The Pharmacy Act, 2024 repeals the 2012 statute, continues the Newfoundland and Labrador Pharmacy Board under a new name — the College of Pharmacy of Newfoundland and Labrador — and recasts the province’s pharmacy regulatory framework.
Beyond a name change, the Act creates discrete registrant categories (pharmacists, pharmacy interns/students, pharmacy technicians and their interns/students), authorizes broader registration pathways (including for non‑CCAPP graduates subject to College requirements), establishes a quality assurance program with routine assessments of registrants and pharmacies, and significantly expands inspection and investigatory powers. It also sets out the College’s governance, discipline and publication rules, and includes transitional amendments to other provincial statutes.
The Act commences September 30, 2024.
At a Glance
What It Does
The Act establishes the College of Pharmacy of Newfoundland and Labrador with explicit objects (registration, licensing, standards, quality assurance and discipline), creates new registrant categories and permits the College to set alternative registration requirements for applicants who lack Canadian‑accredited credentials. It creates a formal quality assurance program that may include routine assessments of registrants and pharmacies and gives inspectors broad, warrant and telewarrant powers to inspect premises and access patient records without consent for regulatory purposes.
Who It Affects
Pharmacists, pharmacy technicians, interns and students; pharmacy owners and pharmacists in charge; the College and its board; provincial health programs that rely on prescription data; and inspectors and adjudication bodies. It also affects internationally trained practitioners seeking registration and pharmacies facing routine assessment or inspection.
Why It Matters
The Act widens regulatory discretion over who may register and how competence is verified, intensifies oversight through routine assessments and inspection powers (including access to patient records), and formalizes stronger publication and sanctioning powers — all of which change compliance risk, privacy exposure and operational obligations for pharmacies and registrants.
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What This Bill Actually Does
The Act recreates the regulator as the College of Pharmacy of Newfoundland and Labrador and sets out its governing structure, objects and powers. The board combines elected registrant directors, public appointees from the minister and board appointments, the dean of Memorial University’s School of Pharmacy, and a non‑voting registrar; by‑laws will fill in procedural detail such as elections, remuneration and registers.
The College can set fees intended to fund its statutory duties and must produce an annual report with statistics about non‑consensual access to patient records during quality‑assurance activities.
Registration is split into clearly defined classes: pharmacists, pharmacy interns and students, pharmacy technicians and their interns/students. The College keeps flexibility to register persons who did not graduate from an accredited Canadian pharmacy program or who were not previously registered in Canada, provided they satisfy “other requirements” the College prescribes.
There is a built‑in timing rule: where two or more years pass between completing exams or practical training and applying for registration, the College may require re‑examination or repeat practical training. Emergency registration routes let the College issue limited, renewable certificates when there is an immediate public‑health need, with reduced documentary barriers allowed in urgent circumstances.Quality assurance and oversight receive a prominent role.
The College must maintain a quality assurance program that can include continuing professional development, practice reviews, and routine assessments of both registrants and pharmacies. Those conducting quality reviews or routine assessments can access and copy records — including patient records — without patient consent, order audits, require evaluations or supervised practice, and make remedial recommendations.
Routine‑assessment reports can lead to directions, reassessments, or referrals into the complaints and discipline process; costs to implement remedial orders fall on the registrant, pharmacist in charge or pharmacy owner.The Act expands investigatory and inspection powers. Inspectors (including the registrar) can enter licensed pharmacies or premises where pharmacy practice occurs without a warrant, inspect records and supplies, make copies or take material for testing, use audio‑visual technology, and require assistance from staff.
Where an inspector suspects an offence, they may obtain a warrant or a telewarrant to seize evidence. Inspectors may order immediate remedial steps or close a pharmacy until compliance is achieved.Discipline is structured through a complaints authorization committee, a disciplinary panel and adjudication tribunals.
The regime allows reprimands, suspensions, conditions on practice, fines up to $25,000 (administrative discipline), and recovery of investigation and hearing costs. The registrar must publish summaries of serious disciplinary outcomes, with specific content required and minimum publication periods.
The Act also preserves appeal rights to the Supreme Court and contains transitional provisions to carry ongoing matters over from the former Act.
The Five Things You Need to Know
The College may register applicants who did not graduate from a Canadian CCAPP‑accredited program or who were not previously registered in Canada if they meet other requirements set by the College.
If two or more years elapse after completing required exams or practical training before an applicant first seeks registration, the College may require re‑writing examinations, redoing practical training, or both.
The quality assurance program explicitly authorizes routine assessments of both registrants and pharmacies and permits reviewers to access patient records without patient consent for the review.
Inspectors may enter licensed pharmacies or premises where pharmacy practice occurs without a warrant, use audio‑visual technology, copy or seize records for testing, and order immediate remedial steps or temporary closure to secure compliance.
Adjudication tribunals may impose disciplinary fines up to $25,000, order restitution or remediation, and the Act also creates summary criminal penalties for contraventions of the Act (first offence up to $2,000 or 3 months imprisonment; subsequent offences up to $4,000 or 6 months).
Section-by-Section Breakdown
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College structure, board composition and governance
This part formalizes the Newfoundland and Labrador Pharmacy Board as the College of Pharmacy of Newfoundland and Labrador, sets the College’s objects (registration, licensing, standards, QA and discipline), and specifies board composition: eight elected registrant members, two ministerial appointees, two board appointees, the Memorial University School of Pharmacy dean and the registrar (non‑voting). Quorum rules, terms (up to 3 years, max 9 consecutive years) and by‑law powers (codes of ethics, definitions of misconduct, registers, and appointment of routine‑assessment personnel) give the College flexibility to operationalize the Act. The College is required to collect fees sufficient, insofar as practicable, to carry out its duties and to report annually to the minister, including stats on non‑consensual access to patient records during QA activities.
Registration categories, alternative pathways and emergency registration
This part creates distinct registration classes and detailed registration criteria: education or alternative College‑set requirements, national exam requirements, practical training, proof of professional liability coverage, criminal conduct certificates and English language competence. It explicitly allows the College to register applicants who do not meet usual accreditation or prior‑registration criteria where they satisfy other College requirements, and permits terms, conditions or restrictions on such registrations. The emergency registration sections allow time‑limited certificates when the College or minister determines there is an immediate need, with relaxed documentary rules and renewal/termination powers for the College.
Quality assurance program, routine assessments and remedial obligations
The College must establish and maintain a quality assurance program that can include continuing professional development, practice reviews, routine assessments of registrants and pharmacies, audits and other initiatives. Quality assurance reviewers and appointed assessors can subpoena records, require evaluations, order counselling or supervised practice, and access patient records without consent. Routine‑assessment reports may contain remedial recommendations; the College can direct compliance and order reassessment, and the costs to implement such directives are borne by the registrant, pharmacist in charge or pharmacy owner rather than the College.
Inspector powers, inspections, warrants and telewarrants
Inspectors (including the registrar) may be designated to inspect premises, operations, books, records and drugs to determine compliance. They may, without a warrant, enter licensed pharmacies or premises where pharmacy work is done, examine and copy records (including electronic formats), conduct tests and remove samples, interview staff, and use audio‑visual technology. Where an inspector has reasonable grounds to suspect an offence, the inspector may obtain a warrant or use a telewarrant procedure to seize evidence; inspectors can also order immediate remedial steps and temporary closure of a pharmacy to secure compliance.
Complaints, discipline and publication of decisions
The disciplinary architecture aligns complaint screening (complaints authorization committee), investigations, a disciplinary panel and three‑person adjudication tribunals. Panels can authorize investigations, practice reviews, or refer matters to the quality assurance committee. Adjudication tribunals hear complaints in public (with limited exceptions), may reprimand, suspend, strike names from registers, impose fines up to $25,000, order costs, and mandate remediation, monitoring or restrictions. Registrants and the College retain appeal rights to the Supreme Court; the registrar must publish summaries of sanctions that meet specified criteria and retain records for at least 10 years.
Reporting, information disclosure, amendments to other Acts and commencement
These sections impose a duty to report professional misconduct, permit disclosure of College records to other health professional regulators (as prescribed), require registrants to provide information to the provincial prescription drug program on request, and update references in multiple provincial statutes to the new Act/name. The Act comes into force on September 30, 2024 and carries over board members, panels and existing proceedings from the former Pharmacy Act, 2012 while repealing that Act.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Internationally trained pharmacists and pharmacy technicians — the College may register applicants who lack Canadian CCAPP accreditation if they meet College‑set requirements, creating additional pathways into practice.
- Provincial health system and patients — emergency registration powers and broader registrant classes increase surge capacity in public‑health emergencies and the quality assurance program targets competence and safety improvements.
- Pharmacy students and interns — the Act creates formal registration categories that allow supervised practice and clearer scope limits, improving training visibility and accountability.
- Public interest representatives and consumers — statutory public appointees on the board, publication of serious disciplinary outcomes and routine assessments increase transparency about regulatory oversight.
Who Bears the Cost
- Pharmacy owners and pharmacists in charge — they must implement remedial orders from routine assessments, cooperate with inspections and pay implementation costs; owners also face obligations when transferring ownership and risk temporary closure orders.
- Registrants (pharmacists and pharmacy technicians) — continuing professional development, potential re‑examination if delayed, professional liability insurance requirements, and the risk of fines, remediation costs and public discipline increase compliance burdens.
- Small or rural pharmacies — unannounced inspections, routine assessments and the possibility of temporary closure or costly remedial orders amplify operational and financial risk in lower‑margin settings.
- The College — while given fee‑setting authority, the College assumes administrative responsibilities (investigations, routine assessments, panels, reporting) that may strain capacity unless fees and staffing are calibrated appropriately.
Key Issues
The Core Tension
The core tension is between protecting public safety through broad, discretionary regulatory powers (flexible registration pathways, routine assessments, unrestricted inspection access to patient records, and strong sanctioning including publication) and ensuring fairness, consistency and privacy for registrants and patients — an approach that improves responsiveness and oversight can also create uncertainty for internationally trained applicants, privacy risks, and significant operational costs for pharmacies with no clear funding backstop.
The Act delegates considerable discretion to the College: it can prescribe ‘‘other requirements’’ to admit non‑accredited or out‑of‑province applicants, set the content and frequency of routine assessments, and determine remedial measures. That discretion enables case‑by‑case judgment but risks uneven standards or opaque decisionmaking if by‑laws and regulations do not spell out objective criteria, equivalency pathways and appealable procedures.
The statutory authority to access patient records without consent for quality assurance and routine assessments, and to disclose College information to other health regulators, runs into privacy and interoperability questions. The Act references disclosure powers and updates to the Personal Health Information Act, but operationalizing record access across electronic systems, meeting PHIA requirements and protecting sensitive health data will require careful regulation and secure processes.
There is also a practical tension in allocating remediation costs to registrants and pharmacy owners: this preserves the College’s budget but may penalize small operators for systemic failures (e.g., staffing shortages) and could incentivize defensive practices or deter pharmacy openings in underserved communities.
Finally, the Act layers administrative discipline (including large administrative fines and public summaries) on top of criminal summary penalties for contraventions. That duality strengthens enforcement but raises questions about proportionality, overlap between regulatory and criminal processes, and the College’s resource needs to implement frequent investigations, routine assessments and appeals.
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