How to register veterinary practice premises for vets to be able to supply veterinary medicines and inspection issues.
Veterinary surgeons are only allowed to supply veterinary medicines from their veterinary practice premises (VPPs) if they are registered with the Royal College of Veterinary Surgeons (RCVS).
Information on registering a VPP is available on the RCVS website.
For VPPs that come within the Veterinary Medicines Directorate’s (VMD’s) inspection programme, there are 2 inspection and registration fees:
- £34 registration fee payable to the RCVS on first application and then annually in April
- £350 inspection fee payable to the VMD which will be invoiced after the inspection
Details of the inspection fee.
The inspection criteria for non-PSS VPPs are available on request from our Inspections Administration team firstname.lastname@example.org.
Main issues found during inspections
Controlled Drugs (CDs)
Most Schedule 2 CDs and some schedule 3 CDs are subject to secure storage requirements. This includes when they’re being stored in vehicles. Being in a locked vehicle is not enough; either store them in a locked glove compartment or in a locked container secured to the vehicle.
If you have Schedule 2 CDs, you must have a register in each place where they’re stored, including vehicles. The Misuse of Drugs Regulations 2001 specifies a strict format for the register. The register must be a bound book (loose leaf binders aren’t permitted) and there must be no crossings out or overwriting of figures.
You can find further information on the recording, using, storing and disposal of CDs page.
Ketamine is a Schedule 4 CD and as such it would not normally be subject to safe custody and recording in a CD register. However, as it is a drug of abuse, the VMD and the RCVS recommend that it is stored securely and recorded in an informal register in the same way as for Schedule 2 CDs.
You can find more details on the Controlled Drugs: Veterinary Medicines page.
You must keep records of all POM-V and POM-VPS medicines bought and supplied, including administered, which must be available for VMD to inspect. Products administered under the ‘cascade’ must be treated as if they were POM-V.
The records must include batch numbers. For cats, dogs and other pets, it’s sufficient that you have a record of either when the batch was delivered to your practice or when you first used it. If the details are on the Tote sheets you receive from the wholesaler, just keep those. If your wholesaler keeps the details for you, that’s acceptable, providing you are able to log onto their site and allow the inspector to see them.
For food-producing species, you must record the batch number each time you supply, including administer, a prescription medicine to a food-producing animal. This includes horses that are not signed out of the food chain.
Further guidance on administering medicines to horses can be found on the Horse Medicines and Record Keeping Requirements page.
You must also record any withdrawal period. If you’re a small animal practice, you may sometimes treat chickens. While your clients may consider their hens to be pets, if they’re eating the eggs then those birds are ‘food-producing animals’ and you must keep appropriate records.
If you administer a POM-V, POM-VPS or cascade product to a food-producing animal, you must either personally enter the details in the animal keeper’s records or give the details to the keeper in writing to enter.
You should store medicines within the temperature range specified in the Summary of Product Characteristics (SPC). Vaccines and some other products must be kept between 2 and 8°C and must not be allowed to freeze. For those temperature-sensitive medicines, the inspector will expect to see the maximum and minimum temperatures monitored and recorded every day.
Most other medicines need to be stored below 25°C. So if either the premises or vehicle where you store medicines is likely to exceed this, their maximum and minimum temperatures should be monitored and recorded. If this shows the temperature does exceed the requirement in SPCs you should take steps to rectify this.
Labelling of medicines dispensed into smaller containers
If you supply a medicine in a different container to its authorised one, you have to supply enough written information to enable your client to use it safely. This could include giving your client a copy of the product’s authorised package insert or leaflet, or providing your own written advice.
Many products have a use-by time after the first withdrawal of a dose. This is often 28 days but does vary. Use after the specified broach time is not permitted. To demonstrate that use outside the broach time has not occurred, vets should record the opening or use-by dates on broached products. However, ensure that you have a single branch policy.
There are legal requirements for what must be included on prescriptions. You can find details of what must be included on a prescription on the Retail of Veterinary Medicines page.
We recommend that practices set up a dummy client called ‘Disposal’ on their practice management system and record all medicines that are unusable. This can help the practice identify where medicines are being wasted and also help with reconciling stock during audits.
Cytotoxic, cytostatic and certain hormonal medicines
These require special handling and disposal procedures, products include:
- cancer chemotherapeutics - which include products such as vincristine, pharmarubicin, methotrexate, and all similar classes of tumour toxic medicines
- antiviral medicines - including aciclovir ophthalmic ointment
- ciclosporin medicines in any form
- certain hormonal preparations - including prostaglandins and androgens
A spill kit and appropriate protective equipment should be readily available to deal with spillages/leakages of all medicines. Particular attention should be given to dealing with spillages of CDs and cytotoxic, cytostatic and certain hormonal medicines mentioned above.