Looking after your inventory

Issues with some pharmacy DAA, RUM and Schedule 8 procedures, investigators report

There remain issues with the compliance of some pharmacies with the procedures required by regulators, the Victorian Pharmacy Authority says.

In its latest circular, the VPA has outlined some of the more common errors and issues it’s investigators have encountered over the past year. 

VPA inspectors reported cases where pharmacies had no dose administration aid (DAA) packing records or where the records do not fully comply with Pharmacy Board of Australia’s Guidelines on dose administration aids and staged supply of dispense medicines.

“These records help mitigate or detect medication errors and allow for accountability throughout the DAA packing process,”  the VPA said.

A record of each packing into a DAA should be made under the patient’s name with:

  • each medicine’s name, form, strength and dose
  • the date of packing
  • the initials of the person who packed it and those of the pharmacist who checked it 
  • the date of supply of the DAA to the patient or their agent, and
  • the quantity of a patient’s medication that remains after packing.

“Pharmacies that engage a third party to pack DAAs should also keep packing records of any changes made to the DAAs at the pharmacy following the supply of the DAAs packed by the third party,” the authority says.

The VPA also emphasised that adequate arrangements must be in place to ensure that medicines are not re-used after dispensing, and after they have left the pharmacy or pharmacy department.

“PSA’s Guidelines for Pharmacists Providing Dose Administration Aid Services states that ‘Any unused medicines in DAA that are returned to the pharmacy or have not been collected from the pharmacy, should be disposed of in accordance with relevant legislation and not be re-used’. The re-use of medicines in DAAs presents risks of error and drug stability issues”.

Meanwhile, there were also concerns raised by reports from VPA inspectors of “instances where filled RUM bins were stored in unsecure locations such as storerooms to which all staff members have unrestricted access.

“Returned or expired medicines should be quarantined in a secure manner and disposed of regularly to prevent build up and misappropriation using Return of Unwanted Medicines (RUM) bins.

Returned or expired medicines/filled RUM bins should be stored in the dispensary or in another part of the premises under lock and key to prevent unauthorised access,” the VPA says.

The VPA also reiterated previous advice that returned and expired Schedule 8 poisons should be stored in the drug safe until they can be destroyed.

“Pharmacists should take all reasonable steps to ensure any S8 poison either returned for disposal or past its expiry is recorded in the drug register when received or identified and a subsequent record made when destroyed in accordance with regulations.

This ensures that all S8 poisons in the pharmacist’s possession are accounted for and reduces the risk of misappropriation”.

Using a separate or designated section of the drug register to record ‘Drugs for Destruction’ is a practice the VPA recommends for accurately accounting for returned or expired drugs.

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  1. Ex-Pharmacist

    “PSA’s Guidelines for Pharmacists Providing DAAS states that ‘Any unused medicines in DAA that are returned to the pharmacy should be disposed of and not be re-used’. The re-use of medicines in DAAs presents risks of error and drug stability issues”.

    I know of 1 prominent pharmacy in the leafy eastern suburb of Balwyn (Melbourne) there was a secondary A-Z shelf of high cost loose tablets & capsules extracted from returned DAA’s, for later repacking into DAA’s.

    I wonder how many pharmacies around Australia repack returned DAA’s, following guidelines and dispose of them. The temptation is real, effectively being paid twice or even three times for the same medication, super-boosting profits for pharmacy owners, and in the Balwyn case, Guild members.

    • Jarrod McMaugh

      The best course of action you have in a situation where you know that there are practices that are in breach of professional guidelines or (as in the case you describe) defrauding the PBS, is to make a notification to VPA (in the case of any victorian town) or the state DHHS; and/or AHPRA.

      Make the notification anonymously if you so wish.

      But make the notification, so that this kind of practice has consequences.

      In the case of the pharmacy you have knowledge of, was it returned medicines?
      My pharmacy kept unused medicines that had been ceased, in small quantities. This way we could provide an emergency supply to someone if necessary; this was reserved for medicines that had not left the pharmacy, not been removed from packaging, and had been ceased greater than 3 months (for those situations where a person re-started a medicine shortly after cessation).

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