Frequently Asked Questions About Pharmacy Practice

Please click the link below to bring you to the appropriate section:

  • General Pharmacy Practice Questions

  • Questions about Narcotics and Controlled Drugs

  • Questions about Prescribing by Pharmacists

  • Questions about Administering Drugs by Inhalation or Injection

  • General Pharmacy Practice Questions

    • Who may prescribe in Newfoundland and Labrador?

      The Pharmacy Act defines a prescription to be “an instruction, directing that a drug be dispensed to or for a person or animal, given orally, in writing or by an electronic means approved by the board by a person authorized to do so by an Act of the province or by a prescriber referred to in section 26;”

      At this time, in Newfoundland and Labrador, physicians, dentists, veterinarians, nurse practitioners optometrists and pharmacists all have varying authority to prescribe. To verify the current status of a prescriber in NL, you can check the relevant list linked on our Find a Health Professional page.

    • Can I legally fill a prescription written by a prescriber licensed in another province of Canada?

      Generally-speaking, the answer to this question is usually “yes”. In accordance with section 26. of the Pharmacy Act, prescriptions written by prescribers licensed and practicing in another province are eligible to be filled in this province.

      Having said that, there are a few conditions to consider. First, it depends on the type of prescriber and whether or not that person would have prescribing authority if they were licensed in Newfoundland and Labrador. At this time, in Newfoundland and Labrador, physicians, dentists, veterinarians, nurse practitioners and optometrists all have varying authority to prescribe. An out-of-province prescriber would have to belong to one of these groups for their prescription to be valid in this province. For example, a prescription from a dentist would be valid; a prescription from a chiropractor would not.

      Second to this would be what the prescription is for. If the prescription is for a narcotic or controlled drug covered by the Tamper Resistant Prescription Drug Pad Program, then the prescription MUST be written on the appropriate tamper resistant pad, regardless of whether or not the prescriber is licensed in NL. For more information on this program, visit the Department of Health and Community Services website.

      Pharmacists are also reminded that the onus is on them to verify the authenticity of any and all prescriptions and if he or she is ever in doubt as to the validity of the prescription or the licensing status of the prescriber, he or she should follow up with the prescriber directly and/or contact the relevant licensing authority.

    • Can a nurse practitioner prescribe narcotics and controlled drugs?

      Yes. In June of 2013, the ARNNL Council passed legislation permitting licensed nurse practitioners (NPs) who have completed the requirements approved by the ARNNL Council to prescribe Controlled Drugs and Substances in accordance with applicable legislation. This includes narcotics, controlled drugs, benzodiazepines and other targeted substances.

      While pharmacists are not required to invigilate NP prescribing practice, you can verify that a NP is licensed to practice in NL by using the ARNNL website Member Search function, available through our Find a Health Professional page.

      For further information/questions, please contact Michelle Osmond, Director of Regulatory Services at ARNNL at mosmond@arnnl.ca or (709) 753-6181.

    • Is an electronic signature on a prescription acceptable?

      No, not at the moment. The Board supports the concept of e-prescribing, but at this time, requirements for securing patient confidentiality, verifying authenticity, and preventing diversion have not been defined.

      A prescription generated via a prescriber’s computer system or PDA and physically given to a patient for eventual processing at a pharmacy must comply with the federal regulations regarding prescriptions and must include a valid signature. Rubber stamps, pre-signed forms, signature images or other forms of signatures that are not distinct for each transaction do not fulfill federal requirements. A pharmacist considering a prescription with one of these forms of signature cannot confirm that this is the one and only copy of the order (as identical copies of the order could have been produced by photocopy). To ensure that the prescription document presented by the patient is the original copy of the order written by the prescriber, the signature must be original.

      A prescription generated via a prescriber’s computer system or PDA and faxed directly to a pharmacy for processing must comply with the NLPB Standards of Practice – Facsimile Transmission of Prescriptions and Personal Health Information (available on the Standards, Guidelines and Policies page).
      As with above, electronic “digitalized” signatures are not permitted since they are not distinct for each transaction. When prescriptions are transmitted by fax directly between a prescriber and a pharmacy, the prescription must still be manually signed prior to transmitting the prescription.

      Prescription authorization via email has not yet been approved by Health Canada.

    • At times we are told as pharmacists to use “professional judgment”. At what point does “professional judgment” become failure to abide by regulations or standards and possibly “professional misconduct”?

      This is an excellent question, and unfortunately one for which there is no clear-cut answer. As pharmacists we make hundreds of professional judgment calls every week. These judgment calls are usually decided after consideration of a number of factors that include the actual wording of regulations or standards, the spirit of those regulations or standards, our past experiences, our knowledge of this specific patient and their health history, and ultimately “the best interests of the patient”. It is important to note, however, that “the best interests of the patient” is not necessarily synonymous with what is most convenient, or easiest, or most inexpensive for the patient, or that the patient’s wishes must be accommodated regardless of all other factors.

      When faced with these types of situations, the best advice we can give is to consider if your decision is one that another pharmacist would also reasonably make if they were presented with the same circumstances. Ultimately, you should always retain documentation of the situation describing what you did or didn’t do and why.

    • How should I handle new prescriptions or requests for refills when a prescriber passes away, retires or otherwise ceases practice?

      Historically, it was felt that since the prescriber-patient relationship no longer exists and the patient is no longer under the practitioner’s care, the prescription should be no longer considered valid. However, this is not always practical in today’s world, since it can often take an extended period of time for a patient to obtain the services of another primary health care provider. In many cases, a prescriber will intentionally write prescriptions for a period of time that extends beyond his or her retirement to specifically cover off such situations.

      Technically, as long as the prescriber was licensed at the time the prescription was written, it can be assumed that the prescription was written in good faith. As such, as long as the prescription is not more than a year old, it would still be considered a legal prescription. The real question in this instance is whether filling or re-filling the prescription is appropriate – which needs to be assessed on case-by-case basis.

      Therefore, the Board advises pharmacists who receive such requests that it is their professional responsibility to evaluate the appropriateness of the prescription in each individual situation, considering questions related to patient assessment and the patient’s best interests. Questions to consider include, but are not limited to:

      • How long ago was the prescription written? Was it intended to be a short-term therapy?
      • Is the medication for a condition that is considered to be chronic or long term? If so, does the patient have an established stable, compliant history with the medication?
      • Is the patient unable to visit a new primary health care provider in a timely manner?
      • Is the patient at an increased risk of harm by filling or re-filling the medication? (Or conversely, is the patient at an increased risk of harm if the medication is not provided in accordance with the original prescription?)
      • If the prescriber was still practicing, would I have consulted with the prescriber for any reason before filling or refilling the medication?
      • Is there another option? Would providing an interim supply or prescription extension, be appropriate, if indicated?

      Regardless of the pharmacist’s decision, the patient should be advised to find a new or interim prescriber as soon as possible.



    Questions About Narcotics and Controlled Drugs

    • Is there a way to easily differentiate the requirements for Narcotics and Controlled Drugs?

      Yes, we have published a convenient summary of Narcotic, Controlled Drug and Benzodiazepine Regulations applicable to Newfoundland and Labrador which can be found on our Legislation page or by clicking HERE.

    • Are all narcotics and controlled drugs affected by the Tamper Resistant Prescription Drug Pad Program?

      No, the list of drugs affected by the Tamper Resistant Prescription Drug Pad Program does include most narcotics and controlled drugs, but not necessarily all of them. The complete list may be found in the Tamper Resistant Prescription Drug Pad Program brochure on the Department of Health and Community Services website or by clicking HERE.

    • Can I accept a prescription for a drugs affected by the Tamper Resistant Prescription Drug Pad Program, if it is written by an out of province prescriber?

      Generally speaking, no, because the intent of the regulation is that all prescriptions dispensed in the province must originate from prescriptions that were written on the approved Tamper Resistant Prescription Drug Pad. Since out-of-province prescribers would not usually have access to these pads, the prescription would not be acceptable.

      Having said that, some out-of-province physicians have been given Tamper Resistant Prescription Drug Pads in certain special circumstances, such as for the specific prescribing of methadone. These prescriptions would be acceptable as long as all other requirements are met.

    • How do I request an emergency supply of a narcotic or a controlled drug from another pharmacy?

      Since the Narcotic Control Regulations only allow for one pharmacist to provide a narcotic or controlled drug to another pharmacist to fulfill an emergency need, this means only the minimum amount necessary to fill an actual prescription may be provided (i.e. 26 tablets of Atasol 30 to make up a total quantity of 30 for a prescription but not 100 tablets, just in case).

      • When requesting a product, the pharmacist should a sign and date a written request that includes the product and the quantity needed as well as the pharmacy to where the product is going.A copy of this request should be retained by the pharmacy.
      • When such a request is received by a pharmacy, they should record the provision in their perpetual inventory and retain the written request with their narcotic and controlled drug prescription files.
      • When the requesting pharmacy receives the product, they should record the receipt in their perpetual inventory and file the written request along with any other documentation with their purchase records.
    • What do I need to do before I destroy Narcotics and Controlled Drugs?

      Previously, a request to destroy drugs covered by the Controlled Drugs and Substances Act and its regulations had to be sent to the Compliance, Monitoring and Liaison Division of the Office of Controlled Substances within Health Canada before any drugs could be destroyed. This is no longer required.

      The Board has revised its Interpretation Guide Regarding the Destruction of Expired or Unusable Narcotics and Controlled Drugs as well as developing a sample record of destruction to assist pharmacists with appropriately destroying these drugs and maintaining the appropriate associated documentation. Both are available on our Pharmacy Practice Resources page.

    • What is going on with Cannabis for Medical and Non-Medical Purposes?

      The Government of Canada has introduced legislation that would legalize non-medical cannabis use in the country. If passed, this legislation is expected to come into effect in July, 2018. For now, there is no change to access cannabis for medical purposes. Access will continue to follow the Access to Cannabis for Medical Purposes Regulations. Additional information on how a patient accesses cannabis can be found on Health Canada’s website – Accessing Cannabis for Medical Purposes.

      In addition to the federal legislation, the province will be establishing guidelines and making decisions related to where non-medical cannabis can be sold, who may purchase it, and whether certain laws should be updated or changed in the interests of public safety and health.

      Recognizing that the landscape around cannabis is evolving rapidly, the national organization for pharmacy regulators, NAPRA, has released its position statement on cannabis and the role of pharmacy practitioners which can be found at http://napra.ca/Content_Files/Files/Position_Statement_Cannabis_for_medical_and_nonmedical_purposes_July2017.pdf.



    Questions about Prescribing by Pharmacists

    • What activities are covered by the new Standards of Practice – Prescribing by Pharmacists

      This new authority includes:

      • Prescribing Schedule I, II, III or Unscheduled Drugs for Minor Ailments
      • Prescribing Schedule II, III or Unscheduled Drugs
      • Prescribing an Interim Supply
      • Extending a Prescription
      • Adapting a Prescription
      • Making a Therapeutic Substitution


    • Can all pharmacists prescribe?

      Only pharmacists authorized by the Board as outlined in the Standards of Practice – Prescribing by Pharmacists (available on the Standards, Guidelines and Policies page) are authorized to prescribe.

      Pharmacists who wish to be authorized to prescribe must complete a mandatory orientation program (available at www.advancingpractice.com/p-90-an-orientation-to-prescribing-by-pharmacists-in-newfoundland-and-labrador.aspx) and then apply to the Board by submitting a completed Application for Authorization to Prescribe, found on the Registration and Authorization page, with the supporting documentation and associated fee.

      Pharmacists will be notified by email once the application has been reviewed and approved.


    • At the end of the online Orientation Program, there is a post-test where you have two attempts to pass the test. What should I do if I fail the test on the second attempt?

      If you fail the post-test on your second attempt, you should contact the NLPB Office. We can clear up any uncertainties you have about the content and then work with Advancing Practice to allow you one additional, final attempt.


    • What if I am not comfortable prescribing?

      There is no obligation for a pharmacist to prescribe. In accordance with the Standards of Practice, pharmacists must rely on their own professional judgement to determine whether or not prescribing is within their scope of practice, knowledge, skills, competencies and experience.


    • Are there limitations on Pharmacists’ Prescribing?

      Yes, pharmacists must adhere to the following limitations:

      • A pharmacist may not prescribe Narcotics, Controlled Drugs or Targeted Substances, including benzodiazepines.
      • A pharmacist may not prescribe for an animal.
      • A pharmacist may not prescribe for themselves.
      • A pharmacist should not prescribe for a family member or someone of a “close personal or emotional relationship” unless there is no alternative. If a pharmacist prescribes in these circumstances, it should be appropriately documented.
      • A pharmacist may not provide an interim supply, extend a prescription, make a therapeutic substitution or adapt a prescription where the original prescription bears a specific indication otherwise.
      • Pharmacists must limit their prescribing activities to those situations covered by these Standards of Practice.


    • What will happen to the Standards of Practice regarding Medication Management?

      Current authorizations for pharmacists to participate in Medication Management services (providing an interim supply, extending a prescription and adapting a prescription) will remain in effect until December 31, 2015, after which time pharmacists must be authorized to prescribe in order to continue participating in these services.


    • The Standards require that the location where the prescribing takes place must be designed and laid out to allow for all patient consultations to be provided in a private patient care environment that is clean, safe, and comfortably furnished for the patient. Does this mean all prescribing-related communications must take place in a private counselling room?

      Not necessarily. Prescribing-related communications with a patient or their agent are to be conducted in a manner that respects patient confidentiality. This may mean conducting patient communications in a separate counseling room or it could mean having the conversation with the patient at the counter, as long as the patient’s privacy is maintained (for example, if there are no other patients or customers within hearing range of the conversation).


    • What is informed consent?

      Informed consent has two basic components:

      • patients have a right to determine what happens to their bodies; and
      • health professionals have an inherent duty to provide patients with enough information to make an informed decision.

      The cornerstone to achieving informed consent is developing a good relationship with the patient. Patients must be provided with sufficient information specific to the circumstances to allow him/her to make an informed decision. When dealing with prescribing, this includes but is not necessarily limited to the condition being treated, the drug therapy being prescribed, any expected benefits and risks of the drug therapy, among other elements as detailed in the Standards.

      To ensure understanding and that suitable information has been provided, the patient or his or her agent should be provided with an opportunity to ask questions.

      Once completed, informed consent must be appropriately documented on the Documentation and Notification Form.


    • Is there a list of drugs pharmacists can prescribe for the minor ailments?

      No, once a pharmacist has determined from their assessment that the condition to be treated is one of the 29 approved minor ailments, he or she is expected to follow best practices and clinical guidelines to choose the best treatment for the patient. The only restriction on this decision would be with regard to the limitation on prescribing narcotics, controlled drugs, benzodiazepines or targeted substances.

      For pharmacists who are looking for the most recent best practices and clinical guidelines, we would suggest referring to:

      • The Compendium of Therapeutics for Minor Ailments (a required reference under the Standards) – a compilation of assessment and treatment algorithms, pathophysiology, pharmacological and nonpharmacological therapies and patient information for a wide variety of minor ailments.
      • The website RxFiles (www.rxfiles.ca) – an academic detailing program providing objective, comparative drug information to clinicians through newsletter reviews, Q&As, Trial Summaries, and up-to-date drug comparison charts.
      • The website MedSask (medsask.usask.ca/professional/guidelines/index.php) – the drug information centre in Saskatchewan (the first province to move forward with prescribing for minor ailments). They have developed treatment guidelines for a select number of minor ailments, including mild acne, allergic rhinitis, cold sores and hemorrhoids.


    • What if I am not sure of the correct therapy or have some doubts as to the diagnosis?

      Again, there is no obligation for a pharmacist to prescribe. A pharmacist shall not prescribe if they determine that there is insufficient information or added risks to the patient. In these cases, pharmacists should refer the patient back to their primary health care provider or another appropriate health care professional.


    • Can I add refills to a prescription that I have initiated?

      Yes, pharmacists are not restricted from adding refills to a prescription if it is determined to be appropriate.


    • What happens to refills when a prescription is adapted?

      In accordance with the Standards, when a pharmacist adapts a prescription, the authorized refills should remain intact. If the pharmacist felt this was not appropriate for some reason and reduced or eliminated the number of refills authorized, they would need to document the rationale for their decision and inform the patient that they will need to return to their physician earlier than intended.

      If the pharmacist adapts the prescription and maintains the authorized refills, when the patient returns for a refill the pharmacist would process the refill as they would any other refill prescription. The process of refilling an adapted prescription is not considered an adaptation per se, so the documentation and notification requirements do not apply to the refills.


    • How should I document my prescribing activities?

      All prescribing activities must be documented in a way that includes details related to the pharmacist’s assessment, communication to the patient, follow-up plans and the results of the planned follow-up.

      Template Documentation and Notification Forms have been provided in Appendix II of the Standards of Practice – Form A is for use when the pharmacist is initiating a prescription under section 5.2 or 5.3 and Form B is for use when the pharmacist is continuing or altering an existing prescription under section 5.4, 5.5, 5.6 or 5.7.

      Once completed, this form can also be utilized for notification purposes and then attached to and/or filed with the related prescription record. Pharmacists may develop their own documentation and notification form, if desired, as long as a standard format is used and ALL required information is documented.


    • I notice that Form A includes a large follow-up section. Does this have to be utilized in every instance of initiating a prescription?

      While not all situations will require specific active follow-up by the pharmacist, if you determine that follow-up is appropriate, your documentation must include information related to your follow-up plan as well as the results of this follow-up.


    • Should pharmacists now have their own prescription pads? If so, is there a standardized format for the pad?

      While there is no specific requirement in the Standards for pharmacists to have their own prescription pad, it is a best practice to help standardize the information on the prescription. This is especially important if the patient is taking the prescription to be filled elsewhere. In these cases, the pharmacist at the dispensing pharmacy must be able to be confident in the validity of the prescription as well as to contact the prescribing pharmacist if there are questions or issues.

      With regard to the format of the pad, the forms should be large enough to contain complete information for each prescription and should be difficult to photocopy or otherwise duplicate (utilizing a watermark or other security features). The prescriber’s name, practice address and telephone number should be preprinted on the prescription form. Pharmacists should always sign their prescriptions, and include their registration number if it is not pre-printed on the pad.


    • When the pharmacist prescribes, are they required to notify other Health Care Providers?

      When a pharmacist initiates a prescription under section 5.2 or 5.3 of the Standards, notification is not required but is recommended. In these cases, the patient must be provided with a copy of the documentation form for their records or to bring to their primary health care provider if they desire.

      When a pharmacist extends a prescription under section 5.4, 5.5, 5.6 or 5.7 of the Standards, the original prescriber and the patient’s primary health care provider (if different) must be notified in accordance with the following timeframes:

      • Prescribing an Interim Supply – 72 hours
      • Extending a Prescription – 1 week
      • Adapting a Prescription – 1 week
      • Making a Therapeutic Substitution – 1 week

      In these cases, the patient should also be provided with a copy of the documentation form for their records.


    • When I add an exempted codeine product to a patient’s profile, is this prescribing?

      No, adding an exempted codeine product (ECP) to a patient’s profile for the purposes of meeting the record-keeping requirements of the Standards of Practice – The Sale of Exempted Codeine Products in Community Pharmacies is not considered to be prescribing.

      In order to be considered prescribing, in accordance with the Standards of Practice – Prescribing by Pharmacists, a pharmacist would have to be:

      • 1. initiating a prescription for a Schedule I, II, III or Unscheduled product to treat a Minor Ailment or
      • 2. initiating a prescription for a Schedule II, III or Unscheduled product to facilitate adherence or to facilitate coverage through the patient’s third party drug benefit plan

      While it could be argued that a pharmacist could prescribe an ECP for mild headache or minor joint pain under #1 above, at this time, the Prescribing Regulations and Standards specifically limit pharmacists from prescribing Narcotics, Controlled Drugs, Benzodiazepines and Other Targeted Substances.


    • The Standards of Pharmacy Operation require me to document the provision of all Schedule II products on the patient’s profile – is this considered prescribing?

      No, adding a Schedule II product to a patient’s profile for the purposes of meeting the record-keeping requirements of the Standards of Pharmacy Operation – Community Pharmacy is not considered to be prescribing.

      In order to be considered prescribing, in accordance with the Standards of Practice – Prescribing by Pharmacists, a pharmacist would have to be:

      • 1. initiating a prescription for a Schedule I, II, III or Unscheduled product to treat a Minor Ailment or
      • 2. initiating a prescription for a Schedule II, III or Unscheduled product to facilitate adherence or to facilitate coverage through the patient’s third party drug benefit plan



    Questions about Administering Drug Therapy by Inhalation or Injection

    • Are all pharmacists authorized to administer drug therapy by inhalation or injection?

      Only pharmacists authorized by the Board as outlined in the Standards for the Safe and Effective Administration of Drug Therapy by Inhalation or Injection (available on the Standards, Guidelines and Policies page) are authorized to administer drugs by inhalation or injection. The requirements for obtaining this authorization and the applicable authorization form can be found on the Registration and Authorization Information for Registrants page.

    • Do I need a private counselling room to administer drug therapy by inhalation or injection to a patient?

      In accordance with the Standards, pharmacists are expected administer drug therapy in a private patient care environment that is clean, safe, and comfortably furnished for the
      patient. This does not necessarily have to be a “counselling room” – it may be an office in the pharmacy, a clinic office or even an off-site location.

      Having said that, whatever location is utilized for injections, the location must still allow for suitable post-therapy observation and be equipped with all necessary emergency support equipment and supplies that may be required. If the injections are being provided off-site, the pharmacist would be expected to bring this equipment and supplies with them.

      In addition, even if injections are provided off-site, all assessment, documentation and follow-up requirements must still be met.

    • What types of supplies should I have on hand?

      A pharmacist must have ready access to all necessary supplies for the administration of injections as well as the drugs and supplies that would be required to treat emergencies or adverse reactions associated with the administration of drug therapy. Information on this is provided during the education and training program, as well as in the Canadian Immunization Guide. In Part 2 of this guide, under “Early vaccine reactions including anaphylaxis”, it gives a list of recommended items in an anaphylaxis management kit. Based on this list, as well as other resources, the following is recommended as a minimum:

      • Anaphylaxis treatment guidelines
      • Laminated table of dosage recommendations for epinephrine and diphenhydramine hydrochloride by weight and by age
      • vials of aqueous epinephrine 1:1000
      • vial of injectable diphenhydramine hydrochloride
      • A range of autoinjectors of epinephrine labelled by age and weight
      • 1 cc syringes with attached needles 25 gauge,1 inch needle and 25 gauge, 5/8 inch needle)
      • One extra 25 gauge, 5/8 inch needle only
      • Two extra 25 gauge, 1 inch and 1.5 inch needles only (for larger adults)
      • Ice or cold compress
      • Resuscitator bag / equipment to maintain airways

    • What reporting is expected in the event of an adverse reaction to an immunization?

      The Public Health Agency of Canada require that all health professionals report any major or moderate adverse events that occur following the administration of an immunization, using the Adverse Events Following Immunization Guidelines and reporting form (available at http://www.phac-aspc.gc.ca/im/aefi-essi-form-desc-eng.php). Once completed, the form is to be submitted to the Division of Communicable Disease Control at the Department of Health and Community Services. More information on this division can be found on the Department of Health and Community Services website.

    • Can the Inhalation or Injection Administration Documentation & Notification Form found in Appendix II of the Standards be modified?

      Yes, this form is provided as a template so it may be modified to suit the purposes of the pharmacy. Having said that, all information on the template MUST also be included on the customized form(s).

    • How should I file the documentation and notification forms afterwards?

      There are several ways this could be accomplished but the main thing you must ensure is that they are retrievable, if needed. An appropriate way to handle these forms would be to file them in sequential order along with your other prescriptions, since each instance of administration will likely generate a prescription/transaction number. You could then attach your computer “hard copy” to the form and file it. Pharmacies that have scanning technology can also scan these forms and attach them to the patient’s file for future reference.

    • Can pharmacy students or interns administer drugs by inhalation or injection?

      Yes, as long as they meet certain criteria set out by the Board:

      The pharmacy student or intern MUST:

      • be registered with the NLPB, and be completing either the Internship portion of the NLPB Practical Training program, or a clinical placement as part of the Memorial University Pharmacy Program.
      • have successfully completed either an education and training program on the administration of injections that has received CCCEP competency-based (stage 2) accreditation OR all education and training on the administration of injections are part of the pharmacy program core curriculum;
      • have current certification in CPR Level C or HCP and Emergency or Standard First Aid from a recognized provider (e.g. St. John Ambulance, the Canadian Red Cross); and
      • be under the direct supervision of a pharmacist who has received authorization from the NLPB to administer drug therapy by inhalation or injection.
©2017 Newfoundland & Labrador Pharmacy Board