Tramadol Scheduling Changes – Impacts on Pharmacy Activities
On March 31, 2022, tramadol was removed from the Prescription Drug List (PDL) and listed in Schedule I of the Controlled Drugs and Substances Act (CDSA). It was also listed as item 19 in the Schedule of the Narcotic Control Regulations (NCR). Therefore, tramadol is now subject to all the regulatory requirements set out in the CDSA and NCR.
Controlling tramadol will strengthen Health Canada's oversight of legitimate activities with this substance, and facilitate detection and prevention of diversion.
For more information on the change, see:
Since March 31, the College has received a number of questions from registrants on the implications of this change on their practice. This article explores and provides clarity on some of the most common questions received by College staff.
Is a Controlled Prescription Program (CPP) form required for a tramadol prescription in BC?
No, at this time, tramadol is not a Schedule 1A drug and therefore not part of BC’s Controlled Prescription Program (CPP). This means that tramadol prescriptions do not need to be written on a CPP form.
Decisions around what drugs should be part of the CPP are made on the recommendation of BC’s Controlled Prescription Program Advisory Committee (CPPAC), which is comprised of representatives from prescribing colleges and the Ministry of Health. The College is currently working with the CPPAC to determine if tramadol should be made a Schedule IA drug in BC, and therefore be added to the CPP. College Board and Ministry approval is also needed to make the scheduling change on the Drug Schedules Regulation.
Any changes to the provincial scheduling of tramadol will be communicated with registrants.
If a patient has a tramadol prescription written prior to March 31, 2022 on file with refills remaining, can the refills be dispensed after March 31, 2022?
No, refills of tramadol prescriptions written prior to March 31, 2022 are not valid after March 31, 2022 unless they were written as a part-fill. Part-fills of tramadol prescriptions written prior to March 31, 2022 may be dispensed, and these prescriptions must be filed in the narcotic prescription file.
Are verbal prescriptions of tramadol permitted? What about transfers or deliveries?
As tramadol is now considered a narcotic federally, it is subject to all the usual narcotic prescription and recordkeeping rules. Typically, narcotic drugs may not be prescribed verbally or transferred. However, in response to the evolving overdose crisis, Health Canada has issued a subsection 56(1) exemption from the Controlled Drugs and Substances Act in the public interest and the College has made temporary authorizations to enable some of the exemptions.
For more information, see the College’s information on Temporary Authorizations for Controlled Drugs and Substances, and Health Canada’s Subsection 56(1) class exemption for patients, practitioners and pharmacists prescribing and providing controlled substances in Canada.
Does tramadol have to be stored in the safe?
No, the Bylaws to the Pharmacy Operations and Drug Scheduling Act only require Schedule 1A drugs to be stored in the safe. While tramadol is not required to be stored in the safe, registrants may still choose to do so.
Are tramadol and acetaminophen combination products also considered a narcotic under the new scheduling change?
Yes, any product containing tramadol is now considered a narcotic.