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What are the main issues regarding labelling Cascade medicines?

All such medicines supplied by a veterinary practice must be labelled in accordance with the Veterinary Medicines Regulations ‘VMRs’.  For products supplied under the Cascade, the following information must be always included: 

  1. The name and address of the pharmacy, veterinary surgery or approved premises supplying the veterinary medicinal product
  2. The name of the veterinary surgeon who has prescribed the product
  3. The name and address of the animal owner
  4. The identification (including the species) of the animal or group of animals
  5. The date of supply
  6. The expiry date of the product, if applicable
  7. The name or description of the product, which should include at least the name and quantity of active ingredients
  8. Dosage and administration instructions
  9. Any special storage precautions
  10. Any necessary warnings for the user, target species, administration or disposal of the product
  11. The withdrawal period, if relevant
  12. The words ‘Keep out of reach of children’ and ‘For animal treatment only’.

Related FAQs

  • This would count as a veterinary prescription, even where the human-licenced medicine is not itself prescription-only.

    Human-licensed medication could be prescribed under step (c)(i) (in Great Britain) or (b)(i) (in Northern Ireland) of the prescribing cascade, however, the justification in this case would also need to account for why a veterinary medicine (authorised for that species and condition, or for another species or condition) could not be used.

    There is specific information regarding prescribing human-licensed paracetamol on the RCVS website.

    Additionally, the VMD has provided guidance on the use of medicines commonly found around the home:

    In exceptional emergency circumstances, you may judge there is a need to alleviate a pet’s discomfort until a home visit can be made or the animal brought to the surgery. You could recommend that an animal owner use a human medicine that they already have in their possession, such as antihistamine tablets. This does not mean a pet owner should be encouraged to go into a pharmacy and ask for a human medicine for their pet.

  • Prescription validity refers to the time in which the medicine must be dispensed, otherwise the prescription will no longer be valid.

    A written prescription for a POM-V is valid for 6 months (unless a shorter period is stated).

    A written prescription for a schedule 2 or 3 controlled drug has a validity of 28 days (unless a shorter period is stated) and is not repeatable.

  • There is nothing to prevent more than one medication (or animal) being included on a written prescription. However, where multiple medicines and animals are noted on one prescription it must be explicit which medicine is for which animal. Veterinary surgeons are free to exercise professional judgement in this regard.

  • Out-of-date stock

    Destruction - The legal requirements to witness the destruction of Schedule 2 CDs apply to stock. This refers to CDs that have not been issued or dispensed to a patient.

    However, any leftover medicines, for example liquids, which are still required for use, are considered as stock. A witness is required if these are to be destroyed on expiry or for other reasons.

    The following are examples of out-of-date stock:

    • The remains of bottles of Ketamine, Methadone, or Fentanyl 28 days after broaching.
    • Any other Schedule 2 CDs that have passed their expiry date.

    There are commercially available denaturing kits, and these can be used to destroy out-of-date stock CDs and returned CDs. Veterinary surgeons should follow the instructions for use and disposal specific to the kit, as these may differ depending on the kit used.

    Recording - The VMD advise that a record must be made of the date of destruction and the quantity destroyed, which the witness must sign. The witness, if an independent veterinary surgeon, should record their RCVS number and confirm their independence in writing in the CD register. The VMD also say that the following information should be recorded: name of the CD, form, strength and quantity, and the signature of the professional destroying the drug.

    Expired stock should not be marked out of the running balance in the CDR until it is destroyed.

    Returned drugs

    Destruction – Any CDs returned to the practice by clients should not be re-used and should be destroyed as soon as possible. The VMD advises that the CD must be clearly labelled as a return and stored in the CD cabinet – but separated from practice stock CDs to avoid potential dispensing errors or re-use.

    Recording - The VMD advise that the requirements to witness and record the destruction of CDs do not apply to returned CDs. However, they advise that it would be good practice for veterinary surgeons should consider making a record of any CD that is returned and having the destruction witness by another member of staff and signed against. This can be recorded in a separate book or sheets designed for that purpose.

    Where an animal has died part way through treatment, the VMD recommends that the prescribing veterinary surgeon should consider making every effort to recover and destroy any remaining product.

    Residual or waste drugs

    Destruction - There is no legal requirement to have the disposal of waste product witnessed. Residual CDs are not usually denatured using kits because, as their destruction is required daily, this would prove too costly. Instead, residual drugs can be rendered irretrievable by collection into cat litter. Periodically, this cat litter is then sent as pharmaceutical waste through the waste contractor.

    Recording - Any medicine left over in an ampoule, vial, or injected into fluids to make a constant rate infusion, which is considered unusable, is considered waste product (as opposed to practice stock). Both the amount administered, and the amount denatured should be recorded on the same line of the CDR to ensure that the running balance tallies – e.g. if 10mg morphine is dispensed to a patient but only 5mg is administered the record should show that 5mg was given and 5mg was wasted. Doing so ensures that the whole vial or ampoule is accounted for in the CDR. It is good practice for the entry in the CDR to be double signed.

  • In order to be an independent witness, a veterinary surgeon must be independent of a practice where the destruction takes place, and they must not have personal, professional, or a financial interest in the veterinary practice where the drug is being destroyed.

    *This is under review by the VMD, it will be updated in due course.

  • One practice may supply to another practice to relieve a temporary supply shortage, without a Wholesale Dealers Authorisation. This exemption from the VMR is intended to prevent shortages of available medicines causing animal welfare problems and should not be a regular occurrence.

  • Veterinary surgeons are required to store CDs securely and appropriately in a suitable cabinet to prevent unauthorised access. The following CDs are legally required to be stored in a locked container which is compliant with the Misuse of Drugs (Safe Custody) Regulations 1973:

    • All CDs in Schedule 2 (with the exception of quinalbarbitone)
    • CDs in Schedule 3 containing buprenorphine, diethylpropion, flunitrazepam and temazepam

    The RCVS considers it advisable for all CDs in Schedule 3 to be stored in the CD cabinet. The Safe Custody Regulations describe the requirements for CD cabinets, safes and rooms and the standards to which they must be manufactured or built.

  • A T28 exemption certificate is what practices need in order to be able to denature controlled drugs for disposal in compliance with the Misuse of Drugs Regulations 2001. Practices can register for the exemption online through the Environment Agency here. Some corporate bodies will register all their practices, and other practices will need to do so on an individual basis. The registration process is free of charge and lasts for 3 years.

    Having a T28 certificate does not change the requirements for witnessed destruction.

  • Once a veterinary surgeon has met their ‘under care’ obligations pursuant to the Veterinary Medicines Regulations 2013, and Chapter 4 of the supporting guidance to the Code of Conduct, they may delegate the dispensing/supply of those POM-Vs to a team member.  They must be satisfied that the person handing it over to the client, is competent to do so. For the veterinary surgeon  to be satisfied the person dispensing must have knowledge of practice protocols (i.e. trained) and there must an SOP in place.

    The prescribing and delegating veterinary surgeon will remain ultimately responsible, and their responsibilities associated with the prescription and supply of POM-Vs, is set out at paragraphs 4.24-4.26 of Chapter 4, as follows:

    4.24  A veterinary surgeon or SQP who prescribes POM-VPS veterinary medicinal product, or supplies a NFA-VPS veterinary medicinal product, and a veterinary surgeon who prescribes a POM-V veterinary medicinal product must:

    1. before s/he does so, be satisfied that the person who will use the product is competent to use it safely and intends to use it for a use for which it is authorised;
    2. when s/he does so, advise on the safe administration of the veterinary medicinal product;
    3. when s/he does so, advise as necessary on any warnings or contra-indications on the label or package leaflet; and
    4. not prescribe (or in the case of a NFA-VPS product, supply) more than the minimum quantity required for the treatment.

    4.25  The Veterinary Medicines Regulations do not define 'minimum amount' and the RCVS considers this must be a matter for the professional judgement of the veterinary surgeon in the individual case.4.26  Veterinary medicinal products must be supplied in appropriate containers and with appropriate labelling.

  • Having prescribed POM-V medicines, if the veterinary surgeon is not present when there is a request for the medicine to be repeated, the veterinary surgeon must:

    • Authorise each transaction individually before the medicine is supplied; and 
    • Be satisfied that the person handing it over is competent to do so.

    A veterinary surgeon could meet the requirement to authorise each transaction by:

    • Handing over a medicine personally following a consultation, or instructing a fellow team member to dispense/supply the medicine;
    • Making a note on a client’s record that repeat prescriptions could be supplied to the client;
    • A team member taking a call from a client and putting a medicine aside for the veterinary surgeon to authorise before being supplied;
    • In the case of a client unexpectedly coming into the practice, by a phone call to the veterinary surgeon, to authorise the supply.

    Whichever method is used there must be an audit trail to show that the medicines has been prescribed by a veterinary surgeon.

    Note: A Suitably Qualified Person (SQP) under the Veterinary Medicines Regulations 2013, is under similar requirements for the prescription and supply of POM-VPS medicines



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