NB. The requirements of the Veterinary Medicines Regulations apply to all practice (stock) medicines.
1. What are the requirements?
In accordance with the Veterinary Medicines Regulations 2013, veterinary surgeons may only supply veterinary medicinal products (excluding AVM-GSL products) from veterinary practice premises on the Register of Veterinary Practice Premises (RVPP).
2. Why is a register of veterinary practice premises needed?
The Register enables an inspection regime to be implemented by the Veterinary Medicines Directorate (VMD) to improve traceability of Controlled Drugs and to ensure veterinary surgeons are compliant with the Veterinary Medicines Regulations. According to the VMD, this answers criticism from EU auditors and brings veterinary surgeons in line with other retail suppliers of veterinary medicinal products, who are permitted to supply only from registered premises.
3. How much do I have to pay for registration?
The annual statutory registration fee is £34 for each veterinary practice premises. For example, if a practice has one main practice premises and two branch premises, each premises must be registered each year (3 x £34 = £102).
For veterinary practice premises accredited under the RCVS Practice Standards Scheme, the annual statutory registration fee is taken from the annual fees paid to the Scheme. An annual statutory registration fee will be payable for any premises that are not PSS-accredited.
4. How have the requirements been introduced?
The legal requirement for the registration of veterinary practice premises is in the Veterinary Medicines Regulations.
The professional requirement for recording where all medicines are stored or kept (and keeping that record at the practice’s main veterinary practice premises in an accessible form) is in Chapter 4 of the supporting guidance to the Code of Professional Conduct: Veterinary medicines. The professional requirement avoids the need for wider ranging registration of premises and cars from which medicines may be supplied; only veterinary practice premises from which medicines are supplied must be registered with the RCVS.
5. Who is responsible for the enforcement of the Veterinary Medicines Regulations?
The Veterinary Medicines Directorate (VMD) is responsible for the enforcement of the Veterinary Medicines Regulations (VMR), including the registration and inspection of veterinary practice premises. Inspections by VMD inspectors will be targeted following an assessment of the risks involved by VMD; the statutory fee for a VMD inspection of a premises is £350. VMD inspectors may issue Improvement Notices and failure to comply with an Improvement Notice is a criminal offence.
6. How does the RCVS Practice Standards Scheme relate to the registration requirements?
Registration of veterinary practice premises builds on the existing registration of practices under the RCVS Practice Standards Scheme (PSS). Those practice premises which are PSS-accredited pay an annual fee already, which provides for the annual registration of the practice’s premises.
7. If a practice is accredited under the RCVS Practice Standards Scheme, will it be inspected by VMD inspectors?
A PSS-accredited practice will not be inspected by VMD inspectors, unless there is an investigation for enforcement purposes. Veterinary practices within the PSS must comply with key aspects of the Veterinary Medicines Regulations and are inspected routinely by RCVS PSS inspectors.
8. Will I be inspected by the VMD if I have applied to join the RCVS Practice Standards Scheme?
The VMD has said it will not inspect practices applying to join the PSS, unless there is an investigation for enforcement purposes. If you are notified of a VMD inspection and then apply to join the PSS there are strict requirements regarding timescales for the application to be submitted and the initial PSS inspection to take place.
9. I practise out of a number of premises; how do I know which are veterinary practice premises?
Premises likely to be considered as ‘veterinary practice premises’ by the RCVS and the VMD are those
- from which the veterinary surgeons of a practice provide veterinary services; and/or,
- advertised or promoted as premises of a veterinary practice; and/or,
- open to members of the public to bring animals for veterinary treatment and care; and/or,
- not open to the public, but which are the base from which a veterinary surgeon practises or provides veterinary services to more than one client; and/or,
- to which medicines are delivered wholesale, on the authority of one or more veterinary surgeons in practice.
This is not an exhaustive list of premises that may be considered as veterinary practice premises.
10. I practise at main practice premises and branch practice premises; are both of these veterinary practice premises?
Yes; all practice premises from which medicines are supplied must be registered with the RCVS.
11. I store medicines at home; is my home a veterinary practice premises?
If you practise from your home and supply medicines from there, your home must be registered with the RCVS as a veterinary practice premises. Even if you store only small quantities of medicines at your home, you will need to register your home as a veterinary practice premises if you supply those medicines to others (supply includes administering medicines to other people’s animals).
However, if you keep a small quantity of medicines at your home, for example, for on-call purposes, and that store of medicines is recorded at a registered veterinary practice premises, the home premises need not be registered.
12. I store medicines in my vehicle or a practice vehicle; are vehicles veterinary practice premises?
No, vehicles are not premises, but you must maintain a record of vehicles in which medicines are stored or kept (the record should be held at the main veterinary practice premises in accessible form).
13. I authorise wholesale supplies of veterinary medicines to a charity/business premises; are they veterinary practice premises?
Yes; the charity/business premises are likely to be considered veterinary practice premises for the purposes of supplies of those veterinary medicines to the charity/business, for animals owned by the charity. (You or the charity may register the premises with the RCVS.)
NB. The Veterinary Medicines Regulations provide that a veterinary surgeon may supply veterinary medicines (for example, POM-Vs after the clinical assessment of an animal under his or her care) ‘irrespective of who owns [those medicines].’ (Schedule 3 paragraph (6) (b))
If you authorise supplies of medicines to the charity/business, you are responsible for the medicines, for example, correct storage and annual audit; responsibility may be shared with the charity/business.
14. Do mobile units and stalls at exhibitions/shows need to be registered?
A mobile unit (which includes an ambulatory unit) cannot be registered by itself as a Veterinary Practice Premises (VPP), but must be linked to a registered ‘bricks and mortar’ premises where the unit is normally stored (even if no veterinary services or VMP supply takes place from the premises itself).
A stall at an exhibition or show which is for the promotion of a registered VPP and/or veterinary services, does not need to be registered as a VPP in its own right, and small quantities of VMPs can be supplied, provided the stall is an extension of the registered VPP. This applies as long as an MRCVS is present to supply the VMPs. If there is no MRCVS present then an SQP is required and the location will need to be registered as a VPP.
If the stall is operating solely to retail supply VMPs, then it needs to be registered as a standalone VPP. However, a tent or marquee cannot be registered as a standalone VPP as neither is considered to be permanent premises.
In the case of a mobile unit, (which would include a tent or marquee), like the vet’s car, the unit must be related to the promotion of a Registered VPP and/or a vet treating animals, and cannot be used solely as a mobile shop to retail supply VMPs.
15. I leave small quantities of veterinary medicines at a charity/business premises which I prescribe later; are they veterinary practice premises?
No; if you take smaller quantities of (stock) medicines to the charity/business premises, the premises are unlikely to be considered veterinary practice premises (unless 15a or b is applicable), but you will need to keep a record of the premises (see Chapter 4 of the supporting guidance to the Code of Professional Conduct: Veterinary medicines and FAQs 21 and 22).
16. I provide veterinary services at a charity/business; are the charity/business premises veterinary practice premises?
The charity/business premises may be veterinary practice premises, if, for example:
- the premises are open to members of the public to bring animals for veterinary treatment and care (i.e. the animals are not owned by the charity/business); and/or,
- the premises are used as a base to provide veterinary services to other clients.
17. Who may register veterinary practice premises with the RCVS?
Anybody involved with the practice may register it as a veterinary practice premises with the RCVS, but it would be helpful if within the practice there is agreement about who is to be the point of contact.
18. How do I register veterinary practice premises?
You will need to complete the Practice Premises Application form, this can be downloaded from the 'Related documents' box, and pay the appropriate statutory registration fee (£34 for each veterinary practice premises).
19. What if I am unsure whether premises are practice premises that must be registered with the RCVS as a veterinary practice premises?
If you are unsure whether premises must be registered, please contact the Registration Department on email@example.com or 020 7202 0707 for further guidance; the Department may liaise with the Veterinary Medicines Directorate before providing further guidance.
20. Our practice is moving premises, do we need to register again?
Yes, if you move your practice to new premises, you need to submit a registration application for the new premises and pay the £34 fee. It is not possible to transfer registration between premises.
To close the premises you are moving from, please complete the Register of Veterinary Practice Premises Removal form, found in the 'Related documents' box.
21. Our practice is changing ownership, do we need to re-register the premises?
If nothing except the owner, or the practice name, is changing and the staff and the operational running of the practice is remaining the same then you do not need to re-register. You only need to advise the College of the new ownership details. The registration for the premises will continue and you will be sent a reminder for the next year’s fee to that address.
You will require a new registration if the staff, management and/or the operational running of the business is changing.
22. What is this record requirement?
The record requirement is outlined in Chapter 4 of the supporting guidance to the Code of Professional Conduct: Veterinary medicines pars, 4.27 - 4.29. It comprises a description of both the legal requirements for practice premises registration and the professional obligation for record-keeping.
23. Do I need to keep details of the medicines stored at the unregistered premises or other places?
You are accountable for your practice (stock) medicines stored at other premises, including, for example, stores at the homes of employees and at charity/business clients; as you are for medicines stored at your practice’s veterinary practice premises.
Last updated November 2013