Vets involved in the prescribing, supplying, recording, storing and disposing of Controlled Drugs (CDs) must comply with the law on the misuse of drugs and veterinary medicines.
When disposing of unused CDs listed in Schedule 2 of the Misuse of Drugs Regulations, vets must ensure that they are destroyed in the presence of and as directed by any one of the following:
- an inspector appointed under the Veterinary Medicines Regulations
- a vet, independent of the practice where the destruction takes place
- a person legally authorised to witness the destruction of CDs such as a Police CD Liaison Officer (CDLO)
We commissioned a survey of vets on issues relating to the use and disposal of CDs to better understand the extent of the issues that they face in complying with their legal obligations. The survey ran for 5 weeks from May to June 2018 and contained 10 questions.
We received 511 responses to the survey and this document provides a summary of the comments received.
The views expressed in the survey will be used to inform our policy in relation to the destruction of controlled drugs in veterinary practices.
Q1 What area is your practice based?
Answered: 507 Skipped: 4
| Region Choices | Responses |
|---|---|
| Scotland | 38 |
| Northern Ireland | 5 |
| North East England | 30 |
| North West England | 53 |
| West Midlands | 41 |
| East Midlands | 37 |
| East England | 44 |
| South Wales | 16 |
| South West England | 80 |
| South East England | 91 |
| Greater London | 72 |
Q2 What type of practice do you work at?
Answered: 510 Skipped: 1
| Region Choices | Responses |
|---|---|
| Mixed | 56 |
| Companion | 436 |
| Equine | 3 |
| Farm | 15 |
Q3 Who do you use as a first option to witness the disposal of controlled drugs?
Answered: 503 Skipped: 8
| Region Choices | Responses |
|---|---|
| Police Controlled Drugs Liason Officer (CDLO) | 148 |
| VMD/RCVS Inspector | 97 |
| Independent Vet | 258 |
Q4 If your first option is unavailable, who would you use to witness the disposal of controlled drugs?
Answered: 491 Skipped: 20
| Answer Choices | Responses |
|---|---|
| CDLO | 118 |
| Inspector | 131 |
| Independent Vet | 242 |
Q5 How often do you routinely dispose of controlled drugs?
Answered: 509 Skipped: 2
| Answer Choices | Responses |
|---|---|
| Once a month | 26 |
| More than once a month | 7 |
| Ever 3-4 months | 132 |
| Every 6 Months | 102 |
| Less than once a year | 138 |
| Once a year | 104 |
Q6 Have you ever experienced any difficulty getting someone to witness disposing of Controlled Drugs?
Answered: 511 Skipped: 0
| Answer Choices | Responses |
|---|---|
| Yes, often | 267 |
| Yes, occasionally | 114 |
| Yes, but very rarely | 36 |
| No difficulty at all | 94 |
Q7 If you answered yes to question 6, please could you explain what the issue has been?
Answered: 401 Skipped: 110
Finding an independent vet. The reasons given were:
- the location of the practice being too isolated
- the nearest practice is a competitor
- that they are part of a chain of vet practices, therefore other vets aren’t deemed independent
- time spent finding a vet that is willing to take time out to witness the disposal
Getting CDLOs to witness disposal. The reasons given were:
- not enough local CDLOs or none at all in their area
- police are reluctant to come out to witness disposal and this is low on their list of priorities
- the police are not always aware of the regulations for controlled drugs disposal
No local RCVS or VMD inspectors which results in practices stockpiling drugs and waiting until their next inspection to dispose of them, causing lengthy delays.
Answered: 419 Skipped: 92
| Answer Choices | Responses |
|---|---|
| CDLO | 119 |
| VMD | 176 |
| RCVS | 124 |
Q9 Please list the most commonly used controlled drugs used in your practice using either the active substance or trade-mark name?
Answered: 498 Skipped: 13
| Controlled drug listed in descending order of use: |
|---|
| Methadone |
| Ketamine |
| Morphine |
| Fentanyl |
| Buprenorphine |
| Phenobarbital |
| Pentobarbital |
| Tramadol |
| Diazepam |
| Secobarbital |
| Midazolam |
| Pethidine |
| Etorphine |
| Clenbuterol |
| Codeine |
The following products listed by respondents were not CDs:
- Butorphanol
- Torbugesic
- Cinchocaine
- Gabapentin (Although Gabapentin was placed in Schedule 3 of the Misuse of Drugs Regulations 2001 from April 2019)
Q10 Please let us know if you have any other suggestions or concerns in relation to controlled drugs being used as veterinary medicines?
Answered: 173 Skipped: 338
The concerns raised followed these themes:
-
General concerns around the destruction of controlled drugs with practices in rural areas experiencing more difficulty. Practices reported stockpiling CDs awaiting destruction because of the difficulty in finding a person to witness.
-
The 28 day broach rule which some feel results in the unnecessary amounts of wastage. Some practices do not follow the 28 day rule and reported carrying on using products until the vial is empty.
-
Insufficient guidance on recording CDs and wastage, with too much regulation and red tape making it difficult to comply.
The suggestions followed these themes:
-
Increase the pool of people able to witness the destruction by allowing staff from the same practice or corporate group to witness disposal. Instead of an external vet two internal vets could sign and witness the disposal.
-
Encourage manufacturers to produce 2ml or 5ml vials for drugs like Ketamine that would lead to less wastage.
-
Put measurement markers on bottles which would help to carry out stock checks.
-
Introduce longer broach dates to minimise waste and financial loss.
-
Make disposal procedure easier and provide clearer guidance on storage and disposal of CDs.
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