Special Considerations

Substitution Policies

An RT’s employer may have developed, and approved policies related to substituting certain medications. Substitution policies are also known as “therapeutic interchange policies”. RTs must have the knowledge, skill and judgement to apply approved substitution policies in their practice. For more information, please refer to the Drug Interchangeability and Dispensing Fee Act.


An “interchangeable drug product” is defined as a drug or combination of drugs in a particular dosage, form, and strength, that have been determined as interchangeable with another (e.g., exchanging one asthma medication for another).


Repackaging a medication that has already been dispensed (e.g., into a daily use container) is not a controlled act and is not considered dispensing. In this case, the RT is responsible for ensuring that the medication has been repackaged safely.

Narcotics and other Controlled Substances

These are drugs as defined in the Controlled Drugs and Substances Act and the Narcotic Control Regulations. The CRTO’s position is that there is nothing in current provincial or federal legislation to prevent an RT from receiving delegation to dispense a controlled substance. RTs may dispense narcotics and other controlled substances but must first obtain delegation to dispense the medication, as with other medications. For more information on delegation, please see the CRTO Practice Policy Handling, Administration and Dispensing of Controlled Substances.


A direct order is required for the administration of a controlled substance.

For example: A medical directive is not an acceptable substitution for a direct order for a narcotic in the Operating Room.

Dispensing Samples

A medication sample is defined as a trial package of medication distributed to a health care professional free of charge. If an RT is dispensing sample medications to patients/clients, it is important that they do the following:

Ensure there is a valid order (direct order or medical directive) for the correct medication;


Obtain informed consent before providing drug samples;


Label the medication if it’s being dispensed based on a prescription (see section on Labelling Dispensed Medication);


Provide the patient/client with all the necessary information about the medication (e.g., dose, frequency, mode of administration);


Document the drug samples given to patients, including: the date provided, name of the drug, drug strength, quantity or duration of therapy, instructions for use, and that the drug’s material risks (including material side effects, contraindications or precautions) were discussed with the patient;


Communicate the need for follow-up to monitor whether any changes to the treatment plan are required; and


Share information about drug samples provided with other health care providers, as appropriate.


Schedule II narcotic substances may not be provided as drug samples.

Medical Errors

Medication errors and preventable adverse drug events present a serious threat to patient/client safety. They can result in serious adverse drug events (ADEs) due to the wrong medication being administered to the wrong patient/client at the incorrect dose, time, reason, and/or route. ADEs can also occur as a result of missing, incorrect or incomplete documentation. RTs play an important role in reducing the incidence of medication errors by carefully following the eight principles outlined previously, (please see section on Administration) and by ensuring their organization applies processes aimed at reducing the possibility of medication errors.

Some of the factors associated with medication errors include the following:

Medications with similar names or similar packaging
Medications that are not commonly used or prescribed
Commonly used medications to which many patients are allergic (e.g., antibiotics, opiates, and nonsteroidal anti-inflammatory drugs)
Medications that require testing to ensure proper (i.e., nontoxic) therapeutic levels are maintained (e.g., lithium, warfarin, theophylline, and digoxin)


Any abbreviations, symbols and dose designations must be recognizable to all those involved with the administration and dispensing of the medication to the patient/client.

Additional information can also be found on the Institute for Safe Medication Practices (ISMP) Canada website.

When a medication error occurs, the RT must take immediate steps to ensure the patient’s/client’s safety, resolve the problem and report it. It is essential for the RT to document the error on the patient’s/client’s chart, including:


what happened;


the intervention(s) carried out;


the patient’s/client’s response to the intervention(s); and


all other organizational requirements s for reporting errors.

It is also important to participate in reflection, identifying challenges and barriers that impact safe medication delivery, and as a team, focus on improvement and solutions.


Your employer may have policies that support safe administration and dispensing of medication by its health professionals. Please familiarize yourself with your organization’s policies. 


Administration (of a medication): the direct application of a drug to the body of a specific patient or research subject by injection, inhalation, ingestion, or any other means.

Authority: the right to act, as outlined in the legislation, usually related to terms, conditions or limitations imposed on a certificate of registration.

Controlled act: one of the 13 acts defined in the RHPA [section 27(2)]

Compounding: the act of combining two or more elements to create a distinct pharmaceutical product. Compounding is not authorized to Respiratory Therapists. Delegation is not required when combining elements to prepare a drug for administration. For example: mixing liquid bronchodilators in normal saline for aerosolized therapy.

Competence: having the requisite knowledge, skills and judgement/abilities to perform safely, effectively and ethically; and applying that knowledge, skills and judgement/abilities to ensure safe, effective and ethical outcomes for the patient/client.

Delegation: the transfer of the legal authority to perform a procedure within a controlled act to a person not otherwise authorized to perform the procedure.

Drug: as defined in the Drug and Pharmacies Regulation Act.

Labelling: the process of preparing and affixing a label to any drug container. Any such label shall include all information required by provincial regulations. In this context, labelling does not include the labelling by the manufacturer, packer or distributor of a non-prescription drug or commercially packaged drug or device.

Order: An “order” is the authority to undertake an intervention if the circumstances are appropriate and, in your professional judgement, it is appropriate to undertake the intervention. For more information of what constitutes a valid order, please see the Orders for Medication Care PPG.

Pharmacy: a premise in or in part of which prescriptions are compounded or dispensed for the public.

Prescriber: a person authorized to give a prescription within the scope of his or her practice of a health discipline or profession.

Prescription: an authorization from a prescriber permitting the dispensing of any drug or mixture of drugs for a designated person or animal.

Regulated health care professional: A health care provider who is a member of a regulatory college and is regulated by the RHPA (e.g., nurse, physician, dentist, massage therapist, physiotherapist, dietitian, occupational therapist, etc).

Respiratory Therapists: Members of the CRTO (RRT, GRT, PRT).

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