Record keeping

Any veterinary surgeon who supplies a prescription medicine must keep the following records for at least five years for all incoming drugs (purchased from wholesalers) and outgoing drugs (prescribed and supplied to clients):

•   date and nature of transaction

•   name of the veterinary medicinal product (VMP)

•   the batch number (in the case of a medicine for a non-food producing animal, this need only be recorded either on the date the batch was received or the date the batch was first used)

•   quantity received or supplied

•   name and address of the supplier or recipient

•   if there is a written prescription, the name and address of the person who wrote the prescription and a copy of the prescription

•   record of the most recent drug audit

•   all imported medicines have the correct relevant paperwork (special import certificates (SICs) and special treatment certificates (STCs).

The requirement for keeping records of drugs purchased may be met by retaining the invoices or delivery notes from wholesalers.

Record keeping for Controlled Drugs

When ordering Schedule 2 and 3 Controlled Drugs, a written requisition signed by a veterinary surgeon should be supplied to the wholesaler. This requisition must state the veterinary surgeon’s name, address and professional qualifications (Figure 1).

Figure 1: Keys to Controlled Drugs cupboards need to be secure, either held by a specified person or locked away when not required

All invoices relating to Controlled Drugs should be kept for two years and a separate Register should be kept for all premises and for each cupboard, if there is more than one. This Register should be in the form of a bound book or computerised record.

Within this Register, each drug, form and strength must have a separate section with the medicine name and strength written at the top of each page; and entries must be made in chronological order with no alterations. If a mistake is made, an explanatory note must be made at the bottom of the page or margin.

Registers may only be kept electronically if safeguards are built into the software to ensure the following:

•   the author of each entry is identifiable

• entries cannot be altered at a later date

• a log of date entered is kept and can be recalled for audit purposes.

The Register must be completed within 24 hours. For example, it is acceptable during procedures to mark on a white board the quantities administered and complete the Register at the end of the day. Legally the Register should be kept for two years. However, since all other paperwork relating to the Veterinary Medicines Regulations (VMR) must be kept for five years, this is recommended.

Controlled Drugs Register

The table summarises the information that should be recorded in the Controlled Drugs Register. If a Schedule 2 Controlled Drug is dispensed to a client, the following additional information should also be recorded:

•   name of the person collecting the Controlled Drug

•   was proof of identity of the person collecting the drug requested (yes/no)? Either way, record the details.

The dispensing and recording of Controlled Drugs also brings into sharp relief the importance of pharmacy stock control to include updating of client records, details of labelling instructions and advice given to clients about these things.

Regular pharmacy ‘stock takes’ are essential and clients should be encouraged to do the same thing so that at any one time there is a coherent legal chain of distribution.

Audits

A detailed audit should be carried out at least once a year. Incoming and outgoing medicines should be reconciled with the stock held and any discrepancies noted.

To achieve this, the practice needs to:

•   perform a full ‘stock take’ of all prescription drugs

•   keep records of all drugs received (e.g. by retaining invoices or delivery notes from wholesalers)

•   keep records of all drugs supplied to clients (e.g. by practice computer system or by sales log)

•   record any out-of-date or damaged drugs discarded.

If computerised records are used, there must be an adequate back-up system in place.

It is up to the practice to account for discrepancies and decide what level is acceptable. Obviously there will be discrepancies in the case of drugs used during procedures and not priced individually – premedicants, anaesthetics and euthanasia drugs, for example.

One category of drugs which should be audited continuously is Controlled Drugs. This can be achieved by recording supply and use, and keeping a running total in the Controlled Drug Register, and having a system of reconciling this with stock-in-hand on a regular basis.

Return of medicines

As correct storage conditions – and therefore safety and efficacy – of medicines returned by owners cannot be guaranteed, such medicines should be disposed of and not accepted back into stock (Figure 2). However, medicines supplied for animals on the premises can be accepted back into stock, providing the storage conditions are known to be acceptable.

Figure 2: Returned medicines should be disposed of in pharmaceutical waste

Returns to wholesalers should be completed as soon as possible. There may be restrictions on such returns because returned VMPs are usually destroyed.

Record keeping and audits

Veterinary practices should have an efficient stock control system to monitor the use of veterinary medicines and to allow for the recall of an individual medicine or particular batch. Records of the most recent drug audit will be checked by the Veterinary Medicines Directorate (VMD) and Royal College of Veterinary Surgeons (RCVS) Practice Standards Scheme (PSS) inspectors during practice inspections.

The VMD guidance clearly states that a system linking incoming and outgoing transactions with stock held may provide an ongoing running total which, with the addition of a periodic physical stock count to verify stock held, may meet the audit requirement.

One area of record keeping that is tightly controlled is the Controlled Drugs book. It is important to either record the patients’ details by hand or if your system is computerised, to print off a label w
hen the drug is booked out. This is then stuck into the drugs book and the veterinary surgeon must sign across the label and the book. Initials are not acceptable.

The amount of drug dispensed is then deducted from the stock kept and also recorded alongside the entry. This should enable an inspector to identify how much of each drug is in stock and verify it instantly by looking in the locked cabinet. 

Essential information that should be recorded in the Controlled Drugs Register

Controlled Drugs received

•   Date received

•   Name and address of the person or supplier from whom the drug was obtained

•   Amount received

•   Form in which received

•   Running total (recommended)

Controlled Drugs supplied

•   Date supplied

•   Name and address of the person to whom the drug was supplied

•   Name and signature of veterinary surgeon

•   Amount supplied

•   Form in which supplied

•   Running total (recommended)

Author(s)

Amanda Rock BVSC MRCVS PGCE

Amanda graduated from Liverpool University in 1998 and has since worked as a veterinary surgeon in Cornwall, first in mixed practice and later in critical care and emergency work. She enjoys writing for the veterinary press and has contributed to several nursing textbooks.

Nicola Ackerman

BSc(Hons) RVN CertSAN MBVNA

Nicola works as the senior medical nurse at The Veterinary Hospital in Plymouth. Nicola graduated from Hartpury College with an honours degree in Equine Science, and subsequently qualified as a veterinary nurse. Nicola is past officer of the BVNA, but now is the vice-chair of The Pet Obesity Taskforce, and sits on the VMD's appraisal panel for suspected human adverse reactions.

• VOL 25 • No8 • August 2010 • Veterinary Nursing Journal