The new rules for the practising of the veterinary professions came into operation on 9 November 2015. These are available on the SAVC’s website at www. savc.org.za. The rules differ dramatically from the previous rules in several respects, such as advertising (now allowed), touting (which fell away), rule 10 which now contains clear rules regarding the compounding of medicines, the categorisation of the various kinds of veterinary facilities (each with its own tailor made minimum standards), amongst others. Some of these rules will be elaborated on in further publications.
A few general issues regarding scheduled medicines are addressed in this first of the publications.
A person practising the veterinary profession must personally be registered at the Council in terms of Sections 23, 24 and 25 of the Veterinary and Para- Veterinary Act, Act 19 of 1982 (the Act). In addition, the physical practise (irrespective of kind of service being rendered, i.e. mobile or otherwise) from which a veterinarian renders a service must be registered as a veterinary facility with the Council in terms of Regulation 1 and 2 of the Regulations relating to the registration of veterinary facilities published in Government Gazette no 29792 on 20 April 2007, as amended on 8 June 2012 in Government Gazette no 35413.
Without this practise number no medicines may be supplied to a veterinarian in terms of the Medicines and Related Substances Control Act, Act 101 of 1965 (Medicines Act). A valid prescription must contain a practise number in terms of Regulation 11 and 28 of the General Regulations promulgated under the Medicines Act.
Prescriptions may not be filled if the practise number is absent. It is both unprofessional conduct (very serious) and a criminal offence to practise from an unregistered facility. The registration number of a company or Close Corporation is not to be confused with the registration number issued by Council.
The company or Close Corporation registration number is issued by the Companies and Intellectual Property Commission and does not suffice for the purposes of the Act or the Medicines Act.
Incorporated company and Closed Corporation codes are not accepted as registered facility codes as they are merely business entities which may not have a structured physical facility, which is contrary to the current rules relating to minimum standards.
The codes which are not accepted start with the letters as follows:
• INC and IN
• FCC and CC
Prescription books (Regulation 11-Medicines Act) and registers for Schedule 5 and 6 medicines (Regulation 30-Medicines Act) must be kept for a period of five years. The physical register for scheduled medicine must be capable of being produced summarily should a Medicines Control Council inspector visits a veterinarian, otherwise all medicines found on the premises will be confiscated.
The register must be balanced at three monthly intervals (March, June, September and December of each consecutive year), within fourteen days of the end of the stated month and signed off.
Scheduled medicines (5 & 6) must be securely locked up in a dispensary and access must be limited to veterinary professionals. A locked vehicle does not suffice as a dispensary and would be no excuse if scheduled medicines are stolen from such a locked vehicle (mobile facility). The medicines in a mobile facility should be locked in the dispensary overnight.
The only exception may be wildlife veterinarians who travel for days on end from their physically registered facilities, without access to a dispensary while travelling. It is difficult to venture an opinion as to how a court would view the theft of scheduled medicines from a locked vehicle with a built-in safe while a veterinarian is travelling.
Section 34 of the Act further provides that a veterinarian may not keep an open shop. That means that medicines may only be supplied to a client and an animal within a client-patient-veterinarian relationship.