On October 1, 2016, Bill 33 - a new set of rules managing fentanyl patches - came into force. Veterinarians who prescribe and dispense fentanyl by patch are affected.
In an effort to combat the abuse, misuse, and diversion of prescription fentanyl, the new legislation requires clients who receive a prescription for fentanyl to return their used patches to a veterinary facility or pharmacy before receiving new ones.
The College of Veterinarians of Ontario (CVO) strongly supports this legislation, as well as the government’s approach to delineate specific roles and responsibilities for veterinarians when prescribing and dispensing fentanyl.
It should be noted that in the vast majority of cases, a veterinarian will prescribe, dispense, and administer a fentanyl patch for an animal at the time of treatment. It is anticipated that the provision of a written prescription for fentanyl will be a rare occurrence.
Guidance regarding veterinary use of fentanyl patches:
- If an animal goes home with a patch, veterinarians must only dispense and administer a next fentanyl patch in exchange for a used patch provided by the client or his/her authorized representative.
- A veterinarian should explain the properties of fentanyl patches with a client and ask if a client has any concerns that having the patch at home may compromise the health of any of their family members (such as small children or drug seekers).
A veterinarian must ensure that clients understand the importance of keeping track of every patch that is dispensed, whether it is used or unused, as failing to do so may result in lost or stolen patches, and failing to return a used patch to the veterinary facility or a pharmacy may result in the withholding of a new patch.
A veterinarian should advise a client that he or she should return to the practice if the patch becomes loose at any time or to have the patch removed. He or she should advise a client that if a patch falls off an animal, it should be stored securely, given the potential harm associated with the residual medication in the used patch. A client should be encouraged to return the used patch to the veterinary facility or a pharmacy for disposal.
Where a client fails to return a used patch, or where a veterinarian has reason to believe that a used fentanyl patch is counterfeit, has been misused, or has been tampered with, he or she must use his or her professional judgment to dispense a patch based on an assessment of the animal, including an assessment of the animal’s circumstances and medical condition.
As with all controlled substances, a veterinarian should ensure that their staff are trained to make sure that proper precautions are taken to store the fentanyl patches in a secure location at the veterinary facility prior to dispensing and prior to proper destruction and disposal (inclusive of ensuring that fentanyl patches are rendered unusable prior to disposal) and that an accurate log is kept of their use and disposal, as outlined in the College`s Professional Practice Standard: Management and Disposal of Controlled Drugs and the Guide to the Professional Practice Standard: Management and Disposal of Controlled Drugs.
Veterinarians should document according to the requirements established under Regulation 1093, the College`s Professional Practice Standard: Medical Records, and the Guide to the Professional Practice Standard: Medical Records.
For added security, it is recommended that two staff members be involved in the disposal and documentation of used fentanyl patches.
Guidance regarding the provision of written prescriptions
In the very rare circumstance when a client requests a written prescription from a veterinarian and it is an animal’s first prescription for fentanyl, the veterinarian must note “first prescription” on the prescription itself. A prescription is considered a “first prescription” when the veterinarian has not previously prescribed a fentanyl patch for that animal and the veterinarian is reasonably satisfied that the client has not previously obtained a prescription for fentanyl from another veterinarian for the animal in question.
If a client specifically requests a written prescription from a veterinarian, the veterinarian must:
- record the name and address of the pharmacy in Ontario where the prescription is to be filled on the prescription; and
- notify the pharmacy in advance that a prescription has been written, either by faxing a copy of the prescription or by telephone.
Safeguarding our Communities Act (Patch for Patch Return Policy), 2015, S.O. 2015, c. 33
O. Reg. 305/16 under Safeguarding our Communities Act (Patch for Patch Return Policy), 2015, S.O. 2015, c. 33 Professional Practice Standard: Medical Records
Guide to the Professional Practice Standard: Medical Records. Professional Practice Standard: Medical Records
Guide to the Professional Practice Standard: Medical Records
Who is in Control of Your Controlled Substances? www.cvo.org