Returns and destruction of controlled drugs are the top query that the DDA receives about CDs, Dr Ben Burgess said in his presentation to the DDA 2020 conference, Controlled Drugs – Updated Information for Dispensing Practices.
Looking at DDA data the following make up the top five queries received from members:
Top query How do we manage CD returns and destruction properly?
- CDs must be denatured before disposal
- Need an SOP including recording of destructions
- Stock CDs (e.g. out-of-date):
- Schedule 2 -destruction needs an authorised witness
- Schedule 3 & 4 –good practice for an authorised witness, otherwise a suitable witness from the practice.
- We can accept CDs dispensed elsewhere
- Record receipt in separate CD returns register
- Requirements for authorised witness do not apply, but good practice to do so.
Denaturing is a waste handling process so practices need a T28 exemption. Download a T28 exemption free online
Who is your local CD Accountable Officer and how to contact them?
2. How do we manage requisition forms?
- FP10CDF or WP10CDF
- States that it must be signed by the practitioner named on the form
- Misuse of Drugs Regulations 2001 (Paragraph 14) states that the recipient can provide a written statement to empower a person to receive their drug on their behalf
- There is a template statement of authority for this on the DDA website.
3 What are CD register requirements?
- All schedule 2 drugs
- The GP has overall responsibility, but can delegate the task
- Format of the registers
- Making and amending entries
- Electronic CD registers (delegates commented that electronic registers save time, can reduce errors, and are useful in multi-branch sites)
- Stocktakes and running balances
4. What are the correct storage requirements?
- Schedule 2 CDs (and some Schedule 3s such as temazepam) must be stored in a CD cupboard with restricted access
- An SOP is needed
- Cupboard requirements
- Key holders and use of digital locks
4. Does a Doctor need to second-check CDs?
- The GP has overall responsibility for the dispensary, and delegates this to their dispensing team
- A clear SOP is essential to cover the process, including second checking and maintaining the register.
The presentation also covered the following recent changes to CD regulations:
- Gabapentin and pregabalin classified in 2019 as Schedule 3
- Schedule 2 and 3 CDs can be prescribed via EPS in England, following the usual CD prescription rules. As yet, e-repeats cannot be used.
- The regional Controlled Drugs Accountable Officers (CDAO) oversee all aspects of CD management. We must report all CD incidents or concerns to them.
- Coronavirus pandemic CD regulations 2020
- Not in effect at present and would be for short term use only
- Would allow a pharmacist to supply prescription-only drugs (including CDs) in an emergency or substitute CDs under a serious shortage protocol