Can you Help the American Veterinary Medicine Association (AVMA)?

Recently, the AVMA advised that the CSA (Controlled Substances Administration) has reinterpreted the statute governing veterinarians carrying controlled substances off site to treat horses and other animals.

It is no longer considered legal to carry controlled substances - including sedatives, anesthetics, and euthanasia solution - unless it is a pre-filled, pre-planned dose. This means if they come to treat an emergency for your horse and it needs one of these, they won't have it on their truck. Your horse will have to wait while they go get it. If they come to your barn and your horse has a broken leg, they won't be able to euthanize it because they won't have the drugs in their truck. If it needs stitching up, too bad; they'll have to schedule an appointment, and bring the anesthetic back with them to do it later. Got a colic that needs palpation? Well, too bad. No sedatives on the truck.

The DEA has already begun telling vets in some states that they are in violation.

Hard to believe, isn't it? Here's the AVMA announcement: http://avmacan.avma.org/avma/issues/alert/?alertid=62592206&PROCESS=Take+Action

Do you want this for your horse? The extra time, extra farm call fees, and unnecessary suffering for your horse while you wait?

Fortunately, a bill has been introduced in Congress - the Veterinary Medicine Mobility Act of 2013 (H.R. 1528), which would amend the CSA that currently prohibits veterinarians from transporting controlled substances to treat their animal patients outside of their registered locations: https://www.avma.org/news/pressroom/pages/AVMA-Lauds-U.S.-Representatives-on-Bill-to-Amend-the-Controlled-Substances-Act.aspx

Can you help? Please let your congressman know you support this bill. If you click the "Take Action!" link on the page I've linked above, it'll tell you how. If you use their form, just be sure to change the line "I am writing as a member of the veterinary community" to "I am writing as a horse owner" or something similar.

Please help.

2013-04-21T08:55:59Z

Kit - thanks for the correction! In my haste to get the news out, I garbled that. Isn't it odd how an act crafted over 40 years ago suddenly means something entirely different?

Vets in Washington state have also been warned. I haven't heard of any others - yet.

Judy and . - thanks for caring and acting.

Allanas - If people always knew what their horses were going to need, we wouldn't need vets. I would never expect someone to break the law for me or my horses. An ethical person should not have to break a law to do the right thing, and risk prosecution and jail for doing so. I prefer to work to change the inappropriate law.

Rosie2013-04-20T17:31:44Z

Favorite Answer

"There appears to have been a 2012 reinterpretation of the Controlled Substances Act (CSA). Or maybe not a reinterpretation, but a reinvention of how to interpret it? Some government employee with outstanding ability to read between the lines and in to the psyche of the original crafters of the CSA in 1970? Or some one or group who got a big high five from upstairs for finding yet another way to cause difficulty for livestock producers in the United States?

It seems that back in 2012 the Drug Enforcement Administration (DEA) stepped in to regulate the movement of certain substances used in the normal course of business for a large animal veterinarian. In the state of California vets were notified of the 'new rules' by June of last year. From everything I've read so far, it is only California vets that received DEA notice of "illegal" acts, which strikes me as odd, maybe it was sequester budget savings in advance? Like if they put the squeeze to CA, the rest of the country's vets will get the word, save a little paper or something? Couldn't find a pigeon perhaps?"

gallop2013-04-20T22:26:24Z

To clarify, the CSA is not an administrative body. It is the Controlled Substances Act that was enacted into US law as Title II of the Comprehensive Drug Abuse Prevention and Control Act in the 70s and that is enforced by the DEA. It is the US federal drug policy regulating the manufacture, importation, possession, use and distribution of classified substances.

The DEA (Drug Enforcement Administration) interprets the Code of Federal Regulations requiring a separate registration for "each principal place of business or professional practice at one general physical location where controlled substances are manufactured, distributed, imported, exported or dispensed by a person.” It is the DEA interpretation of this code of regulations that is causing the confusion and uproar.

The CSA originally created the five substance classifications called Schedules, with specific criteria for classification of substances to be included in each.
The Drug Enforcement Administration (DEA) and the Food and Drug Administration (FDA), determine which substances will be added or removed from each schedule.
It is the narcotic and psychotropic substances classified as Schedule II drugs that are the subject of the current controversy.
For some reason it appears to be veterinarians in California whose veterinary practices and homes are listed at the same address who've been targeted by the DEA so far.

Allanas2013-04-20T18:13:14Z

That just means they can't carry entire bottles of the drugs on their trucks. The thinking behind it is to lessen the likelihood of these controlled chemicals being sold or stolen from veterinarian vans.

Also: Vet vans and clinics are being burglarized by drug seekers. Criminals know they're under lock and key at human clinics - and think they can get it easier from a veterinarian. Rightly sometimes because vets aren't as likely to be watching for these folks.

Veterinarians are human just like anyone else. If they are offered an obscene amount of money to "break" a bottle of some controlled substance - they might be tempted.

If you call and tell a vet your horse has a broken leg - they bring the solution. They aren't stupid. Vets can get around this law by bringing syringes filled with the medications they need. Most farm folks know what's going on with the animal - or the vet asks for the symptoms. By what is said - they know what to bring.



It's really not a big deal.


All the vets I know get some idea of what to expect just by what they are told by the owner, by the vet techs that see the animal first.

Judy and the Beast2013-04-20T17:43:20Z

Zephania what a great question. I hope everyone takes a moment to contact their representatives and let them know that we want our doctors and vets to have reasonable and practical access to the drugs and items they need to care for their patients. We have been dealing with these round after round of new and more restrictive regulations on all drugs but especially pain killers and anesthetics. All due to a few individuals who abuse the system and break the law. These new rules have been applied to laboratory medicine first. I do medical research. You might be horrified by the amount of time and expense wasted on controlling substances that for the most part were quite securely handled prior to the 'improved' regulations. The DEA puts rules onto our backs first before releasing the new rules out into the general public perhaps because we are for the most part federally funded and controlled (ie, a captive audience). It is going to get worse before it gets better for us I'm afraid. We have to do something. Our animals shouldn't suffer for our stupidity.

.2013-04-20T17:47:44Z

Willdo.. Thank you.