, form of CD?<br />

Role of person returning CD?<br />

Name and signature of staff receiving CD?<br />

Name and signature of staff destroying CD<br />

and date?<br />

Name and signature of witness to destruction<br />

and date?<br />

Are patient‘s own CDs destroyed as soon as<br />

possible?<br />

Is the patient‘s own returns process audited?<br />

Page 150 of 196


Section 6: General<br />

Do all staff know who to contact at the<br />

Primary Care Organisation regarding<br />

concerns about other colleagues in relation to<br />

CDs?<br />

Comments<br />

Yes No Details<br />

It is good practice to keep all audit records for 7 years<br />

Revision Date: August 2010<br />

Page 151 of 196


Appendix M <strong>Controlled</strong> <strong>Drugs</strong>: Prison Audit<br />

Medicines Handling Audit for use in IDTS Implementation and CD Management<br />

Criterion 1 There are clear lines of accountability<br />

throughout the organisation…<br />

1.1 Job description of lead Pharmacist /pharmacy<br />

technician describes clear managerial and<br />

professional accountability to the PCT and/or<br />

Healthcare Manager<br />

1.2 Terms of reference of responsible committee(s)<br />

include medicines management and<br />

involvement of a Pharmacist in advising on IDTS<br />

e.g. DTC; IDTS steering & implementation<br />

groups<br />

1.3 An Organisational chart shows the relevant links<br />

to medicines management in IDTS ( clinical and<br />

medicines supply)<br />

1.4 A strategy exists for ensuring the safe & secure<br />

handling of medicines and this includes CDs<br />

1.5 There is an index of medicines policies relating<br />

to CDs and these are accessible and up to date<br />

& available in healthcare and pharmacy dept<br />

Criterion 2 Suitable controls are in place that ensure the<br />

principles of the NPC primary Care CD<br />

Guidance and Duthie report are met<br />

Wings, clinics & wards<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

Planning for<br />

Delivery (1)<br />

Planning for<br />

Delivery (1)<br />

Planning for<br />

Delivery (1)<br />

Planning for<br />

Delivery (1)<br />

IDTS Delivery<br />

(22-<br />

Pharmacy)<br />

Comments Relating to Interpretation for<br />

CDs in Prisons


2.1 Designated staff check items received against<br />

requisition/delivery note<br />

2.2 Goods are signed for at wing level by<br />

designated staff<br />

2.3 Designated staff return requisition/delivery note<br />

to confirm delivery<br />

Pharmacy/Healthcare Centre (HCC)<br />

2.4 There is a schedule for rolling stock checks that<br />

is adhered to and SOPs must reflect the checks<br />

and frequency of checks<br />

2.5 Ad hoc orders are in writing and meet the legal<br />

requirements<br />

IDTS Delivery<br />

(22 -<br />

Pharmacy)<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

Page 153 of 196<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

Where administration/supply occurs on a<br />

designated wing or area/clinic room: official<br />

CD Requisition book is needed (carbonated<br />

and sequentially numbered)<br />

Usually the top (white) copy of the requisition<br />

book mentioned in 2.2<br />

CD Stocks checked regularly in Healthcare on<br />

wings/areas/clinic rooms. An overall prison<br />

stock reconciliation check by designated staff<br />

(e.g.by pharmacist on clinical visit) will be<br />

required at least once a month. This monthly<br />

check to be recorded in a different colour ink<br />

for ease of reconciliation/audit (e.g. green/red<br />

pen). In an on-site pharmacy dept, a rolling<br />

stock check of pharmacy stocks should be<br />

performed at least weekly.<br />

If discrepancies arise, or if volume of use<br />

necessitates, more frequent checks would be<br />

needed.Records of checks must be kept for<br />

as long as legislation dictates. (see section<br />

2.9 - soon to be 11 years, as for registers)<br />

For wings/wards/treatment rooms, requisition<br />

books as in 2.2 are required.


2.6 Copies of orders are kept for 2 years at least see 2.9 below<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

Page 154 of 196<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

2.7 Job descriptions identify responsible staff Legally the doctor is responsible for CD<br />

ordering in Healthcare. The Head of<br />

Healthcare (principal healthcare professional)<br />

should be the designated person responsible<br />

for the possession/handling of CDs in the<br />

prison. The Principal Pharmacist is<br />

responsible for the possession/handling of<br />

CDs in the Pharmacy. Job Descriptions<br />

should include delegated responsibilities of<br />

other prison and healthcare staff relating to<br />

medicines, including CDs.<br />

2.8 Duties of purchasing and receipt are separated Where ever practical, duties should be<br />

separated. All receipts of stock must be<br />

witnessed and checked against the order<br />

2.9 Records are held for periods of time identified by<br />

the CD Regulations e.g. CD Register, CD<br />

Prescriptions and Requisitions/Orders<br />

/requisition and signed as such.<br />

Currently all Registers, requisitions and<br />

orders (and invoices) for controlled drugs<br />

must be preserved for 2 years. The 2001<br />

Regulations have been amended to allow the<br />

information in these records to be preserved<br />

in the original paper form or in computerised<br />

form (as long as secure). Once<br />

computerised recording is in common use,<br />

The Government intends that secure<br />

computerised copies be kept for 11 years.


2.10 An audit trail exists for the ordering, receipt and<br />

supply of medicines<br />

Criterion 3 Medicines are stored and handled in a safe<br />

and secure manner<br />

HCC, wings, clinics & wards<br />

3.1 Medicines are locked away immediately on<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

Page 155 of 196<br />

Essential for CDs as every tablet or ml of<br />

liquid must be accounted for and there must<br />

be a robust audit trail in place.<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

receipt<br />

IDTS Delivery<br />

(22-Pharmacy)<br />

3.2 CD Medicine storage cabinets meet standards<br />

Facilities see the Silver level of the 'Sold Secure'<br />

of the Misuse of <strong>Drugs</strong> Regulations<br />

Required (7 & standard SS304 (domestic safes).Currently<br />

8)<br />

exceed the Misuse of Drug regulations but<br />

advised by the Home Office as being more<br />

effective and appropriate for prisons.<br />

Stationery is kept secure: Facilities Must be kept secure and only available to<br />

Required (7 & designated authorised persons. Their security<br />

8) & IDTS must be dealt with in the relevant Standard<br />

Delivery (22 - Operating Procedures<br />

Pharmacy)<br />

3.3 CD requisition books and Registers<br />

3.4 Prescription pads & charts<br />

3.5 Order Pads<br />

Transport of medicines:


3.6 There is a Standard Operating Procedure for the<br />

secure transport of CDs into and within the<br />

prison<br />

3.7 Ward/wing/clinic area CD's are sealed in a<br />

designated bag/box before delivery to them<br />

Page 156 of 196<br />

Facilities<br />

Required (7&8)<br />

IDTS Delivery<br />

(22 -<br />

Pharmacy)<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

3.8 All stock medicines are sent in sealable<br />

container<br />

Security: Facilities<br />

Required (7&8)<br />

This should be considered in the prison Risk<br />

Management procedure. The messenger<br />

transporting drugs must be aware of the<br />

security issues and the audit trail in 2.9.<br />

Authorised signatory must ensure they sign to<br />

confirm exactly what is received i.e. quantity<br />

and strength of drug. (Gate staff are NOT<br />

authorised signatories). There must be a<br />

robust audit trail from receipt of CD at the<br />

Gate to Healthcare/Pharmacy.<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

Must be considered in prison's CD policy,<br />

including all places in the prison where the<br />

CDs are stored and administered.<br />

Recommended that benzodiazepines are<br />

stored and managed as for all other CDs<br />

3.9 Pharmacy/HCC is secure Gated room; walls floors and ceilings solid.<br />

3.10 Access to Pharmacy/HCC areas is restricted<br />

3.11 Entrances to Pharmacy/HCC have secure solid<br />

doors & security locks<br />

Other:<br />

Adhere to Prison security guidelines


3.12 Lists of CDs that are stocked are available,<br />

maintained and updated regularly for healthcare,<br />

all areas, wings, clinics & wards<br />

3.13 Medicines etc for emergency use are available<br />

in a suitable presentation and regularly checked<br />

for expiry dates and stock levels maintained<br />

3.14 Policies and procedures in place that describe<br />

the actions to be taken with CDs if prison<br />

security is breached or if discrepancies in CD<br />

stock levels are identified<br />

Page 157 of 196<br />

IDTS Delivery<br />

(22-<br />

Pharmacy)<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

IDTS Delivery<br />

(22- Pharmacy<br />

and 24)<br />

IDTS Delivery (<br />

22- Pharmacy)<br />

Facilities<br />

Required (7&8)<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

Naloxone must be available for use in opiate<br />

toxicity (in Emergency Bags?). Consider<br />

availability where opiates are administered<br />

AND where toxicity likely to be identified (on<br />

wings?). Staff training and administration<br />

procedures must also be completed.<br />

This relates to when either<br />

Healthcare/Pharmacy security is breached or<br />

when there is "loss of control" in the prison or<br />

a prison area. Risks to the security of CDs<br />

must be considered in such cases.<br />

Discrepancies and security breaches should<br />

be recorded as critical incidents and a<br />

procedure for reporting these incidents should<br />

be in place. This would include the escalation<br />

of the incident to high risk/ investigation<br />

should more than one incident occur in a<br />

given area over a specified time period,<br />

especially if the same practitioner is involved.


Criterion 4 Prescription, supply and administration<br />

conform to the requirements of relevant<br />

legislation. Prescription, supply and<br />

administration of medicines is undertaken<br />

only by appropriately qualified staff.<br />

Page 158 of 196<br />

IDTS Delivery<br />

(22 -<br />

Pharmacy)<br />

Facilities<br />

Required (<br />

7&8)<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

4.1 All prescriptions are written by a doctor IDTS Delivery<br />

(21)<br />

4.2 All issues of CDs, including benzodiazepines,<br />

are administered by supervised consumption<br />

underpinned by an SOP<br />

4.3 Administration charts are always available to<br />

record all transactions with prisoners including<br />

issues of 'canteen list' medicines<br />

IDTS Delivery<br />

(21 and 22 -<br />

Pharmacy)<br />

Recommend that all Methadone is<br />

administered via automated pumps (manual<br />

or computerised depending on frequency)<br />

NOT by measuring out doses in conical<br />

measures unless methadone is used<br />

infrequently. Pharmacists should advise about<br />

use, maintenance and calibration of these.<br />

SOPs must specify these details.<br />

Administration of CDs requires 2 staff, one of<br />

whom should be a Healthcare Professional<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

Nurse and pharmacist prescribers can<br />

prescribe CDs for substance misuse via<br />

Supplementary Prescribing ONLY<br />

currently.<br />

For IDTS programme<br />

If CDs are administered using a computerised<br />

record, then any written Drug Administration<br />

charts and patient medical notes should<br />

clearly state that the patient is receiving<br />

treatment for substance misuse and what they<br />

are prescribed. This allows for any clinical<br />

review (e.g. for a pharmacist checking the<br />

appropriateness of another prescribed/OTC<br />

medicine or another prescriber) to take into<br />

account this therapy.


4.4 All prescriptions are clinically checked by a<br />

pharmacist<br />

4.5 All relevant policies are in place and up to date<br />

(including PGDs)<br />

4.6 Proof of registration of all pharmacists &<br />

Pharmacy Technicians is checked annually<br />

4.7 Pharmacy services are in place to monitor and<br />

review prescription writing against locally agreed<br />

standards e.g. administration charts handwritten<br />

by Docs/nurse prescribers are clear and<br />

legible<br />

4.8 Prisoners have access to advice and<br />

counselling re their medicines from a<br />

pharmacist/technician or if not available, other<br />

member of the HC staff<br />

4.9 Prisoners are supplied with written information<br />

leaflets ideally each time a medicine is<br />

dispensed (in accordance with EU regulations)<br />

Page 159 of 196<br />

The prescriber is responsible until the<br />

pharmacist check is made<br />

see 4.12 below<br />

Workforce (14) Pharmacy technicians should be registered if<br />

they are managing the supply/administration<br />

of CDs.<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

IDTS Delivery<br />

(22 -<br />

Pharmacy)<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

Prescription writing for CDs must comply with<br />

the Misuse of <strong>Drugs</strong> Regulations.(latest<br />

guidance Jul 06) i.e. quantity must still be in<br />

words & figures etc but Dr does not now need<br />

to handwrite whole prescription<br />

CARAT staff should be able to signpost<br />

prisoners for medicines advice, so this advice<br />

can be part of the advice and counselling<br />

available to prisoners receiving treatment for<br />

substance misuse (including treatment for<br />

benzodiazepines, alcohol as well as opiate<br />

misuse).<br />

Because the CDs will be administered under<br />

supervision (NIP) Healthcare/ pharmacy<br />

should make any patient information leaflets<br />

available during initial stabilisation as well as<br />

later during treatment


4.10 There is a procedure for correctly identifying<br />

prisoners when administering medication<br />

4.11 Prisoners are observed taking/using their NIP<br />

medicines by HC staff<br />

4.12 Supply and administration of drugs is covered<br />

by a Patient Group Direction where appropriate<br />

4.13 Any CDs issued to prisoners directly from stock<br />

are issued under the directions of a doctor and<br />

recorded<br />

Criterion 5 The prescribing, supply, administration, safe<br />

custody and destruction of controlled<br />

medicines complies with the appropriate<br />

legislation.<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

Page 160 of 196<br />

Some IT systems will provide for iris or<br />

fingerprint recognition. In the absence of<br />

these, there must be a clearly stated means<br />

of confirming prisoner ID as part of the SOPs<br />

for administration of methadone.<br />

This should be the case for all CDs used in<br />

Substance Misuse, including benzodiazepines<br />

and SOPs should specify this. Prison<br />

procedures and protocols should mirror those<br />

in primary care/ community pharmacy.<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

Not applicable for CDs for Substance<br />

Misuse as these cannot be supplied under<br />

PGDs. Naloxone is able to be administered,<br />

exempt from the Medicines Act, in an<br />

emergency however.<br />

As all doses will be administered under<br />

supervision (NIP), the CDs should be<br />

administered from stock supplies. There must<br />

be set protocols for administration by<br />

supervised consumption.


5.1 All relevant policies are in place and up to date<br />

5.2 Prescriptions for CDs comply with Legislation<br />

5.3 Pharmacy CD registers are stored for 2 years Likely to be eleven years when regulations<br />

amended<br />

5.4 CD requisitions and registers are completed<br />

correctly<br />

5.5 CD levels checked by the auditor are correct<br />

5.6 CD checks are up to date<br />

5.7 Only authorised personnel order, supply,<br />

possess, prescribe & administer CDs<br />

5.8 The destruction and disposal of CDs complies<br />

with legislation<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

Page 161 of 196<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

Legally only the doctor or pharmacist can<br />

order CDs and so must countersign any<br />

Requisitions but the Head of Healthcare<br />

(healthcare professional) should have<br />

designated overall authority and<br />

accountability for the management of CDs<br />

within the prison. Responsibilities in this<br />

section should be delegated to appropriate<br />

named staff only.<br />

Advice from the PCTs Accountable Officer<br />

should be sought. It is important that there is<br />

an efficient mechanism for arranging for CD<br />

destruction to prevent excess stocks being<br />

stored.


Criterion 6 All medicines no longer required are<br />

destroyed or otherwise disposed of in<br />

accordance with safety, legal and<br />

environmental requirements<br />

6.1 The Pharmacy/HCC procedure is in place and<br />

up to date<br />

6.2 The prison's policy for the management of<br />

pharmaceutical waste is in line with that of the<br />

PCT<br />

6.3 An audit trail exists that can be used to follow<br />

the handling of pharmaceutical waste<br />

Criterion 7 The organisation reports adverse incidents<br />

involving medicinal products and devices to<br />

the relevant agency, and appropriately<br />

manages any subsequent required action.<br />

7.1 Procedure is in place and up to date and<br />

pharmacy/HCC responsibilities are documented<br />

7.2 Staff are aware of incident/ADR/defective<br />

product recall procedures<br />

7.3 There is evidence that recalls are effectively<br />

implemented<br />

Page 162 of 196<br />

IDTS Delivery<br />

(22 -<br />

Pharmacy)<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

IDTS Delivery<br />

(22 -<br />

Pharmacy)<br />

Note the destruction of CDs stock must be<br />

witnessed by an authorised person (check<br />

with Accountable Officer at PCT) and<br />

rendered irretrievable. An SOP is needed.<br />

See 5.8 above<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

Incidents involving CDs are a high priority for<br />

identifying, reporting, investigating and<br />

actioning any follow-up. There should be an<br />

SOP specifying a clear cascade of<br />

alerts/recalls to relevant staff.


7.4 Errors are reported through a risk management<br />

framework<br />

7.5 Medication incidents are investigated and<br />

reported locally<br />

7.6 All NPSA alerts and safety notices are<br />

implemented<br />

Criterion 8 Supervision of pharmaceutical dispensing<br />

processes is undertaken in accordance with<br />

relevant legislation and current professional<br />

standards.<br />

8.1 Procedures are in place and up to date IDTS Delivery<br />

(22-Pharmacy)<br />

Yes No IDTS Toolkit<br />

Reference<br />

8.2 Staff rotas are in place to ensure adequate<br />

cover<br />

Page 163 of 196<br />

Section<br />

Workforce<br />

(15,18)<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

There will always need to be 2 people ( one of<br />

which must be a registered nurse or<br />

registered pharmacy technician or doctor or<br />

pharmacist, plus another competent person)<br />

involved in administering CDs to patients<br />

8.3 Checking technicians are externally accredited Registered Pharmacy Technicians should<br />

complete the ACT course, especially if there<br />

8.4 All prescriptions are clinically checked by a<br />

pharmacist<br />

IDTS Delivery<br />

(22-Pharmacy)<br />

is not an on-site pharmacist.<br />

This should be incorporated into the supply<br />

process, as for patients receiving other<br />

medication, to ensure quality of care. Initial<br />

supplies may not have been checked by a<br />

pharmacist if they have not dispensed the CD.<br />

In this case responsibility rests with the<br />

prescriber until the clinical check has been


8.5 Medication-related errors are recorded and<br />

reviewed<br />

8.6 Policies and procedures are in place if<br />

extemporaneous preparations are needed<br />

8.7 Extemps are only prepared where no equivalent<br />

licensed product is available<br />

Criterion 9 The risk management process contained<br />

within the Risk Management standard is<br />

applied to the safe and secure handling of<br />

medicines.<br />

19.1 All identified risks are documented, assessed<br />

and prioritised<br />

19.2 Action plans are developed and implemented<br />

9.3 The PCT Board or equivalent is informed and<br />

updated on significant risks<br />

Page 164 of 196<br />

Planning for<br />

Delivery (5)<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

made by the pharmacist.<br />

See section 7<br />

Prison Pharmacies should not be<br />

reconstituting Methadone Mixture from the<br />

powder and diluents or using the concentrate.<br />

All supplies should be made using the 1mg/ml<br />

Methadone Mixture that is commercially<br />

available.<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

The IDTS implementation group within the<br />

establishment (in partnership with the D&T /<br />

Medicines Committee) should identify any<br />

risks associated with the medicines storage<br />

and handling of CDs. These should be<br />

included in the PCT/Prison Risk Register.


9.4 Staff are aware of systems in place to minimise<br />

risk e.g. protocols for dispensing and supply of<br />

medicines<br />

Criterion 10 All healthcare staff involved with medicines<br />

undertakes continuing professional<br />

development to ensure that there are safe<br />

and secure handling processes in place.<br />

Page 165 of 196<br />

Workforce (14,<br />

15,16, 17 &<br />

19)<br />

All staff involved in medicines storage and<br />

handling of CDs should have read and signed<br />

the relevant SOPs<br />

Pharmacy Pharmacists: All pharmacists involved in IDTS<br />

should have completed the CPPE course<br />

'Substance Use & Misuse' and the viva day to<br />

attain the RCGP Part 1 certificate in<br />

Substance Misuse. Pharmacy Technicians<br />

should all be registered and have completed<br />

the CPPE course 'Substance Use and<br />

Misuse- fundamentals and practicalities for<br />

the pharmacy technician‘ (modules 1-3) and<br />

the viva day to attain the RCGP Part 1<br />

certificate in Substance Misuse. Pharmacists<br />

involved in clinical services should have<br />

10.1 Training and development plans are in place<br />

10.2 All pharmacy staff maintain CPD records<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

completed RCGP part 2 training.<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

10.3 Staff are aware of local policies<br />

Other healthcare staff / Prison Officers Medicines Management training required by<br />

these groups should be identified, prioritised<br />

and needs met prior to approval of statement<br />

of readiness. This includes training for staff<br />

not directly involved in medicines handling


10.4 Training and development plans are in place<br />

10.5 Healthcare staff maintain CPD records<br />

10.6 Staff are aware of local policies<br />

Criterion 11 The organisation, through the Lead<br />

Pharmacist/Technician, has access to up-todate<br />

legislation and guidance relating to the<br />

safe and secure handling of medicines.<br />

11.1 Can demonstrate access to relevant information<br />

and means of update<br />

11.2 Can demonstrate mechanism for cascading<br />

information to appropriate prison staff<br />

Criterion 12 Adequate resources support the safe and<br />

secure handling of medicines.<br />

12.1 A development plan that includes <strong>Controlled</strong><br />

<strong>Drugs</strong> is in place & there is a planned review<br />

process<br />

Page 166 of 196<br />

Facilities<br />

Required (7&<br />

8)<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

Planning for<br />

Delivery (1 &<br />

6) Workforce<br />

(14,15 20)<br />

and storage.<br />

The registered pharmacy practitioner and<br />

Head of Healthcare will be responsible for<br />

ensuring that developments/requirements in<br />

the management of CDs are identified and<br />

cascaded to other staff as necessary.<br />

Comments Relating to Interpretation for<br />

CDs in Prisons


12.2 The pharmacy service & medicines<br />

administration is safely resourced in terms of<br />

staffing, equipment and facilities<br />

12.3 If resources are not adequate, key areas where<br />

funding is required are identified in the<br />

development plan<br />

Criterion 13 The system in place is monitored and<br />

reviewed by management and the Board in<br />

order to make improvements to the system<br />

13.1 Internal audits reports are seen by the Board<br />

13.2 Minutes of relevant meetings are seen by the<br />

Board<br />

13.3 The PCT Accountable Officer for <strong>Controlled</strong><br />

<strong>Drugs</strong> is also included in IDTS implementation,<br />

as appropriate, and has access to<br />

documentation in 13.1. & 13.2 above<br />

Yes No IDTS Toolkit<br />

Reference<br />

Section<br />

Page 167 of 196<br />

It is essential that, as well as the medical and<br />

nursing workforce needs identified by IDTS<br />

implementation, the growth needed in<br />

pharmacy staff (Pharmacy technicians,<br />

Pharmacy Assistants and Pharmacist clinical<br />

input) is included in the IDTS workforce<br />

requirements.<br />

Comments Relating to Interpretation for<br />

CDs in Prisons<br />

N.B. CD Regulations & The Health Act require<br />

appointment of an Accountable Officer to<br />

ensure there are robust arrangements for safe<br />

& effective handling of CDs. The PCT<br />

Accountable Officer will have jurisdiction over<br />

prisons in their area.


Criterion 14 The PCT Board seeks independent<br />

assurance that an appropriate and effective<br />

system is in place.<br />

14.1 External audit reports reviewed<br />

Page 168 of 196<br />

Commissioning<br />

(11)<br />

Future external audits are likely to include the<br />

management of CDs. A duty of Collaboration<br />

is placed on responsible bodies (Healthcare<br />

organisations, police forces, Healthcare<br />

Commission, Prison Inspectorate etc) under<br />

the Health Act 2006 to share information on<br />

CDs.


Appendix N<br />

USEFUL EXTERNAL CONTACTS<br />

British Medical Association<br />

BMA House Tel: 0207 387 4499<br />

Tavistock Square Fax: 0207 383 6400<br />

London Website: www.bma.org.uk<br />

WC1H 9JP<br />

Care Quality Commission<br />

Citygate Tel: 03000 616 161<br />

Gallowgate<br />

Newcastle upon Tyne Website: www.cqc.org.uk<br />

NE1 4PA<br />

Community practitioners‘ and Health Visitors Association<br />

33-37 Moreland Street Tel: 0207 505 3000<br />

London<br />

EC1V 8HA Website: www.amicustheunion.org/cphva/<br />

Council for Healthcare Regulatory Excellence<br />

1 st Floor, Kierran Cross Tel: 0207 389 8030<br />

11 Strand Fax: 0207 389 8040<br />

London Website: www.chre.org.uk<br />

WC2N 5HR<br />

Department of Health<br />

Richmond House Tel: 0207 210 4850<br />

79 Whitehall Website: www.dh.gov.uk<br />

London<br />

SW1A 2NS<br />

Dispensing Doctors‘ Association<br />

Low Hagg Farm Tel: 01751 430835<br />

Starfitts Lane Fax: 01751 430836<br />

Kirbymoorside Website: www.dispensing doctor.org<br />

North Yorkshire<br />

YO62 7JF<br />

Environment Agency<br />

Millbank Tower Tel: 08708 506 506<br />

25 th Floor Website: www.environment-agency.gov.uk<br />

21/24 Millbank<br />

London<br />

SW1P 4XL


General Medical Council<br />

Regent‘s Place Tel: 0845 357 3456<br />

350 Euston Road Website: www.gmc-uk.org<br />

London<br />

NW1 3JN<br />

Home Office <strong>Drugs</strong> Licensing Branch<br />

2 Marsham Street Tel: 0207 035 0483<br />

London Website: www.homeoffice.gov.uk<br />

SW1P 4DF<br />

Home Office <strong>Drugs</strong> Legislation and Enforcement Unit<br />

2 Marsham Street Tel: 0207 035 0464<br />

London Website: www.homeoffice.gov.uk<br />

SW1P 4DF<br />

Medicines and Healthcare products Regulatory Agency<br />

Market Towers Tel: 0207 084 2000<br />

1 Nine Elms lane Fax: 0207 084 2353<br />

London Website: www.mhra .gov.uk<br />

SW8 5NQ<br />

National <strong>Clinical</strong> Assessment Service (part of the National Patient Safety Agency)<br />

Market Towers Tel: 0207 062 1620<br />

1 Nine Elms Lane Fax: 0207 084 3851<br />

London Website: www.ncas.npsa.nhs.uk<br />

SW8 5NQ<br />

National Patient Safety Agency<br />

4-8 Maple Street Tel: 0207 927 9500<br />

London Website: www.npsa.nhs.uk<br />

W1T 5HD<br />

National Pharmacy Association<br />

Mallinson House Tel: 01727 832161<br />

38-42 St Peter‘s Street Fax: 01727 840858<br />

St Albans Website: www.npa.co.uk<br />

Hertfordshire<br />

AL1 3NP<br />

National Prescribing Centre<br />

The Infirmary Tel: 0151 794 8134<br />

70 Pembroke Place Fax: 0151 794 8139<br />

Liverpool Website: www.npc.co.uk (Internet)<br />

L69 3GF www.npc.nhs.uk (<strong>NHS</strong>Net)<br />

National Treatment Agency<br />

8 th Floor Tel: 020 7261 8801<br />

Hercules House Fax: 020 7261 8883<br />

Hercules Road Website: www.nta.nhs.uk<br />

London<br />

SE1 7DU<br />

Page 170 of 196


<strong>NHS</strong> <strong>Clinical</strong> Governance Support Team<br />

1 st Floor Tel: 0116 295 2000<br />

St. Johns House Fax: 0116 295 2001<br />

30 East Street Website: www.egsupport.nhs.uk<br />

Leicester<br />

LE1 6NB<br />

<strong>NHS</strong> Direct<br />

Headquarters Tel: 0207 599 4200<br />

207 Old Street Fax: 0207 599 4299<br />

London Website: www.nhsdirect.nhs.uk<br />

EC1V 9PS<br />

Nursing and Midwifery Council<br />

23 Portland Place Tel: 020 7637 7181<br />

London Fax: 020 7436 2924<br />

W1B 1PZ Website: www.nmc-uk.org<br />

Pharmaceutical Services Negotiating Committee<br />

59 Buckingham Street Tel: 01296 432 823<br />

Aylesbury Fax: 01296 438 427<br />

Buckinghamshire Website: www.psnc.org.uk<br />

HP20 2PJ<br />

Prescription Pricing Divisions of the <strong>NHS</strong> Business Services Authority<br />

Bridge House Tel: 0191 232 5371<br />

152 Pilgrim Street Fax: 0191 232 2480<br />

Newcastle-upon-Tyne Website: www.ppa.org.uk<br />

NE1 6SN<br />

Prescribing Support Unit<br />

The Health and Social Care Information Centre Tel: 0113 254 7041<br />

1 Trevelyan Square Fax: 0113 254 7097<br />

Boar lane Website: www.psu.nhs.uk<br />

Leeds<br />

LS1 6AE<br />

Royal College of General Practitioners<br />

RCGP Substance Misuse Unit Tel: 0845 4564041 Ext. 217<br />

14 Princess Gate Fax: 0207 225 3047<br />

Hyde Park Website: www.regp.org.uk/substance<br />

London<br />

SW7 1PU<br />

Royal College of Nursing<br />

Head Office Tel: 0207 409 3333<br />

20 Cavendish Square Website: www.ren.org.uk<br />

London<br />

W1G 0RN<br />

Royal Pharmaceutical Society of Great Britain<br />

1 Lambeth High Street Tel: 0207 735 9141<br />

London Fax: 0207 735 7629<br />

SE1 7JN Website: www.rpsgb.org.uk<br />

Page 171 of 196


UK Home Care Association<br />

42b Banstead Road Tel: 0208 288 1551<br />

Carshalton Beeches Fax: 0208 288 1550<br />

Surrey Website: www.ukhca.co.uk<br />

SM5 3NW<br />

Page 172 of 196


Drug<br />

Appendix O<br />

Table of <strong>Controlled</strong> drugs and indications allowed to be prescribed by Nurse<br />

Independent Prescriber‟s<br />

Schedule*<br />

Indication<br />

Page 173 of 196<br />

Route of administration<br />

Buprenorphine 3 Transdermal use in palliative care Transdermal<br />

Chlordiazepoxide<br />

Hydrochloride<br />

4<br />

Treatment of initial or acute<br />

withdrawal symptoms caused by<br />

the withdrawal of alcohol from<br />

persons habituated to it<br />

Codeine phosphate 5 N/A Oral<br />

Co-phenotrope 5 N/A<br />

Use in palliative care, pain relief<br />

Oral<br />

Diamorphine<br />

2 in respect of suspected myocardial Oral or parenteral<br />

Hydrochloride<br />

infarction of for relief of acute or<br />

severe pain of trauma, including<br />

in either case post-operative pain<br />

relief<br />

Use in palliative care, treatment<br />

of initial or acute withdrawal<br />

Diazepam<br />

4 symptoms caused by the withdrawal<br />

of alcohol from persons<br />

habituated to it, tonic-clonic<br />

seizures<br />

Oral, parenteral or rectal<br />

Dihydrocodeine tartrate 5 N/A Oral<br />

Fentanyl 2 Transdermal use in palliative care Transdermal<br />

Lorazepam 4 Use in palliative care, tonic-clonic<br />

seizures<br />

Oral or parenteral<br />

Midazolam 3 Use in palliative care, tonic-clonic<br />

seizures<br />

Use in palliative care, pain relief in<br />

respect of suspected myocardial<br />

Parenteral or buccal<br />

Morphine hydrochloride 2 infarction or for relief of acute or<br />

severe pain after trauma, including<br />

in either case post-operative pain<br />

relief<br />

Use in palliative care, pain relief<br />

Rectal<br />

Morphine sulphate 2 in respect of suspected myocardial<br />

infarction or for relief of acute or<br />

severe pain after trauma, including<br />

in either case post-operative pain<br />

relief<br />

Oral, parenteral or rectal<br />

Oral or parenteral<br />

Oxycodone<br />

2 Use in palliative care<br />

administration in<br />

Hydrochloride<br />

palliative care<br />

*Schedule 1-5 of the Misuse of <strong>Drugs</strong> Regulations 2001<br />

For the purposes of nurse independent prescribing, palliative care means the care of patients with advanced progressive<br />

illness.<br />

Oral


Appendix P<br />

Methods of Destruction of <strong>Controlled</strong> <strong>Drugs</strong><br />

All medicines should be disposed of in a safe and appropriate manner. Medicines<br />

should be disposed of in relevant waste containers which are then sent for incineration<br />

and should not be disposed of in the sewerage system.<br />

All CDs in Schedule 2, 3 and 4 (part I) can be placed into waste containers only after<br />

the controlled drug has been rendered irretrievable (i.e. by denaturing).<br />

Wherever practicable, CD denaturing kits should be used in order to denature CDs.<br />

Where this is not possible or practical other methods of denaturing may be used. In the<br />

past, various methods have been used to denature controlled drugs, including grinding<br />

together with other waste medicines, and / or dissolving in soapy water or adsorbing<br />

onto cat litter.<br />

Having considered the risks posed by destruction of CDs in a pharmacy, the<br />

Environment Agency (EA), which covers England and Wales, has decided that it does<br />

not believe it is in the public interest to expect pharmacies to obtain a waste<br />

management license for denaturing CDs and this is seen by the EA as a ‗low risk‘<br />

activity. The EA emphasises, however, that it may amend or revoke its position at any<br />

time and will continue enforcement in all circumstances where activity has or is likely to<br />

cause pollution or harm to health. So, pharmacists must ensure that the activities they<br />

undertake to denature CDs protect the environment and workers and others within the<br />

pharmacy. These guidelines may transfer to other Healthcare settings e.g. Community<br />

Nursing.<br />

Solid dose formulations<br />

Tablets and capsules can be removed from their outer packaging, removed from blister<br />

packaging and placed in a CD denaturing kit. If a person is removing tablets / capsules<br />

from blister packs they should wear gloves.<br />

CD denaturing kits can be obtained from some PCTs, waste contractors, <strong>NHS</strong><br />

Supplies and the National Pharmacy Association.<br />

Best practice would be to grind* or crush* the solid dose formulation before adding to<br />

the CD denaturing kit to ensure that whole tablets or capsules are not readily<br />

recoverable.<br />

An alternative method of denaturing is to crush or grind the solid dose formulation and<br />

place it into a small amount of hot, soapy water stirring sufficiently to ensure the drug<br />

has been dissolved or dispersed. The resulting mixture may then be added to an<br />

appropriate waste disposal bin supplied by the waste contractor.<br />

*If grinding or crushing of tablets or capsules takes place, steps must be taken to<br />

ensure that particles of CD dust are not released into the air or that this is minimised.<br />

The use of a small amount of water whilst grinding or crushing may assist. It may also<br />

be necessary for the person involved in the grinding or crushing to wear a suitable face<br />

mask for protection, suitable gloves and ensure that the area is well ventilated.<br />

Liquid dose formulations<br />

A CD liquid can be poured from its container and added to the normal CD denaturing<br />

kit where it will mix with the other waste materials, thus rendering it irretrievable.<br />

Page 174 of 196


An alternative method of disposing of a large quantity of a liquid controlled drug is by<br />

adding and adsorbing it into an appropriate amount of cat litter, or similar product.<br />

However, this activity would need to take account of health and safety regulations so<br />

that the person destroying the CDs and the environment are safeguarded from harm<br />

and pollution. The cat litter or similar product should be disposed of for incineration via<br />

the usual waste disposal methods for medicines.<br />

Parenteral formulations<br />

Liquid ampoules should be opened and as much of the content as possible emptied<br />

into the CD denaturing kit or disposed of in the same manner as disposing of liquids<br />

outlined above.<br />

The ampoule should be disposed off in the sharps bin. The sharps bin should be<br />

labelled ―contains mixed pharmaceutical waste and sharps – for incineration‖.<br />

Ampoules containing the CD in a powder form can be opened, water added to dissolve<br />

the powder and the resultant mixture poured into the CD denaturing kit or the bin that<br />

is used for disposal of liquid medicines. The ampoule can then be disposed of in the<br />

sharps bin. The sharps bin should be labelled ―contains mixed pharmaceutical waste<br />

and sharps – for incineration‖. These are the ideal methods of denaturing ampoules.<br />

Suitable gloves should be worn by the person breaking open glass ampoules as a<br />

safety measure and to minimise the risk of injury from sharps.<br />

An alternative but less preferable, disposal method is where the ampoules are crushed<br />

with a pestle inside an empty plastic container. Once broken, a small quantity of hot<br />

soapy water (for powder ampoules) or cat litter (for liquid ampoules) is added. If these<br />

methods are used, care should be taken to ensure that the glass does not harm the<br />

person destroying the CD. The resulting liquid mixture should then be disposed of in a<br />

CD denaturing kit or in the bin that is used for disposal of liquid medicines.<br />

Fentanyl and buprenorphine patches<br />

The active ingredient in the patches can be rendered irretrievable by removing the<br />

backing and folding the patch over on itself and then placing it in a waste disposal bin<br />

or preferably a CD denaturing kit. Gloves must be worn by the person destroying the<br />

CD.<br />

Aerosol formulations<br />

Aerosol formulations should be expelled into water (to prevent droplets of drug<br />

entering the air). As a further precaution, it would be advisable for a facemask to be<br />

worn by staff undertaking the activity and to ensure that the area where the destruction<br />

takes place is well ventilated. The resulting solution can then be disposed of in<br />

accordance with the above guidance on destruction of liquid formulations.<br />

<strong>Controlled</strong> Drug Denaturing Kit<br />

Shake container to loosen granules.<br />

Fill container with one filling. (I.e. even if only one tablet/ampoule to destroy &<br />

complete the process below)<br />

Add the controlled drug as above to half the capacity of the jar.<br />

Fill to capacity with water.<br />

Replace lid securely.<br />

Shake thoroughly to disperse.<br />

Page 175 of 196


Contents congeal in 3 - 5 minute<br />

Dispose of the denaturing kit in the designated medicines waste bins<br />

immediately do not keep for further use.<br />

Dispose of denaturing container by secure incineration service.<br />

<strong>Controlled</strong> drug denaturing kits should not be used for the destruction of non CD<br />

medicines.<br />

Page 176 of 196


Appendix Q<br />

Standard Operating Procedure for witnessing the destruction of <strong>Controlled</strong><br />

<strong>Drugs</strong> by a delegated PCT Pharmacist.<br />

Version: 2<br />

Date produced: 16/9/07, Updated November 2009<br />

Revision Date: November 2012<br />

Produced By: Kate Huddart (Senior Pharmaceutical Adviser)<br />

Purpose: To ensure a standardised approach to controlled drug destruction by<br />

delegated PCT Pharmacists across <strong>County</strong> <strong>Durham</strong> and Darlington.<br />

1. Authorisation.<br />

1.1 PCT staff that destroys controlled drugs must have delegated authority from the<br />

Accountable Officer in writing. Currently delegated authority rests with the 7<br />

pharmacists employed within the Medical Directorate:-<br />

Kate Huddart<br />

Sharron Kebbell<br />

Linda Neely<br />

Joan Sutherland<br />

Ian Morris<br />

Hazel Betteney<br />

Stephen Purdy<br />

1.2 The above named delegated PCT Pharmacists are directly accountable to the<br />

Accountable Officer for controlled drugs destruction.<br />

2. Destruction of <strong>Controlled</strong> <strong>Drugs</strong> in a G.P Practice / Dispensing Doctors<br />

2.1 Delegated PCT Pharmacist should take their own CD Destruction Log and a<br />

CD Denaturing kit with them to the practice.<br />

2.2 Delegated PCT Pharmacist inspects CD cupboard to ensure that it is of the<br />

correct standard and mounted in a secure way.<br />

Page 177 of 196


2.3 Delegated PCT Pharmacist, along with Practice Witness (G.P, Practice<br />

Manager or Practice Nurse) ensures keys are stored in a secure way.<br />

2.4 Delegated PCT Pharmacist makes an entry in the practice CD register giving<br />

the following details of the <strong>Controlled</strong> Drug destruction:-<br />

Date<br />

Drug, Formulation and Strength<br />

Batch Number and date of expiry<br />

Quantity to be destroyed<br />

Signature of the delegated PCT Pharmacist<br />

RPSGB number of the delegated Pharmacist<br />

e.g. 18/9/07 Morphine Sulphate 10mg (Sevredol) 24 tablets BN 213AB Expired<br />

20/06/07. Destroyed by PCT Pharmacist K E Huddart MRPharm Reg No 91749<br />

2.5 Practice Witness also signs the entry in the CD register.<br />

2.6 Prior to destruction check that any remaining in date stock balances with the<br />

running balance of stock.<br />

2.7 Amend running balance of stock<br />

2.8 Delegated PCT Pharmacist then makes an entry in their own CD Destruction<br />

Log Book giving the following details of the <strong>Controlled</strong> Drug destruction:-<br />

Date<br />

Drug, Formulation and Strength<br />

Quantity destroyed<br />

Signature of Pharmacist<br />

Printed name of Pharmacist<br />

2.9 Practice Witness also signs and prints their name against the entry in the<br />

delegated PCT Pharmacist‘s CD Destruction Log Book.<br />

2.10 The delegated PCT Pharmacist then carries out the destruction of the CD in the<br />

presence of the Practice Witness.<br />

2.11 The controlled drug must be destroyed as outlined in the RPSGB guidance for<br />

pharmacists on the Safe Destruction of <strong>Controlled</strong> <strong>Drugs</strong> in England, Scotland and<br />

Wales.<br />

2.12 The process from 2.4 to 2.11 is repeated for each different strength and<br />

presentation of controlled drug that is out of date.<br />

2.13 The used CD Denaturing kit is then placed in the yellow medicines waste bin.<br />

2.14 The delegated PCT Pharmacist conducts a spot check on 2 other CD‘s running<br />

balances of stock. The delegated pharmacist makes an entry within the practice CD<br />

register on the relevant page of the stock check, noting any discrepancies or<br />

amendments to the running total<br />

E.g. 18/09/07 Stock check of Morphine Sulphate 10mg (Sevredol) tablets by PCT<br />

Pharmacist. K E Huddart MRPharm Reg. No. 91749. Stock check correct.<br />

Page 178 of 196


2.15 The delegated PCT Pharmacist conducts a CD Practice Audit (Appendix I within<br />

CD <strong>Policy</strong>) or a G.P. Dispensing Practice Audit (Appendix K within CD <strong>Policy</strong>), if the<br />

practice has not had a previous audit conducted during that financial year.<br />

2.16 If a previous CD Practice Audit has been completed then the delegated PCT<br />

Pharmacist must complete a CD Destruction Form (Appendix R within CD <strong>Policy</strong>)<br />

and forward this form to the Prescribing Support Technician as a record of the visit.<br />

2.17 Any discrepancies or any other concerns must be notified to the Head of<br />

Medicines Management and the PCT‘s Accountable Officer immediately.<br />

3 Destruction of <strong>Controlled</strong> <strong>Drugs</strong> in GP individual stocks<br />

3.1 Delegated PCT Pharmacist should take their own CD Destruction Log and a<br />

CD Denaturing kit with them to the practice.<br />

3.2 Delegated PCT Pharmacist inspects CDs are stored in a secure way by the<br />

G.P.<br />

3.3 Delegated PCT Pharmacist makes an entry in the G.P. CD register giving the<br />

following details of the <strong>Controlled</strong> Drug destruction:-<br />

Date<br />

Drug, Formulation and Strength<br />

Batch Number and date of expiry<br />

Quantity to be destroyed<br />

Signature of the delegated PCT Pharmacist<br />

RPSGB number of the delegated Pharmacist<br />

3.4 GP must also sign the entry in his/her CD register.<br />

3.5 Prior to destruction check that any remaining in date stock balances with the<br />

running balance of stock.<br />

3.6 Amend running balance of stock<br />

3.7 Delegated PCT Pharmacist then makes an entry in their own CD Destruction<br />

Log Book giving the following details of the <strong>Controlled</strong> Drug destruction:-<br />

Date<br />

Drug, Formulation and Strength<br />

Quantity destroyed<br />

Signature of Pharmacist<br />

Printed name of Pharmacist<br />

3.8 GP must sign and print their name against the entry in the delegated PCT<br />

Pharmacist‘s CD Destruction Log Book.<br />

3.9 The delegated PCT Pharmacist then carries out the destruction of the CD in the<br />

presence of the GP.<br />

Page 179 of 196


3.10 The controlled drug must be destroyed as outlined in the RPSGB guidance for<br />

pharmacists on the Safe Destruction of <strong>Controlled</strong> <strong>Drugs</strong> in England, Scotland and<br />

Wales.<br />

3.11 The process from 3.3 to 3.10 is repeated for each different strength and<br />

presentation of controlled drug that is out of date.<br />

3.12 The used CD Denaturing kit is then placed in the yellow Medicines Waste bin.<br />

3.13 The delegated PCT Pharmacist conducts a spot check on 2 other CD‘s running<br />

balances of stock. The delegated pharmacist makes an entry within the practice CD<br />

register on the relevant page of the stock check, noting any discrepancies or<br />

amendments to the running total<br />

E.g. 18/09/07 Stock check of Morphine Sulphate 10mg (Sevredol) tablets by PCT<br />

Pharmacist. K E Huddart MRPharm Reg. No. 91749. Stock check correct.<br />

3.14 The delegated PCT Pharmacist conducts a GP CD audit if the GP has not had<br />

a previous CD audit in that financial year.<br />

3.15 If a previous GP CD Audit has been completed then the delegated PCT<br />

Pharmacist must complete a CD Destruction Form (Appendix R within CD <strong>Policy</strong>) and<br />

forward this form to the Prescribing Support Technician as a record of the visit.<br />

3.16 Any discrepancies or any other concerns must be notified to the Head of<br />

Medicines Management and the PCT‘s Accountable Officer immediately.<br />

4 Destruction of <strong>Controlled</strong> <strong>Drugs</strong> in a Community Pharmacy<br />

4.1 Delegated PCT Pharmacist should take their own CD Destruction Log and a CD<br />

Denaturing kit with them to the practice.<br />

4.2 Delegated PCT Pharmacist inspects CD cupboard to ensure that it is of the<br />

correct standard and mounted in a secure way<br />

4.3 Delegated PCT Pharmacist, along with community pharmacist ensures keys are<br />

stored in a secure way.<br />

4.4 Delegated PCT Pharmacist to ensure that any patient returned controlled drugs<br />

are separated and inform the community pharmacist that they need to be destroyed by<br />

the community pharmacist as soon as possible in line with RPSGB guidance for<br />

pharmacists on the safe destruction of <strong>Controlled</strong> drugs in England, Scotland and<br />

Wales.<br />

4.5 Delegated PCT Pharmacist to ensure that all out of date stock is clearly marked<br />

‗out of date‘ on packaging and has been segregated from other stock. The RPSGB<br />

inspector currently recommends out of date stock is placed in a clear bag,<br />

appropriately labelled, stating ‗out of date stock‘ and also the quantity enclosed within.<br />

4.6 Delegated PCT Pharmacist makes an entry in the community pharmacy CD<br />

register giving the following details of the <strong>Controlled</strong> Drug destruction:-<br />

Date<br />

Page 180 of 196


Drug, Formulation and Strength<br />

Batch Number and date of expiry<br />

Quantity to be destroyed<br />

Signature of the delegated PCT Pharmacist<br />

RPSGB number of the delegated Pharmacist<br />

E.g. 18/9/07 Morphine Sulphate 10mg (Sevredol) 24 tablets BN213AB Expired<br />

20/06/07. Destroyed by PCT Pharmacist K E Huddart MRPharm Reg No 91749<br />

4.7 The community pharmacist must also sign and add their RPSGB number to the<br />

entry in the CD register.<br />

4.8 Prior to destruction the delegated PCT pharmacist must check that any<br />

remaining in date stock balances with running balance of stock. Please Note that out of<br />

date CDs should be included in the running balance until they are destroyed.<br />

4.9 Delegated PCT Pharmacist then makes an entry in their own CD<br />

Destruction Log Book giving the following details of the <strong>Controlled</strong> Drug destruction:-<br />

Date<br />

Drug, Formulation and Strength<br />

Quantity destroyed<br />

Signature of Pharmacist<br />

Printed name of Pharmacist<br />

4.10 Community Pharmacist also signs and prints their name against the entry in the<br />

delegated PCT Pharmacist‘s CD Destruction Log Book.<br />

4.11 The delegated PCT Pharmacist then carries out the destruction of the CD in the<br />

presence of the community pharmacist.<br />

4.12 The controlled drug must be destroyed as outlined in the RPSGB guidance for<br />

pharmacists on the Safe Destruction of <strong>Controlled</strong> <strong>Drugs</strong> in England, Scotland and<br />

Wales.<br />

4.13 The process from 4.6 to 4.12 is repeated for each different strength and<br />

presentation of controlled drug that is out of date.<br />

4.14 The used CD Denaturing kit should then be placed in the yellow Medicines<br />

Waste bin within the department.<br />

4.15 The delegated PCT Pharmacist conducts a spot check on 2 other CD‘s running<br />

balances of stock. The delegated pharmacist makes an entry within the practice CD<br />

register on the relevant page of the stock check, noting any discrepancies or<br />

amendments to the running total<br />

E.g. 18/09/07 Stock check of Morphine Sulphate 10mg (Sevredol) tablets by PCT<br />

Pharmacist. K E Huddart MRPharm Reg. No. 91749. Stock check correct.<br />

4.16 The delegated PCT Pharmacist completes a CD destruction form for community<br />

pharmacy (Appendix R within CD <strong>Policy</strong>) and forwards this to the Prescribing Support<br />

Technician as a record of the visit.<br />

4.17 Any discrepancies or any other concerns must be notified to the Head of<br />

Medicines Management and the PCT‘s Accountable Officer immediately.<br />

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4.18 The Head of Medicines Management will discuss any discrepancy or other<br />

concern with the relevant parties e.g. RPSGB Inspector.<br />

5 Destruction of <strong>Controlled</strong> <strong>Drugs</strong> in the OOH‟s Centres<br />

5.1 All stock within UCC/OOH CD cupboard expiring within the week is highlighted<br />

to the UCC/OOH manager when a spot check is carried out.<br />

5.2 If the stock has not been used within that month, the UCC/OOH manager then<br />

contacts the delegated PCT Pharmacist and organises a date for destruction.<br />

5.3 Delegated PCT Pharmacist should take their own CD Destruction Log and a CD<br />

Denaturing kit with them to the practice.<br />

5.4 Delegated PCT Pharmacist inspects CD cupboard to ensure that it is of the<br />

correct standard and mounted in a secure way.<br />

5.5 Delegated PCT Pharmacist, along with ECP/<strong>Clinical</strong> Lead ensures keys are<br />

stored in a secure way.<br />

5.6 Delegated PCT Pharmacist makes an entry in the UCC/OOH Centre CD<br />

register giving the following details of the <strong>Controlled</strong> Drug destruction:-<br />

Date<br />

Drug, Formulation and Strength<br />

Batch Number and date of expiry<br />

Quantity to be destroyed<br />

Signature of the delegated PCT Pharmacist<br />

RPSGB number of the delegated Pharmacist<br />

E.g. 18/9/07 Morphine Sulphate 10mg (Sevredol) 24 tablets BN 213AB Expired<br />

20/06/07. Destroyed by PCT Pharmacist K E Huddart MRPharm Reg No 91749<br />

5.7 Emergency Care Practitioner/ <strong>Clinical</strong> Lead must also sign the entry in the CD<br />

register.<br />

5.8 Prior to destruction check that any remaining in date stock balances with the<br />

running balance of stock.<br />

5.9 Amend running balance of stock.<br />

5.10 Delegated PCT Pharmacist then makes an entry in their own CD Destruction<br />

Log Book giving the following details of the <strong>Controlled</strong> Drug destruction:-<br />

Date<br />

Drug, Formulation and Strength<br />

Quantity destroyed<br />

Signature of Pharmacist<br />

Printed name of Pharmacist<br />

5.11 ECP/<strong>Clinical</strong> Lead also signs and prints their name against the entry in the<br />

delegated PCT Pharmacist‘s CD Destruction Log Book.<br />

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5.12 The UCC/OOH Centre stock control book should be amended accordingly by<br />

the ECP /<strong>Clinical</strong> Lead witnessing the destruction and initialled by the delegated PCT<br />

Pharmacist.<br />

5.13 The delegated PCT Pharmacist then carries out the destruction of the CD in the<br />

presence of the ECP or <strong>Clinical</strong> Lead.<br />

5.14 The controlled drug must be destroyed as outlined in the RPSGB guidance for<br />

pharmacists on the Safe Destruction of <strong>Controlled</strong> <strong>Drugs</strong> in England, Scotland and<br />

Wales.<br />

5.15 The process from 5.6 to 5.14 is repeated for each different strength and<br />

presentation of controlled drug that is out of date.<br />

5.16 The used CD Denaturing kit is then placed in the yellow medicines waste bin at<br />

the UCC. Please Note: If the UCC/OOH centre does not have a medicines waste bin<br />

for out of date medicines then take the used CD Denaturing kit to the nearest available<br />

GP practice or community pharmacy and place in their yellow medicines waste bin.<br />

5.17 The delegated PCT Pharmacist conducts a spot check on 2 other CD‘s running<br />

balances of stock. The delegated pharmacist makes an entry within the practice CD<br />

register on the relevant page of the stock check, noting any discrepancies or<br />

amendments to the running total<br />

E.g. 18/09/07 Stock check of Morphine Sulphate 10mg (Sevredol) tablets by PCT<br />

Pharmacist. K E Huddart MRPharm Reg. No. 91749. Stock check correct.<br />

5.18 The delegated PCT Pharmacist should conduct an UCC/OOH centre CD audit<br />

(Appendix K within CD <strong>Policy</strong>) if the UCC/OOH centre has not had a previous audit<br />

conducted in that financial year.<br />

5.19 If a previous CD UCC/OOH centre audit has been completed then the<br />

delegated PCT Pharmacist must complete a CD destruction form (Appendix R within<br />

CD <strong>Policy</strong>) and forward it to the Prescribing Support Technician as a record of the visit.<br />

5.20 Any discrepancies or any other concerns must be notified to the Head of<br />

Medicines Management and the PCT‘s Accountable Officer immediately.<br />

5.21<br />

6 Destruction of <strong>Controlled</strong> <strong>Drugs</strong> in Prisons.<br />

6.1 Delegated PCT Pharmacist should take their own CD Destruction Log and a CD<br />

Denaturing kit with them to the prison.<br />

6.2 Delegated PCT Pharmacist inspects CD cupboard to ensure that it is of the<br />

correct standard and mounted in a secure way.<br />

6.3 Delegated PCT Pharmacist, along with Prison Pharmacist ensures keys are<br />

stored in a secure way.<br />

6.4 Delegated PCT Pharmacist to ensure that any patient returned controlled drugs<br />

are separated and inform the prison pharmacist that they need to be destroyed by the<br />

community pharmacist as soon as possible in line with RPSGB guidance for<br />

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pharmacists on the safe destruction of <strong>Controlled</strong> drugs in England, Scotland and<br />

Wales.<br />

6.5 Delegated PCT Pharmacist to ensure that all out of date stock is clearly marked<br />

‗out of date‘ on packaging and has been segregated from other stock. The RPSGB<br />

inspector currently recommends out of date stock is placed in a clear bag,<br />

appropriately labelled, stating ‗out of date stock‘ and also the quantity enclosed within.<br />

6.6 Delegated PCT Pharmacist makes an entry in the prison pharmacy CD register<br />

giving the following details of the <strong>Controlled</strong> Drug destruction:-<br />

Date<br />

Drug, Formulation and Strength<br />

Batch Number and date of expiry<br />

Quantity to be destroyed<br />

Signature of the delegated PCT Pharmacist<br />

RPSGB number of the delegated Pharmacist<br />

E.g. 18/9/07 Morphine Sulphate 10mg (Sevredol) 24 tablets BN 213AB Expired<br />

20/06/07. Destroyed by PCT Pharmacist K E Huddart MRPharm Reg No 91749<br />

6.7 The prison pharmacist must also sign and add their RPSGB number to the entry<br />

in the CD register.<br />

6.8 Prior to destruction the delegated PCT pharmacist must check that any<br />

remaining in date stock balances with running balance of stock. Please Note that out of<br />

date CDs should be included in the running balance until they are destroyed.<br />

6.9 Delegated PCT Pharmacist then makes an entry in their own CD Destruction Log<br />

Book giving the following details of the <strong>Controlled</strong> Drug destruction:-<br />

Date<br />

Drug, Formulation and Strength<br />

Quantity destroyed<br />

Signature of Pharmacist<br />

Printed name of Pharmacist<br />

6.10 Prison Pharmacist also signs and prints their name against the entry in the<br />

delegated PCT Pharmacist‘s CD Destruction Log Book.<br />

6.11 The delegated PCT Pharmacist then carries out the destruction of the CD in the<br />

presence of the Prison Pharmacist.<br />

6.12 The controlled drug must be destroyed as outlined in the RPSGB guidance for<br />

pharmacists on the Safe Destruction of <strong>Controlled</strong> <strong>Drugs</strong> in England, Scotland and<br />

Wales.<br />

6.13 The process from 6.6 to 6.12 is repeated for each different strength and<br />

presentation of controlled drug that is out of date.<br />

6.14 The used CD Denaturing kit should then be placed in the yellow medicines<br />

waste bin within the department.<br />

6.15 The delegated PCT Pharmacist conducts a spot check on 2 other CD‘s running<br />

balances of stock. The delegated pharmacist makes an entry within the prison<br />

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pharmacy CD register on the relevant page of the stock check, noting any<br />

discrepancies or amendments to the running total<br />

E.g. 18/09/07 Stock check of Morphine Sulphate 10mg (Sevredol) tablets by PCT<br />

Pharmacist. K E Huddart MRPharm Reg. No. 91749. Stock check correct.<br />

6.16 The delegated PCT Pharmacist should conduct a CD Prison Audit (Appendix M<br />

within CD policy), if the prison has not had a previous audit conducted in that financial<br />

year.<br />

6.17 If a previous CD Prison Pharmacy Audit has been completed then the delegated<br />

PCT Pharmacist must complete a CD Destruction Form (Appendix R within CD <strong>Policy</strong>)<br />

and forward this form to the Prescribing Support Technician as a record of the visit.<br />

6.18 Any discrepancies or any other concerns must be notified to the Head of<br />

Medicines Management and the PCT‘s Accountable Officer immediately.<br />

6.19 The Head of Medicines Management will discuss any discrepancy or other<br />

concern with the relevant parties e.g. RPSGB Inspector.<br />

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Appendix R <strong>Controlled</strong> Drug Destruction Record<br />

Location (please circle) Name and Address of location<br />

General Practice<br />

Community Pharmacy<br />

Community Hospital<br />

Other – please give detail<br />

Details of <strong>Controlled</strong> drugs destroyed<br />

Drug name /strength / formulation Quantity Reason for destruction<br />

Comments/advice given<br />

Authorised witness<br />

(name and designation)<br />

Second witness<br />

(name and designation)<br />

Date<br />

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Appendix S – SUMMARY OF CONTROLLED DRUGS GUIDANCE FOR GPs<br />

1.0 INTRODUCTION<br />

1.1 Medicines Legislation governs the purchase, prescribing, storage, record<br />

keeping, monitoring and destruction of <strong>Controlled</strong> <strong>Drugs</strong>.<br />

1.2 The PCT Accountable Officer and the Police have the right of entry into<br />

premises for the purpose of <strong>Controlled</strong> <strong>Drugs</strong> Monitoring and Inspection. This<br />

authority can be delegated to suitably trained personnel such as the PCT<br />

Commissioning Pharmaceutical Advisers.<br />

1.3 Refer to the PCT <strong>Controlled</strong> Drug <strong>Policy</strong> for more detailed guidance and be<br />

aware that legislation around CDs is subject to change.<br />

2.0 GOVERNANCE, INSPECTION AND MONITORING<br />

2.1 All practices and GPs are required to complete an annual declaration stating<br />

whether or not they keep a stock of CDs.<br />

2.2 Practices and GPs holding stock will be required to complete a self assessment<br />

of their management of CDs<br />

2.3 PCT will arrange for a small number of routine inspections from a random<br />

sample of GPs, annually.<br />

2.4 <strong>Controlled</strong> drug prescribing and purchases are monitored by the PCT via ePACT<br />

and GPs may periodically be requested to review their prescribing.<br />

3.0 STANDARD OPERATING PROCEDURES (SOPs) Appendix T of CD <strong>Policy</strong><br />

3.1 These should ensure there is a full audit trail for movement of CDs from<br />

acquisition to administration and disposal and record keeping.<br />

3.2 SOPs should also include how to deal with discrepancies in CD stock and<br />

register; how and to whom staff can raise any concerns relating to CDs.<br />

4.0 PURCHASING CONTROLLED DRUGS<br />

4.1 A requisition form FP10CDF should be completed to purchase Schedule 2 & 3<br />

CDs<br />

4.2 FP10CDF forms are available from the service that provides prescription forms.<br />

4.3 FP10CDF forms are controlled stationary and should be stored securely with<br />

restricted access.<br />

4.4 GPs must not use FP10 prescriptions to top up their personal or practice stock<br />

CDs.<br />

4.5 A system should be put in place for completing the FP10CDF forms as these are<br />

monitored to individual GPs via ePACT.<br />

4.6 The pharmacy will record the name of the person collecting the CDs in their<br />

registers.<br />

4.7 If a member of staff is sent to collect the CD they must carry a bearer‘s note,<br />

signed and dated by the prescriber, stating they are authorised to carry the CD;<br />

the pharmacy may retain the note.<br />

5.0 STORAGE IN THE PRACTICE<br />

5.1 CDs requiring safe custody must be stored in a designated locked CD cabinet or<br />

safe.<br />

5.2 The cabinet should be metal and fixed to the wall or floor with rag bolts and<br />

within a lockable room with restricted access.<br />

5.3 Ideally no other items should be stored in the CD cupboard/ safe; if this isn‘t<br />

possible the CDs should be segregated from other items stored in the<br />

cabinet/safe.<br />

5.4 A designated person should be responsible for the safe custody of the keys and<br />

records of who has access to keys or security code numbers. It is recommended<br />

Page 187 of 196


that key codes are changed regularly to maintain security.<br />

5.5 A designated person should be responsible for accepting stock into the practice,<br />

transfer of stock to individual GPs and maintaining the stock CD register.<br />

6.0 STORAGE IN GP HOME VISIT BAGS<br />

6.1 Bags should be lockable and kept locked at all times except when in use.<br />

6.2 <strong>Controlled</strong> drugs should not be left unattended in a car for prolonged periods of<br />

time.<br />

6.3 When on annual leave the Dr should consider handing over their controlled<br />

drugs to the practice for safekeeping.<br />

6.4 <strong>Controlled</strong> drug stock should be kept to a minimum and only one strength kept to<br />

reduce the likelihood of an error.<br />

6.5 Each ‗bag‘ must have its own designated CD register, which should ideally be<br />

kept separate from the bag, in case the bag is lost or stolen.<br />

6.6 Each GP is personally responsible for making entries into their bag register.<br />

6.7 Supplies into a doctor‘s bag should be witnessed; this is considered essential if<br />

top up is made from the practice central store.<br />

6.8 SHARED BAGS: A full audit of the date and time of bags being handed to and<br />

from each person should be made in a hard bound book. The stock balance and<br />

CD register should be checked at each handover. The bag should be locked in a<br />

cupboard with restricted access when not in use. A record should be made of<br />

who has access to the bag and who is responsible for handing over and<br />

receiving the bag.<br />

7.0 STOCK CHECKS<br />

Designated person(s) should be responsible for checking the CD stock and<br />

expiry dates on at least a monthly basis and a record made that this has been<br />

done.<br />

8.0 CONTROLLED DRUG REGISTERS<br />

8.1 The registers must be bound or computerised.<br />

8.2 Entries in hard copy must be made in ink and in chronological order;<br />

computerised records must be fully attributable and auditable.<br />

8.3 A separate page is required for each controlled drug and presentation and<br />

strength.<br />

8.4 A running balance should be maintained.<br />

8.5 All receipts and issues should be made within 24 hours of transaction<br />

8.6 There should be no gaps between each line in the register<br />

8.7 If an error is made then do not obliterate. Bracket entry in a manner that details<br />

can still be seen, mark ‗error‘ and next to or in margin write the correct details<br />

8.8 <strong>Drugs</strong> received; All register entries must show: -<br />

Date received<br />

Name and address of person or firm from whom they are received<br />

Name and signature of person making the CD entry.<br />

The amount received<br />

Form and strength in which supplied<br />

Running balance<br />

8.9 <strong>Drugs</strong> administered/ supplied<br />

Date and time administration/ supply made<br />

Name and address of person for whom it was administered/supplied.<br />

Name and authority of person who supplied/administered the item.<br />

Amount administered/supplied<br />

Running balance.<br />

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Reimbursement should be made via a personally administered claim via FP10<br />

for the practice.<br />

9.0 OUT OF DATE STOCK or STOCK NO LONGER REQUIRED<br />

9.1 The PCT Commissioning Medicines Management Team should be contacted to<br />

make arrangements for disposal of stock CDs as this can only be performed by<br />

an authorised person.<br />

9.2 If the practice hold a central stock out of date CDs can be returned to the central<br />

store; a record of this should be made in the CD registers.<br />

9.3 If the practice does not hold central stock the destruction should take place<br />

directly from the doctor‘s bag.<br />

9.4 Out of date stock should be clearly marked and segregated from in date stock.<br />

10.0 PATIENTS OWN CONTROLLED DRUGS<br />

10.1 Medicines dispensed for one patient must not be used to treat another patient.<br />

10.2 Patients should be encouraged to return their unwanted CDs to a pharmacy for<br />

destruction.<br />

10.3 Nursing and practice staff should not accept patients controlled drugs for<br />

destruction except in exceptional circumstances.<br />

10.4 If handed to a GP they cannot in theory be passed on to a pharmacy for<br />

destruction.<br />

10.5 The CDs should be recorded in a book specifically kept for this purpose.<br />

10.6 Strict environment legislation covers the handling of all waste in the UK;<br />

medicines should never be disposed of in household waste, sinks or flushing<br />

down toilets.<br />

10.7 CDs should be denatured before destruction. ‗DOOP‘ kits specifically designed<br />

for this purpose are available from the waste company or the PCT; the DOOP kit<br />

should be disposed of in the pharmaceutical waste bins.<br />

10.7 Destruction should be witnessed.<br />

10.8 ONLY in exceptional circumstances, district/community nursing staff can<br />

destroy, with consent, patients controlled drugs and a record must be made and<br />

witnessed if possible.<br />

10.9 If a GP administers a patients own CDs during a home visit a record of this must<br />

be made on the patient held nursing records or administration chart if available<br />

and the practice computerised medical records. This should include drug, dose,<br />

form, date and time of administration and if applicable running balance.<br />

11.0 PRESCRIPTIONS<br />

11.1 It is a criminal offence for a pharmacist to dispense a controlled drug against a<br />

prescription which does not fully comply with legislation.<br />

11.2 Prescriptions for CDs should be limited to 30 days supply.<br />

11.3 Instalment prescriptions for drug addiction must be limited to a maximum of 14<br />

days supply.<br />

11.3 If more than 30 days supply is considered clinically appropriate a note should be<br />

made in the patient‘s records stating the reason why.<br />

11.4 Prescriptions for CDs are valid for 28 days; a later start date can be added; for<br />

instalment prescriptions, the first instalment must be made within 28 days of the<br />

start date.<br />

11.5 A Home Office licence is required to prescribe diamorphine, dipipanone and<br />

cocaine to substance misusers; GPs can prescribe these drugs for the relief of<br />

pain due to organic disease or injury without a licence.<br />

11.6 Other than in emergencies practitioners should not prescribe for themselves or<br />

anyone they have a close personal relationship with including friends, family and<br />

colleagues.<br />

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12.0 PRIVATE PRESCRIPTIONS<br />

12.1 A unique private prescriber code is required for a practitioner wishing to issue<br />

private prescriptions.<br />

12.2 Requests for a private prescriber code should be made to the PCT.<br />

12.3 Private prescriptions must be written on designated private prescription forms<br />

FP10 (PDC) NC.<br />

12.4 FP10(PDC) NC private prescriptions are available from the PCT.<br />

13.0 PATIENTS TRAVELLING OVERSEAS<br />

13.1 Persons travelling for over three months either abroad or to the UK will need a<br />

personal export/import licence.<br />

13.2 If travelling for 3 months or less a Home Office licence is not required.<br />

13.3 A personal licence has no authority outside the UK; it allows unhindered<br />

passage through UK customs.<br />

13.4 Personal licence application forms can be downloaded from the Home Office<br />

web site.<br />

13.5 Applications should be made at least 10 days prior to travel.<br />

13.6 Licences are normally issued with an expiry date of one week after the expected<br />

return to the UK.<br />

13.7 It is good practice for CDs to be carried in their original container in hand<br />

luggage with a letter from the prescribing doctor confirming the carriers name,<br />

destination, drug details and amount.<br />

13.8 If a person is staying outside their resident country for a period exceeding 3<br />

months they should be advised to register with a doctor in the country they are<br />

visiting for the purpose of receiving further prescriptions.<br />

13.9 Other countries have their own import regulations for controlled drugs; travellers<br />

should check this with UK based representative of country they are travelling to.<br />

Issued by PCT Commissioning Medicines Management Team September 2008. Valid until 2010 or<br />

sooner if newlegislation. To be read in conjunction with full PCT <strong>Controlled</strong> Drug <strong>Policy</strong>.<br />

Page 190 of 196


APPENDIX T – GUIDANCE ON STANDARD OPERATING POLICY<br />

This is intended as a guide for areas to consider when completing an SOP. Not all<br />

areas but most will apply to each setting and more details may need to be added; refer<br />

to full policy.<br />

Designated person with overall<br />

responsibility for controlled drugs<br />

List of personnel allowed to prescribe<br />

controlled drugs<br />

List of personnel allowed to<br />

supply/administer controlled drugs via<br />

PGD<br />

List of personnel allowed access to<br />

controlled drug cabinet/safe/Drs bag<br />

Prescriptions for controlled drugs<br />

generated by (hand/computer/both)<br />

A maximum of 30 days supply will be<br />

prescribed.<br />

Who is allowed to generate<br />

prescriptions for CDs via computer<br />

Prescription for controlled drugs<br />

awaiting doctor‘s signature are placed<br />

separately – where.<br />

Details of where records are made for<br />

CD prescriptions awaiting collection<br />

Where are CD prescriptions awaiting<br />

collection stored?<br />

Details of where records are made of<br />

person collecting the CD prescription<br />

Procedure for missing CD<br />

prescriptions<br />

Name and Address of where CDs are<br />

ordered from<br />

Persons authorised to order<br />

controlled drugs<br />

Requisition forms used<br />

Requisition forms are stored securely,<br />

where<br />

How is the requisition form sent to the<br />

supplier<br />

How are the CDs transferred from<br />

supplier to the premises and by whom<br />

The level of stock required is<br />

If more than 30 days supply of a CD<br />

is required on a prescription the<br />

prescribing doctor will make a note in<br />

the patient‘s clinical records.<br />

Page 191 of 196


eviewed annually by<br />

Who is authorised to receive<br />

controlled drugs onto the premises<br />

Where are the CDs placed when they<br />

arrive at premises<br />

The CDs received into the premises<br />

are recorded in the controlled drug<br />

register immediately on receipt by?<br />

A running balance is maintained and<br />

the stock checked on receipt.<br />

The record of order and invoices<br />

stored for 7 years, where?<br />

Supply<br />

Statement if CDs are supplied or not<br />

Who is allowed to supply CDs<br />

Including supply from central store to<br />

doctors bags<br />

What is the procedure for supplying<br />

CDs<br />

Administration<br />

Are patients own CDs administered<br />

Are stock CDs administered to<br />

patients<br />

Records of administration include<br />

patients name, address, Drug, dose,<br />

route and time of administration.<br />

This record is made where<br />

CD register<br />

Patients clinical records<br />

If patient has medicines chart/nursing<br />

record or similar a record is also<br />

made there.<br />

The administration of CDs is<br />

witnessed by.<br />

If administration is not witnessed<br />

state circumstances where this is<br />

allowed.<br />

Storage<br />

Where are controlled drugs stored<br />

List all places including each<br />

individual doctors bag<br />

Is a Home Office Licence required<br />

Are there keys? What is procedure for<br />

access and storing keys?<br />

Who is allowed access to keys/ codes<br />

and how is this regulated?<br />

Doctors/Home visit bag (lockable<br />

how?)<br />

Points to consider<br />

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Where is the bag stored<br />

Whilst in practice<br />

When on a home visit<br />

When car unattended<br />

Overnight<br />

When on holiday<br />

Transport<br />

Who is allowed to transport CDs<br />

Under what circumstances<br />

What records are made<br />

Stock Checks<br />

List of CDs allowed to be stocked in<br />

each area<br />

The stock balance is checked by<br />

This check is performed (state<br />

intervals)<br />

A record of the check is made (in the<br />

CD register/on computer)<br />

Destruction - Stock<br />

Out of date/obsolete and CDs no<br />

longer required are segregated by<br />

placing in a bag (preferably clear<br />

plastic) clearly labelled out of date<br />

stock not for use.<br />

Where CDs awaiting destruction are<br />

stored)<br />

Out of date CDs should remain in<br />

running balance in register until time<br />

of destruction.<br />

Contact authorised person list names<br />

and contact email/phone number.<br />

Who is responsible for overseeing<br />

this<br />

Destruction Patients Own<br />

Patients own medicines are not<br />

reused for the treatment of any other<br />

patient<br />

Do you advise Patients to return CDs<br />

to community pharmacy for<br />

destruction<br />

Under what circumstances do you<br />

receive or are responsible for<br />

destruction of patients own CDs<br />

CD denaturing kits must be used<br />

Enter details of how this is done<br />

Where to obtain kits and where to<br />

dispose of<br />

Records must be kept, how is this<br />

done and where<br />

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Patients Own CDs - residential<br />

Is the patient self medicating<br />

Is there a policy/procedure for<br />

patients who self medicate?<br />

All above may apply & help complete<br />

SOP<br />

Record Keeping, including CD<br />

registers<br />

Where will records be stored<br />

Should be kept for minimum of 7<br />

years or longer if other <strong>NHS</strong> record<br />

keeping policies apply<br />

Dealing with discrepancies and<br />

concerns<br />

How are discrepancies in the running<br />

balance dealt with<br />

If stock/patients own CDs are missing<br />

who should this be reported to<br />

Give details of incident reporting<br />

system<br />

Give details of who else staff may<br />

contact if they have concerns<br />

How will staff reporting concerns be<br />

protected<br />

How would you deal with member of<br />

staff about whom concerns have<br />

been raised? May refer to other<br />

policies about fitness to practice,<br />

regulatory authority and codes of<br />

conduct etc<br />

National Patient Safety Alerts<br />

Different strengths of injectable<br />

opiates should be stored separately.<br />

High dose injectable opiates i.e.<br />

diamorphine 30mg and over should<br />

be clearly marked and stored<br />

separately from lower strengths. How<br />

is this achieved in organisation?<br />

Naloxone should be kept in each<br />

clinical area including Drs bags where<br />

injectable opiates are stored/<br />

administered.<br />

How is this done in the organisation?<br />

There should be clear SOPs for<br />

administration of injections including<br />

how to prepare an injection i.e.<br />

reconstitute<br />

Page 194 of 196


Staff should be made aware of any SOPs applicable in the organisation and a record<br />

made that they have read and understood them including the consequences of not<br />

complying with the SOP.<br />

SOPs should be reviewed on a regular basis to ensure they are practical and reflect<br />

current practice and legislation. If training or competency is required in order to<br />

implement an SOP a record should be made of when, how, what and to whom this was<br />

completed.<br />

Page 195 of 196

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