Richard Hough and Thorrun Govind refresh pharmacists’ knowledge on veterinary medicines following some legislative changes to the regulations earlier this year…

Historically, pharmacies played a pivotal role in animal health with veterinarians issuing prescriptions and pharmacists dispensing them. However, over time changes in NHS contract responsibilities eventually eroded pharmacists’ involvement in this area.

Earlier this year, the Competition and Markets Authority (CMA) published its main concerns following its review of the veterinary sector:

·      Lack of consumer information: Pet owners may not receive enough information to choose the best veterinary practice or treatment.

·      Weak competition: Local market concentration, partly due to sector consolidation, may lead to weak competition in some areas.

·      Corporate influence: Large corporate groups might reduce choice and weaken competition.

·      Overpricing: Pet owners could be overpaying for medicines or prescriptions.

·      Outdated regulations: The current regulatory framework may no longer be suitable.

While it might be convenient to purchase medicine directly from the vet during a consultation, the CMA noted that around 25% of pet owners were still unaware they could fill prescriptions elsewhere, potentially saving money even after paying the prescription fee.

Access to medicines

In response to these concerns, the CMA provisionally decided to launch a formal market investigation.

Given the increased focus on access to veterinary medicines and the rise of online retailers, it is important for pharmacists to stay informed about the legal framework which governs the supply of veterinary medicines, particularly as pet owners are seeking more competitive pricing. 

Owners will also be looking for reassurance as to where to purchase medication. Under changes made earlier this year to the Veterinary Medicines Regulations 2013 (VMR), online retailers of veterinary medicines are now required to register with the Veterinary Medicines Directorate’s (VMD) Register of Online Retailers.

Registered Qualified Persons (RQPs)

Only veterinary surgeons can diagnose clinical conditions in animals. Under the VMR, veterinarians, pharmacists, and Suitably Qualified Persons (SQPs), collectively known as RQPs, can prescribe or supply certain categories of authorised veterinary medicines, including:

•        Prescription Only Medicine – Veterinarian (POM-V);

•        Prescription Only Medicine – Veterinarian, Pharmacist, SQP (POM-VPS);

•        Non-Food Animal – Veterinarian, Pharmacist, SQP (NFA-VPS); and

•        Authorised Veterinary Medicine – General Sales List (AVM-GSL)

The highest level of control is the POM-V category, which includes veterinary medicines containing controlled drugs and those intended for administration only following a diagnosis and clinical assessment by a veterinary surgeon.

The Cascade

The veterinary cascade is a regulatory framework within the VMR that provides veterinarians with the flexibility to prescribe medicines that are not specifically authorised for a particular species or condition (akin to off-licence prescribing).

This risk-based system is essential for ensuring that animals receive the necessary treatment when a suitable authorised medicine is not available.

Considerations for prescribing and supplying under the cascade include risks to the animal, the owner, the person administering the medicine, the environment, consumers of produce from treated animals, and broader public health concerns.

Only vets who are registered with the Royal College of Veterinary Surgeons (RCVS), the regulatory body for veterinary surgeons, may prescribe the following types of medicines under the cascade.

SQPs may supply an authorised veterinary medicine that falls within the scope of the registration they hold, against a prescription from a vet for use under the cascade.

1.   A veterinary medicine with a marketing authorisation valid in GB or UK-wide for the specific condition and species being treated. These medicines have been tested and approved for safety and efficacy for that particular use.

2.   A veterinary medicine with a marketing authorisation valid in Northern Ireland for the specific condition and species being treated, in accordance with a special import certificate (a SIC) granted by the VMD.

3.   A veterinary medicine with a marketing authorisation valid in GB, NI or UK-wide for a different species or condition. For products not authorised in GB or UK-wide, a SIC is required.

4.   A human medicine with a marketing authorisation valid in GB, NI or UK-wide or an authorised veterinary medicine from outside of the UK. For products not authorised in GB or UK-wide, a SIC is required; in the case of a food-producing animal, the medicine must be authorised for a food-producing species.

5.   If none of the above options are suitable, an extemporaneous preparation prepared by a vet, pharmacist or person holding an appropriate manufacturer’s authorisation, located in the UK is acceptable.

It is an offence to promote or facilitate any use of the cascade which is not in accordance with Schedule 4 of the VMR.

Piriton for my cat?

Pharmacists might encounter conflict if a pet-owning customer seeks to purchase medication over the counter which they state is for their animal. In some cases, the individual might even advise that a veterinarian has told them to do so.

The RCVS is very clear that pet owners should not be advised or encouraged to purchase human medicines for their pet from a pharmacy. This would count as a veterinary prescription, even where the human-licensed medicine is not itself prescription-only.

Furthermore, the justification for provision in this case, would also need to account for why a veterinary medicine (authorised for that species and condition, or for another species or condition) could not be used instead.

Richard Hough is a partner and head of healthcare at Brabners LLP and a former pharmacist. His co-author Thorrun Govind is a solicitor at Brabners, a pharmacist and TV health expert.