Published in the December 2008 Vermont Board of Pharmacy Newsletter
As there has been some confusion regarding emergency drug kits in long-term care facilities, the Board wishes to clarify certain issues pertaining to the physical, labeling, and restocking requirements of such kits.
- Emergency kits should contain only those drugs deemed necessary to meet the immediate therapeutic needs of patients and are not available from any other authorized source in sufficient time to prevent risk of harm to patients.
- All drugs are properly labeled.
- All emergency kit drugs are equipped with a breakable seal, are sealed by a pharmacist, and are secure from unauthorized personnel.
- The emergency kits shall be stored in secured areas to prevent unauthorized access and to ensure a proper environment for preservation of drugs in the kits.
- The exterior of each emergency kit shall be labeled so as to clearly indicate that it is an emergency drug kit and that it is for use in emergencies only.
- The label on the emergency kit shall contain a listing of the drugs contained in the kit, including the name, strength, quantity, and earliest expiration date of the contents. It shall also include the name, address, and telephone number(s) of the supplying pharmacist.
- Drugs shall be removed from emergency kits pursuant to a valid prescription drug order only.
- Whenever an emergency kit is opened, the supplying pharmacist shall be notified within 24 hours and the pharmacist shall restock and reseal the kit within a reasonable time so as to prevent risk of harm to patients.
- The expiration date of an emergency kit shall be the earliest date of expiration of any drug supplied in the kit. Upon the occurrence of the expiration date, the supplying pharmacist shall replace the expired drug.
It is the Board’s intent that the last person to inspect and seal an emergency drug kit must be a pharmacist. This task may not be delegated to a technician or a nurse. To further clarify this point, if the emergency drug kit is to be exchanged in its entirety and leaves the pharmacy after being sealed by a pharmacist, the intent of the rules has been met. If the drugs in the emergency drug kit are individually sealed in tamper-proof containers, such as plastic cubes that are sealed either by plastic locks or tamper-evident tape, then individual drugs may be “swapped” out of kits as long as they are properly labeled and it is done by authorized personnel. If an automated dispensing system is utilized in the long-term care facility, only those systems that are designed to prevent improper placement of medications, such as the Pyxis CUBIE system, may be utilized. Any emergency drug kit system, either conventional or auto¬mated, that requires a nurse or technician at the long-term care facility to replenish the kit with a drug item that has not been pre-sealed in an individual container by a pharmacist, is prohibited. This requirement is to prevent loose unit-dosed medications from being placed in the wrong locations in an emergency drug kit.