Practical adherence to controlled drugs regulations - help please!

Re: Practical adherence to controlled drugs regulations - help please!

Michael Woodhouse — Thu, 03 Feb 2011 18:18:38 GMT

[quote user="Mark Thirkell"]

May I suggest that it is possible to provide satisfactory balanced analgesia using licensed, non-CD opiates, NSAID, local analgesia, medetomidine (etc) and atraumatic surgical technique and thus avoid the many potential pitfalls of using and recording CDs. I know morphine is cheap to buy but the administrative burden makes it costly to use.

[/quote]

Agree 100%

Re: Practical adherence to controlled drugs regulations - help please!

Rob Loxley — Thu, 03 Feb 2011 18:16:34 GMT

[quote user="Mark Thirkell"]non-CD opiates[/quote]

Um, buprenorphine is a CD...

[quote user="Mark Thirkell"]the administrative burden makes it costly to use[/quote]

Yes sorting out compliance and protocols takes a bit of upfront time but the aforementioned BVA guides and guidance on the RPSGB website make this more easy. The ongoing 'administrative burden' is low, and IMHO outweighed by the benefits of having the sched 2 CDs available.

[quote user="bob lehner"]However for larger volumes of unused or out of date Sch 2 CDs...[/quote]

Our answer to this is to keep sufficiently low stocks of sched 2 CDs, only stock what we will definitely use, and definitely use it before it goes out of date

Re: Practical adherence to controlled drugs regulations - help please!

bob lehner — Thu, 03 Feb 2011 17:18:54 GMT

The simplest and clearest instructions that I have found with regard to what to record in the CD Register are in a). BVA Good Practice Guide on Veterinary Medicines (see p 5), or b) BSAVA Guide to the Use of Veterinary Medicines - 'Controlled Drugs' - 'Record Keeping'. Both of these are available on the BVA or BSAVA websites.

For disposal of unused Sch 2 CDs see the VMD Veterinary Medicines Guidance Note No 29 'Controlled Drugs' - 'Destruction', available on the VMD website. I have had it on very high authority that for part-used small (1 ml) vials of Sch 2 CDs it is acceptable to dispose of the vial and any left overs in the sharps bin - tipping out the contents so that it cannot be recovered. You must however record the entire contents of the vial to the patient so as to keep your running balance in the CD Register accurate. Alternatively you could use a denturing kit to dispose of the residue . However for larger volumes of unused or out of date Sch 2 CDs (eg 50 ml bottle of pethidine) you must go through the denaturing process using a 'denaturing kit' (available from your Clinical Waste company or wholesaler) to render it unusable and this must be witnessed by a designated person (e.g. AMI inspector , PSS Inspector or a witnessing VS who is independent of the practice concerned).

Re: Practical adherence to controlled drugs regulations - help please!

Mark Thirkell — Thu, 03 Feb 2011 17:17:27 GMT

Re: Practical adherence to controlled drugs regulations - help please!

Mark Holmes — Thu, 03 Feb 2011 15:28:46 GMT

With regards to 1) I usually vary my dosing to try and avoid discards. With 10mg/ml and 30mg/ml available and a reasonably wide theraputic range you can usually come up with something. If thats not possible I ditch it into the sharps but tip it out (ie no longer in the vial). I would consider a fraction of a ml amongst a bucket of sharps "beyond use" to all but the most committed and record it as disposed of.

2) Ordering I usually just order small quantities and am aware of when they are ordered and expected to arrive. The only problem we have had is Dunlops delivered morphine to us for a neighbouring practice on a day when myself and the head nurse were absent. It was put into the safe and nobody realised it was there. Not a problem for us but caused a headache for Dunlops and the neighbouring practice who were trying to locate it.

Re: Practical adherence to controlled drugs regulations - help please!

An On MRCVS — Thu, 03 Feb 2011 15:09:10 GMT

Thanks Mark. That does help and is the same as what we've been doing, so I think will probably just keep dong this. Neither the VMD, nor the Home Office representative they directed me to, seemed to be able to distinguish between admininistering and supplying and told me that the column headings in a controlled drugs book were legally specified. I would agree with your definition of 'suppy' (as would common English parlance) and I never do this, I therefore didn't want to initial multiple entries a day to say I had! Will bin the 'Controlled Drugs book' that we ordered and just use a bound notebook with manually inserted headings that make a bit more sense :-)

2 further points I'd appreciate advice on:

1) What do you do wth the remainder of a vial of morphine? (I normally drop them into the sharps bin once I've taken what I need, but am told that that's not acceptable as have to 'denature' the remnants; was also told that I couldn't then record this as one vial used, but would have to record amount used/'supplied' in mls and then on separate line amount disposed of, which I'm permitted to calculate rather than measure so it adds up correctly!)

2) Ordering: currently order via Dunlops (who obviously aren't that up on the regs as they require a faxed authorisation for Apomorphine!) and it occurred to me that really I should record in CD register when I signed an aquisition for morphine (or indeed personally faxed it) so that I could ensure it arrived and was put into the safe?

Re: Practical adherence to controlled drugs regulations - help please!

Rob Loxley — Thu, 03 Feb 2011 15:05:14 GMT

We have a bound A5 Black'n'red book marked up as our CD register. We have running balances as it makes stock-checking simpler. We have vet signature (and witness) recorded but not RCVS number (we can easily supply RCVS numbers if required).

We treat CDs as recieved from the wholesaler and supplied to an individual animal (be it a whole patch or vial etc.). This doesn't mean that the owner is given the drugs but the drugs are signed out to the named animal. It makes it easy to deal with left over portions of vials or MLK infusions as 'patient-returned drugs'. If sending CDs out of the practice door then it would seem sensible to record to whom they are given.

The VMD and BVA's recent guidelines are an improvement; when we formulated our CD protocol and SOPs there wasn't that available and advice was sought from the RPSGB and Home Office who seemed to find our protocols sensible, as did our PSS inspectors.

Re: Practical adherence to controlled drugs regulations - help please!

Mark Holmes — Thu, 03 Feb 2011 14:46:55 GMT

I think you need to distinguish between administering and supplying. By supplying I would take that as the owner removing the drug from the practice in a useable form. That is, not inside the dog. (unless ingested in a vial and if thats the case you have bigger problems to deal with)

I usually record a box of 5 x 1ml vials as entering the practice and then record which 5 dogs they were used in with a running total presently in the practice.

This way if you come to a box expecting 4 vials and there are only 3 (plus one very smiley nurse (or VNA)) you can start investigations. Some practices have a register for enteries and a separate regester for useage. That is much more difficult to police.

Hope that helps

Mark