Who can administer Controlled Drugs (including pentobarbitone)?
Technical advice is our interpretation of how professional standards apply in a particular situation. It is designed to help veterinarians deal with common issues in practice, using their professional judgement to apply the advice to their own situation. It represents our best efforts at the time of publication but standards and expectations change over time and particular care should be used when reading old advice.
Are they vet only, or can they be authorised for a non-veterinarian to (have in their possession and) administer?
If they can be authorised for non-veterinarians to administer does the veterinarian have to be present?
The Misuse of Drugs Act allows a veterinarian to authorise (prescribe) controlled drugs such as pentobarbital for a non-veterinarian to hold and administer to an animal in their care.
Health and safety (Health and Safety at Work Act 2015) requirements mean that a veterinarian and a veterinary clinic or business must have in place very clear measures to assess and manage the risks associated with the authorisation and use of controlled drugs and other products that carry significant risk. It is important to note that as a ‘duty holder’ veterinarians must ensure, so far as is reasonably practicable, the health and safety of workers, and that other persons are not put at risk by their work.
An assessment of risk should include the potency and the volume of the product (including controlled drugs) being authorised (or that the non-veterinarian would have access to). Both factors contribute to the potential for harm.
This would include authorising controlled drugs in a quantity that has regard to the dose and frequency of dose, or the directions given by the veterinarian such that the risks are sufficiently mitigated.
For example, a veterinarian authorising 1 months’ supply of an opiate (allowable under the Code) for a large 60kg dog that requires a significant dose for its pain management may limit the volume of drug dispensed to only two weeks at a time in order to manage the risks.
Another example might be where an animal is discharged from one practice to another, in the context of emergency care services, while it is receiving a controlled rate infusions (CRI) containing controlled drugs such as opioids like fentanyl or morphine, often with ketamine – the risk could be mitigated by administering a dose prior to discharge that is sufficient for transporting the animal.
When deciding whether to authorise a non-veterinarian to hold and administer controlled drugs, veterinarians must comply with sections 1, 2, 3 and 5 of the Veterinary medicines section of the Code .
The classification of Controlled Drugs is based on the assessment of risk of harm the drug poses to individuals or to society when misused – for example there are risks associated with the selling, or use, of the drug for recreational practices or self-harm. There are also risks associated with accidental ingestion by family members (e.g. young children) or other animals in the example of Fentanyl patches.
Veterinarians should also consider the issue of ‘moral distress’. There is a degree of responsibility, both professionally and psychologically, associated with the process of euthanasing an animal and careful consideration should be given to the delegation of this procedure to non-veterinarians.
Taking this all into account, the expectations for appropriate stewardship are high and it would be prudent, when veterinarians are authorising and dispensing controlled drugs, to consider the following:
- The character and state of the client/non-veterinarian. Are they sufficiently competent, reliable and trustworthy?
- The qualification, or training and experience, of the person being given the responsibility of having the controlled drugs in their custody. Are they sufficiently skilled or trained?
- What level of supervision or oversight is appropriate for this controlled drug?
- What recommendations will you make regarding the safe storage of and access to the product?
- How should it be dispensed and labelled (e.g. appropriate warnings, etc)? Is it better dispensed in pre-prepared syringes (for example Temgesic for oral treatment for cats, which may avoid users needing to use needles to draw up the dose, etc)?
- How much should be dispensed? The Misuse of Drugs Regulations 1977 specify a maximum period of supply of 1 month and leave management of the risks to the veterinarian’s judgement.
- How is use monitored? This is difficult, though observing the patient’s condition and the frequency of repeats may provide some insight into the appropriate use of the product.
- What are the options financially? If cost is an important factor and an alternative medicine is available that can be used to achieve the same intended effect the veterinarian should consider choosing it before the dispensing of a high risk Controlled Drug.
NB The decision to dispense a Controlled Drug should not be based solely on cost.
The National Velveting Standards Body is an example of compliance system that applies a set of acceptable criteria to the authorisation of the use of controlled drugs in specific conditions.
The Veterinary Operating Instructions (VOI) framework allow veterinarians to authorise trained and skilled personnel to hold and use restricted veterinary medicines (RVMs) in anticipation of future use. A VOI is however limited to the authorisation of RVMs in cases in which no veterinary discretion, oversight or guidance is need at the time the RVM is used. For example, for the authorisation of local anaesthetic.
Veterinarians are not obliged to provide a requested treatment, providing animal welfare and professional standards are met.
With these aspects in mind, the responsibility sits with the veterinarian to make a reasonable judgement. Ultimately the veterinarian will need to take all of these factors into account to decide if it is a good idea to authorise a controlled drug in this situation.