Technical advice: Authorising Controlled Drugs for use by non-veterinarians

12 January 2022

Technical advice is our interpretation of how professional standards apply in a particular situation. It is designed to help veterinarians deal with common issues in practice, using their professional judgement to apply the advice to their own situation. It represents our best efforts at the time of publication but standards and expectations change over time and particular care should be used when reading old advice.

Who can administer Controlled Drugs (including pentobarbitone). Are they vet only, or can it be authorised for a non-veterinarian to administer? If they can be authorised for non-veterinarians to administer does the veterinarian have to be present?

The Misuse of Drugs Act allows a veterinarian to authorise (prescribe) controlled drugs such as pentobarbital for a non-veterinarian to administer to an animal in their care.

Health and safety requirements mean that a veterinarian and a veterinary clinic or business must have in place very clear measures to manage the risks associated with the authorisation and use of controlled drugs and other products that carry significant risk.

The assessment of risk should include the potency and the volume of the product (including controlled drugs) being authorised (or that the non-veterinarian would have access to). Both factors contribute to the potential for harm.

This would include authorising controlled drugs in a quantity that has regard to the dose and frequency of dose, or the directions given by the veterinarian such that the risks are sufficiently mitigated.

For example, a veterinarian authorising 3 months’ supply of an opiate (allowable under the Code) for a large 60kg dog that requires a significant dose for its pain management may limit the volume of drug dispensed to only a few weeks at a time in order to manage the risks.

When deciding whether to authorise a non-veterinarian to administer controlled drugs, veterinarians must consider the risks associated with any misuse of the drug for example the selling, or use, of the drug for recreational practices or self-harm. Veterinarians should also consider the issue of ‘moral distress’. There is a degree of responsibility, both professionally and psychologically, associated with the process of euthanasing an animal and careful consideration should be given to the delegation of this procedure to non-veterinarians.

Taking this all into account, it would be prudent, when authorising and dispensing controlled drugs, to consider the following:

  • The character and state of the client/non-veterinarian. Are they sufficiently competent, reliable and trustworthy?
  • What recommendations will you make regarding the safe storage of and access to the product?
  • How should it be dispensed and labelled (e.g. appropriate warnings, etc)? Is it better dispensed in pre-prepared syringes (which may avoid the users needing to use needles to draw up the dose, etc)?
  • How much should be dispensed? The Code does not specify volumes, other than the maximum of 3 months as a period of supply and leaves it to the veterinarian’s judgement.
  • How is use monitored? This is difficult, though observing the patient’s condition and the frequency of repeats may provide some insight into the appropriate use of the product.

With these aspects in mind, the responsibility sits with the veterinarian to make a reasonable judgement. Ultimately the veterinarian will need to take all of these factors into account to decide if it is a good idea to authorise a controlled drug in this situation.