November 19, 2019
Notice to the Profession
Since February 22, 2018, all Fentanyl Certificates of Analyst that the Public Prosecution Service of Canada has received from Health Canada's Drug Analysis Service have stated that they analysed the substance to be "Fentanyl or an isomer thereof." The Controlled Drugs and Substances Act (CDSA) Schedule I, item 16, does not list "isomers" as one of the included substances of Fentanyl. However, we have recently been advised by Health Canada that Fentanyl, as listed at subitem 16(5) in Schedule I of the CDSA, and Acetylfentanyl, not listed but captured under item 16 in Schedule I of the CDSA, currently have no known isomers that could have been seized and analyzed by Health Canada. As a result, for all Certificates of Analysis that say "fentanyl, or its isomers", the substance referred to was Fentanyl, and for "Acetylfentnayl, or its isomers", the substance referred to was Acetylfentanyl.
For copy of the Health Canada notice or any further information about this subject, please contact Health Canada at: https://www.canada.ca/en/health-canada/services/health-concerns/controlled-substances-precursor-chemicals/drug-analysis-service.html or your local PPSC office.
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