Change of Location

Change of Location ("Relocation")

What is a Change of Location?

• Occurs when the address and physical location of the pharmacy changes.
• The pharmacy licence is cancelled when the location of the pharmacy changes.
• The new location cannot operate or open to the public until the College issues a new licence.
• The authorized representative must submit the application at least 30 days prior to the proposed effective date.

How do I apply for a Change of Location?

1. Submit a Change of Location Application (Phase 1)
   An authorized representative must submit the following Phase 1 application requirements to: [email protected]:
   • Application Form & Applications Fee:
     • Form 8F: Application for Change of Location 
        
   • Pharmacy Diagram:
     • The diagram must be professionally drawn to scale, include measurements, and all requirements must be labelled. Only digital copies will be accepted.
     • Use the Diagram Checklist to ensure all requirements are included in the diagram.
        
   • Business Licence (new location)*:
     • ​The business licence must include the operating name of the pharmacy, the name of the direct owner, the new pharmacy address, and the licence period must be valid and current.

     • If a business licence is not required for your pharmacy, submit written correspondence from the jurisdiction that they do not issue business licences.

   *If available at the time the change application is submitted. Must be submitted before the effective date of change.

   Allow up to 7 days for processing.

   Once all Phase 1 requirements have been met, the authorized representative will be notified via email that Phase 1 is complete. Health Insurance BC (HIBC) of the Ministry of Health will be notified.

2. Build the Pharmacy in the New Location

   Build the new pharmacy as indicated in the diagram approved by the College.

   It is the responsibility of the pharmacy owner to read and understand what the physical requirements are before building the pharmacy. Refer to Appendix B in the Pharmacy Licensure Guide for further information.

   Notify the College at [email protected] if there are any changes to the approved layout, or if the proposed effective date changes. If the College is not notified, this may delay the opening date of the pharmacy.

   Note: the new location cannot open to the public until a pharmacy licence has been issued to the new location. If the new location is opened before a new licence is issued by the College, the pharmacy will be operating unlawfully without a pharmacy licence.

3. Submit Pre-Opening Documents (Phase 2)

   Submit the following documents to [email protected] no later than 14 days prior to the proposed licensure date. Submission 30 days prior to the proposed licensure date is recommended to allow sufficient time to review and address any non-compliant items:

   • Pre-Opening Inspection Report:
     • Choose the appropriate report based on your licence type:
       • Community: Form 10A – Pre-Opening Inspection Report - Community
       • Hospital/Satellite: Form 10C – Pre-Opening Inspection Report – Hospital/Hospital Pharmacy Satellite
          
   • Digital Evidence:
     • Use the PowerPoint template to submit digital evidence (photos/video). Choose the appropriate template based on your licence type:
       • Community: Digital Evidence Submission Form – Community Pharmacy
       • Hospital/Satellite: Digital Evidence Submission Form – Hospital/Hospital Pharmacy Satellite
          

     Digital evidence:

     • Must provide sufficient context for College inspector to determine whether the physical requirements have been met,
     • Must be consistent with the approved pharmacy diagram,
     • Must have been recently produced at the new pharmacy**,
     • Must not have been previously submitted for the same location or any other location.

     **If you cannot move equipment to the new location until the effective date, see the More Questions Section.

   • Business Licence (if not submitted in Phase 1):
     • The business licence of the new location must include the name of the pharmacy, name of the direct owner, the new pharmacy address, and the licence period must be valid and current.
        

   Allow up to 14 days for processing.*

   *Note that an additional 14 days may be required if your pharmacy provides sterile compounding

4. Pre-Opening Inspection(s)

   An on-site pre-opening inspection is generally not required for community pharmacies if the digital evidence provided with the Pre-Opening Inspection Report demonstrates that the pharmacy has met all the physical requirements.

   Onsite inspections may be required for hospital pharmacies. If an on-site inspection is required (for either a community or hospital pharmacy), an email will be sent to the authorized representative(s) to schedule an inspection within 14 days of the proposed licensure date. A College inspector will conduct the inspection at the pharmacy using the Pre-Opening Inspection Report submitted in Step 3.

   Note that a follow-up visit will be required if the pre-opening requirements are not met during the first inspection. This may delay the opening of the new location.

5. Prepare for Pharmacy Closure of the Current Location
   The manager must complete the following prior to the closure of the previous location in accordance with section 18(2)(ee) of the Pharmacy Operations and Drug Scheduling Act (PODSA) Bylaws:
   • Provide for the safe and secure transfer and appropriate storage of all Schedule I, II, and III drugs and controlled drug substances to the new location,
   • Advise the registrar in writing of the disposition of all drugs and prescription records at the time of a closure (or confirmation* that all drugs, medical devices and prescriptions records have been transferred from the previous location to the new location),
   • Provide the registrar with a copy of the return invoice and any other documentation sent to Health Canada in respect of the destruction of all controlled drug substances at the previous location prior to the move (or confirmation* that narcotic counts and reconciliations and other process in PPP-65 have been completed),
   • Arrange for the secure transfer and continuing availability of the prescription records at the new location, or to a storage facility that is monitored and secured from unauthorized access, and
   • Remove all signs and advertisements from the previous location when closed*.
      

   *The manager is responsible for completing Part B of the PODSA Form 8F: Application for Change of Location to confirm that all the above duties have been completed at the previous location. Submit the completed form to the Licensure Department within 2 weeks of closure of the previous location. Include digital evidence to confirm compliance that all signs and advertisements from the previous location have been removed.

6. Pharmacy Licence Issued
   Once all licensure requirements are met, the authorized representative(s) will be notified via email that the application is complete. A new pharmacy licence with the new address will be issued to the direct owner on the effective date (or the next business day). The new licence will be available to download in eServices within 24 hours.

   Should any requirements be missing on the effective date, the new licence will instead be issued on the date the College approves the application.

Definitions

Direct Owner(s) – As defined in PODSA. Most pharmacies in BC have a corporation as the direct owner.

Authorized Representative(s) – the director(s) of the Direct Owner.

Physical requirements – items that must be included within the pharmacy or minimum square footage requirements. Examples include shelving, a time delay safe, minimum dispensary area, minimum counter area, etc. Refer to the documents below for more information:

• Diagram Checklist (community or hospital) and
• Appendix B (community) or Appendix C (hospital) for more information.

More Questions?

What if I cannot move the equipment from the current location to the new location until the effective date?

If equipment (i.e. safe, computers, etc.), from the current location cannot be moved to the new location until the date of relocation, submit photos of the equipment at the current location and photos of where the equipment will be placed at the new location. If any photos cannot be taken at the site, explain in the inspection report. Review Appendix B for recommended content in digital evidence before producing digital evidence. 

What are some tips for producing digital evidence?

Digital evidence must be provided to determine if the physical requirements are met. Photos should be taken from different angles and distances to provide full context. For example, photos of the refrigerator should include a photo of inside the fridge, and a photo from 5-10 feet away. This allows the College inspector to confirm that the equipment is correct and that the location of the equipment matches the location on the approved diagram. The PowerPoint template will provide further guidance regarding what to include in your photos.

Photos must be recently produced and may not have been previously submitted for the same location or any other location. Review Appendix B for recommended content in digital evidence before producing digital evidence.

Do I have to submit a separate application if the pharmacy manager is changing? What about other types of changes?

Yes, if other changes occur at the same time as the Change of Location, separate application forms will be required. For example, a Change of Manager, or Change of Operating Name or External Signage require separate application forms. See the Multiple Changes section for more information.

What if the date of relocation changes?

Update the College as soon as possible if there are any changes to the effective date or any other details of the application to avoid disruption to pharmacy services. 

Will there be any interruption to pharmacy services with this type of change?

Pursuant to section 6(1)(b) of the Pharmacy Operations and Drug Scheduling Act, a pharmacy licence is cancelled when the location of a pharmacy changes. This means that a new pharmacy licence is issued to the Direct Owner for the new location on the effective date. To ensure there are no disruptions to pharmacy services, a Change of Location application should be submitted no later than 30 days prior to the effective date. Note that there cannot be a gap between the licence dates of the previous location and the new location.

Can I submit the business licence after the effective date?

No, the business licence for the new location is required prior to the effective date . Contact the College if you have cannot obtain an updated business licence by the relocation date.

Who is the authorized representative(s) of my pharmacy?

The authorized representative(s) is the director(s) of the direct owner (the corporation/hospital/association/etc. that owns the pharmacy). Officers and shareholders of the direct owner, and any directors, officers, and shareholders of parent corporations are not considered authorized representatives. Pharmacy managers are also not considered authorized representatives unless they are also directors of the direct owner. The authorized representative(s) is the only person who has signing authority on pharmacy applications. More information about pharmacy ownership can be found in the Pharmacy Licensure Guide.

What is the best way to submit my application?

The application form and all applicable requirements should be sent via email to [email protected]. Original physical documents do not need to be sent via mail (this includes certified documents and pharmacy diagrams). If possible, please submit all documents as PDF files.