Dispensing a Drug

Under the Naturopathy Act, 2007, a naturopath is authorized to perform the controlled act of “prescribing, dispensing, compounding or selling a drug designated in the regulations.”

The designated drugs are listed in table 4 of the General Regulation.  A naturopath may only dispense a drug in table 4, in accordance with any limitations outlined in the table.  

When dispensing a drug, the general requirements for performing a controlled act, as outlined on the About Controlled Acts page, do not apply.  Instead, Part II (Controlled Acts) of the General Regulation establishes the requirements a naturopath must meet to dispense a drug to a patient:
  • The naturopath can only dispense a drug to their own patient, or a patient of another ND in certain circumstances.
  • The drug can only be dispensed for therapeutic purposes.
  • The naturopath can only dispense the drug to a patient or their authorized representative, or a patient or authorized representative of a patient of another naturopath.
  • The naturopath must advise the patient or their authorized representative that the drug may be available at a pharmacy.
  • The naturopath must have sufficient knowledge, skill and judgment about the drug and the patient’s condition to dispense the drug.
  • The naturopath must ensure that the drug has been obtained and stored in accordance with all applicable laws.
  • The naturopath must ensure that the drug has not expired and will not expire before the date on which the patient is expected to take the last of the drug.
  • Where a limitation, route of administration or dosage is indicated in table 4, the naturopath can only prescribe the drug in accordance with those conditions.
  • The naturopath must ensure that the container in which the drug is dispensed (or, if there is not sufficient space, a paper attached to the container) contains the specified information.
  • The naturopath must retain a copy of the information specified to be on the container.

What is on a Container of a Dispensed Drug?


The General Regulation requires that a naturopath include certain information on the container of a drug to be dispensed, or on a paper attached to the container (if there is not sufficient room on the container).  This information includes:
  • Identification number, if applicable.
  • Member’s name and title.
  • Name, address and telephone number of the location from which the drug is dispensed.
  • Drug’s name, strength (where applicable) and, if available, manufacturer.
  • Quantity of the drug dispensed.
  • Date the drug is dispensed.
  • Expiry date of the drug, if applicable.
  • Name of the patient for whom the drug is dispensed.
  • Directions for use of the drug, including its dose, frequency, route of administration and any special instructions.

Dispensing a Drug to a Non-Patient


A naturopath may dispense a drug to a person who is not their patient only if:
  • The naturopath possesses the prescription for the drug at the time it is dispensed.
  • The prescriber is another naturopath;
  • The prescription contains all the information required under the Part II (Controlled Acts) of the General Regulation.
  • The naturopath retains a copy of the prescription in their records.

Additional Education and Training


A naturopath may only dispense a drug to a patient if they have met the Standard of Practice for Prescribing. That requires a member to successfully complete a College-approved course and an examination in Therapeutic Prescribing.  The College’s Naturopathic Doctor Registry includes information about whether a member has met this standard of practice.

Dispensing a Product that Does Not Require a Prescription


A naturopath may dispense a product that does not require a prescription (such as a natural health product) to their own patients or patients of other naturopaths (with a recommendation from another naturopath).  This is not covered by the General Regulation. However, naturopaths must comply with all of the applicable standards of practice of the profession, including, but not necessarily limited to:
  • Dispensing.
  • Recommending Non-scheduled Substances.
  • Conflict of Interest.
  • Fees and Billing.
  • Selling.

What Can or Cannot be Dispensed?


Substances on the Prescription Drug List or NAPRA Schedule 1 are drugs that require a prescription.  A naturopath can only dispense a drug that appears on these lists if it also appears on table 4 of the General Regulation.

Substances that do not appear on the Prescription Drug List, NAPRA Schedule 1 or table 4 are not drugs. In these cases, a naturopath may provide the product to their own patient, or a patient of another naturopath who has made a recommendation to the patient, in accordance with the standards of practice for Recommending Non-scheduled Substances.

Table 4


The following includes information in table 4 from the General Regulation.  Every precaution has been made to provide an accurate reproduction; in the case of a discrepancy, defer to the listing of table 4 in the regulation.  Explanatory notes describe how to apply the limitation; these are for information purposes and do not constitute advice from the College of Naturopaths of Ontario.

Insert table

 Drug  Limitations, routes of administration, dosages  Explanatory note
Colchicine
Must not be dispensed unless the drug is botanical colchicine, compounded from the corm of the colchicum autumanle.  This limitation requires that only the botanical version of colchicine that is compounded from the corm of colchicum autumnale is dispensed. 
Digitalis Purpurea and its glycosides  Only if dispensed in conjunction with monitoring of patient’s serum level by the member.  This drug always requires a prescription.  In addition, a ND must ensure that the patient’s blood serum levels are being monitored when dispensing this drug.
Estrogen (bioidentical)  Only if dispensed in topical or suppository form.  This always requires a prescription and may only be dispensed in a topical or suppository form. 
Folic Acid  Only if dispensed in oral dosage containing more than 1.0 mg of folic acid per dosage or, where the largest daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 1.0 mg of folic acid.  This is only a drug when dispensed in a dosage of more than 1 mg per dose or more than 1 mg of daily dose.  A ND may dispense at this level or higher where indicated and a prescription is provided.  Folic acid below 1 mg per dose or per daily dose is not a drug and does not require a prescription. 
L-Tryptophan  Only if dispensed for patient’s use in oral dosage form at a concentration of more than 220 mg per dosage unit or per daily dose.  Recommended daily dose must not exceed 12g and must be provided in 3 to 4 equally divided doses.  This is only a drug when it is dispensed in oral dosage at a concentration of more than 220 mg per dosage unit or per daily dose.  The daily dose must not exceed 12g and must be provided in the dosed identified. 
Levocarnitine and its salts  Only if dispensed for the treatment of primary or secondary levocarnitine deficiency.  This is only a drug when dispensed for the treatment of primary or secondary levocarnitine deficiency in which case a prescription is required. If recommended for any other condition, it is not a drug and a prescription is not required. 
Pancreatin  Only if dispensed in a dosage form that provides more than 20,000 USP units of lipase activity per dosage unit or for the treatment of pancreatic exocrine insufficiency.  This drug requires a prescription only when it is dispensed a form that provides more than 20,000 USP of lipase activity per dosage or at any dosage amount when dispensed for the treatment of pancreatic exocrine insufficiency. Lower dosages for other conditions do not require a prescription. 
Pancrelipase  Only if dispensed in a dosage form that provides more than 20,000 USP units of lipase activity per dosage unit or for the treatment of pancreatic exocrine insufficiency.  This drug requires a prescription only when it is dispensed at more than 20,000 USP of lipase per dose or when it is being dispensed for treatment of pancreatic exocrine insufficiency. Lower dosages of this substance used for other conditions are not drugs and may be dispensed at the discretion of the ND. 
Pilocarpine and its salts  Must not be dispensed unless, 1. the dispensed drug botanical pilocarpus compounded  from the leaves of pilocarpus microphyllus, 2. the member monitors his or her patient’s drug levels during treatment with the drug and, 3. the drug is never dispensed to treat a patient with glaucoma.  This drug may only be dispensed in its botanical form as identified and requires that the naturopath monitor the patient’s levels during treatment.  The drug cannot be dispensed to treat a patient with glaucoma. 
Podophyllotoxin  Must not be dispensed unless, 1. the dispensed drug is botanical podophyllotoxin compounded from podophyllum peltatum and, 2. the drug is never dispensed to treat a patient with rheumatoid arthritis.  This drug may only be dispensed in its botanical form and cannot be dispensed to a patient with rheumatoid arthritis. 
Progesterone (bioidentical form)  Only if dispensed in a topical or suppository form.  Progesterone requires a prescription and may only be dispensed in topical or suppository form. 
Rauwolfia  No limitation, etc., specified.   
Thyroid  No limitation, etc., specified.   
Vitamin A
Only if dispensed in oral dosage containing more than 10,000 International Units of Vitamin A per dosage or, where the largest daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 10,000 International Units of Vitamin A.  Vitamin A requires a prescription only when it is dispensed for oral use at more than 10,000 IU per dose or where the largest daily does would be more than 10,000 IU.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Vitamin D
Only if dispensed in oral dosage containing more than 1,000 International Units of Vitamin D per dosage or, where the largest recommended daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 1,000 International Units of Vitamin D.  Vitamin D requires a prescription only when it is dispensed for oral use at more than 1,000 IU per dose or where the largest daily does would be more than 1,000 IU.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Vitamin K1
Only if dispensed in oral dosage when the maximum daily dose is more than 0.120 mg.  Vitamin K1 requires a prescription only when it is dispensed for oral use at more that .120 mg per day.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Vitamin K2  Only if dispensed in oral dosage when the maximum daily dose is more than 0.120 mg.  Vitamin K2 requires a prescription only when it is dispensed for oral use at more that .120 mg per day.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Yohimbine and its salts  Must not be dispensed unless the dispensed drug is botanical yohimbine compounded from the bark of pausinystalia yohimbine.  This is always a drug and always requires a prescription.  It may only be dispensed in its botanical form as identified. 

For a copy of the General Regulation, see the Resources section of the College’s website.