Authority & Authorizing Mechanisms
As mentioned at the beginning of this practice guideline, other methods of gaining the authority to perform a controlled act are delegation and exceptions that exist within specific pieces of legislation, such as the RHPA and the Controlled Acts Regulation.
Delegation of Controlled Acts Not Authorized to Respiratory Therapists
RTs may, in some specific circumstances, receive delegation to perform a controlled act that is not authorized to Respiratory Therapists. This is permitted provided the specific task to be performed falls within the Scope of Practice of Respiratory Therapy. The controlled acts that RTs are permitted to accept delegation are as follows:
Communicating to the individual or his or her personal representative a
diagnosis identifying a disease or disorder as the cause of symptoms of
the individual in circumstances in which it is reasonably foreseeable that
the individual or his or her personal representative will rely on the
diagnosis. (RHPAs.27 (2)1)
- beyond the external ear canal,
- beyond the opening of the urethra,
- beyond the labia majora,
- beyond the anal verge,
- into an artificial opening into the body. (RHPA s.27 (2)6)
Applying or ordering the application of a form of energy prescribed by the regulations under the RHPA.* (RHPA s.27 (2)7)
* The Controlled Acts Regulation (Forms of Energy) outlines the specific tasks that fall under this controlled act.
Dispensing a drug as defined in the Drug and Pharmacies Regulation Act.* (RHPA s.27 (2)8)
* RTs are not permitted to receive delegation for the other portions of this controlled act, which are prescribing, selling, or compounding a drug and supervising the part of a pharmacy where such drugs are kept. More information on Dispensing is available in the CRTO’s Administering and Dispensing Medications PPG.
Allergy challenge testing of a kind in which a positive result of the test is a significant allergic response. (RHPA s.27 (2)13)
More information on the delegation process is available in the CRTO’s Delegation of Controlled Acts Professional Practice Guideline (PPG).
Exceptions within the RHPA
The RHPA contains certain exceptions that enable someone who is not otherwise authorized to perform a controlled act in specific circumstances, provided they have the requisite competence (knowledge, skills, and judgment) to perform the task safely. The exceptions outlined in the RHPA are as follows:
Rendering first aid or temporary assistance in an emergency; (RHPA s.29 (1)a)
Fulfilling the requirements to become a member of a health profession and the act is within the scope of practice of the profession and is done under the supervision or direction of a member of the profession; (RHPA s.29 (1)b)
Treating a person by prayer or spiritual means in accordance with the tenets of the religion of the person giving the treatment; (RHPA s.29 (1)c)
Treating a member of the person’s household and the act is a controlled act set out in paragraph 1, 5 or 6 of subsection 27 (2) (RHPA s.29 (1)d), which are:
- Communicating to the individual or his or her personal representative a diagnosis identifying a disease or disorder as the cause of symptoms of the individual in circumstances in which it is reasonably foreseeable that the individual or his or her personal representative will rely on the diagnosis. (RHPA s.27 (2)1)
- Administering a substance by injection or inhalation. (RHPA s.27 (2)5)
- Putting an instrument, hand or finger,
- beyond the external ear canal,
- beyond the point in the nasal passages where they normally narrow,
- beyond the larynx,
- beyond the opening of the urethra,
- beyond the labia majora,
- beyond the anal verge, or
- into an artificial opening into the body. (RHPA s.27 (2)6)
assisting a person with his or her routine activities of living and the act is a controlled act set out in paragraph 5 or 6 of subsection 27 (2) (RHPA s.29 (1)d), which are:
- Administering a substance by injection or inhalation. (RHPA s.27 (2)5)
- Putting an instrument, hand or finger,
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- beyond the external ear canal,
- beyond the point in the nasal passages where they normally narrow,
- beyond the larynx,
- beyond the opening of the urethra,
- beyond the labia majora,
- beyond the anal verge, or into an artificial opening into the body. (RHPA s.27 (2)6)
-
PLEASE NOTE:
Student RTs do not require delegation to perform controlled acts. They are permitted to perform controlled acts authorized to Respiratory Therapists via the exception in the RHPA provided:
- they are enrolled in a program to become a Respiratory Therapist, and only perform the authorized acts as part of their educational program;
- the authorized acts are within the Respiratory Therapy scope of practice; AND
- they perform these authorized acts under the supervision or direction of a Member of the profession.
Exemptions within the Controlled Acts Regulation
Tracheostomy Tube Changes
The authority for RTs to perform tracheostomy tube changes for an established stoma and for a fresh stoma is derived from the Controlled Acts Regulation (s.14).
Table 3: Procedures below the Dermis & Tracheostomy Tube Changes
| PROCEDURE | RRT | GRT* | PRT |
|---|---|---|---|
| Tracheostomy tubes change for a stoma that is more than 24 hours old. | ✓ | ✓ | ** |
| Tracheostomy tubes change for a stoma that is less than 24 hours old. | ✓ |
** PRTs are only able to perform tracheostomy tubes change for a stoma that is more than 24 hours old if explicitly permitted to do so by the terms and conditions of their certificate of registration, and for the purpose of gaining competence in that procedure and only if performed under the direct supervision of a regulated health professional who is authorized to perform the procedure.
PLEASE NOTE:
Due to the fact that tracheostomy tube changes are now listed as an exemption in the Controlled Acts regulation, respiratory therapists (RRTs, GRTs and PRTs) are no longer permitted to delegate tracheostomy tube changes.
The timelines regarding tracheostomy tube changes of > and < 24 hours refers to surgical tracheostomies, not Percutaneous Tracheostomies. When changing percutaneous tracheostomy tubes, RTs must ensure they are doing so in accordance with their organizational policy with respect to timelines.