Figure 1. Sample Language for a Hospital Policy on Anesthesia Medication Security

 

Pharmaceutical Services

 

Policies and Procedures — Security of Anesthesia Medications

Preamble
Anesthesiologists use medications both to sedate or anesthetize patients and to relieve pain, most commonly with controlled substances from DEA Schedules II, III and IV. Anesthesiologists also administer medications to manage the neuromuscular system, cardiovascular system and pulmonary system: drugs used for these purposes must be immediately available at all times in any active anesthetizing location. Limiting access to these resuscitation drugs even for a few seconds could seriously compromise patient safety. Any protocols or procedures designed to prevent tampering with or diversion of anesthesia medications must permit immediate access to resuscitation drugs, consistent with federal regulations (42 C.F.R. §462.25(b) (2)) that were revised effective January 26, 2007.

Purpose
This policy provides that medications shall be stored securely to protect the safety of patients and the public health while allowing appropriate access by authorized personnel.

Pharmacy Policies
Pharmacy is ultimately responsible for the storage, dispensing and inventory control of all perioperative medications.

Coordination with Anesthesiology Policies
The Department of Anesthesiology is responsible for the safety of patients under its care. Pharmacy and Anesthesiology will together ensure that medication security policies proposed by either service (1) maintain patient safety, (2) do not conflict with each other and (3) comply with federal and state regulations.

Controlled and Noncontrolled Medications

Drugs used in anesthesiology are divided into controlled (DEA Schedules II, III and IV) and noncontrolled substances. (For the purpose of this policy on medication security, ephedrine and propofol are treated like controlled substances.)


Procedures and Definitions

1. All anesthesia medications will be kept in a secure area.
2. Controlled substances must be locked within a secure area.

“Secure Area”
A Suite or Unit is secure when it is locked, or when the Suite/Unit is in active use and access and egress is monitored and restricted to authorized personnel. Procedures to ensure that only authorized personnel (see below) and patients have access to secure areas are described in the Facilities Policies and Procedures.

A. All active operating room (O.R.) suites are considered secure areas when they are staffed and being used to provide patient care, as long as they are accessible only to authorized personnel (see below). When the entire O.R. Suite is closed and not staffed, it may be considered secure if it is locked.

B. The Procedure Units listed below are considered secure areas during regular hours when they are staffed and being used to provide patient care, as long as they are accessible only to authorized personnel. When the Units are closed, they will be considered secure only if they are locked.

• Postanesthesia Care Unit

• Labor and Delivery Unit

• Surgical Intensive Care Unit

• Radiology

• Interventional Radiology

• Cardiac Catheterization Lab

• Endoscopy Unit

Security of NONCONTROLLED Medications
When the O.R. Suite or Procedure Unit is in use and access is restricted, NONCONTROLLED anesthesia medications may be left in or on top of unlocked anesthesia carts or anesthesia machines immediately prior to, during and immediately following surgical cases in an O.R. so long as there are authorized operating room personnel in the O.R. suite.

If access to any Unit is not restricted to authorized personnel, medications must be kept in a cart, cabinet or individual procedure room to which access is controlled or which is locked if not in active use (i.e., awaiting a scheduled or emergency case, being used for a case, or during turnover or cleanup from a case).

The O.R. Suite is locked at all times when it is not in use. Anesthesia carts and/or individual O.R.s in a locked O.R. Suite may themselves be locked but are not required to be locked.

When the individual O.R. or procedure room in which medications are kept is not in active use, it is not considered secure even though the O.R. suite or the Procedural Unit is actively staffed and access restricted. Noncontrolled medications must be alternatively 1) locked in the anesthesia cart in the unused room, 2) secured by locking the individual room in which they are located or 3) moved to a secure room within the O.R. Suite or Procedure Unit.

Security of CONTROLLED Substances

CONTROLLED Substances are kept under lock and key in all locations at all times. The sole exception is for controlled substances under the direct control of the anesthesiologist or other clinician involved in the immediate administration of the drug.

“Authorized Personnel”

The following are considered “authorized personnel”:

• Members of the medical, clinical (including residents and medical students, anesthesia and O.R. nurses, anesthesia and O.R. technicians and student nurses) and pharmacy staff with patient care responsibilities in the secure area;

• Housekeeping, engineering and security staff and orderlies when needed to perform their assigned duties;

• Visitors (including technical consultants and drug and equipment manufacturer representatives) when under the supervision or in the presence of a medical or clinical staff member;

• Government and accreditation organization representatives when they are performing their regulatory responsibilities.