EMS Controlled Drug Policy

Controlled Drug Policy Purpose

• Establishes procedures for quality control.
• Procedures for distribution, administration, and inventory of controlled drugs.
• Applies to drugs used by the Philadelphia Fire Department's EMS.

Definitions

• Attending Paramedic: Provides primary patient care, attends during transport, and completes documentation.
• Box Lots: Packages of 10 cartridges, 10 vials, or 15 auto-injectors.
• Controlled Drugs: Medications from a "controlled substance" given during ALS procedures.
• Controlled drugs used in the Philadelphia Fire Department's ALS system:
  • Morphine Sulfate (MS)
  • Midazolam (Versed)
  • Diazepam (Valium) auto-injectors
• Controlled Drug Administration Record (CDAR): A record of controlled drug administration.
• Controlled Drug Daily Count Log: Verifies integrity and inventory levels of “on-board” controlled drugs.
• Controlled Drug Restock Inventory Log: Filled out ONLY when changes are made to controlled drugs in the CONTROLLED DRUG RESTOCK LOCKER.
  • Changes made by a paramedic or by Emergency Medical Services Apparatus and Equipment (EMS A&E).
  • It is to be locked in the CONTROLLED DRUG RESTOCK LOCKER with its corresponding CONTROLLED DRUG SECURITY BOX.
• Controlled Drug Restock Locker: An ELECTRONIC IDENTIFICATION LOCKED locker.
  • Located within the CONTROLLED DRUG SECURITY CABINET.
  • Is authorized and supplied by the EMS A&E Office.
  • It will only be used for the storage of the CONTROLLED DRUG SECURITY BOX and Diazepam Auto- Injectors.
• Controlled Drug Security Box: Authorized and supplied by EMS A&E.
  • Capable of holding a maximum of six (6) cartridges of each controlled drug.
  • Adequately protects cartridges from damage and can be sealed with an electronic security lock.
• Controlled Drug Security Cabinet: A locked cabinet authorized and supplied by EMS A&E.
  • Located within the firehouse.
  • Contains only a CONTROLLED DRUG RESTOCK LOCKER.
  • Only accessible by Fire Service Paramedics, EMS A&E, ES-3, EMS Field Operating Officers.
• Downloader: A Universal Serial Bus (USB) device.
  • Mounted in medic unit or supervisor apparatus.
  • Updates/modifies electronic identification keys and locks in Philadelphia Fire Department System.
• Electronic Identification Key: A battery-operated electronic key assigned to each person.
  • Each Fire Service Paramedic and EMS Field Supervisor is assigned a key.
  • It can be downloaded to retrieve access information, uploaded to grant/change permissions.
• Electronic Identification Lock: A lock placed on the Controlled Substance Security Box and Locker.
  • It can be downloaded to retrieve access information.
• WMD Controlled Drug Container: Black box used to store up to 15 Valium Auto-injectors.
  • Authorized and supplied by EMS A&E.
  • Supports a CONTROLLED DRUG SECURITY NUMBERED TAB.

Responsibility

• It is the responsibility of all members to follow control dictated by their rank.
• All Paramedics will carry their ELECTRONIC IDENTIFICATION KEY when conducting Department business.
• New uniformed members receive their ELECTRONIC IDENTIFICATION KEY at the Philadelphia Fire Academy.
• Update ELECTRONIC IDENTIFICATION KEY the first working day after a return to duty.
  • Click the “I” icon on the Mobile Data Terminal (MDT).
  • Click “Websites”.
  • Select Cyber key from the dropdown list.
  • Place Identification key into station key port until tones are heard.
  • Leave the key in place until configuration is complete.
  • The monitor will display "You may remove your key."
  • If another member needs to configure a key, repeat steps.
  • Place mouse pointer on "file" and click, then "exit" to close the station key port window.
• Members who lose or damage their key must notify their “On-Duty” Commanding Officer. Lost keys must also be reported to the local police district.
• Notification and documentation of any controlled drug usage and/or restocking is required.

Commanding Officers

• Forward all forms, documentation, and memos required.
• Inspect all assigned member’s ELECTRONIC IDENTIFICATION KEY’s during annual.
• When a member's lock is lost, stolen, or destroyed, the Commanding Officer/Supervisor will prepare a memo requesting a new key.
  • The memo includes loss circumstances, Police District details, officer contacted, date, time, etc.
  • Send memo to Deputy Commissioner of Operations for approval.
  • The member must include a $120.00 check/money order payable to the City of Philadelphia.
• An approved memo copy will be returned to the company once approved by the Deputy Commissioner of Operations.
  • The member will then call EMS A&E to arrange a new ELECTRONIC IDENTIFICATION KEY pick-up.
• When picking up the new key, the member signs a copy of the memo, acknowledging receipt.
  • The signed copy is forwarded to the Personnel Office.
• Unauthorized ELECTRONIC IDENTIFICATION KEY use results in disciplinary action.

Procedures - Controlled Drugs

• Paramedics administering controlled drugs must comply with Pennsylvania State Advanced Life Support Protocols and/or verbal orders from a Medical Command Physician.
• No controlled drug shall be administered outside of these two accepted circumstances; protocol and/or verbal order.

Inventory Control

• EMS A&E maintains an adequate inventory of controlled drugs for departmental use.
• Each ALS unit gets an initial inventory of:
  • One box lot (10 cartridges) of Morphine Sulfate
  • One box lot (10 cartridges) of Midazolam
  • Fifteen Diazepam auto-injectors
• The following controlled substances may be added or substituted depending on inventory, protocol changes, or additions:
  • Diazepam
  • Lorazepam
  • Fentanyl
• All procedures must follow PA State Protocols and EMS Procedure 7A if any controlled substances are issued.
• Controlled Drug Security Boxes are supplied as follows:
  • One red box is carried in the ALS "first-in" bag. This is the “on-board” CONTROLLED DRUG SECURITY BOX.
  • A second clear box is stored in the Controlled Drug Restock Locker with a maximum of five of any assigned controlled drug.
• During ALS unit shift changes, the on-coming and off-going paramedics will:
  • Verify integrity of the “on board” CONTROLLED DRUG SECURITY BOX and WMD CONTROLLED DRUG BOX.
  • Count and record the number of cartridges in the “on board” CONTROLLED DRUG SECURITY BOX on the CONTROLLED DRUG DAILY COUNT FORM.
  • Record the CONTROLLED DRUG SECURITY SEAL NUMBER of the WMD CONTROLLED DRUG BOX on the CONTROLLED DRUG DAILY COUNT LOG.
  • Sign the CONTROLLED DRUG DAILY COUNT LOG.

Opening the Controlled Drug Security Cabinet

• Paramedics only open the CONTROLLED DRUG SECURITY CABINET when 4 of a particular controlled drug have been used or when the controlled drug(s) in the “on board” box have expired.
• A paramedic opening the cabinet will:
  • Immediately document the change on the CONTROLLED DRUG RESTOCK INVENTORY LOG.
  • Document the change on the CONTROLLED DRUG DAILY COUNT LOG at shift change.
• The key-holding entrant completes the CONTROLLED DRUG RESTOCK INVENTORY LOG each time the cabinet is entered.
• It is required to immediately inform the Company Officer if if the logs cannot be located.
• Complete a count of on-board controlled drug and restock inventory, and follow procedures in section 5.5 if needed.

ALS Units Operating Less Than 24 Hours (BLS Units)

• For ALS units operating less than 24 hours, the "off-going" paramedic will:
  • Remove the "on board" CONTROLLED DRUG SECURITY BOX from the ALS “first-in” bag.
  • Sign the CONTROLLED DRUG DAILY COUNT LOG as the “off-going” paramedic and place.
  • “BLS” in the “on-coming” paramedic spot.
  • Lock all drugs in the CONTROLLED DRUG SECURITY LOCKER (including the WMD CONTROLLED DRUG BOX).
  • Keep the controlled drug daily count log with its corresponding security box.
  • Secure the cabinet keys in the Company Officers' office.
• The “on-coming” paramedic will:
  • Retrieve standard keys or Medic unit keys from secured location.
  • Remove the “on-board” box and the log from the cabinet.
  • Sign the “on-coming” paramedic spot on the log and place BLS in the “off-going” spot.
  • Re-secure the drugs in the cabinet.
  • Secure standard keys in the Company Officer's Office.

Administration of Controlled Drugs

• After each controlled drug administration:
  • The attending paramedic selects the administered drug in the electronic PCR so the CDAR appears.
  • The attending paramedic completes the CDAR on the Mobile Data Terminal (MDT).
  • The members, paramedic and/or EMT signs the CDAR on the MDT and sends the report immediately.
  • Any wasted/unused drugs will be witnessed by both Paramedic(s) and/or EMT.
  • “Wasted” is recorded on the PCR. The empty cartridge is discarded into a sharps container.
  • The off-going paramedic informs the on-coming paramedic of the change in Controlled Drug Count.
• In the event the MDT is unavailable or PA State EMS paper reports are in use, the on-duty paramedic will:
  • Obtain a paper CDAR from the company computer, “Office 365” EMSA&E/Supplies/Narcotics/SingleuseCDAR.
    • A paper CDAR will contain one space for each administration.
    • If more than one drug is administered, complete appropriate CDARs.
  • Secure the completed CDAR in the CONTROLLED DRUG RESTOCK LOCKER.
  • Immediately contact EMS A&E or leave a detailed message at (215) 906-8970.
  • EMS A&E will pick up the CDAR from the medic unit's firehouse.
  • Completed paper CDARs will not be sent via inter-departmental mail or left unsecured due to patient confidentiality.

Damaged, Lost/Stolen, Expired Drugs

• Damaged: The “on-duty” attending paramedic will complete an electronic memo to the Medical Director, forwarded to the Medical Director, EMS Deputy Chief (ES-1), and EMS A&E.
  • A copy is kept with the station files including the lot #, expiration date, and damage circumstances.
  • The personnel (Paramedic(s) and/or EMT) and company officer must sign it.
  • A single-use CDAR completed for each is sent to EMS A&E.
• Expired drugs should be removed by the “on-duty” paramedic from the “on board” box.
  • Placed in the CONTROLLED DRUG SECURITY LOCKER with all drugs from the box lot. Notification will be give EMS A&E.
  • The expired drugs are replaced with current drugs.
  • Single-use Complete CDAR and place in the Controlled Drug Security Locker for pick-up. Expired drugs are discarded under EMS A&E direction.
• Lost/Stolen:
  • The “on-duty” attending paramedic will immediately notify the Company Officer and EMS A&E.
  • The Company Officer will notify the Battalion Chief.
  • EMS A&E will secure a copy of the Police Report for the Medical Director’s Records.
  • Prepared single-use CDAR for each cartridge Lost/Stolen and secure for EMS A&E to pick-up.
• Suspicious Activity: Paramedic or Investigating Officer will notify the unit’s Company Officer. The Company Officer will notify the Battalion Chief and ES-3. A full investigation will be completed if the suspicion is valid by Battalion Chief or ES-3

Distribution

• EMS A&E delivers drugs to medic units and adjusts inventory levels on the log in the restock locker.
• EMS A&E keeps an electronic record of deliveries to any restock locker.
• Restocking from restock locker only occurs when four (4) or more are used from the on-board box.
  • Attending paramedic removes five (5) cartridges from the box in the restock locker following procedure 5.1.6
  • Secures them in the “on board” box.
  • A maximum of six (6) cartridges/vials of an individual drug will be carried in the security boxes.
• Individual cartridges cannot be stocked from the restock locker.
  • Only half box lots/5 carpujects/vials will be replenished.
• EMS A&E receives notification of administration, damage, loss, or theft from the MDT or paper CDAR.
  • Stores info in the director's records.
  • Delivers half box lots/five cartridges/vials to the unit's restock locker, unless notified otherwise, after 5 notifications.
• The on-duty attending paramedic who restocked drugs will notify EMS A&E at (215-906-8970) or EMS.A&[email protected] that drugs were removed.

Controlled Drug Daily Count Logs

• On the 1st and 16th of each month, the on-coming day shift paramedic will give the previously used log to the on-duty day shift Company Officer.
• Officer will scan and electronically submit the log to EMS A&E at [email protected].
• Email the log regardless of incomplete signatures.
• The log is filed and secured in the Medical Director’s Record.
• The Company Captain ensures all steps in section 5.7 are posted in the Company Officers office and followed.

Storage

• Each station with an ALS Unit will maintain a secured cabinet containing a secured metal locker for drug storage.
• Locker will be secured with one standard cam lock and one Electronic Identification Lock.
• Cabinet secured with one cam lock. All 3 locks must be locked.
• Standard cam locks use standard keys kept in a secured location in the Company Officer’s office. Electronic Identification Lock uses an Electronic Identification Key which members keep with them on duty.
• ALS "first-in" bag locks inside the medic unit, and the medic unit is locked when not being utilized, with all security precautions taken.
• Notify company officer, EMS field operations officer and EMS A&E if Medic unit loses keys.
• Controlled drugs stored at EMS A&E are kept in an approved controlled substance closet, in an approved controlled substance locker.
  • The closet will also contain the Medical Director's Controlled Drug Records.
  • Both are secured with an Electronic Identification Lock.
• No more than six cartridges or vials of one drug, and 30 auto-injector cartridges, on any ALS unit.

Mass Casualty Vehicle (MC-1 & MC-2)

• MC-1 & MC-2 will have 200+ Diazepam Auto-Injectors secured with an Electronic Identification Lock.
• The Company Officer at each shift will check the integrity of the Security Cabinet and document it in the officer's log. Notify EMS A&E if tampered with
• EMS A&E will inspect the auto-injectors monthly, follow procedures, and document results in the Electronic Inventory Log and Company Officers Log.

EMS Field Operations Officer Responsibilities

• Maintain storage of Controlled Substances, as stated in section 5.
• Maintain a max. of 15 cartridges of each drug and 50 Valium auto-injectors.
• Secure 5 of each drug and 15 Valium auto-injectors in their vehicle.
• Their daily log reflects these quantities/seal numbers.
• Follow the same drug maintenance procedures as ALS units. Notifies EMS immediately via receipted e-mail the date, time, and medic unit of all controlled drugs being issued off.
• Ensure the receiving medic unit documents increase on their log, and the decrease is documented on officers restock log and placed books are put into the log book.
• Every effort will be made to issue to medics unit restock cabinet in which signature entry and increase can be documented.
• Document any changes to controlled substances in company log book.
• All drugs issued to ALS Units, EMS Field Officer, MC and SERT. Records secured for 7 years.
• 10.3 A&E will have monthly checks within all ALS units, the lockers, and discrepancies recorded.
• Maintain data base of all electronic locks and keys within Philly emergency system.
• EMS operations complete semi-annual ALS unit audits.
• Scheduled by ES-1
  • Physical inspection of all onboard controlled drugs and WMD box.
  • Verification of the quantity of controlled drugs.
  • Verification of the integrity of security boxes, cabinets, restock Locker and all electronics.
• Appropriate entries recorded in controlled logs.
• Discover any discrepancies or evidence section 5.5 will be followed

Identification and Lock Maintenence

• If key is broken, commanding officer is to be informed and EMs is to be contact.
• Identification locks cleaned.
• New batteries, the members will get new ones.
• Will open compartment on the key, take old battery out, in 1 unit put in new battery

Reference

• Pennsylvania Statewide Advanced Life Support Protocols
• Philadelphia Fire Department EMS Operational Procedures (#7)
• Pharmaceutical Supply Policy
• Philadelphia Fire Department Forms Directive Philadelphia Fire Department Controlled Drug Daily Count Log
• Philadelphia Fire Department Forms Directive Philadelphia Fire Department Controlled Drug
• Failure to comply with procedure may result in department disciplinary action and/or loss of medical command.