VMD inspection!

RE: VMD inspection!

Bob Russell — Wed, 22 Aug 2018 09:15:39 GMT

[quote user="David Mills"]

[quote user="Beats"]

[quote user="David Mills"]There's no specific legislation, it's just good practice to know where your drugs are going[/quote]

Fair enough, but it sounds like this good practice is being enforced on Bob, against his will, or at least has been enforced to be a higher priority concern to him than is perhaps would be otherwise. I thought a VMD inspection was to ensure compliance with legislation?

There will be lots of things that are good practice that Bob may not partake in (flossing daily, avoiding screen-time before bed, I'm just guessing - Bob might do all these!). It should be up to him to prioritise implementation of such aspects of good practice in the absence of a specific regulatory requirement?

[/quote]

The good practice recommendations are just that. They have no influence on your inspection interval - I suspect Bob is on a 48 month. Only the legislative aspects relating to veterinary medicines can lower the interval (and then you need >6 minors or one major, and a major very hard to get).

This is somewhat a storm in a teacup. As I've said, ours have always been very helpful in this regard, and we are open to constructive criticism, even welcome it. I can't understand all the fuss really.

[/quote]

No reduced to 36 month inspection because was noted in previous inspection.

I am not sure if there has been miscommunication but as far as I can see we have not recorded the amount drawn up but have the amount administered therefore the fuss appears to be over the amount that goes into the bin at the end of a procedure.

Sleeping on it I am now really pis+ed off and have made my feelings clear to the VMD.

I expect the highest possible standards from myself. Everyone else here expects the highest standards they can achieve (I have confidence they do this!) and a nit picking exercise just aggravates things.

I did pick up a few things that the inspector did not!!!

RE: VMD inspection!

Anthony Todd — Tue, 21 Aug 2018 22:22:34 GMT

[quote user="Ceri Gruffudd Jones"]Like your example of paracetamol, licensed in babies but highly toxic to cats?? Or is that what you implied by “Specific species licence “?[/quote]

Why is there someone that always picks a ridiculous example?

I was, I thought. obviously meaning the same drug for the same indication in the same species, one "licensed", although how that changes anything is beyond me, and one, probably made in the same plant, with a VMD licence only 10 [?] times the price.

PS, take prednisolone or phenobarbitone as better examples [i should have emphasised POMV and POM...., but thought it was obvious]

RE: VMD inspection!

David Mills — Tue, 21 Aug 2018 20:43:35 GMT

[quote user="Beats"]I would also have no objections to anything that is purely a recommendation and, like you, would welcome them. If I am left with the ability to implement or ignore as I see fit, then I can't see a problem.[/quote]

Exactly this.

It's a bit like the Animal Welfare Act and the Code for Animal Welfare. The code is not enforceable in law but may be referenced as best practice (OK acceptable practice in most cases, so not the best example)

One of the things that regularly comes up, for instance, is AMR and whether there are practice protocols in place (essentially the big BSAVA PROTECT posters you see everywhere). Similarly how you report a serious side effect or lack of efficacy.

The stock issue is best practice, to know where potentially addictive, lethal or dangerous drugs are going, regardless of whether they are controlled or not. Of which propofol is one such drug. So an annual stock take, or more frequently (twice a year here) is sensible, even if boring. We're not talking about counting every ml or every needle. But we are talking about responsible drug stewardship as befits the profession. Again, I cannot really see a problem here, and kicking the man isn't the answer. Out of all govt departments to deal with, the vmd are one of the most available, sensible and helpful IME.

RE: VMD inspection!

Beats — Tue, 21 Aug 2018 20:16:25 GMT

[quote user="David Mills"]The good practice recommendations are just that. They have no influence on your inspection interval[/quote]

I would also have no objections to anything that is purely a recommendation and, like you, would welcome them. If I am left with the ability to implement or ignore as I see fit, then I can't see a problem.

RE: VMD inspection!

David Mills — Tue, 21 Aug 2018 20:10:12 GMT

[quote user="Beats"]

[quote user="David Mills"]There's no specific legislation, it's just good practice to know where your drugs are going[/quote]

[/quote]

RE: VMD inspection!

Russell leadsom — Tue, 21 Aug 2018 19:59:12 GMT

further to my previous comments, which I still uphold - I must be an awful vet in grave danger of knuckles being wrapped and all the litigious forces of all the ‘jobsworth’ folk out there descending upon me.

what excuse could I have for having operated without a signed consent and no gaseous anaesthetic, saved a fitting dog with diluted (admittetly not expired!) euthetal, pinned and plated a bone fracture with no radiographic proof etc etc and no patient died, but thrived and all clients extremely grateful. I have even used a NSAID with prednisonolone (Sshhh)

i have vivid memories of our last practice fire inspection in UK when we were fined for having a blue not green ‘running man’ escape sign- to which I suggested it should also be in Brail, an excelllent idea she said! And there’s plenty more where that came from, how about being told we could not use the ground floor bay-windows to escape a fire as it was “not allowed“ !

Where I practice now litigation is a far off thought, medical expertise, discretion and experience is expected. Whilst evidence based practice is acknowledged, experience based practice often wins through. We are still allowed to use our professional training in deciding on the best course of therapy, including medicines, that in our unique (veterinary medicine graduate) training feel is in the best interests of our patients.

RE: VMD inspection!

Beats — Tue, 21 Aug 2018 19:56:48 GMT

[quote user="David Mills"]There's no specific legislation, it's just good practice to know where your drugs are going[/quote]

RE: VMD inspection!

David Mills — Tue, 21 Aug 2018 19:45:32 GMT

There's no specific legislation, it's just good practice to know where your drugs are going, and being charged properly secondarily. In smaller practices with fewer vets I agree rarely a problem, and you would notice something amiss very quickly. In larger hospitals stock control can be a nightmare, we did a stock take recently and its amazing how much things can be out.

RE: VMD inspection!

Beats — Tue, 21 Aug 2018 19:32:08 GMT

[quote user="Bob Russell"]Problem would appear to be that this makes it impossible to audit propofol use and some may go missing. [/quote]

Just for my information, can someone link to specific part of legislation which makes it a requirement to be able to account for every ml of propofol? Is this England only law or applicable in all parts of UK? Many thanks!

(PS - Does this count for all drugs or only propofol due to a potential for abuse? i.e. do you also need to record fluorescein used = 1 drop, disposed of = rest of vial, alongside the pre-use non-marketed consent form, signed and stamped in triplicate oibviously; how do you record and audit your isoflurane usage? I'm intriugued!)

RE: VMD inspection!

Bob Russell — Tue, 21 Aug 2018 17:49:55 GMT

Good job our head nurse is away!

Failure to include propofol volumes in 'fixed price' surgeries on PMS is a Major issue (had been raised last time hence the escalation).

Volume drawn up is standard eg:20Kg dog - 10ml drawn up.

Actual volume used recorded on the monitoring sheet!

Problem would appear to be that this makes it impossible to audit propofol use and some may go missing.

OK probably not ideal but in my opinion covers my professional responsibilities and VDS would be OK in case of questions regarding the surgery.

A few nit picking but overall blood pressure has gone up and a bit pi++ed off with the jobsworth attitude.

We did have the right number of isathal tubes and they had the right batch numbers so that was a relief!

No patient put at risk, no people at risk and with a bit of work we could do the audit if it was worth the effort.

Signed

Unhappy of Hampshire

RE: VMD inspection!

Martin Atkinson — Fri, 17 Aug 2018 14:57:19 GMT

[quote user="Bob Russell"]Specific mention that surgery consent forms should include mention that in emergency non-licenced drugs may be used. [/quote]This has now been added to our surgical consent forms.

[quote user="robloxley"]

[quote user="Martin Atkinson"]But what sort of person takes legal action when you've done your best to save their dog[/quote]

Probably no client, but rather their ambulance-chasing no win-no fee solicitor looking for someone to blame when the proverbial has hit the fan. They're just a click away on t'interwebs...

[/quote]Thought about this again and it became obvious: disgruntled client because dog died at vets; found no win-no fee solicitor to sue vet; found couldn't sue vet or report for negligence as there was no fault - it was just unfortunate that these things happen; solicitor wants his payday/client wants pound of flesh and found something they could get their teeth into.

Would they have taken action if the dog had survived thanks to the off licence adrenaline. Well wadyer think?!

RE: VMD inspection!

Bob Russell — Fri, 17 Aug 2018 14:28:42 GMT

I would hope that nobody is saying that any human drug can automatically be considered safe because it can be used in babies.

The decision to prescribe any POM medicine lies with the veterinary surgeon (excepting this nonsense allowing SQP's to 'prescribe' medication) as does the responsibility to make sure the benefits outweigh the risks and owners are aware.

We will modify our consent forms along the lines:

Please be aware that some human drugs not licenced for animal use may be used on occasions.

RE: VMD inspection!

bob lehner — Fri, 17 Aug 2018 14:19:59 GMT

[quote user="Richard Carter"]which is emasculating your professional status as a trained person[/quote]

With the greatest of respect that's pure nonsense.

PSS is there (amongst other things) to help you as a busy practitioner to be aware of, and keep on the right side of the multitude of rules and regs imposed on your business by the Govt. and all manner of bodies - not just the RCVS, but also the likes of VMD, HSE, D of E, DEFRA etc., which like them or not, you are obliged to comply with.

This level of knowledge is generally not something that comes easily to most MRCVSs, who are far too busy doing the job they have been trained to do.

I've said it before - PSS is your friend!

RE: VMD inspection!

Ceri Gruffudd Jones — Fri, 17 Aug 2018 13:27:52 GMT

[quote user="Anthony Todd"]

Surely, even a jobs-worth couldn't argue that a drug licensed for use on babies is therefore unsafe for animals ? [unless there was a specific species licence]

[/quote]

Like your example of paracetamol, licensed in babies but highly toxic to cats?? Or is that what you implied by “Specific species licence “?

RE: VMD inspection!

Martin Atkinson — Fri, 17 Aug 2018 11:08:25 GMT

[quote user="Bob Russell"]I have worked in a number of practices over my career and have never seen any of these apparent horrors.[/quote]I certainly did when I was seeing practice in the 60's and early 70's but not since I qualified, albeit I've been self-employed since 1981 so I have set my own (high) standards. Maybe I was selective about who I worked for.

[quote user="Bob Russell"]

I have seen corners cut and not always agreed with them and have cut corners as much as anyone else. I have never considered animal welfare to have been compromised at any stage by these cuts.

CPD and the willingness to improve has been a massive change and I am sure has been far more important for clinical standards than 99% of this red tape.

[/quote]Wot he says.

RE: VMD inspection!

Bob Russell — Fri, 17 Aug 2018 10:43:57 GMT

I have worked in a number of practices over my career and have never seen any of these apparent horrors.

I have seen corners cut and not always agreed with them and have cut corners as much as anyone else. I have never considered animal welfare to have been compromised at any stage by these cuts.

CPD and the willingness to improve has been a massive change and I am sure has been far more important for clinical standards than 99% of this red tape.

I have never been in a practice that misused its staff although we all worked crazy hours including on-call.

Have most of these changes improved things more than good education alone would? I doubt it.

The very occasional bad apple is inevitable and I suspect they will be better at fiddling the books than we would be!

RE: VMD inspection!

Richard Carter — Fri, 17 Aug 2018 10:12:53 GMT

[quote user="bob lehner"]Viva PSS[/quote] which is emasculating your professional status as a trained person who has achieved and knows (supposedly) the knowledge of what is good practice and what you should be doing. This is why you are allowed to wear the badge of MRCVS.

Now there is a good cop-out - it's in the rules so I don't have to think, it is someone else's responsibility, I'm just the vet, can't go against the rules even when I know something to be wrong/ inappropriate. Just like the NHS is getting into

Soon won't need any MRCVS - just a trained technician who can follow the rules.

RE: VMD inspection!

Anthony Todd — Fri, 17 Aug 2018 10:00:39 GMT

Oh sure, there are always gross examples, and I'm sure they will still be found.

But does this really warrant the illogical and pedantic regulations you vets are now saddled with.

Common sense and sensible practice [broached discard???] has been overridden by unnecessary and excessive regulation.

RE: VMD inspection!

bob lehner — Fri, 17 Aug 2018 09:50:28 GMT

[[quote user="Russell leadsom"]I have watched from afar how over the last 20 years the red tape, rules and regulations, compliance and controls have taken over the once pure pleasure of being a practising veterinary surgeon. All under the guise of furthering the quality of the professional ‘offerings’ and of course protecting the public[/quote]

Of course, most people would read that and nod sagely in agreement.

The fact is that things really weren't always that great in the 'Good old days'.

A few random observations from my own personal experiences in the past (and I'm really not that ancient):

1. Employees seldom got any written terms & conditions of employment - bosses could hire and fire, change holidays, rotas etc at a whim - often depending upon their own commitments at the golf club. 2. Flagrant sexual discrimination, racism and homophobia. 3.H&S didn't exist - e.g. an ancient WW1-era X ray machine - never serviced, no collimation, everything held (no effective sedative meds) , no badges, but a manky old gown and gloves available. 4. Ops room floor painted red - didn't show the blood, so saved on cleaning. 5. Senior partner smoking a cigar whilst operating, no concept of asepsis, filthy finger nails from gardening (a squirt of mastitis cream into the wound did the job anyway). 6. senior partner doing no CPD 'I've been doing this job long enough - I don't need that nonsense' - and didn't believe in lab tests - 'I know what wrong with an animal by looking' 7. No regard to care of medicines - equine vaccines carried about on the back shelf of the car - alternately cooked or frozen, depending on the season. A bottle of lignocaine 12 years past its expiry date still in use. The 'so called' cat expert giving every sick cat a hefty shot of streptomycin./dihydrostreptomycin (licensed for pigs - but rather ototoxic for cats) - ''It'll shake him up for a few days, but then he'll be fine''. 8. Needles and syringes used multiple times - it was quite common to see bottles lined up in the consulting room with a needle and syringe inserted in the top of the bottle - used, then replaced ready for the next patient. Any old combo of meds mixed in the same syringe.

And so on.....'Good old days'? I think not. Viva PSS.

(Oh well - that'll propel me to the top of the 'Disagree' table....)

RE: VMD inspection!

Utlendigur — Thu, 16 Aug 2018 21:22:09 GMT

Or not knowing whether it was adrenaline or saline (it was a double blind trial)..

https://www.dailypost.co.uk/news/north-wales-news/paramedic2-adrenaline-trial-guinea-pig-14327749

RE: VMD inspection!

Beats — Thu, 16 Aug 2018 19:39:09 GMT

Do you send a copy of the health and safety manual for the inspector to read and sign that they have read to permit access to an area where drugs are kept ahead of date, or do you sit them down with a cup of tea at the start of their inspection?

My practice conveniently had their last RCVS PSS inspection on a day I wasn't there. I think it was considered a mutually-beneficial chance happening.

RE: VMD inspection!

Anthony Todd — Thu, 16 Aug 2018 19:10:01 GMT

[quote user="Bob Russell"]we have been more than flat out for several weeks[/quote]

Probably 'cos the word in the park and on the street is that you're a good vet, and don't do tests unless you don't know what's wrong, or want to confirm a serious diagnosis!

[or you're cheap??

RE: VMD inspection!

Bob Russell — Thu, 16 Aug 2018 18:04:39 GMT

That suggests a rubber bung should be OK to perforate a hundred times. No problems there!

Why should the product fail on the 29th day when there is a very long history of these bottles being in use for many months?

We have given Ketamidor the boot because it is only available in 10ml bottles.

I am sure the RCVS would happily sanction anyone they thought they could. They appear to have been fast asleep when the regulations were introduced and playing second fiddle to the VMD since.

BVA was snoozing all the way through as the rules made good sense for food producing animals.

Many medicines are too expensive for use for no better reason than someone plucked a number out of the air.

RE: VMD inspection!

Rob Loxley — Thu, 16 Aug 2018 16:13:11 GMT

[quote user="Martin Atkinson"]VMD know that it would not stand up in a crown court if it went to appeal[/quote]

Not sure I'd be so confident, anyway the RCVS would happily sanction you I'd suggest...

[quote user="Bob Russell"]Would it be more logical to limit the number of broaches?[/quote]

EMEA adresses this http://www.ema.europa.eu/ema/index.jsp?curl=pages/regulation/q_and_a/q_and_a_detail_000072.jsp&mid=WC0b01ac058002c2b0#section17 section 5. But rarely does it seem to come up in datasheets IME

RE: VMD inspection!

Martin Atkinson — Thu, 16 Aug 2018 13:48:51 GMT

[quote user="Bob Russell"]It is an offence to use out of date drugs but is it an offence to exceed the so called broach date? Genuine question, not a recommendation![/quote]As I said in my previous post - no. My last inspector categorically stated this. Why you would want to keep a bottle beyond 28 days unless you intended using it is debatable but it is not an offence in itself. This particularly applies to controlled drugs when you might have to wait some time for it to be practical/convenient to have the destruction witnessed.

[quote user="Bob Russell"]

Would it be more logical to limit the number of broaches? [/quote] When has logic ever come into this regulation? All you say is common sense but someone has to wear the jobsworth hat.

AFAIA no-one has yet been persecuted* (*genuine typo I'm leaving because its apt) for breaking the 28 rule (someone may correct me if I'm wrong) as VMD know that it would not stand up in a crown court if it went to appeal and a jury had to decide based on all the evidence that it does no harm, that the rule is totally arbitrary, and that by us religiously sticking to it they are paying a lot more for their veterinary treatment or that they may not get the best treatment because we are not prepared to stock drugs that we only use very occasionally.