The Controlled Substances Act extends the same legal requirements for use of controlled substances in veterinary settings as well. Registration with the DEA is mandatory as are the other regulations.
Veterinarians use a variety of controlled substances for their animal patients – in the form of pain medications, anesthetics, anabolic steroids, euthanasia solutions and more. This raises professional and legal considerations as the Controlled Substances Act requires strict adherence to the regulations related to the ordering, storing, dispensing and recording of controlled substances.
Following is a brief look at the mandates related to veterinary controlled substances:
Registration - Every veterinarian who orders, dispenses, prescribes or administers a controlled substance must be registered with the Drug Enforcement Administration (DEA). All registrants get a unique DEA number which should be compulsorily quoted on the prescriptions, orders, etc. If the veterinarian practices in more than one location, he/she has to get a separate license for every location.
Security – The controlled substances should be stored in a secure manner - a substantial container and a significant primary lock are the basic necessities – to prevent unauthorised access.
Ordering – Schedule II drugs have to be ordered using the DEA Form 222. The same form has to be used even for transferring these drugs from one location to another. Controlled substances in Schedules III through V can be ordered in the regular manner; the supplier will require a copy of the current DEA registration to keep on file.
Recordkeeping – The dispensing or administering of a controlled substance should be carefully recorded both on the medical record and a ‘readily retrievable’ record. The log should contain:
All records related to the purchase and use of controlled drugs must be maintained for at least two years.
Inventory - The DEA requires an initial inventory to be taken on the day of the first controlled substance activity followed by repeating the inventory procedure and documentation every two years.
Shortage or theft – Any theft or substantial loss of controlled substances should be immediately reported to the local DEA field office using Form 106
Disposal – There are specific rules for disposing of expired or no-longer-needed controlled substances. They should ideally be transferred to ‘Authorized Reverse Distributors’ who are registered to receive such materials.
Apart from the above, the DEA will conduct regular audits in an unannounced manner. There will be inspections to investigate any complaint or doubts of suspicious activities.
Going by the overload of regulations and other formalities, it is better to entrust the DEA veterinary compliance activities to a professional service like the Titan Group. They will assess the facility and ensure that it always stays in compliance while also preparing the staff for audits and inspections. Training options are also available.