Duties and Responsibilities of Pharmacy Designated Managers

Our firm regularly assists pharmacists, including designated managers, in various regulatory proceedings. 

The Drug and Pharmacies Regulation Act (DRPA) requires each pharmacy owner to assign a designated manager of a pharmacy. The owner of the pharmacy must also file notice of the assignment of designated manager with the Ontario College of Pharmacists (“OCP”). 

According to the OCP Standards of Practice, a designated manager is “responsible for managing the pharmacy.” In other words, the designated manager is responsible for the overall operation of a pharmacy including supervision of staff, facilities, equipment, and supplies.

There are a number of OCP policies that provide guidance on the designated manager’s specific responsibilities. 

The OCP policies Designated Manager – Professional Supervision of Pharmacy Personnel and Accreditation and Operation of a Pharmacy provide guidance with respect to human resources aspects of the designated manager’s responsibilities. Some of the designated manager’s duties in this area include:

  • Ensuring that a pharmacist is on duty at all times that a pharmacy is open; 
  • Ensuring that only registered members perform acts such as controlled acts of dispensing, selling, or compounding a drug; 
  • Ensuring that delegation protocols within the pharmacy are in compliance with College policy on the delegation of controlled acts;
  • Supervising the area of a pharmacy where drugs are kept; 
  • Development of policies and procedures to ensure that clinically relevant information is immediately available to appropriate staff members; 
  • Ensuring that pharmacy practices meet all privacy and health information custodianship requirements; 
  • Taking steps to restrict the practice of an incapacitated and/or incompetent member to protect public safety; 
  • Ensuring that staff performing dispensing or compounding activities must adhere to appropriate hygienic behaviour including wearing appropriate attire and the use of proper hand washing techniques.

The OCP policy Designated Manager – Medication Procurement and Inventory Management provides guidance to the designated manager with respect to the manager’s inventory management duties. Some of the designated manager’s duties in this area include: 

  • Ensuring that the pharmacy is appropriately laid out, including that requirements with respect to placement of prescription and non-prescription drugs are met;
  • Ensuring that all medications purchased are of acceptable standard and quality; 
  • Ensuring that staff members whose duties include procurement and inventory management are appropriately trained and that proper records are kept; 
  • Ensuring that proper inventory is kept and stored, including management of narcotics, controlled drugs, and targeted substances; 
  • Investigating shortages or losses of inventory, and reporting such losses as necessary; 
  • Ensuring that products requiring cold chain are managed appropriately.

Above all, designated managers must be aware that they have the same liability as pharmacy owners with respect to any breach of the Drug and Pharmacies Regulation Act (section 166(1) of the DRPA). Because of the liability imposed by the Act, designated managers must ensure that they are familiar and involved with the pharmacy’s day-to-day operations. 

Designated managers could face serious consequences as a result of any breach of their duties, such as OCP investigations and discipline proceedings, Ontario Drug Benefit (“ODB”) investigations, or prosecution of offences under the DRPA. Any designated manager facing such a proceeding should take immediate and early steps to retain a lawyer experienced in this area.

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