Reporting of loss or theft of controlled substances and precursors

Guidance Document: Document #: CS-GD-005
Published by authority of the Minister of Health

Table of Contents

Foreword

Guidance documents are meant to provide assistance to industry and health care professionals on how to comply with governing statutes and regulations. Guidance documents also provide assistance to Health Canada employees on how the Department’s mandates and objectives should be implemented in a manner that is fair, consistent and effective.

Guidance documents are administrative instruments not having force of law and, as such, allow for flexibility in approach. Alternate approaches to the principles and practices described in this document may be acceptable provided they are supported by adequate justification. Alternate approaches should be discussed in advance with the relevant program area to avoid the possible finding that applicable statutory or regulatory requirements have not been met.

As a corollary to the above, it is equally important to note that Health Canada reserves the right to request information or material, or define conditions not specifically described in the document, in order to allow the Department to adequately assess the safety, efficacy or quality. Health Canada is committed to ensuring that such requests are justifiable and that decisions are clearly documented.

This document should be read in conjunction with the accompanying notice and the relevant sections of other applicable guidance documents.

Health Canada is the federal department responsible for helping the people of Canada maintain and improve their health. Health Canada is committed to improving the lives of all of Canada's people and to making this country's population among the healthiest in the world as measured by longevity, lifestyle and effective use of the public health care system.

- Health Canada

The Office of Controlled Substances (OCS) within the Controlled Substances Directorate (CSD) administers legislation and activities controlling the possession, import, export, production, distribution and sale of substances listed in the schedules to the Controlled Drugs and Substances Act (CDSA). These include narcotics, controlled drugs, restricted drugs, benzodiazepines, targeted substances and precursors.

The Cannabis Legalization and Regulation Branch (CLRB) administers the Cannabis Act (CA) and its regulations, which among other things, provide legal access to cannabis and to control and regulate its production, distribution and sale. Among its objectives, the CA seeks to prevent young persons from accessing cannabis, to protect public health and public safety by establishing strict product safety and quality requirements and to deter criminal activity by imposing serious criminal penalties for those operating outside of the legal framework.

In addition, the OCS and the CLRB also establish open communication with regulated parties and foster collaboration amongst other federal departments (such as the Canada Border Services Agency), provincial agencies (such as provincial or territorial licensing authorities for medicine and pharmacy) and law enforcement, for the purposes of protecting public health and safety by minimizing the diversion of controlled substances, precursors and cannabis to the illegal market.

Office of Controlled Substances
Opioid Response Team
Cannabis Legalization and Regulations Branch

1. Purpose

This document provides guidance to regulated parties and exemptees under the Controlled Drugs and Substances Act (CDSA), the Cannabis Act (CA) and their regulations in completing a Loss or Theft Report form for controlled substances, precursors and cannabis.

Regulated parties and exemptees must notify the Minister of the loss or theft of controlled substances, precursors and cannabis in accordance with the relevant regulations or the conditions of their exemption. Such notifications must be submitted to Health Canada, Office of Controlled Substances (OCS) for controlled substances and precursors or the Cannabis Legalization and Regulations Branch (CLRB) for cannabis using the Loss or Theft Report Form for Controlled Substances, Precursors and Cannabis (CS-FRM-011).

2. Scope

This document was developed to provide guidance to regulated parties in meeting the regulatory requirements for reporting losses or thefts of controlled substances, precursors and cannabis.

Under the CDSA, the regulated parties include (but are not limited to) licensed or registered dealers, pharmacists, practitioners (e.g. physicians, nurse practitioners), and hospitals.

Under the CA, regulated parties include (but are not limited to) holders of a licence to cultivate, process, conduct analytical testing or research, or a cannabis drug licence, registered persons, pharmacists, health practitioners and hospitals.

This document also applies to exemptees who must report any losses or thefts as per the conditions of their exemptions.

2.1 Regulations Governing the Reporting of Losses or Thefts

This document is not intended to replace the CDSA or the CA or their regulations respecting the loss or theft of controlled substances, precursors and cannabis. The CDSA, the CA and their regulations shall in all circumstances take precedence over these guidelines should there be any inconsistency.

To report the loss or theft of the following documents covered under the CDSA and its regulations:

  • Official documents/information such as: Licences, Registration Certificates, Authorization Certificates, Export or Import Permits, Transshipment Permits, Transit Permits:

Please contact the OCS at (613) 952-2177 or hc.ocs-bsc.sc@canada.ca

To report the loss or theft of the following documents covered under the Cannabis Act and its regulations:

  • Official documents/information such as: Licences, Registration Certificates, Export or Import Permits:

Please contact the CLRB at cannabis@canada.ca

3. Background

Canada is signatory to the Single Convention on Narcotic Drugs, 1961, the Convention on Psychotropic Substances, 1971 , the Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances, 1988 and is party to the resolutions set by the International Narcotics Control Board (INCB). Part of the mandate of the INCB is to prevent diversion of controlled substances, precursors and cannabis to the illegal market.

The OCS and the CLRB each play an important role in ensuring that controlled substances and cannabis are used for legal purposes and as such, uses multiple avenues to accomplish that task, by administration of legislation and activities governing the possession, import, export, production, and sale or provision of substances listed in the schedules of the CDSA and the CA. Prevention of diversion is also accomplished through gathering information regarding losses or thefts of controlled substances, precursors and cannabis. These can be primary sources of substances for the illegal market.

Furthermore, as per INCB guidelines, Canada is also required to submit information regarding yearly losses or thefts that have occurred nationally to the United Nations, so as to create a more concrete picture regarding the diversion of controlled substances and cannabis across the country.

4. What is a reportable loss?

For the purpose of this document, a reportable loss is an incident in which the possibility that the lost substance will be diverted to an illegal market is high or where no explanation exists at the time of reporting as to how the substance has gone missing. Notwithstanding discrepancies described in section 5.1 of this document (i.e. known losses) all other losses with the potential for diversion should be reported. This being said, any discrepancies (regardless of diversion risk) should be recorded in an incident report and filed on site for 2 years to be made available during inspections.

N.B. The lost substance may come from unserviceable stock, filled prescriptions awaiting pickup or delivery, transportation or inventory. This should be indicated on the loss or theft report submitted.

An example of a reportable loss would be when physical inventory counts fall short of those in the records and for licence holders under the Cannabis Act, exceed the acceptable limits set by your organization. Routine reconciliation of records will help prevent the diversion of controlled substances, precursors and cannabis.

4.1 Examples of cases that do not meet the definition of a reportable loss but must be recorded (with records kept on site):

  • A known and accidental dispensing error (as long as it is recorded in accordance with applicable regulations) is not considered a reportable loss. In this case, the pharmacist has full knowledge of where the product is and there is no risk of diversion.
  • Substances rendered unserviceable due to spillage or breaking do not qualify as reportable losses.
  • An economic loss (that is, one in which there is no risk of the substance being diverted to any illegal markets, but results in the loss of the monetary value of the substance) is not considered a reportable loss under the CDSA or the CA (e.g. fire, flood).
  • Claims of waste of a controlled substance, precursor or cannabis that can be reasonably explained on the basis of normally accepted operations.

N.B. Overages do not need to be reported but they should be recorded in an incident report.

5. What is a theft?

A theft is the removal of any quantity of controlled substances, precursors or cannabis under the custody of a regulated party without its explicit legitimate consent.

6. Internal investigation

An internal investigation should be initiated without delay after a loss, a suspected loss or theft is discovered. If the internal investigation is in progress at the time of reporting (i.e. within the time frames specified in section 10 of this document) or within the time period required for reporting past the date of discovery, this should be indicated on the form. Once the internal investigation is completed, any additional information should be provided to the OCS or the CLRB as an amendment to the original form. Please indicate that this attachment is supplemental to the previously submitted loss or theft report.

An internal investigation may be useful to the establishment as it may reveal inconsistencies in certain procedures or point out blind spots.

If a substance suspected to be lost or stolen is recovered, the OCS or the CLRB should be informed that the substance is no longer considered lost or stolen and the original report is to be retracted. This can be done by completing a new Loss or Theft Report form to amend the previous one by checking recovery in box 1.

7. Loss or theft reporting

7.1 Contact Information for Loss or Theft Reports

Loss or theft reports for substances covered under the CDSA Regulations must be reported to the OCS.

Loss or theft reports for substances covered under the Cannabis Regulations must be reported to the CLRB.

Contact information can be found at the end of the document.

7.2 Situations where a Loss Should be Reported

A Loss or Theft Report Form must be completed and submitted to the OCS or the CLRB if a loss (as specified in section 5 of this document) or theft of a controlled substance, precursor or cannabis has occurred at a regulated establishment. Some types of Losses or Thefts are listed in Appendix B of this document.

Any unexplainable losses such as: manufacturer’s shortages (i.e. sealed bottles that contain less than the listed amount of product outside the ranges specified by C.01.061 of the FDR or s.133-136 of the Cannabis Regulations); unexplained yield loss during manufacturing or packaging; and other unexplained loss should also be reported as per the regulations.

N.B. The official individual that discovers the loss or theft is responsible for reporting it. Picking errors and manufacturer’s shortages should be reported by the entity that discovers the error (for example, the receiver once the chain of signature is signed or the Licensed Dealers if discovered before or during transport).

7.3 Situations where Reporting is not Required

A Loss or Theft Report Form is not required for losses of a controlled substance, precursor or cannabis that results from normal business activities, e.g. yield loss during manufacturing which falls with the organization’s predefined acceptable limits (e.g. discrepancy in weigh scale and billing accuracy of bulk form precursor delivery at a licensed facility, visual estimates of precursor residues removed from tanker trucks at tank cleaning facility). Where an incident occurs and results in unusable/unserviceable product (e.g. through spillage, breakage in transit, breakage on site, fire or flood), the official individual need not report a loss or theft, but should create an Incident Report or its equivalent and keep it on file at site for a minimum of two years. The official individual is to develop their own method of documenting non reportable losses for their inventory records.

An Incident Report should be signed by the official individual and a witness and include at least the information outlined below:

  • the date of the incident;
  • the name of the drug or product;
  • the strength of the product;
  • the dosage form;
  • the quantity wasted or destroyed; and
  • a brief summary of the incident.

8. Loss or theft reporting form for controlled substances, precursors and cannabis

The form is available online or by writing to hc.ocs.reporting-rapporter.bsc.sc@canada.ca or cannabis@canada.ca

Loss or Theft Report Form for Controlled Substances, Precursors and Cannabis

The online fillable form can be saved and emailed as the preferred method of submission. Alternatively, the form may be printed out and filled in by hand (in blue or black ink) and faxed or mailed in to the OCS or the CLRB. Contact information can be found at the end of the document.

8.1 Instructions for completing the Loss or Theft Report Form

8.1.1 Contact Information

The administrative information listed below must be entered on the form:

  • The name of the establishment that is reporting the loss/theft exactly as it appears as per their accreditation.
  • The CRA Business Number, if available. Please note that this field is not mandatory.
  • The date of discovery is when the loss or theft was discovered or suspected to have occurred. Please note that this is not the date of submission of the form or the date at which an internal investigation was completed.
  • The address where the establishment is located along with the phone number of the official individual.
  • The type of establishment should be entered, along with the licence number assigned to them by their licensing body:
    • Pharmacists must enter their licence number as assigned by the College of Pharmacists in their province or territory, if pharmacy is chosen as the type of establishment.
    • Practitioners must enter their licence number as assigned by the College of Physicians and Surgeons in their province or territory.
    • Nurse Practitioners must enter their licence number as assigned by the College of Registered Nurses in their province or territory.
    • If the establishment is a hospital and the responsible person is not one of the above, the licence number field can be ignored.
    • Licensed Dealers and Registered Dealers must enter the licence number assigned to them by the OCS.
    • Licensed Researchers must enter the number assigned to them by OCS or CLRB.
    • Licensed Analytical Testers, Cultivators, and Processors must enter the licence number assigned to them by the CLRB.
    • Holder of a Cannabis Drug Licence must enter the licence number assigned to them by the CLRB.
    • Registered Persons or Designated Persons must enter their Medical Cannabis Registry (MCR) registration number assigned to them by the CLRB.
    • Exemptees under section 56 of the CDSA should enter the authorization number assigned to them by the OCS. Exemptees under section 140 of the CA should enter the authorization number assigned to them by the CLRB. Exemptees that carry a Class Exemption should enter their professional licence numbers.
  • The type of loss suffered by the establishment should be entered. If the loss falls under the parameters of the options listed, choose the one that fits. If the type of loss does not fit those listed, choose ‘other’ and describe the type of loss that occurred as best as possible.

8.1.2 Reporting to the Police

8.1.2.1 Mandatory Reporting

It is mandatory to report losses or thefts pertaining to restricted drugs to the police immediately and those pertaining to precursors and cannabis to the police within 24 hours of discovery.

8.1.2.2 Licensed Dealers

Licensed Dealers must respect the conditions on their licence such as but not limited to conducting regulated activities with controlled release formulations of oxycodone products, to report loss (including unusual waste) to the police within 24 hours of discovery. The report provided to the police, a copy thereof or a summary should accompany the loss or theft report submitted to OCS within 72 hours of the date of discovery. Please refer to the Circular Letter dated January 10, 2013 that can be made available on request.

8.1.2.3 Registered person or designated person

To note that under s.327(1)(c) of the Cannabis Regulations a registered person who is authorized to produce cannabis, or for whom cannabis may be produced by a designated person must report the theft or loss of the cannabis in their possession or their registration certificate to a police force within 24 hours after becoming aware of the theft or loss . Similarly, a designated person must report the theft or loss of the cannabis in their possession or of the document referred to in subsection 313(3) of the Cannabis Regulations to a police force within 24 hours after becoming aware of the theft or loss. Report of the theft or loss must be submitted to the Minister within 72 hours after becoming aware of the theft or loss and include confirmation that the theft or loss was reported to the police.

8.1.2.4 Voluntary Reporting

Although the regulations do not require that all types of losses or thefts be reported to the police, it is advised that the official individual notify the local police force in the case of any reportable loss or theft.

If a police report has been made, please check the appropriate box on the form and provide the following information:

  • The date of the report;
  • The name of the police service;
  • The incident number assigned to the case by the police service;
  • The telephone number and e-mail address of the investigating police officer; and
  • The name of the investigating officer.

8.1.3 Loss in Transit

8.1.3.1 Transportation

The official individual responsible for the product during transit must specify the name of the company transporting the controlled substance(s), precursor(s) or cannabis.

N.B. the Canadian organization doing the shipping is responsible for the product while in transit in Canada until signed for by the recipient. Therefore, any losses must be reported by the Canadian originating organization if the recipient had not yet signed for the product

8.1.3.2 Investigation Report

Any additional information obtained from the company transporting the controlled substance(s), precursor(s) or cannabis should be provided as an attachment including:

  • A summary of the investigation report issued by the transportation company.

8.1.4 List of Controlled Substance(s), Precursor(s) or Cannabis Lost or Stolen

The official individual should ensure the following information is indicated regarding the controlled substances, precursors or cannabis listed as lost or stolen:

  • The trade name of the substance as it appears on the bottle or in inventory reports should be listed. If the trade name is unknown, the proper or chemical name (generic name) of the substance along with the manufacturer should be listed. It is imperative that the name of the substance be filled out as comprehensively as possible (without the use of acronyms or internal short forms) because it is one of the most important pieces of information the OCS or the CLRB has to track diversion.
  • The form the substance is present in should be listed. Some of the common forms are as follows:
    • Tablets
    • Capsules
    • Gels
    • Injectables (liquid)
    • Liquid (e.g. oil)
    • Powders (raw materials)
    • Patches
    • Suppositories
    • Drops
    • Topical Creams
    • Seeds
    • Plants
    • Dry Material
  • The quantity of substance lost or stolen has to be listed. This should be an exact number and based on the dosage form of the substance lost/stolen. For example, if the substance is present in tablet form, the quantity listed would be 100, which would mean that 100 tablets have been lost or stolen. If the substance is a powder, please specify the unit lost or stolen in mg, g, or kg (as applicable).
  • The DIN or NPN of the drug, the Lot # for precursors or cannabis products, if applicable. This is a unique identifier for the substance and should always be listed if known.

N.B. The last recorded inventory count may be used to determine the quantity of substance lost or stolen for losses where the exact number would be hard to determine, such as for thefts, armed robberies and pilferages.

8.1.5 Discovery: The Specifics

In the report to Health Canada, the official individual may also include the following information as an attachment to the form:

  • A detailed synopsis regarding how the loss or theft occurred to the best of the official individual’s knowledge regarding the situation, including any potential explanations for the loss or theft.
  • A description of the security measures that the establishment had in place prior to the loss or theft. This may include physical security (such as alarms, safes, etc.) and also other precautionary measures such as frequency of drug counts, electronic flagging, the type of record keeping conducted and others. For Licensed Dealers, a description is only required if the measures are different than what the Authorizations Division, formerly known as the Licences and Permits Division, of OCS, has on file.

A description of the security measures put into place after the loss or theft. As above, this may include physical changes or changes in the way business is conducted. For Licensed Dealers, changes to physical security for the storage of controlled substances may require approval prior to implementation. Please submit any proposed security changes to hc.cds-sdc.sc@canada.ca indicating your file/licence #. For Licensed Analytical Testers, Cultivators, Processors, Researchers or Holders of a Cannabis Licence, changes to the physical security of the site or to areas for cannabis is present may require approval prior to implementation – please submit any proposed security changes to cannabis@canada.ca

9. Submission of the completed report form

The loss or theft should be reported to the OCS or the CLRB within the time limits specified by the Regulations relevant to the missing substances. To note that, when reporting the loss of multiple substances, separate forms can be used to comply with the different timeframes set out in the regulations.

Reporting Timeline
Type of Substance Lost / Stolen Regulated parties Loss to be reported to Police within: Loss to be reported to Minister within:
Precursors Regulated parties under the Precursor Control Regulations 24 hours 72 hours
Narcotics Regulated parties under the Narcotic Control Regulations Without delay based on best practices 10 days
Oxycodone CR (for LDs) Licensed dealers conducting activities with oxycodone controlled release products 24 hours 72 hours
Controlled Drugs – Part G Regulated parties under Part G of the Food and Drug Regulations Without delay based on best practices 10 days
Targeted Substances – BOTSR Regulated parties under the Benzodiazepines and Other Targeted Substances Regulations Without delay based
on best practices
10 days
Restricted Drugs – Part J Regulated parties under Part J of the Food and Drug Regulations Immediately Immediately
Cannabis Part 2 of the Cannabis Regulations – Licences

Cultivator, Processor, Researcher and Analytical Tester
24 hours 10 days
Part 8 of the Cannabis Regulations – Division 1 - Drugs Containing Cannabis

Holder of a Cannabis Drug Licence

Pharmacist, Practitioner or Hospital
24 hours

N/A
10 days

10 days
Part 14 of the Cannabis Regulations – Division 2 – Sub Division C

Registered Persons or Designated Persons
24 hours 72 hours
Part 14 of the Cannabis Regulations – Division 3

Health Care Practitioner, Pharmacist or Hospital
N/A 10 days

The Loss or Theft Form (CS-FRM-011) and its attachments can be faxed or emailed to the OCS or the CLRB at the number or email listed on the form.

Any additional information provided post-submission must be sent as an amendment to the original report and specified as such on the form by referencing the original report’s date of submission and checking the relevant type of report in box 1.

Contact Information for the Office of Controlled Substances:

Health Canada
Office of Controlled Substances
161 Goldenrod Driveway
A.L. 0300B Ottawa ON K1A0K9
Tel: 613-952-2177
Toll Free: 1-866-569-2560
Fax: 613-957-0110
E-mail: hc.ocs.reporting-rapporter.bsc.sc@canada.ca

Contact Information for the Cannabis Legalization and Regulations Branch:

Health Canada
Cannabis Legalization and Regulations Branch
A.L. 0300B
Ottawa ON K1A 0K9
Toll Free: 1-866-337-7705
Fax: 613-941-6840
E-mail: cannabis@canada.ca.

Appendix A: Terms Defined in the Controlled Drugs and Substances Act (CDSA) and the Cannabis Act (CA)

The terms listed below are defined in the Controlled Drugs and Substances Act and regulations made under this act (Precursor Control Regulations, Narcotic Control Regulations, Benzodiazepines and Other Targeted Substances Regulations).

  • Precursor
  • Restricted Drugs
  • Unserviceable stock
  • Practitioner
  • Registered Dealer

The terms listed below are defined or in the Cannabis Act and regulations made under this act (Cannabis regulations).

  • Cannabis
  • Cannabis plant
  • Designated Person
  • Hospital
  • Nurse
  • Nurse practitioner
  • Pharmacist
  • Registered Person

Appendix B: Definitions for the Loss and Theft Report Form

“Date of Discovery”
means the date at which the regulated party discovers (i.e. becomes aware of the occurrence) or suspects that a loss or theft has occurred. Please note that this applies to a situation in which it is assumed a loss has occurred, even if there is an investigation ongoing to confirm it. If, after 10 days post-date of discovery, the occurrence no longer meets the definition of a reportable loss, an amendment to the Loss or Theft Report should be sent to Health Canada.
“Exemptee”
means an individual or class of individuals that are exempted under s. 56 or section 140 of the CA of the CDSA such as but not limited to: Methadone Prescribers, Paramedics, Researchers, Principal Investigator of Human Clinical Trial, Research Laboratories, registered nurses delivering primary health care at health facility in a remote and/or isolated community, Officers of the Canada Border Services Agency (CBSA).
“Facility”
means the premises or site used for the purpose of conducting regulated activities with controlled substances and/or precursors.
“Post-consumer return”
means unused or expired drug substance or drug products containing a narcotic, controlled drug, cannabis, or targeted substance that are returned by an individual consumer to a retail pharmacy for destruction purposes but do not include drug products returned to a hospital pharmacy from patient wards;

Regulated parties

“Holder of a Cannabis Drug Licence”
means the holder of a licence referred to in s.62 of the Cannabis Act
“Licensed Analytical Tester”
means the holder of a licence for analytical testing issued under s.62(1) of the Cannabis Act.
“Licensed Cultivator”
means the holder of a licence for cultivation issued under s.62(1) of the Cannabis Act.
“Licensed Dealer”
means the holder of a licence to produce, make, assemble, package, import, export, sell, provide, transport, send, deliver controlled substances or precursors or destroy cannabis.
“Licensed Processor”
means the holder of a licence for processing issued under s.62(1) of the Cannabis Act.
“Licensed Researchers”
means the holder of a licence under s. 67 of the NCR to cultivate, gather or produce opium poppy for scientific purposes. This also includes the holder of a licence for research issued under s.62(1) of the Cannabis Act.
“Midwife”
means a person who is registered and entitled under the laws of a province to practice midwifery and who is practicing midwifery in that province.
“Official Individual”
means the regulated healthcare professional or other individual designated in accordance with the CDSA, the CA and/or their regulations that is responsible on behalf of the organization /establishment for ensuring regulated activities, e.g. possession, provision, dispensing, import, export, production, comply with the CDSA or the CA and their regulations with respect to controlled substances, precursors or cannabis. Note that the official individual is responsible for the information reported on the loss or theft form.The official individual varies with the type of facility. e.g. for a licensed dealer of controlled substances, the Qualified Person in Charge (QPIC) or their alternates is the official individual. For a pharmacy, staff pharmacists or the pharmacy manager (if they are a pharmacist) are the official individuals.
“Podiatrist”
means a person who is registered and entitled under the laws of a province to practice podiatry and who is practicing podiatry in that province.

Types of Reportable Losses or Thefts

“Armed Robbery”
means the theft of a controlled substance or precursor accomplished through threats of violence toward personnel at a facility during working hours.
“Break and Entry”
means the theft of a controlled substance or precursor from the storage of a facility by forced entry after working hours.
“Grab Theft”
means the theft of a controlled substance or precursor from a facility during working hours without warning. The person conducting the theft ‘grabs’ the product and escapes.
“Loss in Transit”
occurs when product has been lost or misplaced during transport from one location to another.
“Loss Unexplained”
including inventory discrepancies that cannot be explained (comment on the frequency of reconciliation counts), is:
  • a loss unexplained at the time of reporting (i.e. within 10 days of its discovery, except under the IHR and Part J of the FDR) that continues to be investigated internally and upon completion, and additional information should be provided to the OCS or the CLRB as an amendment to the original form; or
  • a loss that remains unexplained after an internal investigation, which may be subject to an external investigation by law enforcement and for which an amendment must be sent to the OCS or the CLRB upon completion of the investigation, if known; or
  • a loss that cannot be attributed to any particular cause or action (excluding unusual waste).
N.B.
Any report that is submitted as a loss unexplained must be amended if an investigation into the loss is completed with an explanation regarding the findings that contradicts/complements the report already submitted.
“Other Loss or Theft”
means any other type of loss or theft that doesn’t fit in the categories above (e.g. picking errors, manufacturer’s shortages: i.e. sealed bottles containing fewer product than listed on label, etc.
“Pilferage”
means the theft of a controlled substance, precursor or cannabis from a facility by an employee during working hours.
“Theft in Transit”
occurs when product has been stolen during transport from one location to another.
“Unusual Waste”
means claims of waste of a controlled substance or precursors that can be explained but not on the basis of normally accepted business activities. (e.g. production waste, yield loss).
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