Authorising restricted veterinary medicines for dispensing and use by non-veterinarian staff

Can veterinarians authorise non-veterinarian staff members (e.g. nurses and techs) to use medicines?

This advice outlines the expectations of veterinarians who authorise restricted veterinary medicines (RVMs) and Prescription Medicines (PMs) for dispensing or use by a non-veterinarian staff member (staff) under the veterinarian’s direction. 

This guidance does not apply where Veterinary Operating Instructions are required or where a veterinary student is undertaking a treatment or procedure under veterinary supervision.

Guiding principle

The public has the right to expect that their animals receive high quality care regardless of whether that is delivered by a veterinarian directly or via other team members.

What does the law allow?

The Code and ACVM Notice allow a veterinarian to authorise (prescribe) RVMs and PMs for staff to administer to an animal under the veterinarian’s care.

What is expected when authorising?

Conducting a consultation

The Code requires that veterinarians must only authorise RVMs and PMs following a veterinary consultation and either having seen the animal(s) at the time of the consultation or have seen recently or often enough for the veterinarian to have sufficient personal knowledge of the condition and health status of the animal(s).

Addressing animal welfare risks and emergency care

Veterinarians must take reasonable steps to ensure that animal health and welfare is protected when they enable others to provide care to animals.

The duty on veterinarians extends to ensuring people undertaking treatments are able to recognise when treatment is and isn’t indicated; recognise early signs of animal distress, injury or ill-health; and take remedial action or seek help when necessary.

In any situation where a veterinarian authorises treatment with RVMs or PMs by staff, they must have arrangements in place to respond where a side effect or adverse event associated with the RVM or PM occurs.

Considering risks

Veterinarians must consider the risks of the use of an RVM or PM and act to avoid or mitigate those risks. This includes risks to:

• public health
• trade in primary produce
• agricultural security
• animal welfare
• occupational health and safety
• the environment

Veterinarians must also: 

• comply with the regulatory controls of all veterinary medicines they choose to use, sell or authorise
• meet the requirements of the maximum periods of supply when authorising of RVMs and PMs

It is worth noting that veterinarians are not obliged to provide RVMs or PMs, especially where they have concerns about a non-veterinarian’s competence.

Considering competency

Veterinarians must:

• Confirm that any person who will administer the RVM understands and is able to competently carry out the authorising veterinarian’s instructions for use.
• Ensure that staff they delegate tasks to have training that enables them to deliver the veterinary service to an appropriate standard. Consider what evidence there is, of a person’s competence, including the currency and recency of that person’s training in the correct treatment.
• Ensure practice resources enables staff to deliver delegated veterinary services to an appropriate standard. Resources include equipment, facility and inventory.

Qualifications

Veterinarians may, where appropriate, rely on a person’s qualification to indicate their competence e.g. veterinary nursing and technician certificates, diplomas and degrees. 

Third parties, who have robust training and assessment methodologies can also provide competency training e.g. another veterinarian. Training should include currently accepted practices and meet accepted professional and industry standards.

Veterinarians should use their professional judgement, and consider asking other knowledge experts, when considering the quality of the person’s education and experience.

Where a person is not yet competent, veterinarians may elect to provide training in:

• Treatment, to enable those treatments to be performed safely and humanely
• Competent management and use of RVMs and PMs, prior to authorising
• Recognition of early signs of animal distress, injury, or ill health, including veterinary emergencies and adverse events, and how to engage in that care.

Importantly it is not necessarily the experience, but the treatment being carried out correctly, using appropriate methodology, that determines competence.

Evidence of competency assessments should be supported by training and assessment records, attendance at training events such as an industry training days or online training modules etc. Records should also reflect updated training with current techniques and equipment.

Veterinary Nurses Registration

The Allied Veterinary Professional Regulatory Council (AVPRC) is a voluntary regulatory body that registers veterinary nursing, technology professionals and allied animal healthcare practitioners. It sets and monitors the educational and professional standards for veterinary nurses, technicians, and allied animal healthcare practitioners. 

This provides a pathway for accountability for staff and, for this reason, veterinarians could turn their minds to endorsing staff registration with AVPRC.

Supervision

In considering whether to direct staff to carry out a treatment, the veterinarian must consider how difficult the treatment is (including any associated risks), whether the staff member understands the associated risks and has the necessary competence to react appropriately if any problem should arise. 

The veterinarian must then use their judgement when determining the level of supervision required by the staff member that has been authorised to carry out the treatment.

The veterinarian must also be sure that they will be available to answer any call for assistance, and should be satisfied that the staff member feels capable of carrying out the treatment competently and successfully.

VCNZ use the following terms to describe differing levels of supervision:

Veterinary direction means that the veterinarian instructs a person on the tasks to be performed but is not necessarily present.

Veterinary supervision means that the veterinarian is readily available to provide advice and support in response to a request for assistance if needed.

Direct and constant veterinary supervision (or observation or oversight) means that the veterinarian is physically present and giving the veterinary nurse or student veterinary nurse his/her undivided personal attention.

Responsibilities

Veterinarians are considered to be responsible for the conduct of the people they delegate to, and must take steps to ensure that they work within the standards expected.

This does not mean that the veterinarian takes on responsibility for the treatment itself. If concerns were raised, questions about the veterinarian’s conduct would focus on whether the veterinarian took reasonable steps to ensure the points above were met.

Where the veterinarian’s instructions and methods provided during any training are not followed, responsibility would normally sit with the person undertaking the treatment. 

Veterinarian Competence

Veterinarians should work within their area of competence and have the appropriate skills and knowledge to assess another person’s competence, before delegating to them (and authorising medicines). For example, veterinarians without appropriate knowledge in equine treatments, should not authorise RVMs or PMs for treatments by staff on equids.

Owner Consent

When considering whether a treatment can be delegated to a staff member, the veterinarian has a duty to ensure their clients are informed. This information may for example be contained in a client registration pack that outlines that the practice provides a team-based healthcare approach to veterinary medicine that enhances the quality of care their patients receive, and that all staff are appropriately trained and supervised.

Veterinarians should also be aware of their own insurance policies and understand what cover is (or is not) provided when they delegate non-veterinarians to undertake, for example, a regulated treatment such as teat sealing in cattle.

Employment and health and safety law

Veterinarians who are employers or in management positions need to have current knowledge of employment law requirements. For example, an employee or contractor who is under 15 years cannot work in any area where the work being done is likely to harm the employee.

Veterinarians must follow all Health and Safety legislation. Employers must look after the health and safety of their workers, including managing risks associated with the use and administration of RVMs and PMs. Employees must take reasonable care of their own health and safety and to ensure that others are not harmed by something they do or don’t do. Again, this for example extends to potential harm associated with RVMs and PMs.

Further reading

The Code of Professional Conduct, specifically:

• the definition of veterinary consultation
• the Veterinary medicines chapter including section 1 (product stewardship) and section 2 (legislative requirements)
• the Veterinary services chapter, including section 3.
• ACVM Notice: Requirements for Authorising Veterinarians