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This modules presents the rules SQPs must follow when prescribing and supplying veterinary medicines, as set out in the Code of Practice for SQPs. There is a lot to cover in this module. Most of it is general, in that it applies to all SQPs; at the end there are there small sections on the specific rules about supplying sheep dips, supplying medicines for horses and other equidae, and on wormers for sheep and cattle. 

The main part of the module is set out in the following parts:

  1. About the Code of Practice
  2. Definition of who can prescribe or supply veterinary medicines.
  3. The four legal categories of veterinary medicines.
  4. Definition of an SQP. 
  5. The rules around prescribing and supplying a POM-VPS (including what is meant by prescribing; and what a prescription must contain).
  6. Information to collect before supplying a POM-VPS or NFA-VPS medicine.
  7. What you must do when supplying against a prescription.
  8. Record-keeping on POM-VPS medicines.
  9. Supplying a medicine against a prescription written under the cascade.
  10. Offences under the Code.
  11. Adverse events to medicines
  12. Nominated SQPs

By the end of this module you will:

  • know the purpose of the Code 
  • understand how the Code relates to the work of an SQP
  • understand the rules about prescribing and supplying veterinary medicines
  • The Code of Practice for SQPs is issued by the Secretary of State for the Department for Environment, Food and Rural Affairs (Defra) under the Veterinary Medicines Regulations, which set out the legislation that relates to veterinary medicines. The Code is published by the Veterinary Medicines Directorate (VMD), the government agency responsible for animal health, public health and the environment.
  • The Code of Practice sets out the standards for Suitably Qualified Persons (SQPs) who are registered with a recognised body (AMTRA or VetSkill) and who can supply veterinary medicines classified as POM-VPS and NFA-VPS in accordance with the particular registration they hold (i.e. farm animals, birds, equines, companion animals, or all animals - food and non-food producing). 
  • All SQPs must follow this Code of Practice. It applies equally to all SQPs whether you work in a shop, a vet practice or a pharmacy.
  • The Code defines offences under the Veterinary Medicines Regulations in relation to the supply of veterinary medicines.
  • The SQP registration body can bring about disciplinary action and remove from the register anyone who has breached the Code.
  • The Code is revised from time to time in line with any changes in the Veterinary Medicines Regulations that are relevant to SQPs.

Only registered qualified people can prescribe or supply veterinary medicines. There are three groups of qualified people:

  • vets who are registered with the Royal College of Veterinary Surgeons
  • pharmacists who are registered with the General Pharmaceutical Council or the Pharmaceutical Society of Northern Ireland
  • SQPs who are registered with AMTRA or VetSkill.

The medicines each of these groups can prescribe or supply depends on the legal category of the medicine. There are four legal categories of veterinary medicines. 

The four legal categories of veterinary medicines

the 4 legal categories.jpg

An SQP is a person who has passed exams specified by a regulatory body (AMTRA or VetSkill) and is registered with a regulatory body (AMTRA or VetSkill).

As an SQP you can prescribe and supply products in the POM-VPS category and supply products in the NFA-VPS and AVM-GSL categories, as long as the products are within the scope of your registration category. There are five registration categories:

  • all animals (food-producing and non food-producing)
  • farm animals
  • equines
  • companion animals
  • birds, including poultry (avian)

An SQP may be registered for more than one category.

  • An SQP must be sure to comply with the legal requirements for prescription and supply of POM-VPS and NFA-VPS veterinary medicines, however supplied (e.g whether by direct sale or by post).
  • All SQPs must keep up to date through continuing professional development (CPD). This can be done through learning activities; reading relevant books or trade journals; gaining practical experience by taking on a relevant new role; or work shadowing a colleague who works in a different area of the business.
  • To continue to be registered, an SQP must satisfy the registration body that they have fulfilled the CPD requirements.

Before supplying a POM-VPS medicine, you must first prescribe it, unless you are supplying it against a written prescription from another SQP or a vet or a pharmacist.

Prescribing is the decision you make about which veterinary medicine to supply for a specific animal(s). When prescribing, you (the SQP), must take into account the following:

  • the disease/condition of the animals requiring treatment;
  • the type of holding and the animals being treated;
  • the authorised veterinary medicines on the market and their warnings and contraindications; 
  • the responsible use of medicines;
  • the requirement to prescribe the minimum amount of medicine needed for the treatment and condition presented (subject to minimum pack sizes and whether the pack can be split without contravening the Veterinary Medicines Regulations);
  • that the person receiving the product must use it for the purpose specified in the product's licence;
  • the abilities and competence of the person administering the product;
  • any available farm or animal health plan.

A client may want to buy the prescribed product from another supplier. So, if requested, you must supply a written prescription, which must contain the following information:

  • your name, address and telephone number; 
  • your qualifications/registration number;
  • the name and address of the owner or keeper of the animal;
  • the identification (including species) of the animal, or group of animals to be treated;
  • the address of the premises at which the animals are kept (if this is different from the address of the owner or keeper);
  • the date;
  • your signature or other authentication;
  • the name and amount of the product prescribed;
  • the dosage and administration instructions;
  • any necessary warnings;
  • for food-producing animals, the withdrawal period, even if nil.

When prescribing and supplying a POM-VPS medicine or supplying a NFA-VPS medicine, you must always (unless supplying against a written prescription from another SQP, or a vet or a pharmacist):

  • be satisfied that the person who will administer the product will do so safely;
  • advise on any warnings or contraindications on the label or package leaflet;
  • provide advice on the safe use of the product.

There is certain information you should find out before supplying a POM-VPS or NFA-VPS medicine:

  • species
  • total number of animals
  • weight of each animal
  • age of each animal
  • whether the animal is in general good health
  • whether the animal is pregnant or lactating
  • whether the animal is on any other medication (prescription, non-prescription or herbal)
  • whether the customer knows what is expected of the product
  • whether the customer is aware of the warnings in the product information

For food-producing animals you also need to check:

  • the intended food use for the animal (e.g. milk, meat, eggs)
  • that the customer knows the relevant withdrawal period.

There is no need to record this information. As the SQP, collecting this information is your responsibility. It is not acceptable, for example, simply to tell the customer that they must answer yes or no to a list of questions. When supplying a veterinary medicine (other than one classified as AVM-GSL) you must either hand over or despatch the product personally; or ensure that, when the product is handed over or despatched, you are in a position to intervene if necessary; or check the product after it has been allocated for supply to a customer and be satisfied that the person handing over or dispatching it is competent to do so.

When supplying a product against a written prescription from another SQP or a vet or pharmacist you must:

  • only supply the product specified in the prescription. It is an offence to substitute a different product or to amend the prescription. If you cannot supply the prescribed product or you disagree with the prescription, you should refuse supply and return the prescription to the customer. You could prescribe a different product that falls within the scope of your registration and follow the requirements for prescription and supply.
  • ensure the prescription has been written by an SQP, vet or pharmacist who is allowed to prescribe the product. 
  • check the prescription is suitable for the condition. If in any doubt, you should contact the prescriber before supplying the product.
  • ensure that the product is supplied to the person named on the prescription. 
  • not break open the immediate packaging of a veterinary medicine. For example, you cannot supply a small number of tablets from a single container and keep the rest for supply later. You are allowed to supply individually wrapped boluses (doses) from a package provided there are enough package leaflets for each separate bolus. You may copy a package leaflet or summary of product characteristics (SPC) to give to the customer.

You must record the following information on all incoming and outgoing POM-VPS transactions:

  • the date
  • the name of the product
  • the batch number
  • the quantity
  • the name and address of the supplier or recipient
  • if there is a written prescription, the name and address of the person who wrote the prescription.

Outgoing medicines include: any sold, returned to a supplier, destroyed or otherwise disposed of.

The records must be kept for 5 years at the approved premises. They may be kept electronically and must be available on request. There is more information on record keeping on the Government website in Veterinary Medicines Guidance. It is not necessary to keep individual batch records providing it is possible, using all the records together, to fully recall a batch.

You may sell a veterinary medicine that falls within the scope of your registration category against a prescription from a vet for use under the prescribing cascade. When a medicine is prescribed under the cascade, the Veterinary Medicines Regulations specify that the person supplying the medicine is legally required to supply written information about the medicine, that includes, at least, the following:

  • name and address of the pharmacy, veterinary surgery or approved premises supplying the veterinary medicinal product;
  • name of the veterinary surgeon who has prescribed the product;
  • name and address of the animal owner;
  • identification (including the species) of the animal or group of animals;
  • date of supply;
  • expiry date of the product, if applicable;
  • name or description of the product, which should include at least the name and quantity of active ingredients;
  • dosage and administration instructions;
  • any special storage precautions;
  • any necessary warnings for the user, target species, administration or disposal of the product;
  • the withdrawal period, if relevant;
  • the words “Keep out of reach of children” and “For animal treatment only”.

The Veterinary Medicines Regulations state that the product must be labelled with this information, but it is reasonable to place some of the required information on a separate sheet. 

Read more about the cascade here.

  • Supplying a veterinary medicine that has passed its expiry date. 
  • Not supplying a product in its original packaging. A product must normally be supplied in its original packaging. If it is not supplied in its original packaging (for example because a vet has prescribed a smaller quantity of individually wrapped boluses [doses]) then sufficient written information must be provided to enable the product to be used safely. 
  • You may not add to, or change the original label or any of the information provided in the product leaflet, unless the supply is being made under a prescription from a vet. 
  • You may not substitute a different product for a medicine that has been prescribed by another SQP, a vet or a pharmacist.

You must know how to report adverse events to veterinary medicines. Adverse events (also called adverse effects or side effects) are effects suspected to be caused by a medicine, other than the expected beneficial effect. The Veterinary Medicines Directorate collects reports of adverse events to medicines. This process is called pharmacovigilance. It is very important in helping us learn about the safety of medicines. You can also report the lack of a beneficial effect because, for example, this can be a sign of resistance developing to parasiticides. You can read more about pharmacovigilance here and make a report on the Veterinary Medicines Directorate website. Anyone, including pet owners, can report an adverse event. If requested, you must be able to give customers advice on adverse event reporting. 

A named SQP is responsible for professional standards in a registered premises. This person takes overall responsibility for how veterinary medicines are obtained, stored, supplied and disposed of. This SQP should also ensure that colleagues recognise the professional responsibilities of an SQP. 

In a business with several registered premises there can be a single nominated SQP responsible for several premises in the business.

You must be satisfied that the product is supplied only to a person (or someone acting on his/her behalf) who holds a Certificate of Competence in the Safe Use of Sheep Dips. Sheep dip supply must be in accordance with the legal requirements. For organophosphorus dips this includes the supply of protective gloves and the laminated notice specified in the Veterinary Medicines Regulations. 

It is good practice to recommend that the purchaser reads the leaflet on Sheep Dipping (AIS41) which is available on the Health and Safety Executive website. It describes safe working practice and safe disposal.

You need to check whether the animal has been declared as non-food producing in the horse passport. SQPs supplying veterinary medicines for horses should advise whether the medicine is suitable for use in food-producing horses. This allows horse keepers to fulfill the requirements for the Horse Passport Regulations. Further information on horse medicines and horse passport record keeping is available on the Government veterinary medicines guidance website.

When prescribing or supplying wormers for sheep or cattle you must follow the relevant recommendations:

Practical exercise

During your work you might need to refer to the Code of Practice from time to time to check up or remind yourself of the rules. Make sure you know where to find the most recent version.

Podcast 

You can listen to a complete podcast of the module below by pressing play or use the download link on the right hand side of the player to download the podcast to your mobile device.

Test yourself

To do the CPD quiz and receive your certificate, just hit the play button on the video below and enter your name and email address before you start.

 

References

Suitably Qualified Persons (SQPs) Code of Practice. April 2017. Defra (Department for Evironment, Food and Rural Affair under the Veterinary Medicines Regulations).

Veterinary Medicines Directorate, 2013. Veterinary Medicines Guidance Note 13 – Guidance on the use of cascade.

The Veterinary Medicines Regulations 2013. (Schedule 3, Part 1, Para. 13).