Questions about Lock and Leave
- When must a lock and leave enclosure be installed and utilized?
The Standards of Pharmacy Operation-Community Pharmacy state that “the dispensary must be able to be secured against entry by the public or other staff when a pharmacist or pharmacy technician is not present in the pharmacy” and “if the pharmacy is accessible to the public or other staff at any time when a pharmacist or pharmacy technician is not present (such as for cleaning, inventory, or overnight stocking), a lock and leave enclosure must be installed and utilized”.
- What area of the pharmacy must be secured by a lock and leave enclosure?
In general, it is the dispensary area of the pharmacy that must be secured by a physical lock and leave enclosure; however, in the context of the Standards, this includes any area of the pharmacy where patient information and prescription records are stored as well as all shelves, displays, fixtures or storage areas containing Schedule I or II drugs. Therefore, any stock rooms or storage areas outside the dispensary where Schedule I and II drugs are stored or where patient information and prescription records are kept must also be secured to prevent access by the public or non-registrant staff.
- Our pharmacy is an “open concept” design. Do I have to put a gate around the entire dispensary area?
For an open concept pharmacy design, there would appear to be no way of preventing access from the remainder of the premises without putting a gate around the entire dispensary area.
- The Standards of Pharmacy Operation-Community Pharmacy state that “the lock and leave enclosure should be constructed in such a way to physically and securely separate the dispensary from the rest of the pharmacy”, what would be an appropriate lock and leave enclosure?
The lock and leave enclosure must be a physical barrier that is secure. In general, the following guidelines can be applied in order to install an enclosure that meets NLPB expectations:
- a) a wall composed of transparent, semi-transparent or opaque materials, or any combination thereof, at least five feet high with adequate doors to permit complete security during periods of closure, and to permit full access by the public to the dispensary area when professional services are available; or
- b) a sliding or folding wall in accordance with the height and material specifications in (a) above, which will completely surround and secure dispensary area during the period of closure, and
- c) a lockable entrance to the Lock and Leave enclosure, which prevents access by the public, or non-registrant staff, when a pharmacist or pharmacy technician is not in attendance.
An Application for Lock & Leave Approval, that includes a description of the construction of the physical enclosure must be submitted by the pharmacist-in-charge and approved by NLPB prior to operating a pharmacy with a lock and leave enclosure. Any concerns and/or recommendations related to the proposed lock and leave structure will be communicated to the pharmacist-in-charge at that time so that they can be addressed in advance of construction.
- Does the lock and leave enclosure have to be utilized if I am on the premises but not in the dispensary?
The dispensary area and any area where patient information, prescription files, and Schedule I and II drugs are stored must be secured any time a pharmacist or pharmacy technician is not present, even if they are on the pharmacy premises (for example, during lunch or supper breaks or during extended patient consultations).
- Can I leave an assistant in the dispensary while the pharmacist is not there?
No, since assistants are not regulated and do not have their own independent scope of practice, they may only be present in the dispensary when they are being directly supervised by a pharmacist or pharmacy technician.
- Can prescriptions that are ready for pick-up be given to patients when the pharmacist is not present?
As per the Standards of Pharmacy Operation-Community Pharmacy, previously-prepared prescriptions may be made available for pick-up when the lock and leave enclosure is secured, in accordance with the following:
- a) Such prescriptions must be stored in a secured area outside of the lock and leave enclosure that also takes into account any special storage considerations including breakage and refrigeration.
- b) The patient’s confidentiality must be protected at all times by ensuring the outer package containing only the patient’s name and address.
- c) Any patient (or designated agent) who picks up a prescription during these times must still be provided with proper and sufficient counseling by the pharmacist.
- d) A documented “paper trail” (either physical or electronic) of all prescriptions picked up, including patient or designated agent signatures must be retained in the pharmacy.
- I have to indicate the hours that a pharmacist will be present on the lock and leave application. Can I change those hours later?
Yes, you may change these hours at any time, as long as you communicate the change to the Board office by completing a revised application form.