friend here. You need to create an easy-to-follow trail of controlled
drug withdrawal from the PACU to the ORs each day, with documen-
tation of the when — and by whom (at least 2 licensed individuals).
To prevent diversion, you'll want to ensure a licensed individual wit-
nesses discards of partial portions of any controlled substance. Both
the discarder and witness should sign off at the time of discard. You
should also validate a count of the controlled drug cabinet at the
beginning and end of each day.
Many facilities keep their controlled substances in a safe as well as in
a PACU cabinet. Your safe will ultimately stave off diverters. First, you'll
need to ensure the safe is appropriately protected and that only a few (I
recommend no more than 3) authorized individuals have access to the
combination. Generally, this is the clinical director, PACU manager or
the "pharmacy nurse" and the medical director or the holder of the con-
trolled drug registration certificate. You'll also need to ensure the count
— a count that should always include expired drugs — within the safe
is validated and documented at least monthly or upon the withdrawal
of the medication for facility distribution. But keep in mind, some states
require more frequent validation/documentation.
When it comes to controlled substances, you should also make
every effort to minimize stocking various strengths of drugs. How?
Adjust the formulary as much as possible to minimize the calculations
of drugs on hand and the potential for error. Many medication errors,
especially those involving pediatric patients, are the result of a
provider or medication administrator using the wrong strength of a
controlled substance. These potentially catastrophic mistakes can be
greatly reduced (if not eliminated) through a bare minimum approach
to stocking various strengths of drugs. However, this can be difficult
— particularly with pediatrics and certain classes of drugs such as
anesthetic injectables. If multiple strengths of drugs are essential, dis-
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