Health Canada loss or theft reporting: a step-by-step for pharmacies

If a controlled substance is lost or stolen — including an unexplained shortage you've investigated and identified as a loss — federal rules require you to report it to Health Canada. Report it to Health Canada's Office of Controlled Substances within 10 days of discovering it (Narcotic Control Regulations s. 42; Food and Drug Regulations s. G.03.013; Benzodiazepines and Other Targeted Substances Regulations s. 72(2)). The steps below cover how to tell a genuine loss from an explainable variance, what to gather, and who submits the report. Always confirm the current requirements and forms with Health Canada and your provincial college.

1. Establish whether it is a genuine loss

A shortage on a count is not automatically a loss. Investigate first — re-count, and check the records behind the expected figure for an unlogged destruction, a dispense under a different DIN, or a transaction outside the count window. Do it promptly. The reporting clock runs from discovery of the loss or theft, not from the day the investigation closes, so a slow reconciliation spends the window rather than pausing it.

2. Report to Health Canada within 10 days of discovering it

Report a loss or theft of a controlled substance to Health Canada's Office of Controlled Substances within 10 days of discovering it. The narcotic and controlled-drug regulations both word it “within 10 days of his discovery thereof”, and the benzodiazepine regulations say “within 10 days after becoming aware” — none of the three says “confirmed”. A theft involving a break-in or robbery should also be reported to the police — often immediately — in addition to Health Canada.

A note on precursors: a different class, and a much shorter clock

Everything above is about controlled substances — the narcotics, controlled drugs and targeted substances NarcCount counts. Precursors are a separate class and NarcCount does not track them: pseudoephedrine and ephedrine are Class A precursors under Schedule VI of the CDSA, not controlled substances, so the 10 days does not reach them. They have their own rule, and its clock is much shorter. On discovering an unusual waste or disappearance of a Class A precursor that normally accepted business practices cannot explain, a pharmacy selling them on a retail basis notifies a police force within 24 hours of the discovery and the Minister, in writing, within 72 hours (Precursor Control Regulations s. 91.96(b)). This is federal and changes nothing above.

3. Gather the details

You'll typically need the substance(s) and strength, the DIN, the quantity involved, the date you discovered the loss, the circumstances, and the steps you took. Health Canada publishes a form for this, the Loss or Theft Report Form, alongside its guidance document CS-GD-005 — both linked under Sources at the foot of this page.

4. The right person submits it

Submitting the report is the pharmacy's responsibility, made by the qualified person in charge (or the responsible person at your pharmacy). Health Canada calls that person the “official individual”, and says anyone can draft a report in its E-Services Portal but only the official individual can submit one. A reconciliation tool can prepare a draft from the count's shortages, but a qualified person must review it for accuracy and submit it.

5. Keep a copy

Retain the report and the supporting records — your count, your investigation notes, and any corrective action — with your reconciliation documentation, retrievable for at least 10 years in Ontario (O. Reg. 264/16 s. 21); the federal narcotic minimum is 2 years.