Non PSS Meds inspection

Re: Non PSS Meds inspection

Bob Russell — Fri, 07 Jan 2011 15:28:18 GMT

Actually seems to J G Wray of GPVets - sorry if I have caused confusion.

The anti-vet comments are driven more at my impression that all the comments from the VMD seem to have been to tell us what we cannot do as vets rather than allowing us to show maturity and common sense in our prescribing behaviour.

The VMD have rules to enforce and that is what they do.

Re: Non PSS Meds inspection

J G Wray — Fri, 07 Jan 2011 14:52:54 GMT

[quote user="Bob Russell"]Good letter in the VR by Jonathan Wray[/quote]

There are two Jonathan Wray in the Register. I have no idea who this is.

[quote user="Bob Russell"]

do I see a glimmer of light from the response by Steve Dean?

Is an element of common sense creeping in and a less anti-vet attitude from the VMD? I do hope so!

[/quote]

Steve Dean is keeping all options open, which is pragmatic. I haven't noticed a particularly anti-vet attitude from this independent , non-partisan organisation. They may be a bit hidebound and bureaucratic, but not exactly anti-vet. I think the evidence, m'lud, is that they, unlike European counterparts have supported our privilege to dispense.

The other Jonathan Wray is more interested in seeing the response of the BVA and RCVS to this suggestion. He thinks both will hope it founders, the RCVS because of the howls it will get from PSS practices and the BVA because it cannot decide how to support non-PSS practices. Both organisations can make headlines relishing the challenges ahead in 2011, but they're not that great at making decisions and keeping all parties sweet. There is a dearth of creative thinking.

JGW

Re: Non PSS Meds inspection

Bob Russell — Fri, 07 Jan 2011 13:14:08 GMT

Good letter in the VR by Jonathan Wray and do I see a glimmer of light from the response by Steve Dean?

Is an element of common sense creeping in and a less anti-vet attitude from the VMD? I do hope so!

Re: Non PSS Meds inspection

karen jones — Fri, 19 Nov 2010 19:16:57 GMT

Apparently can do spot checks at any time with PSS. It went ok I think except the inspector turned up an hour early before the practice manager got there but the receptionist coped well and we were only picked up on a few minor things!

We have been a hospital practice for years, initially due to the now retired senior partner. each time it comes up for reinspection we have a discussion whether to carry on. We did the farm PSS this time so we didnt have to have VMD inspection . Farm vets seem to do their own thing in their cars so I leave it to them .One part of PSS is monitoring of temperatures in the cars but there is no stipulation what to do this info so I put it in a file................... the whole thing is a paper exercise which I keep in office upstairs after getting staff to sign that they've read the H&S info

Re: Non PSS Meds inspection

Bob Russell — Fri, 19 Nov 2010 14:03:56 GMT

[quote user="Michael Woodhouse"]

[quote user="Bob Russell"]Needless to say I am not suggesting we should be injecting WFI!!![/quote]

That's what it's for, Bob! The daftest thing to EVER make POM-V!

[/quote]

Sorry - did not make it clear - do not inject WFI in place of proper medication - even that does not make much sense must be Friday

Re: Non PSS Meds inspection

Michael Woodhouse — Fri, 19 Nov 2010 13:22:39 GMT

[quote user="Bob Russell"]Needless to say I am not suggesting we should be injecting WFI!!![/quote]

That's what it's for, Bob! The daftest thing to EVER make POM-V!

Re: Non PSS Meds inspection

Bob Russell — Fri, 19 Nov 2010 09:55:49 GMT

[quote user="Gillian Mostyn"]

Ours was VMD, not PSS, and as far as I am aware the 'guidelines' for the 28day discard are pretty firm?

[/quote]

The VMD have made it very clear in the past that this 28 days rule is more a quality issue and comes under the remit of trading standards rather than them. The logic, if there is any being that if you are injecting a 29 days opened product it is no longer fit for purpose!!

If we chose to inject water for injection instead of a particular drug as long as it has not been open more than 28 days they have no control over our actions. It would of course be fraudulent so would be covered by trading standards as well as our own professional standards.

Needless to say I am not suggesting we should be injecting WFI!!!

Re: Non PSS Meds inspection

Gillian Mostyn — Fri, 19 Nov 2010 09:28:07 GMT

Ours was VMD, not PSS, and as far as I am aware the 'guidelines' for the 28day discard are pretty firm?

Re: Non PSS Meds inspection

Peter Ding — Fri, 19 Nov 2010 09:13:30 GMT

28 day guideline!

The PSS inspectors are certainly not bothered if bottles, of antibiotic for instance, beyond that period by a week or two.

Re: Non PSS Meds inspection

Gillian Mostyn — Thu, 18 Nov 2010 20:53:22 GMT

Have to admit inspector was very nice and inspection today went well. He thought that the 28 day rule is absolutely ridiculous and is not based on any facts - just a number plucked from the air. We had to obviously abide by the rules today but nice to see that even the inspector thinks the rules are flawed!

Re: Non PSS Meds inspection

J G Wray — Thu, 18 Nov 2010 19:43:44 GMT

[quote user="karen jones"]having a spot check of our branch surgery tomorrow (PSS) Fortunately had phone call on wednesday at 6.30pm so have been able to check that everythings ok as I am too busy to get over on Friday so will have to delegate.....This time of year in a mixed practice is hectic so the vets tend to be fully booked. I am not sure what to expect.[/quote]

Phew!

What precipitated the spot check?

Presumably you will be paying for this. I hope you get good value.

JGW

Re: Non PSS Meds inspection

karen jones — Thu, 18 Nov 2010 18:39:13 GMT

having a spot check of our branch surgery tomorrow (PSS) Fortunately had phone call on wednesday at 6.30pm so have been able to check that everythings ok as I am too busy to get over on Friday so will have to delegate.....This time of year in a mixed practice is hectic so the vets tend to be fully booked. I am not sure what to expect.

Re: Non PSS Meds inspection

Martin Atkinson — Thu, 18 Nov 2010 15:38:31 GMT

[quote user="Evelyn Barbour-Hill"]

[quote user="Martin Atkinson"]rather than getting their arses in their hands [/quote]

Their what?

[/quote]

Its a saying my father used, he was from the Midlands so its translation isn't precise! I interpreted it as a cross between getting your knickers in a twist, throwing your toys out of the cot and making a mountain out of a molehill - maybe getting unecessarily angry or sulky about a perceived slight or minor irregularity. Does that fit?

Re: Non PSS Meds inspection

Bob Russell — Wed, 17 Nov 2010 16:45:46 GMT

[quote user="bob lehner"]

[quote user="Bob Russell"]A random inspection makes better sense to me. I assume once you have had your inspection you can sit back and break the rules for a few years. The knowledge that an inspection can happen at almost any stage is more likely to keep you on your toes![/quote]

PSS practices can be (and are) subjected to spot checks at any time between their four yearly inspections.

[/quote]

If the VMD cannot keep up with four yearly inspection are they likely to do random inspections as well? I have absolutely no argument with inspections in principle and would have no objection to random or routine inspection. I think random visits would be a more efficient way of using inspectors.

In the old days practices could (but rarely were) be inspected and the controlled drugs registers against drugs present and used checked. Enforcement of this would keep the Shipman element out of the equation.

If the main purpose of the VMD inspection is to check if we are complying with cascade and labelling bottles with broach dates that is another matter!!!

Re: Non PSS Meds inspection

bob lehner — Wed, 17 Nov 2010 16:32:24 GMT

PSS practices can be (and are) subjected to spot checks at any time between their four yearly inspections.

Re: Non PSS Meds inspection

bob lehner — Wed, 17 Nov 2010 16:28:49 GMT

[quote user="Bob Russell"]Shipman is of limited relevance to vets as we do not (as a rule) have access to elderly people that we can con out of their savings and quietly overdose with morphine![/quote]

No - but veterinary practices do carry dangerous and addictive drugs - and this is well known to the criminal fraternity, as well as the obvious possibilities for mis-use within the practice by vets and other staff. Post Shipman I think the authorities had to look at the wider implications of who is allowed to hold drugs like morphine and had to be seen to be tightening up on their general regulation. Let's be honest, there were some veterinary practices out there that were pretty lax about how they handled these products - hopefully less so these days.

Re: Non PSS Meds inspection

Evelyn Barbour-Hill — Wed, 17 Nov 2010 15:49:34 GMT

[quote user="Martin Atkinson"]rather than getting their arses in their hands [/quote]

Their what?

Re: Non PSS Meds inspection

Mark Holmes — Wed, 17 Nov 2010 15:32:54 GMT

[quote user="Bob Russell"]

Shipman is of limited relevance to vets as we do not (as a rule) have access to elderly people that we can con out of their savings and quietly overdose with morphine!

[/quote]

Most of us have access to one or two

Re: Non PSS Meds inspection

J G Wray — Wed, 17 Nov 2010 15:23:12 GMT

[quote user="bob lehner"]the PSS now requires daily fridge temperature monitoring - which I think is more sensible than weekly - if your vaccine fridge does conk out you don't want to wait a week to find out, particularly in the heat of the summer). [/quote]

Have to disagree there. I think it is silly to record a non-event, i.e. fridge at normal temperature. I think we should record abnormality. So, checking the fridge daily and recording any action taken if too high or low is what should be doing.

[quote user="bob lehner"]I would be interested to know how long the VMD inspector spent with you. PSS inspectors have to look at a multitude of other topics, over and above those relating to medicines, so the VMD inspector would seem to have a somewhat easier job.[/quote]

A couple of hours, but that's because we swapped anecdotes. Interestingly he opened his session by pointing out that it was not a PSS style visit and unlike PSS I would not be incurring the cost of lost fee earning time and paying for cover to nearly the same extent. Of course he has an easier job, he's only doing the meds, but he is independent of any veterinary body and therefore, in my view, his inspection carries a higher level of authority for the public.

[quote user="bob lehner"]I can't personally see the authorities allowing self-certification on medicine issues post Shipman.[/quote]

Bah humbug! - seasonal note

It may be a matter of necessity. 3 inspectors going to 2,500 practices every four years plus merchants wholesalers, feed-additive people etc etc doesn't compute. However, if we are allowed to certify and spot check, the VMD can save and rely on the RCVS regulatory system to pull in non-compliers.

JGW

Re: Non PSS Meds inspection

Martin Atkinson — Wed, 17 Nov 2010 14:44:39 GMT

[quote user="Bob Russell"]

If we can be trusted with POM's we should be trusted to self-certify. Random potentially short notice inspections would seem to be a more efficient way of using scarce resources.

I have no problem with such inspections. We may not get 9/10 for all box-ticking but I guarantee our handling of medicines is both ethical and safe. This is more important than ticking boxes however box-ticking exercises can help prevent things slipping through the net!

[/quote]

Ditto. However, I suspect that although most of us would get less than 9/10 for box ticking we'd get 10/10 for common sense. For example, wouldn't you notice the fridge didn't feel very cold if if it when off today and would the vaccines really die if it did? And just to add a bit of controversy: a) would it matter if they did die given we only need to give them every 3 years but most vets still give annual boosters, b) wouldn't time be better spent by officialdom making sure ALL vets kept their CPD up to speed rather than getting their arses in their hands over a few labelling anomalies? Just some food for thought.

Re: Non PSS Meds inspection

Bob Russell — Wed, 17 Nov 2010 12:21:52 GMT

A random inspection makes better sense to me. I assume once you have had your inspection you can sit back and break the rules for a few years. The knowledge that an inspection can happen at almost any stage is more likely to keep you on your toes!

Shipman is of limited relevance to vets as we do not (as a rule) have access to elderly people that we can con out of their savings and quietly overdose with morphine!

I did see an article where the head policeman in charge of finding other Shipmans expressed the opinion that he was not worried about vets and controlled drugs as the only people they were likely to hurt were themselves!!! Not a nice thought but quite appropriate with our history of suicides.

Not an excuse for less regulation of controlled drugs but can be used as a reason for only employing four inspectors in the UK.

Re: Non PSS Meds inspection

bob lehner — Wed, 17 Nov 2010 11:16:26 GMT

[quote user="Jonathan Wray"]

Do you think the PSS inspectors are operating in the same way? I like to think that because they're part of an official Government organisation, their approval carries a higher level of authority than the obvious self-interest of the vets regulating vets system.

What do you think of the idea of self-certifying?

[/quote]

Reading your account of your VMD inspection it would seem to me to be pretty similar to the medicines part of a PSS inspection. Of course there will be some discrepancies ( e.g. from your examples - the PSS now requires daily fridge temperature monitoring - which I think is more sensible than weekly - if your vaccine fridge does conk out you don't want to wait a week to find out, particularly in the heat of the summer).

I would be interested to know how long the VMD inspector spent with you. PSS inspectors have to look at a multitude of other topics, over and above those relating to medicines, so the VMD inspector would seem to have a somewhat easier job.

I can't personally see the authorities allowing self-certification on medicine issues post Shipman.

Re: Non PSS Meds inspection

Bob Russell — Wed, 17 Nov 2010 09:24:57 GMT

If we can be trusted with POM's we should be trusted to self-certify. Random potentially short notice inspections would seem to be a more efficient way of using scarce resources.

Re: Non PSS Meds inspection

Gillian Mostyn — Tue, 16 Nov 2010 22:22:39 GMT

very true! They'd probably try.

Re: Non PSS Meds inspection

Evelyn Barbour-Hill — Tue, 16 Nov 2010 22:16:23 GMT

[quote user="Gillian Mostyn"]

[quote user="Jonathan Wray"]What do you think of the idea of self-certifying?[/quote]

well it would save us £250.

[/quote]

How do you know they wouldn't charge you £250 for accepting your self-certification?