Policy Statement on the Electronic Ordering of Controlled Substances

This new policy statement replaces the 1999 Interim Guidelines for the Electronic Ordering of Controlled Substances. It aims to provide guidance while providing maximum flexibility necessary to allow for the implementation of electronic ordering (e-ordering) of controlled substances by licensed dealers, pharmacists and practitioners. In time, we will update relevant regulations to reflect the content of this policy statement.

The Controlled Drugs and Substances Act (CDSA) provides a legislative framework aimed at controlling access to substances that can alter mental processes and produce harm to the health of an individual and/or society when diverted or misused. The Narcotic Control Regulations (NCR), the Benzodiazepines and Other Targeted Substances Regulations (BOTSR) and Part G of the Food and Drug Regulations (FDR-G) are regulations made under the CDSA that govern, amongst other things, the ordering of controlled substances between licensed dealers, pharmacists, practitioners and other authorized persons.

Electronic ordering, or e-ordering, refers to the electronic transmittal and receipt of product orders. E-ordering is an established business practice, and is widely used in the controlled substances industry.

Health Canada advises that electronic ordering is acceptable provided that the digital or electronic signature generated by an electronic ordering system can be authenticated similar to one signed by hand.

Licensed dealers, pharmacists, practitioners, and other authorized persons who wish to implement e-ordering are responsible for ensuring that the system they choose to use will permit them to meet the requirements of the relevant regulations. Such systems could include the following features:

• secure transactions such that the integrity and security of the information transmitted is protected;
• limited access to the data through a series of security checks;
• authentication of persons placing orders and those supplying controlled substances so as to ensure that only licensed dealers, pharmacists, practitioners, or other authorized persons order and receive controlled substances;
• traceability of controlled substances from order to delivery so as to ensure continuity of the custodian chain;
• retention of accurate data, including the name and quantity of controlled substances ordered and supplied; and
• the ability to access data and to generate reports on demand.

Any further questions on this subject should be sent to the Director, Office of Controlled Substances, Controlled Substances and Tobacco Directorate, Health Canada at
OCS-BSC@hc-sc.gc.ca.