This comes following an incident in California where mobile veterinarians were told they were in violation of the Controlled Substances Act (CSA).
Recently, Strain sent a letter to the DEA in which he states that the CSA should not apply to mobile veterinarians who transport controlled substances stored in boxes that are locked.
Strain says, “This law will dramatically curtail our ability to address disease outbreaks should they occur.” He adds, “It is important to note that not all veterinarians have facilities to accept patients, and not all clients can deliver their animals to a clinic or hospital.”
Allowing veterinarians to treat animals in the field using controlled substances enhances their ability to medicate these animals and treat their illnesses in a humane manner.
Following is a letter dated Feb. 21 from the National Food Animal Veterinary Institute regarding its support of Commissioner Strain's position in a letter he sent to the DEA.
Michelle M. Leonhart, Administrator
U. S. Drug Enforcement Administration
Dear Ms. Leonhart,
The National Food Animal Veterinary Institute (NFAVI) was formed just over two years ago to help address the needs and issues facing rural America and the rural food animal veterinarian. The major goal of NFAVI is to safely and efficiently help protect our protein supply through education and communication of ideas that make it more affordable to operate a rural American business.
Our group was recently made aware of an issue in California, whereby the U.S. Drug Enforcement Administration prohibited mobile veterinarians from transporting controlled substances off veterinary clinic premises, and forced registration of every location where they store, distribute or dispense controlled substances, due to violation of the Controlled Substances Act (CSA). Currently, mobile/rural food animal veterinarians are working under the understanding that the CSA does not apply to their work as long as proper precautions are taken and access to the transported controlled substances is limited to a licensed veterinarian working under a valid DEA registration. It is our belief that this law was never intended to limit the ability for a mobile or rural food animal veterinarian to treat animals in the field.
It is clear to our group that rural veterinarians need to have access to certain controlled substances in order to humanely treat animals on site. This California application of the CSA will have a significant impact on the mobile and rural veterinarians’ ability to treat large animals in a humane manner. The truth of the matter is that transport of most large animals to a veterinary clinic simply isn’t logistically possible. Enforcement of these provisions of the CSA could and would hinder veterinarians’ abilities to anesthetize, sedate, or provide analgesia to animals in the field.
From another perspective, the California application of this law will not only have a negative impact on the quality of services provided by veterinarians but also on the economic sustainability of some rural veterinary practices. Maintaining a strong sustainable rural veterinary infrastructure in rural America is critical to our national security. The rural veterinary practitioner is the front line of defense to assure the safety our nation's food supply by preventing, diagnosing, treating and containing diseases in animals. This is critical for human, animal and environmental health.
For these reasons, NFAVI believes that mobile veterinarians should not be restricted from transporting controlled substances off of the veterinary premises. We are confident in our veterinarians and their ability to appropriately manage these substances. We feel adequate oversight is provided through state licensing by their state examining board and being required to work under a valid Drug Enforcement Administration (DEA) registration.
Through this letter, the Board of Directors of NFAVI is asking that the U.S. Drug Enforcement Agency re-evaluate their position on the Control Substances Act as it relates to our mobile and rural food animal veterinarians from this provision.
Please feel free to contact NFAVI if you have any questions.
Dr. David Hardin, DVM
Department Head, University of Nebraska-Lincoln School of Veterinary Medicine and Biomedical Sciences
Dr. Neil Olson, DVM
Dean, University of Missouri College of Veterinary Medicine
Special Assistant to the President, Missouri Western State University
Dr. Ralph Richardson, DVM
Dean, Kansas State University College of Veterinary Medicine
Dr. Chris Ross, DVM
Association Dean for Academic Affairs/Professor, Oklahoma Sate University Center for Veterinary Health Sciences
Dr. John Thomson, DVM
Professor/Dean Emeritus, Iowa State University College of Veterinary Medicine