Guide to the Policy Statement
Published: June 2020
Introduction
The College’s Policy Statement: Sale of Non-Drug Veterinary Products outlines the expectations for when a veterinarian chooses to sell a non-drug veterinary product to a client for the purpose of maintaining or promoting the health of an animal(s) or group of animals. Using a question-and-answer format, this Guide to the Policy Statement addresses questions and offers suggestions on how to apply the Policy Statement in situations that arise in veterinary practice. It also offers scenarios that outline suggested approaches.
A veterinarian is required to have a VCPR with a client before selling them a non-drug veterinary product. Establishing a VCPR involves a conversation in which a relationship is created. Beyond this, a veterinarian should use their professional judgment and consider:
- The type of product being sought and its intended use;
- The information that they have regarding the animal and its health status;
- The known risks or side effects of the product; and
- Whether they are comfortable with providing the product without conducting a physical examination or premise visit.
Appropriate Use Scenarios
Scenario One
A client attends at Dr. Kimbel’s veterinary clinic with their cat. Upon examination, Dr. Kimbel diagnoses the cat with fleas and sells Advantage II for treatment. The client then informs Dr. Kimbel that there are other cats in their household who have not seen a veterinarian. Dr. Kimbel is aware of the need to treat all animals in the household in order for the flea product to be effective and to eliminate the flea infestation. After discussion, Dr. Kimbel decides to sell additional doses of the pesticide to the client to be used on the other cats. Dr. Kimbel makes a written entry of this transaction, noting the client’s name, the identification of the animal(s), the product sold, the name of the individual who sold the product, and the date of sale.
Scenario Two
An individual attends at Dr. Ahuja’s veterinary clinic for the first time and asks Dr. Ahuja if there are any supplements that they can use for their geriatric dog whose movements are described as slow and stiff. Dr. Ahuja believes that chewable glucosamine tablets would be appropriate for the dog in question. He explains to the individual that, in order to sell the tablets, he will need to establish a VCPR. The VCPR is established via a brief conversation in which the individual agrees to retain Dr. Ahuja, they reach an agreement as to the scope of the services to be provided by the Dr. Ahuja, which in this case is narrow, and Dr. Ahuja advises the individual that services will only be provided in accordance with the standards of practice of the profession. Dr. Ahuja makes a written record of this transaction, noting the client’s name, the identification of the animal(s), the product sold, the name of the individual who sold the product, and the date of sale.
Scenario Three
An individual enters a veterinary clinic owned by Dr. Sobry for the first time looking for a leash of a particular brand which the veterinary clinic stocks and displays at the front of the store, in the retail section. That section of the store displays pet food, leashes, cosmetics, medical supplies, nutraceuticals, etc. A veterinary technician who greets the individual determines that since the leash is a retail item that is not a drug or a non-drug veterinary product used in the maintenance or promotion of the health of an animal(s), it may be sold without establishing a VCPR, and sells the leash to the individual.
Scenario Four
A client attends at Dr. Bodnar’s veterinary clinic and informs a staff member at the front desk that they are seeking a calcium supplement for their dairy cows. Dr. Bodnar has worked with this client before and has a current VCPR. Dr. Bodnar has trained his staff about the non-drug veterinary products available in the clinic to allow them to provide assistance to clients. After discussion, the staff member decides to sell the client an oral calcium supplement. The staff member makes a written record of this transaction, noting the client’s name, the identification of the animal(s), the product sold, the name of the individual who sold the product, and the date of sale.
Legislative Authority
Food and Drugs Act and Regulations (Federal)
Controlled Drugs and Substances Act and Regulations (Federal)
Drug and Pharmacies Regulation Act and Regulation 58/11 (Provincial)
Veterinarians Act (Provincial)
Regulation 1093 made under the Veterinarians Act (Provincial)
Resources
The following can be found at the College’s website at cvo.org:
Policy Statement: Sale of Non-Drug Veterinary Products
Professional Practice Standard: Prescribing a Drug
Guide to the Professional Practice Standard: Prescribing a Drug
Professional Practice Standard: Dispensing a Drug
Guide to the Professional Practice Standard: Dispensing a Drug
Professional Practice Standard: Extra-Label Drug Use
Guide to the Professional Practice Standard: Extra-Label Drug Use
Professional Practice Standard: Use of Compounded Drugs in Veterinary Practice
Guide to the Professional Practice Standard: Use of Compounded Drugs in Veterinary Practice
Professional Practice Standard: Management and Disposal of Controlled Drugs
Guide to the Professional Practice Standard: Management and Disposal of Controlled Drugs
Professional Practice Standard: Informed Client Consent
Guide to the Professional Practice Standard: Informed Client Consent
Professional Practice Standard: Establishing, Maintaining and Discontinuing a Veterinarian Client Patient Relationship (VCPR)
Guide to the Professional Practice Standard: Establishing, Maintaining and Discontinuing a Veterinarian Client Patient Relationship (VCPR)
College publications contain practice parameters and standards which should be considered by all Ontario veterinarians in the care of their patients and in the practice of the profession. College publications are developed in consultation with the profession and describe current professional expectations. It is important to note that these College publications may be used by the College or other bodies in determining whether appropriate standards of practice and professional responsibilities have been maintained. The College encourages you to refer to the website (www.cvo.org) to ensure you are referring to the most recent version of any document.