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Dispensing Drugs

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Approved by Council: May 2010
Reviewed and Updated: November 2011


Policies of the College of Physicians and Surgeons of Ontario (the “College”) set out expectations for the professional conduct of physicians practising in Ontario. Together with the Practice Guide and relevant legislation and case law, they will be used by the College and its Committees when considering physician practice or conduct.

Within policies, the terms ‘must’ and ‘advised’ are used to articulate the College’s expectations. When ‘advised’ is used, it indicates that physicians can use reasonable discretion when applying this expectation to practice.

Additional information, general advice, and/or best practices can be found in companion resources, such as Advice to the Profession documents.



This policy was drafted in collaboration with the Ontario College of Pharmacists.

  1. Physicians who dispense drugs must meet the same standards of dispensing that a pharmacist must meet.
  2. Physicians who dispense drugs must comply with the requirements that are set out in this policy as well those contained in any other relevant College policies1 and provincial/federal legislation2.3
  3. Physicians are permitted to charge a dispensing fee; however, physicians must not charge a fee that is excessive.4
  4. Physicians must not profit on the sale of a drug to a patient except in the limited circumstances permitted by legislation.5
  5. Physicians who dispense6 drugs must:
    1. dispense drugs only for their own patients;
    2. use proper methods of procurement7 in order to be assured of the origin and chain of custody8 of drugs being dispensed, along with knowledge of:
      1. who had the product;
      2. when they had the product;
      3. how long they had the product;
      4. how the product was stored;
      5. who they bought it from; and
      6. who they sold it to;
    3. store drugs securely;
    4. have an audit system in place in order to identify possible drug loss;
    5. store drugs appropriately to prevent spoilage (for example, temperature control where necessary);
    6. keep records of the purchase or sale of drugs;
    7. keep records which allow for the retrieval and/or inspection of prescriptions;
    8. provide appropriate packaging9, labelling, and patient related material for the drugs they dispense;10 and
    9. dispose of drugs that are unfit to be dispensed (e.g. expired or damaged) safely and securely and in accordance with any environmental requirements.
  6. Physicians must not dispense drugs that are past their expiry date or that will likely expire before a patient has finished using them.


1. Including, but not limited to, the Prescribing Drugs policy.

2. Relevant legislation includes, but is not limited to: the Controlled Drugs and Substances Act, the Narcotics Safety and Awareness Act, the Drug and Pharmacies Regulation Act, the Drug Interchangeability and Dispensing Fee Act, and the Food and Drugs Act. These pieces of legislation set out the requirements for the sale and dispensing of drugs, including labelling, record keeping and the retention of records.

3. Guidance for dispensing drug samples is included in the College’s Prescribing Drugs policy.

4. It is a ground of professional misconduct to charge an excessive fee for a service (Paragraph 21, Subsection 1(1) Ontario Regulation 856/93 under the Medicine Act).

5. Section 16 (d) Ontario Regulation 114/94 under the Medicine Act specifies the circumstances in which physicians are permitted to profit on the sale of a drug to a patient. These circumstances include: where the drug is necessary for the immediate treatment of the patient, in an emergency, or where the services of a pharmacist are not reasonably readily available.

6. It is advisable to have standardized dispensing procedures (including labelling, instructions and documentation) in order to minimize errors.

7. The Ontario College of Pharmacists suggests that physicians consider procuring drugs from wholesalers who are registered with the Ontario College of Pharmacists.

8. This includes documentation of each sale or transaction of the product, e.g., a packing slip from the manufacturer or wholesaler registered with the Ontario College of Pharmacists.

9. This includes using child resistant packaging unless: (a) the person to whom the drug will be dispensed to directs otherwise; (b) in the professional judgment of the physician who is responsible for the dispensing of the drug, it is advisable not to use a child resistant package given the particular circumstances; or (c) a child resistant package is not suitable because of the physical form of the drug (Section 45 Ontario Regulation 58/11 under the DPRA).

10. Under the Food and Drug Regulations, physicians who dispense Class A opioids are required to apply a warning sticker to the prescription bottle, container, or package, and provide a patient information handout to accompany the drug. A sticker or handout is not required if the prescription is being administered under the supervision of a practitioner (for example, a physician or a nurse). For more information about these requirements, and to access digital copies of the materials, please see Health Canada’s FAQ.