Ontario · Ontario College of Pharmacists

How to respond to an OCP complaint

The College must act on every complaint, and the ICRC decides your case on paper — you are not permitted to attend its meeting. Your written response is, in most cases, the only submission you will ever make.

Who regulates you, and what “the College” covers

Pharmacists and pharmacy technicians in Ontario are regulated by the Ontario College of Pharmacists (OCP) under the Regulated Health Professions Act, 1991 (RHPA), the Health Professions Procedural Code in Schedule 2, the Pharmacy Act, 1991, and the Drug and Pharmacies Regulation Act. The OCP’s reach is broader than the individual: it also accredits and oversees pharmacies as premises, so a concern can attach to how a pharmacy operates, not only to what one registrant did. Its mandate is public protection — ensuring registrants practise in accordance with the Pharmacy Act, the standards of practice and the Code of Ethics.

Report or complaint — the two front doors

The College offers the public two routes. Someone can report information, in which case they generally are not engaged in the process and are not told the outcome; or they can file a complaint, in which case they are involved and are notified of the result. Either way, the information may reach you as the registrant. And a formal complaint engages section 25(1): the College must investigate and act on it, subject only to very limited exceptions, however trivial you consider it.

The 14 days, the 30 days, and a document duty

The College must give you a copy of the complaint within 14 days, and you normally have 30 days to respond in writing. If you need longer, ask the assigned investigator before the deadline. Alongside the clock is a duty that is specific and easy to breach without thinking: the OCP requires you not to destroy or remove any pharmacy documents for the duration of the matter. Preserve dispensing records, the patient profile, hard copies, and the audit trail exactly as they stand.

Why the written response carries the weight

There is no hearing, meeting or phone conference at which you get to tell the ICRC what happened. Pharmacists and complainants are not permitted to attend the ICRC meeting; the committee reviews paper. Your written response is, in most cases, the one and only chance to persuade the College to take no action or to make the least restrictive order. A strong response addresses not only the merits of each concern but the options open to the ICRC and how similar matters have been decided before.

Everything you write is shown to the complainant

Your response is provided to the complainant, who may submit a reply; if the reply raises something new, the OCP has discretion to send it back to you for further comment. Two practical consequences follow. First, write on the assumption that the patient will read every word — irritation or a dismissive characterisation does not stay private. Second, there is one carve-out worth knowing: if the College gives you copies of your prior decisions to comment on, those comments must be submitted separately from your response, or they too go to the complainant.

What to enclose

Submit the finalised response to the investigator with the pharmacy records the OCP has requested. Typically that means:

• The patient profile and dispensing history relevant to the concern.
• The original prescription, any transfer records, and the audit trail for the fill in question.
• Records of patient counselling and any communication with the patient or prescriber.
• For a pharmacy-operations concern, the relevant policy, the technician-checking record, and staffing detail.

What the ICRC can do

A panel of the ICRC — pharmacist and public members — reviews the file and decides on risk. Where it sees no or minimal risk it will take no further action or give written advice and recommendations, neither of which is noted on the public register. Otherwise it may require you to attend for an oral caution, order a Specified Continuing Education or Remediation Programme (SCERP), have you sign an undertaking to restrict your practice, refer you for a health inquiry, or — most seriously — refer specified allegations to the Discipline Committee. A discipline referral is posted on the register immediately and brings a Notice of Hearing.

ADR, withdrawal, and appeals

Low-risk matters may be diverted early to the College’s Alternative Dispute Resolution process, which proceeds only if both you and the complainant consent and is facilitated by an OCP appointee. Note too that a complainant cannot simply make the matter disappear: a withdrawal request is decided by the Registrar, who may refuse it and complete the investigation if that is in the public interest. Finally, both you and the complainant may ask the Health Professions Appeal and Review Board (HPARB) to review an ICRC complaint decision for reasonableness and adequacy of investigation — but a referral to Discipline cannot be taken to HPARB.

For what the investigation itself involves, read what happens during an OCP investigation. For the corrective record that shapes the outcome, read remediation and reflection for Ontario pharmacists.

This guide describes the process of the Ontario College of Pharmacists. It is general information about how the regulator works and is not legal advice. Every case turns on its own facts. Before you respond to the College, notify your professional liability insurer (professional liability insurance is a registration requirement for Ontario pharmacists) and consider a lawyer experienced in RHPA regulatory matters and OCP defence. Completing a course does not resolve a College matter and does not guarantee any outcome. Last updated July 14, 2026.