Managing controlled substances can be a daunting task that usually falls squarely on a veterinary technician’s shoulders. Issues arise when a technician does not understand the regulations or when the hospital lacks good systems for preventing the illegal acquisition, diversion and use of controlled drugs.
Federal, state and local governments regulate controlled substances. The U.S. Drug Enforcement Administration serves as the primary federal agency responsible for enforcement of the Controlled Substance Act (CSA).
Drugs that fall under the CSA are divided into five schedules:
- I: No accepted use in human or veterinary medicine. The potential for abuse is high.
- II: A high potential for abuse that “may lead to severe psychological or physical dependence,” according to the CSA. The federal government sets production limits for these drugs.
- III: Lower potential for abuse than Schedule I or II drugs. Any abuse may lead to moderate or low physical dependence or high psychological dependence.
- IV: Even lower potential for abuse.
- V: Lowest potential for abuse. These drugs consist primarily of preparations containing limited quantities of certain narcotics.
Most controlled drugs used in veterinary hospitals are classified under Schedules II, III and IV.
Understand Basic Rules
A current, original and address-specific DEA license must be on file at the clinic and with drug vendors before a hospital can purchase, store or dispense controlled substances. Each veterinarian who prescribes controlled substances that a client then obtains elsewhere must obtain a separate DEA registration.
Additional and separate address-specific DEA registration numbers are required:
- If a doctor orders, oversees or dispenses controlled substances at more than one hospital.
- When the ordering, storing and dispensing is separate and distinct from the primary hospital environment, such as at a satellite clinic or animal shelter or with an unaffiliated house-call practice.
Additional and separate address-specific DEA registration numbers are not required when:
- The activities are considered an extension of hospital-based ordering and dispensing.
- House-call services or in-home euthanasia is performed using a registered hospital as a home base.
Take Precautions
The diversion of controlled substances in the veterinary profession is rampant. Establishing a drug-free workplace is essential, as is performing pre-employment background and drug screenings of all potential new hires, including veterinarians. Several states require background checks and additional screenings of employees who have access to controlled substances.
Establishing procedures and protocols is essential in maintaining the security of controlled substances. Unopened containers — your back stock — must be securely stored in an immoveable cabinet. This means something that is attached to the building, such as a wall safe.
Opened containers in active use may be stored in a locked, less substantial, immobile cabinet or drawer during working hours. All supplies are to be locked in substantial cabinets when not in active use, which means they must be returned to the most secure location at the end of the day.
Schedule II drugs must be stored separately from those in schedules III, IV and V. This can be accomplished by placing them on separate shelves in the drug safe. If controlled substances such as the anesthetic agent Telazol are to be stored in a refrigerator, they should be placed in a locked box attached to a shelf. A refrigerator lock would be appropriate.
Maintain Paper Trail
Proper recordkeeping is an essential step in maintaining controlled drugs. Usage logs are required for all controlled substances when they are administered in or dispensed from the practice. That means every milliliter, tablet, capsule and patch.
Schedule II logs must be stored separately from Schedule III, IV and V logs. The records should be bound, although loose-leaf binders with clear dividers are acceptable. Entries should be made in black or blue ink.
Using a pencil or correction fluid or making alterations is not acceptable. The way to handle a mistaken entry is to draw a line through it and add a brief explanation and your initials.
Logs should include:
- Date of activity
- Client name
- Client address or unique chart number
- Patient name
- Amount used or dispensed
- Balance after use
- The drug handler’s initials (not just the doctor who prescribed or ordered the drug)
Drug logs kept within practice management software are acceptable if the above information is entered and is unalterable.
Know Your Numbers
Logs should be reconciled and balanced as you go rather than weekly or monthly. Discrepancies or math errors caught early are easier to fix.
In addition to logging requirements, the DEA requires a full and complete inventory count at these specific intervals:
- Initial inventory: With controlled substances engagement, such as upon opening or purchasing a practice
- Biennial inventory: Every two years thereafter
- Closing inventory: When a practice is closed or sold
Although the DEA requires counts only every two years, more frequent checks are a good idea. Remember that all logs are required to be retained for at least two years and kept onsite.
Outdated, damaged, unusable or unwanted controlled drugs require proper disposal. The DEA offers drug-disposal information at bit.ly/2s8pfa3.
An increasing number of individual state agencies require additional reporting of controlled substances when dispensed to a client for home use, so check the DEA website or with your local veterinary medical association or state licensing board.
When you and your team understand the regulations and the importance of having good systems in place, managing controlled substances will not be such a daunting task.
Popular veterinary drugs
Schedule II
- Hydromorphone
- Morphine
- Fentanyl
- Oxymorphone
- Pentobarbital sodium
- Demerol
Schedule III
- Hydrocodone (Tussigon)
- Ketamine
- Telazol
- Buprenex (Buprenorphine)
Schedule IV
- Alfaxan (Alfaxalone)
- Diazepam (Valium)
- Alprazolam
- Phenobarbital
- Torbugesic (Butorphanol)
- Tramadol