12. miscellaneous legislation student

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    Miscellaneous Legislation affecting

    Pharmacy

    1

    Legislation relevant to retailers

    Sale of Good Act 1979

    Trade Descriptions Act 1968

    Weights and Measures Act 1985

    Environmental Protection Act 1990

    waste disposal

    Consumer Protection Act 1987

    product liability

    price control

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    Sale of Goods/Faulty Goods

    2

    relevant or related Legislation: Sale of Goods Act 1979; Supply of Goods and Services Act 1982;

    Sale and Supply of Goods Act 1994; The Sale and Supply of Goods toConsumers Regulations 2002

    wherever goods are bought they must conform tocontract this means they must be as described, fit for purpose and ofsatisfactory quality (i.e. not inherently faulty at the time of sale)

    goods are of satisfactory quality if they reach thestandard that a reasonable person would regard assatisfactory, taking into account the price and anydescription.

    aspects of quality include fitness for purpose, freedomfrom minor defects, appearance and finish, durabilityand safety.

    it is the seller, not the manufacturer, who isresponsible if goods do not conform to contract

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    Sale of Goods/Faulty Goods

    3

    if goods do not conform to contract at the time of sale, purchasers canrequest their money back "within a reasonable time

    this is not defined and will depend on circumstances

    for up to six years after purchase (five years from discovery in

    Scotland) purchasers can demand damages (which a court would

    equate to the cost of a repair or replacement).

    a purchaser who is a consumer, i.e. is not buying in the course of a

    business, can alternatively request a repair or replacement.

    if repair and replacement are not possible or too costly, then the

    consumer can seek a partial refund, if they have had some benefitfrom the good, or a full refund if the fault/s have meant they have

    enjoyed no benefit

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    Sale of Goods/Faulty Goods

    4

    in general, the onus is on all purchasers to prove thegoods did not conform to contract (e.g. was inherentlyfaulty) and should have reasonably lasted until this pointin time (i.e. perishable goods do not last for six years).

    if a consumer chooses to request a repair or replacement,then for the first six months after purchase it will be forthe retailer to prove the goods did conform to contract(e.g. were not inherently faulty)

    after six months and until the end of the six years, it is forthe consumer to prove the lack of conformity

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    Sale of Goods and Services

    5

    the Supply of Goods and Services Act 1982 requirestraders to provide services to a proper standard ofworkmanship

    furthermore, if a definite completion date or a price

    has not been fixed then the work must be completedwithin a reasonable time and for a reasonable charge

    also, any material used or goods supplied in providingthe service must be of satisfactory quality

    the law treats failure to meet these obligations asbreach of contract and consumers would be entitledto seek redress, if necessary through the civil courts

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    Weights and Measures

    6

    Metric units of measurement are now used for mosttransactions regulated by the Weights and Measures Act1985

    Consumer & Competition Policy Directorate at theDepartment for Business, Enterprise and Regulatory

    Reform (BERR) is responsible for the policy on thoseprovisions of the Weights and Measures Act

    The National Weights and Measures Laboratory (NWML) isresponsible for the provisions of the Weights andMeasures Act relating to measuring equipment and

    definitions of units of measurement Trading Standards Departments of Local Authorities are

    responsible for enforcing weights and measures law

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    Weights and Measures

    7

    A reliable, well regulated system for weights and measures controls isone of the fundamental tenets of an effective regime of consumer

    protection

    The system must be one in which consumers can have confidence, so

    that when they make a purchase they do so in the knowledge that

    they are not being sold short weight or measure. Businesses, too, must

    be protected from unscrupulous competitors who would seek to gain

    an unfair competitive advantage by flouting the law.

    In the UK, transactions in goods by weight or measure are, in most

    cases, regulated by the Weights and Measures Act 1985 and its

    secondary legislation the Weights and Packaged Goods Regulations

    2006

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    Trade Descriptions Act

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    The Trade Descriptions Act 1968 makes it an offencefor a trader to apply, by any means, false or misleadingstatements, or to knowingly or recklessly make suchstatements about goods and services

    The Act carries criminal penalties and is enforced bylocal authorities' Trading Standards Officers

    Labelling of, and the provision of information on, foodand drink is the responsibility of the Foods StandardsAgency

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    Sunday and Christmas Day Shopping

    9

    The Sunday Trading Act 1994 and the Christmas Day(Trading) Act 2004 regulate opening hours of large

    shops* on Sundays and Christmas Day

    The Sunday Trading Act also prohibits large shops

    from opening on Easter Sunday

    *Some categories of large shop are exempt from the

    Sunday Trading Act 1994 including pharmacies

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    Environmental Protection Act 1990

    Waste Disposal

    10

    legislation (derived largely for European Directives) subjects thestorage, carriage, processing and disposal of waste to stringent

    controls

    the Environment Agency is responsible for regulating certain

    types of waste - referred to as Controlled Waste

    controlled waste can include household, industrialor

    commercial waste and also covers clinical waste

    this is waste which results from treating humans or animals

    and which might cause infection or other harm. Some waste

    is potentially particularly hazardous or harmful

    there are more stringent controls on this type of waste.

    see Hazardous Waste Regulations 2005

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    Environmental Protection Act 1990

    Waste Disposal

    11

    all producers and handlers of wastes, other than householders andtheir domestic rubbish produced at home, have a legal Duty of Carefor their wastes

    definition of wastes subject to Duty of Care

    a waste is any substance which the person in possession discards

    or intends to discard this is a wide definition who has a legal Duty of Care?

    anyone who produces or handles wastes, from the point ofproduction to final disposal, is subject to the waste managementDuty of Care

    there are specific exceptions for:

    private householders - but only for their own domestic rubbish

    certain wastes subject to other systems of control escape their controluntil passed to a registered waste carrier

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    Environmental Protection Act 1990

    Waste Disposal

    12

    duty of care continues throughout the waste chain until its final disposal important to engage only reputable waste disposal contractors to remove

    waste from pharmacies as initial producer may (in certain circumstances)

    be held liable if any part of the disposal chain fails

    waste disposal contractors are contracted by the PCT as part of the

    pharmacy contractual framework

    sent (with duty of care transfer note) to a suitable authorised authorised

    waste disposal for incineration

    Waste Management Licensing Regulations 1994 39(1)

    provides conditional exemption for community pharmacies for secure

    storage pending disposal elsewhere, of waste medicines returned from

    patients

    limits on size and length of time stored

    requires registration by the pharmacy with local Environment Agency

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    Hazardous Waste Regulations 2005

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    requires pharmacies to separate hazardous wastemedicines from non-hazardous if technically and

    economically feasible where not separated, then is

    specified as hazardous waste and accompanied by a

    hazardous waste consignment note medicines designated as hazardous are those identified

    in the European Wastes Catalogue as exhibiting

    hazardous properties such as cytotoxic/cytostatic;

    teratogenic, etc

    consider hazard codes relevant to hazardous materials;

    safety data sheets, etc.

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    Pharmacy waste

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    Standard Operating Procedures for Controlled Drugs mustinclude disposal and destruction (see MEP)

    Controlled Dugs Schedule 2 (and some Schedule 3)

    patient returns

    clearly mark and stored in CD cabinet until denaturedto render them irretrievable

    denaturing should, if possible, be witnessed(pharmacist or pharmacy technician)

    place in waste container only after denaturing

    out of date stock see law lectures - witness/records,etc

    Also See MEP

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    Pharmacy waste

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    Pharmacy Standard Operating Procedure include, forexample: medicine waste including hazardous medicines products other than medicines identifying incompatible products (e.g. flammable

    products; oxidising products) protective measures for staff in segregating

    medicines and products identifying risks to carriers and waste contractors

    monitored dosage systems sharps retention/audit requirements for transfer notes

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    Summary

    Disposal of medicinal products

    responsibility ofEnvironment Agency in England & Wales

    special requirements when classified as hazardous waste

    such as medicines with cytotoxic or cytostatic properties ;any medicine that possesses one of more of the following

    hazardous properties is classified as cytotoxic and

    cytostatic and is a hazardous waste: Toxic; Carcinogenic;

    Mutagenic; Toxic for reproduction

    advice available from local waste regulation authorities

    NB a pharmacy or veterinary surgery is required to denature

    controlled drugs prior to their disposal

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    Duty of Care (DoC)

    DoC requires that a waste holder (producer, carrier ordisposer) takes all reasonable steps to ensure there is no

    unauthorised deposit, treatment, keeping or disposal of

    controlled wastes, that it does not escape from their

    control, and is only transferred to an authorised person also requires waste to be described in a way that permits

    its safe handling and management and that any transfer of

    waste is accompanied by a written description of the waste

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    Product Liability

    Consumer Protection Act 1987

    20

    Part I of the Act, which implements into UK law theprovisions of the Product Liability Directive (85/374/EEC),

    came into force on 1 May 1988. Part II of the Consumer

    Protection Act, containing consumer safety provisions,

    came into force on 1 October 1987 these provisions apply throughout the UK.

    Product Liability:

    people injured by defective products may have the right

    to sue for damages; product liability is the term given tolaws affecting those rights

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    Consumer Protection Act 1987 (cont)

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    in the past those injured had to prove a manufacturernegligent before they could successfully sue for damages

    the Consumer Protection Act 1987 removes the need to

    prove negligence - a customer can already sue a supplier,

    without proof of negligence, under the sale of goods law the Act provides the same rights to anyone injured by a

    defective product, whether or not the product was sold to

    them

    the Act does not affect any existing civil laws governingproduct liability

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    Consumer Protection Act 1987 (cont)

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    a defective product is defined as one where the safety of the product is not such as

    persons generally are entitled to expect

    this definition provides an objective test of defectiveness

    and refers neither to the particular injured person nor tothe particular producer

    a product will not be considered defective solely because it

    is of poor quality

    a product will not be considered defective simply becausea safer version is subsequently put on the market

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    Consumer Protection Act 1987 (cont)

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    An injured person can take action against: Producers:

    usually the manufacturer; also included are processors but those

    involved solely in packaging are not affected unless the packaging alters

    the essential characteristics of the products

    Importers:

    meaning importers into the European Community, not just into the

    United Kingdom - where goods are imported into another EC country

    and subsequently sold in the United Kingdom, liability rests with the first

    importer, not the United Kingdom importer.

    Own-branders:

    suppliers who put their own name on the product and give the

    impression that they are the producers

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    Consumer Protection Act 1987 (cont)

    24

    other suppliers, such as wholesalers and retailers, are not liableunless they fail to identify the producer, importer or own-

    brander if asked to do so by a person suffering damage.

    liability under the Act is joint and several, so the plaintiff may

    sue both (or all, if more than two) defendants. It is not possible

    to exclude liability under the Act by means of any contract term

    or other provision

    liability under this part of the Act applies to all consumer goods

    and goods used at a place of work

    enforcement of the Consumer Protection Act 1987 is theresponsibility of officers of the local weights and measures

    authority - usually called Trading Standards Officers

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    Consumer Protection Act 1987 (cont)

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    A producer or importer can avoid liability if he can prove any of sixdefences:

    he did not supply the product

    the state of scientific and technical knowledge at the time he

    supplied the product was not such that a producer of products of

    the same description as the product in question might be expectedto have discovered the defect if it had existed in his products while

    they were under his control (the so-called development risks

    defence);

    the defect was caused by complying with the law

    the defect was not in the product at the time it was supplied

    the product was not supplied in the course of a business

    the producer of a component will not be liable if he is able to show

    that the defect was due either to the design of the finished product

    or to defective specifications given to the component manufacturer

    by the producer of the finished product.

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    Consumer Protection Act 1987 (cont)

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    a plaintiff must begin his court action within 3 years of the date he wasinjured by the defective product or, if later, the date when they knew

    they had a claim against the defendant - however, an injured person

    cannot sue under this part of the Act if 10 years have elapsed since the

    defective product was supplied by the producer

    a person can sue under the Act for compensation for: death

    personal injury

    private property (provided the amount of loss or damage is 275 or

    more)

    the Act imposes no financial limit on a producers total liability.

    the plaintiff must be able to show that, on the balance of probabilities,

    the defect in the product caused the damage

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    Consumer Protection Act 1987 (cont)

    27

    Pharmacists medicines - MA holder/manufacturer likely to be

    primary producer

    ensure adequate systems and records to ensure able to

    identify producer pharmacist would have full liability for own branded

    goods and for own remedies prepared by him

    maintain full manufacturing records so producer of

    ingredients can be identified records kept for >10 years

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    Consumer Protection Act 1987

    Price Control

    28

    Section 20 of the Consumer Protection Act 1987 makes it a criminaloffence for a person in the course of his business to give consumers a

    misleading price indication about goods, services, accommodation

    (including the sale of new homes) or facilities

    it applies however you give the price indication - for example, in a TV

    or press advertisement, on a website, by email or text message, in acatalogue or leaflet, on notices, price tickets or shelf-edge marking in

    stores, or if you give it orally, for example on the telephone

    the term "price indication" includes price comparisons as well as

    indications of a single price

    there is a requirement to display a price in such a way that customerssee it without having to ask, in close proximity to goods available for

    sale

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    Veterinary Medicines

    Legislation

    Classification of Medicines

    Prescription

    Supply Cascade

    Labelling

    Records keeping

    MEP guide

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    Legislation

    The law on veterinary medicines has been uncoupledfrom the Medicines Act 1968 and there are revisions

    from a European directive; these are set out in new

    legislation, the Veterinary Medicines Regulations 2005

    (SI No 2745) which came into force on 30 October2005

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    The Veterinary Medicines

    Regulations

    Took effect 30 October 2005 (except for medicated feedingstuffs: 1 January 2006)

    Enforced mostly by Veterinary Medicines Directorate(VMD) through the criminal courts

    Implements an EU Directive and separates out from theMedicines Act all the provisions which relate to veterinarymedicine

    The Regulations are revoked and replaced every year, sothe references to the Regulations should be read as

    referring to the ones that are currently in force. The VMR 2011 (SI No. 2159) came into force on 1 October

    2011

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    Definition of

    VETERINARY MEDICINAL PRODUCT

    Because they transpose the requirements of EU legislation,the Veterinary Medicines Regulations use the Communitylaw definition of veterinary medicinal product

    Article 1.2 of the amended Directive (2001/82/EC asamended by 2004/28/EC) defines a "veterinary medicinal

    product" as: (a) any substance or combination of substances presented as

    having properties for treating or preventing disease inanimals; or

    (b) any substance or combination of substances which may beused in, or administered to, animals with a view either to

    restoring, correcting or modifying physiological functions byexerting a pharmacological, immunological or metabolicaction, or to making a medical diagnosis

    33

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    33

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    Classification of medicines

    POM-V = Prescription-only medicine veterinarian POM-VPS = Prescription-only medicine - veterinarian,

    pharmacist, suitably qualified person

    NFAVPS = Non-food animal - veterinarian, pharmacist, suitablyqualified person

    AVM-GSL = Authorised veterinary medicine - general sales list

    Other abbreviations: VMP = veterinary medicinal product

    SQP = Suitably qualified person

    Veterinary Medicines Directorate (VMD) Registered qualified person (RQP) - veterinary surgeon, pharmacist

    or suitably qualified person according to the distribution category ofthe veterinary medicinal product concerned

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    POM-V

    A product will generally be included in the POM-V categorywhen it: requires a strict limitation on its use for specific safety

    reasons

    requires the specialised knowledge of a veterinary surgeonfor its use/application;

    has a narrow safety margin requiring above average care in itsuse

    is Government policy to demand professional control at a highlevel

    Veterinary medicinal products containing controlled drugs

    will be authorised in this distribution category Products containing Controlled Drugs in Schedule 2 or 3 of

    the Misuse of Drugs Act 1968 will be clearly identified withCD and the relevant schedule detailed on their labels

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    POM-V

    A veterinary medicinal product, previously classifiedas a MFS, is for incorporation into animal feeding

    stuffs that may only be supplied to keepers of animals

    on presentation of a written medicated feeding stuff

    prescription from a veterinary surgeon Such a product is therefore included in the POM-V

    category.

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    POM-VPS

    POM-VPS products can be supplied by other veterinary surgeons,

    pharmacists or registered suitably qualified persons (SQPs)against a written prescription

    prescription from veterinary surgeons, pharmacists or suitablyqualified persons (SQPs) *

    SQPs will need to undergo approved training, be registered andcomply with a code of practice

    SQPs can prescribe and supply POM-VPS and NFA-VPS but onlyfrom registered premises

    For POM-VPSs the prescribing veterinary surgeon need not havethe animals under his/her care

    * The customer may request a written prescription if they do notwant the prescribing RQP to supply the product. Any RQP maysupply POM-VPS medicines in accordance with a writtenprescription from another RQP

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    POM-VPS

    A product will generally be included in the POM-VPScategory when: it is used to reduce or prevent the effects of endemic disease in

    herds, flocks or in individual animals

    its use implies risks for the user, the animal, consumer safety or the

    environment but users can be made aware of suitablecountermeasures through simple, oral or written, advice

    a professional user can be given adequate training in its regular use

    A veterinary medicinal product for incorporation into animal feedingstuffs that were able to be supplied to keepers of animals without aprescription was previously classified as MFSX. These were generally

    anthelmintics. However under the amended legislation, if the productis for the treatment of food producing animals it is included within thePOM VPS category

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    A clinical assessment of the animal(s) is not requiredwhen prescribing this category of veterinary

    medicines

    The prescribing RQP must, each time they prescribe,

    be satisfied that the person administering themedicine has the competence to do so safely and that

    the medicine is intended for its authorised use

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    SQPs

    Subject to certain conditions, Suitably QualifiedPersons (SQPs) may prescribe and supply certain

    categories of veterinary medicines, mainly

    parasiticides and other medicines for the routine

    control of endemic disease SQPs are able to prescribe and supply POM-VPS and

    NFA-VPS products for the species in which they have

    training; they need to have appropriate training and

    work in registered premises but will be able to operateautonomously.

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    NFA - VPS

    A veterinary medicinal product classified as NFA-VPS may be suppliedby a RQP

    a registered veterinary surgeon

    a registered pharmacist; or

    a registered suitably qualified person (SQP)

    A clinical assessment is not required for supply of this category ofveterinary medicine.

    The RQP, however, must be satisfied, each time they supply a NFAVPSproduct, that the person administering the medicine has thecompetence to do so safely and the medicine is intended for itsauthorised use

    it is part of the professional requirements of the RQP to judge howto determine that these criteria are satisfied in each case

    The RQP must also provide advice related to any warnings or contra-indications relevant to it for every product

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    NFA - VPS

    A product will generally be included in the NFA-VPScategory when:

    it is indicated for use only in non-food animals

    it is used routinely to prevent or limit the effects of

    endemic disease in non-food animals its use implies risks for the user, the animal, for

    consumer safety or for the environment but users can be

    made aware of suitable countermeasures through

    simple, oral or written advice the animal keeper can be given sufficient practical

    advice to permit effective/safe usage

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    AVM - GSL

    A veterinary medicinal product classified as an AVM-GSL may be supplied by any retailer as there are no

    restrictions on its supply

    A product will generally be included in the AVM-GSL

    category when: its use has a wide margin of safety

    it is used to alleviate or prevent the signs of disease or

    support the treatment of common ailments

    special advice is not required to permit safe/effectiveuse

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    Prescriptions

    A prescription may be verbal or in writing. Prescribingis considered to be the action of deciding, instructingand recording which treatment should beadministered to an animal

    It can be carried out by any registered qualified person(RQP) that is a veterinary surgeon, pharmacist orsuitably qualified person according to the distributioncategory of the veterinary medicinal productconcerned

    Generally, most written prescriptions are expected tobe provided by veterinary surgeons

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    Prescriptions

    As well as specifying an authorised veterinarymedicinal product, a prescription from a veterinary

    surgeon may be for a product that has been

    prescribed under the cascade. In these cases the

    prescription may be written for a human medicine ora preparation that is to be made up to meet the

    particular circumstances.

    Veterinary surgeons must note on prescriptions for

    human medicines that the product has beenprescribed under the cascade and this must be done

    for all cascade prescriptions.

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    Form of a Written Prescription

    No particular format is required for a written veterinaryprescription but prescribers must include the followinginformation:-

    the name, address and telephone number of theperson prescribing the product

    the qualifications enabling the person to prescribethe product; e.g. MRCVS or the SQP registrationnumber

    the name and address of the owner or keeper

    identity (including the species) of the animal or groupof animals

    the premises at which the animals are kept if this isdifferent from the address of the owner or keeper

    cont

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    Form of a Written Prescription (cont)

    the date of the prescription the signature or other authentication of the person

    prescribing the product

    the name and amount of the product prescribed

    the dosage and administration instructions; anynecessary warnings (Note: dosage of as directed is not

    acceptable)

    the withdrawal period if relevant

    if it is prescribed under the cascade, a statement to thateffect

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    Prescriptions

    An offence to prescribe more than the minimum amount ofVMP required for a treatmentpharmacist may need to check

    Prescriptions valid for 6 months (or shorter if specified)

    Repeatable prescription that does not specify the number ofrepeats repeat once

    Controlled Drugs Schedules 2 and 3 prescription valid 28 DAYS

    see MEP guide for details

    address of prescriber in UK total quantity (words & figures)

    pharmaceutical form strength (where appropriate)

    name &address person to whom delivered

    declaration (animal/herd under vets care)

    instalment directions no repeats

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    Prescriptions

    Pharmacist dispensing a prescription must: only supply vet medicine specified

    take reasonable steps to satisfy self that theprescription has been written and signed by a

    person entitled to prescribe the product ensure vet medicine is supplied to person

    named on

    Note: 2009 Regulations introduced offence ofaltering a written prescription without

    authorisation of the person who signed it

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    Prescribing/supply

    Pharmacist prescribing (or making a supply of ) a POM-VPSmust always:

    advise on safe administration of product

    advise as necessary on any warnings/contraindications, etc

    on label/package leaflet

    not prescribe (or in case of NFA-VPS, supply) more than

    minimum amount required for treatment EXCEPT where:

    Product is in a container specified in marketing

    authorisation

    Manufacturer does not supply in a smaller container, and Pharmacist is not authorised to break open package

    NB only veterinary surgeon may break open immediate

    packaging of injectable products

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    Supply by Pharmacists

    A registered pharmacist may only supply veterinary medicinalproducts from premises, which have been registered as apharmacy with either the GPhC or the Pharmaceutical Society ofNorthern Ireland and in the case of POM-VPS or NFA-VPSproducts premises approved for the storage and supply of theseproducts

    It is an offence to supply a veterinary medicine that has passedits expiry date

    Suspected Adverse Reactions

    suspected adverse reactions surveillance scheme (SARSS) run

    by Veterinary Medicines Directorate (VMD) suspected ADR in either animal or human (e.g. from

    administration) must be reported to Veterinary MedicinesDirectorate

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    Labelling Requirements

    The label information on the product is specifically authorised toprovide necessary information relating to safety includingwarnings for the user and animal owner, so it must not beobscured by any additional labelling or amendments made tothe packaging.

    A veterinary surgeon or pharmacist supplying a product againsta written prescription may amend the authorised label inaccordance with the prescription, for example to change thedose, but none of the other information on the outer packagingor the immediate container may be obscured

    SQPs may only supply in accordance with the authorised label Note: Manufacturers labelling and leaflet info in MEP guide

    R d k i f t i

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    Record keeping for veterinary

    transactions (receipt and supply)

    All POM-V and POM-VPS medicines In writing/indelible

    Kept for 5 years

    date of transaction

    identity of VMP

    quantity received or supplied name and address of the supplier or recipient

    batch number (for VMP for non-food producing animals BN needonly be recorder on either date batch was received or starts to beused)

    where a written prescription- name and address of person whowrote and a copy of the

    NB documentation kept for at least 5 years

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    The Prescribing Cascade

    The prescribing cascade provisions are set out in the Regulations they are available only to veterinary surgeons who have

    responsibility for the treatment of the animals concerned andmay only be supplied by a veterinary surgeon or a pharmacist

    if there is no medicine authorised in the UK for a condition

    affecting a non-food producing species, the veterinarysurgeon responsible for treating the animal(s) may, inparticular to avoid unacceptable suffering, treat the animal(s)in accordance with the following sequence:

    (a) a veterinary medicine authorised in the UK for use in

    another animal species;(b) or for a different condition in the same animal species

    (off-label use);

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    The Prescribing Cascade (cont)

    (c) or, if there is no such product:either

    (i) a medicine authorised in the UK for human use

    (ii) a veterinary medicine not licensed in the UK butlicensed in another member state for use with

    any animal species for a non-food producingspecies

    or, if there is no such product described in (ii) issuitable:

    a medicine prepared extemporaneously, by a

    veterinary surgeon, a pharmacist or a personholding an appropriate manufacturersauthorisation, as prescribed by the veterinarysurgeon responsible for treating the animal.

    h b d

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    The Prescribing Cascade

    Food producing animals

    If there is no medicine authorised in the UK for a conditionaffecting a food producing species, the veterinary surgeonresponsible for treating the animal(s) may use the cascadeoptions as set out above except that the following additionalconditions apply: the treatment in any particular case is restricted to animals on a

    single holding any medicine imported from another Member State (option c(ii))

    must be authorised for use in a food-producing species in theother Member State

    the pharmacologically active substances contained in the medicinemust be listed in Annex I, II or III to Regulation (EEC) No. 2377/90

    the veterinary surgeon responsible for prescribing the medicinemust specify an appropriate withdrawal period

    the veterinary surgeon responsible for prescribing the medicinemust keep specified records.

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    The Prescribing Cascade

    A medicine prescribed in accordance with the cascademay be administered by the prescribing veterinary

    surgeon or by a person acting under their direction.

    Responsibility for the prescription and use of the

    medicine remains with the prescribing veterinarysurgeon.

    L b lli f di d i di i

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    Labelling of dispensed veterinary medicines

    under the cascade

    See earlier lecture on labelling; See MEP Label must include at least:

    name and address of pharmacy

    name of prescriber

    name and address of animal owner

    identification of animal

    date of supply

    expiry date

    name and description of product

    dosage and administration instructions

    special storage precautions

    necessary warnings for use; target species; administration or disposal ofthe product

    withdrawl period (if necessary)

    Keep out of reach of children and For Animal Treatment Only

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    Labelling at the time of supply

    If the product is placed into a container, which has notbeen authorised as part of the marketing

    authorisation, such as tablets being supplied in a

    standard bottle with a child resistant closure, the

    necessary information must still be provided in writing

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    Summary of Key Points

    The law allows owners to purchase medicines from a pharmacist or from aveterinary surgeon

    For some medicines a prescription is needed, and veterinary surgeons canonly provide a prescription for POM-V medicines for animals under theircare, and following a clinical assessment

    Those supplying medicines not on the general sale list must advise on safe

    administration, warnings and contra-indications

    It will be an offence to supply or possess an unauthorised veterinarymedicinal product

    Records must be kept of all products supplied on prescriptions for fiveyears

    When a batch is brought into use the batch number and date must berecorded

    Suspected ADRs must be reported to the Veterinary Medicines Directoratevia Suspected Adverse Reaction Surveillance Scheme (SARSS)

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    Summary of Key Points

    Veterinary medicines no longer controlled under the Medicines Act 1968Regulations updated every year

    All medicines for food-producing animals are Prescription Only Medicines

    Classes:

    POM-V supplied by pharmacists and vets against a prescription from a

    vet

    POM-VPS - supplied by vets, pharmacists or suitably qualified persons

    against a prescription from one of these

    NFA-VPS similar to POM-VPS but for non-food producing animals no

    prescription required

    AVM-GSL - no restrictions on supply

    Pharmacists must not sell human medicines for use in animals

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    Summary of Key Points

    Prescribing Cascade used when no suitable veterinary medicine authorised and

    available in UK to treat a particular species or indication

    three levels:

    use an UK authorised veterinary medicine indicated for same speciesbut for another condition or indicted for use in another species

    use a UK authorised human medicine or use a veterinary medicineauthorised somewhere in EU* but not UK

    specially prepared extemporaneous medicine

    NB need to be aware of extra requirements if dealing with afood-producing species*Special Import Certificate requirements

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    Veterinary Medicines

    Any questions?