Controlled drugs: Veterinary medicines
Controlled drugs and the Misuse of Drugs Regulations as they relate to veterinary medicines.
Veterinary surgeons, pharmacists and anyone involved in prescribing, supplying, keeping records of, storing, disposing or destroying veterinary medicines that contain controlled drugs (CDs) must comply with the law on the misuse of drugs and veterinary medicines.
This guidance clarifies what these legal requirements are for veterinary surgeons, pharmacists and others on specific veterinary issues where it may not be easy to find this in the misuse of drugs legislation.
All CDs are listed in Schedules 1 to 5 of the Misuse of Drugs Regulations 2001. The schedules relate to the drugs’ therapeutic usefulness, the need for legitimate access and the potential harm caused by their misuse. Schedule 1 CDs are subject to the most restrictions; Schedule 5 the fewest.
Veterinary medicines only contain CDs in Schedules 2, 3, 4 and 5.
Schedule 2 CDs have therapeutic value but are highly addictive. Their use is strictly controlled, including special prescription, storage, destruction and record keeping requirements.
Schedule 3 includes barbiturates and some benzodiazepines. While less rigorously controlled than drugs in Schedule 2, they are also subject to special prescription writing requirements. Some are also subject to special storage requirements.
Schedule 4 is divided into 2 parts; Part 1 contains most of the benzodiazepines and Part 2 contains the anabolic and androgenic steroids. There are no additional special controls on Schedule 4 drugs.
Schedule 5 includes preparations containing substances such as codeine or morphine, which are used in such low strength that they present little or no risk of misuse. There are no additional special controls on Schedule 5 drugs.
For any CD listed in Schedule 2 or 3:
a written prescription must be signed by the person issuing it
it may be hand-written, typed in a computerised form or computer generated
A written prescription for a CD listed in Schedules 2, 3 and 4 is valid for 28 days only.
For all CDs, as a veterinary surgeon, you should consider prescribing only 28 days’ worth of treatment unless in situations of long term ongoing medication (e.g. when treating epilepsy in dogs).
If you prescribe more than 28 days worth of treatment you must be sure the owner is competent to use the medicine safely.
You can only dispense a prescription for a CD in Schedule 2 or 3 once and only within the 28 days of the validity of the prescription. Single prescriptions with multiple dispenses (i.e. repeatable prescriptions) are not allowed for CDs in Schedules 2 and 3.
Prescriptions for CDs in all Schedules can legally be issued without a consultation, providing the animal is under the care of the veterinary surgeon and a clinical assessment has been carried out.
You should, however, consider reviewing a patient before repeat prescribing of a Schedule 2 or 3 drug. This is a clinical decision not a legal requirement.
You should only post date prescriptions for Schedules 2 and 3 CDs in specific and exceptional circumstances (e.g if there is to be a delay in the start of the 28 day period due to a bank holiday).
However, the decision whether to prescribe in this manner is a clinical decision for the veterinary surgeon who must consider the risk of diversion of the CD. The veterinary surgeon has full responsibility for the decision.
Repeat prescriptions for Schedule 4 and 5 CDs are permitted. But the repeats must be dispensed within the period of validity of the prescription (28 days or six months).
If the prescription is not repeatable you should consider stating this on the prescription to avoid any misuse of the prescription. If the prescription has a section that states number of repeats you should consider crossing this out if the prescription is not to be repeated to avoid any misuse of the prescription.
The first instalment must be dispensed within the 28 day validity period.
Further installments do not need to be dispensed during the 28 day validity for Schedule 2, 3 and 4 CDs.
Supply of a CD
A veterinary surgeon may supply a CD they have prescribed or another veterinary surgeon or a pharmacist may supply a CD against a veterinary surgeon’s written prescription. Veterinary nurses are only legally permitted to possess or supply Schedule 2 CDs under the supervision of a veterinary surgeon.
You must, at the time of supply, mark on the prescription the date when the drug is supplied and retain the prescription on the premises from which the drug was supplied for at least 5 years.
If you’d like more information on applications for a CD see the Apply for a veterinary medicine wholesale dealer’s authorisation (WDA) page.
You should consider if you require a signed requisition for a CD specified in Schedule 4 or 5 to help you in complying with the law on wholesale supply.
As a veterinary surgeon you should consider keeping a copy of a CD requisition to improve the audit trail of CDs received to help you in complying with the law on wholesale supply.
For more information on applications for CD wholesale dealers’ licenses see the Controlled drugs: licences, fees and returns page.
Supply against a prescription via the internet
Schedule 2 and 3 CDs must not be supplied unless the original prescription has been received first.
You should consider confirming the receipt of the drug by requiring a signature at the time of delivery.
If a Schedule 2 drug is being delivered via a courier it should be received and signed for by the person specified on the prescription.
Any person who purchases or supplies any product containing a CD specified in Schedule 2 must maintain a Controlled Drugs Register (CDR). The prescribing veterinary surgeon may delegate the task of completing the CDR. However, they remain responsible for supplying the CD.
The CDR must:
- be either a computerised system or a bound book (which does not include any form of loose leaf register or card index)
- be separated into each class of drug
- have a separate page for each strength and form of that drug at the top of each page
- have the entries in chronological order and made on the day of the transaction or, if not reasonably practical, the next day
- have the entries made in ink or in a computerised form in which every entry can be audited
- not have cancellations, obliterations or alterations
- ensure any corrections are made by a signed and dated entry in the margin or at the bottom of the page
- be kept at the premises to which it relates (e.g separate registers for each set of premises) and be available for inspection at any time
- not be used for any other purpose
- be kept for a minimum of two years after the date of the last entry
The CDR must record for all CD purchased and supplied:
- date supply received
- name and address of supplier (e.g wholesaler, pharmacy)
- quantity received
The CDR must record for all CD supplied (including by way of administration)
- date supplied
- name and address of person or firm supplied
- details of the authority to possess (prescriber or licence holder’s details)
- quantity supplied
- person collecting a Schedule 2 CD (animal owner or animal owner’s representative, or healthcare professional) and if a healthcare professional, their name and address
- whether proof of identity was requested of animal owner or animal owner’s representative (yes or no)
- whether proof of identity of person collecting was provided (yes or no)
You should consider when keeping records whether to include any relevant additional information in the CDR, such as running balances and the veterinary surgeon’s name and RCVS number.
Pharmaceutical companies try to ensure that every bottle of medicine is precisely filled but some small variability may occur. This may result in discrepancies regarding the amount of CD used when taking into consideration the volume remaining in the container.
As a veterinary surgeon you should consider recording the total use of the product even if the reconciliation of the quantity used exceeds the nominal volume on the product stated on the label. This will help to ensure accurate record keeping of the use of the CD.
Product literature and specific product characteristics
Veterinary medicines containing CDs in Schedule 2 or 3 must be clearly identified with CD, preferably in a black triangle, and the relevant Schedule detailed on the product label, outer packaging and product leaflet.
As a veterinary surgeon, pharmacist or wholesale dealer you must ensure for the following CDs that are under your control are kept in a locked container which is constructed and maintained to prevent unauthorised access to the drugs and can only be opened by a veterinary surgeon, pharmacist, wholesaler or other persons you authorise:
- all CDs in Schedule 2 (with the exception of Quinalbarbitone)
- CDs in Schedule 3 containing Buprenorphine, Diethylpropion, Flunitrazepam and Temazepam
There should be no indication on the outside of the container that CDs are kept in the container. The room housing this container should be lockable and tidy to avoid drugs being misplaced. Its keys should not be kept with keys to other parts of the building. The room should not normally be accessible to clients.
However, if clients do have to enter the area, you should consider continuously supervising them until they leave the area.
For further information on storage requirements.
A list of authorised veterinary medicines containing a CD. The list indicates which medicines have special storage requirements.
You should consider keeping CDs in a separate container from other medicines.
You should consider for other drugs that are liable for misuse locking them in a container and recording their use in an informal register.
If a veterinary surgeon requires a supply of Schedule 2 or 3 drugs (excluding drugs listed in Schedule 1 of the Misuse of Drugs (Safe Custody) Regulations) for call out visits, the CDs should be transported in a locked glove compartment or in a lockable bag, box or case which should be kept locked when not in use. If such a bag, box or case is locked, it is considered a suitable receptacle for storing CDs. Simply being placed in a locked car is not suitable.
You should consider making sure the locked bag is not left unattended in a vehicle for any length of time. This does not apply to locked containers that are fixed within the boot of the car.
Veterinary surgeons are responsible for the receipt and supply of CDs from their own bag and must maintain a separate CDR.
Return and disposal requirements
Return of medicines that are used or part-used
As the prescribing veterinary surgeon you should consider making every effort to recover and destroy any remaining product if the animal dies before completing a treatment.
Any CD prescribed for and dispensed for an animal may be returned to a veterinary surgery or pharmacy unused or part-used in order to be destroyed. Any returned CDs should not be re-used and should be destroyed.
The requirements to witness and record the destruction of CDs set out below do not apply to returned CDs. However, you should consider making a record of any CD that is returned and having the destruction witnessed by another member of staff and signed against. This can be recorded in a separate book or sheets designed for that purpose.
Returned CDs should be destroyed as soon as possible. If this is not possible, the CD must be clearly labelled as a return, and stored securely in compliance with the storage requirements but kept apart from normal CD stock to avoid potential dispensing errors or re-use.
Returned CDs must not be entered into the CDR.
Destruction and disposal
Schedule 2 CDs must be destroyed in the presence of, and as instructed by, any of the following:
- an Inspector appointed under the VMR
- a veterinary surgeon independent of a practice where the destruction takes place (including those who have no personal, professional or financial interest in the veterinary practice where the drug is being destroyed but excluding temporary staff and family members)
- a person legally authorised to witness the destruction of CD such as a Police CD Liaison Officer (CDLO)
Conditions that apply to independent witnesses:
- a veterinary surgeon acting as an independent witness should not accept or demand any form of payment, beyond that reasonable to cover transportation costs, for witnessing the destruction of a CD
- if the witness is an independent veterinary surgeon, they should record their RCVS number and confirm their independence in writing in the CD register
The above also applies to schedules 3 and 4 CD that have been prepared extemporaneously for use under the prescribing Cascade.
A record must be made of the date of destruction and the quantity destroyed which the witness must sign.
You should also record the following information:
- name of the CD, form, strength and quantity
- date it was destroyed
- the signature of the witness and the professional destroying the drug
CDs should be rendered irretrievable before disposal, e.g by using a denaturing kit. These are plastic boxes containing absorbent material which can be passed on to an authorised waste contractor. Alternatively, an injectable solution may be placed into sawdust or cat litter and tablets may be crushed and mixed with soapy water. For further advice on disposing veterinary medicines.
Disposal of waste product
The legal requirements to witness the destruction of Schedule 2 CDs apply to stock. This refers to CDs that have not been issued or dispensed to a patient. However, any leftover medicines, for example liquids, which are still required for use is considered as stock. A witness is required if these are to be destroyed on expiry or for other reasons.
Left over medicines are generally considered waste and not stock if they are unusable.
Any medicine left over in an ampoule or vial which is considered unusable is considered waste product. There is no legal requirement to have the disposal of waste product witnessed.
Controlled Drug Liaison Officer (CDLO) or a Single Point of Contact (SPOC)
Most UK police forces have a CDLO or SPOC who can advise veterinary practices in their area on:
- safe storage
- suspicious activity
- internal thefts
- forged or stolen prescriptions
- current crime trends
- demands for drugs on the streets
A list of CDLOs and SPOCs is available on the Association of Police Controlled Drug Liaison Officers website.
Import and Export
The import and export of CD raw materials and medicines (packaged for use) under Schedules 2, 3 and 4 Part I is licensed by the Home Office.
Schedule 4 Part II drugs must be carried on the patient (or pet owner), or in their luggage, through UK ports. Importation or exportation using postal or courier services is not permitted.
Schedule 4 Part II CDs in a medicinal form for personal use (i.e already dispensed for a named animal or animals) and Schedule 5 CD do not need a personal import or export licence to enter or leave the UK.
Restrictions on the export of CD
There are restrictions on the export of short and intermediate acting barbiturate anaesthetic agents.