Rules on dispensing

RE: Rules on dispensing

Martin Atkinson — Wed, 05 Apr 2017 10:20:54 GMT

[quote user="Thomas Johnson"]It's not that different to us having to pay the RCVS retention fee to be able to practice.[/quote]At least the RCVS does something for us in the background other than finding ways to strike us off! I think!

[quote user="Thomas Johnson"]Or could they remove your license to store medications for continued refusal to pay?[/quote]Whatever, they have us by the short hairs.

RE: Rules on dispensing

Thomas Johnson — Wed, 05 Apr 2017 10:02:41 GMT

[quote user="Martin Atkinson"]Yup it is a bit of a piss take charging for a compulsory inspection.[/quote]

It's not that different to us having to pay the RCVS retention fee to be able to practice.

[quote user="Martin Atkinson"]What if we refused to pay?, they would still have to make the inspection but then presumably really wear the 'jobsworth hat'![/quote]

Or could they remove your license to store medications for continued refusal to pay?

RE: Rules on dispensing

Martin Atkinson — Wed, 05 Apr 2017 09:35:22 GMT

[quote user="Bob Russell"]I would prefer flexible to lenient![/quote]Yup better choice of word.

[quote user="Bob Russell"]not in the least traumatic beyond the irritation of the bill![/quote]Yup it is a bit of a piss take charging for a compulsory inspection. What if we refused to pay?, they would still have to make the inspection but then presumably really wear the 'jobsworth hat'!

RE: Rules on dispensing

Bob Russell — Wed, 05 Apr 2017 09:22:59 GMT

I would prefer flexible to lenient! If your system works and it falls within the rules then it is not up to them to decide how you do things!

The cascade products that are species specific (eg Sulphasalazine) have 'dog' added permanently to the label so it does not get missed. Others have it added manually. Still seems a little silly. These are prescription products and we should already be giving clear information regarding their use. Presumably the owner knows which species is being treated and should not be using the medicines for any other patient.

Our last visit was pretty straight forward and not in the least traumatic beyond the irritation of the bill!

I have no issues with some form of compulsory inspection to weed out the blatant non-compliers.

RE: Rules on dispensing

Martin Atkinson — Wed, 05 Apr 2017 09:14:13 GMT

[quote user="robloxley"] how are to we have confidence in the VMD's inspectors?[/quote]We don't! I get the impression most think the rules are as shambolic as we do, are just doing their job and have to go through the tick list although there may be the odd ex traffic warden 'jobsworth' doing it. No-one who has a brain can think the 28 rule is any sense at all or that minor infractions of the cascade are of any consequence. So long as 3 vials of ketamine are not missing, you have no CD cabinet, store the vaccines next to the boiler or keep no clinical records I think they are fairly sensible and lenient.

RE: Rules on dispensing

Rob Loxley — Tue, 04 Apr 2017 23:23:46 GMT

[quote user="bob lehner"]

[quote user="Evelyn Barbour-Hill"]

[quote user="Julie Innes"] I was told that we needed the species in all our labels too. [/quote]

Just not true. You could write your labels entirely by hand if you wanted to, as long as they bore all the necessary information. And the species is only required for things dispensed "off-licence".

[/quote]

Evelyn is correct - under the Veterinary Medicines Regulations only cascade products prescribed legally require the species to be identified - along with lots of other stuff which I mentioned previously.

[/quote]

Assuming Julie hasn't got the wrong end of the stick, how are to we have confidence in the VMD's inspectors?

RE: Rules on dispensing

bob lehner — Sat, 01 Apr 2017 18:09:20 GMT

[quote user="Evelyn Barbour-Hill"]

[quote user="Julie Innes"] I was told that we needed the species in all our labels too. [/quote]

Just not true. You could write your labels entirely by hand if you wanted to, as long as they bore all the necessary information. And the species is only required for things dispensed "off-licence".

[/quote]

For non-cascade products the labelling requirements are surprisingly woolly and non specific - if dispensed in the original packaging you must not obscure any info shown on the package. If dispensed outwith the original packaging you just require non-specified suitable labelling and info on the product to be given to the client.

PSS has its own specific and detailed requirements - as was detailed in Rob Loxley's post above - so PSS practices should comply with these.

The BSAVA Medicines Guide probably gives the clearest account of what is needed for labelling under different situations.

RE: Rules on dispensing

Beats — Sat, 01 Apr 2017 16:39:05 GMT

[quote user="Julie Innes"]For species I would need to get my pms provider to change the set up. [/quote]

Might be worth asking if they can do it in large print, braille and audio as well for improved accessibility. A Q code on each label which links to a video of you smiling and reading out all the contra-indciations on the datasheet would be nice also.

Then you could wrap a little red ribbon around each box for the owner to cut when they get home.

Or stuff each box inside a cuddly toy of the correct species to which it should be administered.

Simply having the patient's name must be too vague for most owners to figure out if it's for them their dog or their budgie. Perhaps including breed and coat colour and favourite toy on the label as well as species would be helpful safety-netting to consider?

RE: Rules on dispensing

Evelyn Barbour-Hill — Sat, 01 Apr 2017 15:43:53 GMT

[quote user="Julie Innes"] I was told that we needed the species in all our labels too. [/quote]

Just not true. You could write your labels entirely by hand if you wanted to, as long as they bore all the necessary information. And the species is only required for things dispensed "off-licence".

RE: Rules on dispensing

Julie Innes — Sat, 01 Apr 2017 13:00:26 GMT

Oh, and we have a few flea products in the shelf behind reception and it wasn't mentioned!

RE: Rules on dispensing

Julie Innes — Sat, 01 Apr 2017 12:59:34 GMT

I had my VMD inspection the other day as well (must be the season!) and I was told that we needed the species in all our labels too. Our labels do have a "dispensed by" bit, but it prints out as the person who was logged into the computer eg. Student nurse, so we were told it had to be logged in as the vet. For species I would need to get my pms provider to change the set up.

RE: Rules on dispensing

Bob Russell — Sat, 01 Apr 2017 11:01:36 GMT

We have a few of the 'over the counter' products on shelves behind the desk but as someone nicked a pile of Advantage boxes even this is kept to a minimum.

Our local Boots has shelves of POM drugs visible at all times.

I have no problem with them being in any particular place as long as they are not 'on display' for commercial purposes. Boots shows storage in visible sites is not a problem for human drugs so why should it be different for us?

Most of our medicines are in closed cupboards away from the general public. Seemed acceptable in out last inspection.

I hate it when someone feels they have to find something wrong just because!

RE: Rules on dispensing

Michael Woodhouse — Fri, 31 Mar 2017 19:17:55 GMT

[quote user="Martin Atkinson"]How many practices lock the flea products away?[/quote]

We do. Away in dispensary or closed cupboards and draws in consulting room.

RE: Rules on dispensing

Thomas Johnson — Fri, 31 Mar 2017 14:54:10 GMT

[quote user="Bob Russell"]I don't know a single PMS that places the veterinary surgeons names or initials automatically on a label. Ours are the only ones I have ever seen with such information on![/quote]

Ours (Voyager) prints both the person who prescribed and the person who dispensed the medication on the label.

RE: Rules on dispensing

bob lehner — Fri, 31 Mar 2017 10:49:35 GMT

[quote user="Bob Russell"]We do send them out with a copy of the appropriate BSAVA information sheet.[/quote]

These are very useful and to be encouraged.

Surprising number of people I meet are still blissfully unaware of them.

RE: Rules on dispensing

Bob Russell — Fri, 31 Mar 2017 09:49:38 GMT

I don't know a single PMS that places the veterinary surgeons names or initials automatically on a label. Ours are the only ones I have ever seen with such information on!

This is only because I check all medication before it is dispensed.

Does anyone at all do this?

Will amend out labels accordingly but it really is a nonsense as long as it is on the clinical records.

Far too much to be expected to fit on a label and expect an owners to be able to read the important bits! We do send them out with a copy of the appropriate BSAVA information sheet.

RE: Rules on dispensing

Martin Atkinson — Fri, 31 Mar 2017 09:16:12 GMT

[quote user="Michael Woodhouse"]We will dispense flea and wormer POM-V for 12 months, but otherwise usual prescription rules apply. If we treat it as a formality to ignore then the VMD might as well just downgrade them to POM-VPS (monepantel, anyone?).[/quote]How many practices lock the flea products away? The VMD inspector wasn't happy that we had ours on display, out of reach, on shelves behind the reception desk. He said they should be in a locked cabinet in case someone leaned over while the receptionists attention was distracted and took one. This is marked as a deficiency but not one I'm in a hurry to correct.

RE: Rules on dispensing

Michael Woodhouse — Thu, 30 Mar 2017 19:16:02 GMT

[quote user="janine redman"]practice management have just advised that when dispensing prescription flea treatments we have to have the name of the vet who authorised it on the labels and the person who dispensed it[/quote]

The practice management can request that you draw a small caricature of if they want - it's up to them. The record has to be opened to dispense and we would book such things under the vet consulting rather than who originally authorised the prescription (for everything). The labels do put vet initials on as standard (Teleos) as it's easier doing it for everything than singling out cascade items (especially when anything can be a cascade medicine).

I don't see how this adds any time on to things. We will dispense flea and wormer POM-V for 12 months, but otherwise usual prescription rules apply. If we treat it as a formality to ignore then the VMD might as well just downgrade them to POM-VPS (monepantel, anyone?).

RE: Rules on dispensing

bob lehner — Thu, 30 Mar 2017 18:19:28 GMT

[quote user="Bob Russell"]Not sure it is a requirement under law for cascade medication to be labelled with the vets initials[/quote]

The Veterinary Medicines Regulations state:

Supply of veterinary medicinal products for use under the cascade

13.—(1) A veterinary medicinal product supplied for administration under the cascade may only be supplied in accordance with a prescription from a veterinary surgeon.

(2) Unless the veterinary surgeon who prescribed the veterinary medicinal product both supplies the product and administers it to the animal in person, the person supplying it must label it (or ensure that it is labelled) with at least the following information—

(a)the name and address of the pharmacy, veterinary surgery or approved premises supplying the veterinary medicinal product;

(b)the name of the veterinary surgeon who has prescribed the product;

(c)the name and address of the animal owner;

(d)the identification (including the species) of the animal or group of animals;

(e)the date of supply;

(f)the expiry date of the product, if applicable;

(g)the name or description of the product, which should include at least the name and quantity of active ingredients;

(h)dosage and administration instructions;

(i)any special storage precautions;

(j)any necessary warnings for the user, target species, administration or disposal of the product;

(k)the withdrawal period, if relevant; and

(l)the words “Keep out of reach of children” and “For animal treatment only”.

Quite a lot to put on a label?

(But the VMD Guidance Notes do say you can use a separate sheet if not enough room on the label....!).

RE: Rules on dispensing

Rob Loxley — Thu, 30 Mar 2017 16:01:40 GMT

[quote user="Bob Russell"]We were told off for overwriting an entry in the controlled drugs book when the pen ran out. Also for not having written guidance on how to fill out the CD book (it had it all printed in the front!).[/quote]

I suspect they can't leave without picking up on something!

RE: Rules on dispensing

Bob Russell — Thu, 30 Mar 2017 15:51:45 GMT

Most medicine requests go into a medicines book for checking. Routine flea and worming gets done a bit less formally but perhaps should not really. I am made aware of all requests and authorise.

Not sure it is a requirement under law for cascade medication to be labelled with the vets initials. Perhaps it is hidden in there just as it was found necessary to state the species being treated on the label. Pet owners generally know what species they are having treated and I consider the label primarily to inform the client what the medication is and how to use it.

Clinical records should really be enough to identify the prescribing vet.

However as you have said it is not the end of the world to comply!

We were told off for overwriting an entry in the controlled drugs book when the pen ran out. Also for not having written guidance on how to fill out the CD book (it had it all printed in the front!).

Overall was not too trying and it gave us the opportunity to get rid of old part used CD bottles which were in quarantine!

RE: Rules on dispensing

Rob Loxley — Thu, 30 Mar 2017 15:17:43 GMT

[quote user="janine redman"]have to have the name of the vet who authorised it on the labels and the person who dispensed it[/quote]

Not sure the name of the dispenser is ever needed; we do however get the person dispensing & packing the medication to initial the item to try and reduce and be able to backcheck dispensing errors.

[quote user="janine redman"]has to be checked against previous records as to who authorised the treatment originally[/quote]

If a repeat prescription we will append the vet who authorised the repeat prescription, rather than looking back to see who first put the animal on a particular drug

RE: Rules on dispensing

Martin Atkinson — Thu, 30 Mar 2017 11:11:07 GMT

Just had my VMD inspection and the advice was that non-veterinary medicines and when using under the cascade the label should be initialed - its easy enough to do, otherwise it is just good practice not compulsory. Hardly an issue for me as sole charge mind you.

RE: Rules on dispensing

janine redman — Thu, 30 Mar 2017 00:25:37 GMT

Thanks a lot guys. Bit busy this evening and haven't had time to read up

RE: Rules on dispensing

janine redman — Thu, 30 Mar 2017 00:18:55 GMT

Thanks a lot guys. Bit busy this evening and haven't had time to read up