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S8 medications – Who holds the key? |
 Therese Greenlees
There has been much discussion lately regarding S8 medicine storage and disposal and it appears some practices have received some conflicting advice.
The RACGP 3rd Edition Standards for Accreditation (Criterion 5.3.1) states that a practice must ensure that “Schedule 8 medications are stored securely and are only accessed by authorised personnel”. While the criterion is clear, the interpretation can be confusing, as practices also need to comply with NSW legislation.
Storage and documentation
S8 medicines need to be stored securely in a locked cabinet or safe that is fixed to an immoveable structure. All acquisitions, use, transfers and disposal of the medications must be documented in a bound book with consecutively numbered pages (available from RACGP). Entries must be written in ink on the day of the transaction, and need to include the date, the name and address of the patient or supplier, the quantity of drug, the progressive balance remaining in stock, and the name and signature of the authorised person who administered the drug or made a transaction entry into the book. While not legislated, it is considered best practice for a second authorised person to witness any transaction wherever possible.
Each strength of drug needs to be recorded on a separate page and a stock inventory needs to be completed in March and September. The record book must be kept for two years after the last entry and no transaction can be erased or altered, although corrections can be noted in the margin or as a footnote, as long as it is initialled and dated.
Who can hold the key?
The Pharmaceutical Services branch of NSW Health has advised that it is “the principal GP’s responsibility to hold the key to the S8 cupboard within the practice.” However, GPs who wish to delegate this responsibility may do so to other GPs and/or a registered nurse, but a practice based policy would be required to reflect this delegation. Where S8s are stored within the doctor’s bag then it is the individual GP bag owner’s responsibility to hold the key. It is advised that the key to S8s, whether to the doctor’s bag or a locked drug cupboard, be maintained separately to other keys.
The difficulty of holding the key arises where there is no continuity of authorised staff, for example where practices are staffed by part time or casual staff. In this instance, the Pharmaceutical Services adviser recommends using a key safe to store the S8 drug key, with only authorised GPs and RNs knowing the safe combination. The practice manager and receptionists should not know the combination of the key safe.
Disposal of S8 medications
The NSW Health Guide to Poisons & Therapeutic Goods Legislation for Medical Practitioners and Dentists (Jan 2006) states: “A drug of addiction in the possession of a medical practitioner or dentist for use in connection with their profession may legally be destroyed only by a member of the police force or by a person authorised by the NSW Department of Health to do so.”
While it is feasible in urban areas to contact the duty pharmaceutical adviser at NSW Health and have an authorised pharmacist destroy expired S8 medications, in rural areas practices rely on their local police station to do the same.
The correct procedure is to contact your police station and organise for an officer to attend your surgery to destroy any expired drugs. The police officer should be familiar with this procedure, however new officers to country areas may not be, in which case they need to be asked to contact the duty pharmaceutical adviser (ph: (02) 9879 3214) for clarification. The police officer should then break the ampoule over a tissue; the tissue and broken ampoule are then placed in the sharps container. Finally, the police officer must record the destroyed drugs in the drug register, with the transaction witnessed by the GP or an authorised RN.
For further information, please refer to the RACGP Accreditation Standards 3rd Edition (www.racgp.org.au) and the NSW Health Guide to Poisons & Therapeutic Goods Legislation for Medical Practitioners and Dentists (http://www.health.nsw.gov.au/ public-health/psb/publications/ pdf/poisons_medprac_dentists.pdf). If you have any questions regarding the NSW legislation, you can contact the NSW Health duty pharmaceutical adviser direct on (02) 9879 3214.
Therese Greenlees and Angela McAnally – Practice Liaison Officers
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