Standards & Advice update: January 2023

This month’s Standards & Advice update details changes we’ve made to our supporting guidance to the Code on client confidentiality (Chapter 14) as well as changes to the both the Code supporting guidance, and the Practice Standards Scheme guidance on the safe use and storage of the barbiturate quinalbarbitone.

Please note: this article contains references to self-harm and suicide. 

Client confidentiality

Updated guidance on client confidentiality has been published, to address common issues arising in advice queries and make the guidance easier to read.

The update to Chapter 14 of the supporting guidance to the Code of Professional Conduct makes it clearer that veterinary surgeons and veterinary nurses should feel empowered to exercise their professional judgement to make a decision to disclose confidential client information to authorities in certain circumstances.

The updated guidance, which was recently approved by the RCVS Standards Committee, also clarifies that there is no requirement to seek permission from the RCVS before making a disclosure, and that the RCVS will support any reasonable decision by a veterinary surgeon or veterinary nurse who genuinely believes they are acting on the basis of animal welfare or the public interest.

The new guidance includes an expanded discussion of animal welfare concerns that focuses not only on animal abuse, but also neglect and failure to attend follow-up appointments. It also suggests that veterinary surgeons and veterinary nurses may wish to cite RCVS guidance and include photo or video evidence in their records to support disclosure decisions, and clarifies the application of the General Data Protection Regulation (GDPR).

New requirement for safe storage of quinalbarbitone

Following concerns over its use in self-harm and suicide amongst veterinary professionals, the Standards Committee has agreed to introduce new guidance regarding the barbiturate quinalbarbitone, including advice that it should be locked away to the equivalent extent of other Schedule 2 controlled drugs, ie in a locked secure cabinet.  

One of the reasons the veterinary profession has a relatively high rate of suicide compared to the general population is access to means, including drugs such as quinalbarbitone. Following discussions with the Canmore Trust, a charity set up by the family of a young vet who used quinalbarbitone to end his own life, and other stakeholder groups, the College has updated its guidance to try and help prevent such incidents in the future.

Unlike other Schedule 2 controlled drugs, it is not currently a requirement of the Misuse of Drugs (Safe Custody) Regulations 1973 that quinalbarbitone be subject to safe custody, which means that legally it does not have to be locked away. However, given the potential for misuse and serious harm it can cause to humans, the Standards Committee has accepted a recommendation from the Practice Standards Group that there should be an RCVS requirement that quinalbarbitone is securely locked away. The Committee has therefore approved new guidance in both the supporting guidance to the Code of Professional Conduct and the Practice Standards Scheme’s (PSS) Core requirements that brings quinalbarbitone in line with other Schedule 2 controlled drugs.

This decision follows a previous decision by the Committee in May 2021 that all Schedule 3 controlled drugs should be locked away, meaning that the guidance on storing barbiturates is now consistent.  

In coming to its decision, the Standards Committee considered the impact of such a change on veterinary surgeons, especially those in equine or farm roles, who may prescribe and administer quinalbarbitone from their vehicles. However, it was agreed that the inconvenience of the new storage requirement of the drug could be justified. 

The new guidance is effective as of 1 February 2023 as is as follows: 

PSS Core Standards: 

Chapter 10.1.12 in Small Animal Standards/Chapter 9.1.12 in the Equine Standards/Chapter 8.1.12 in the Farm Standards: 

Schedule 2: Includes ketamine, etorphine, fentanyl, morphine, papaveretum, pethidine, methadone and quinalbarbitone. Drugs must be kept under safe custody (locked secure cabinet). Quinalbarbitone is not legally subject to safe custody, but it is a Core requirement that all Schedule 2 drugs are locked away equivalent to safe custody. Drugs may not be destroyed except in the presence of a person authorised by the Secretary of State. Failure to comply with this Act can lead to prosecution. 

PSS Core standards guidance note: 

Veterinary surgeons should ensure that Schedule 2 controlled drugs under safe custody in practice vehicles are kept in a locked receptacle which is fixed within the car. If the car cannot be modified in such a way, it may be reasonable to secure the receptacle to a structure in the car, for example, using a metal cable tethered to an anchor point, such as the seat runners or seatbelt post, or bolting the lockable receptacle to the floor of the car. In any case, the receptacle should be kept out of sight. The secure container would ideally be fixed to the frame of the vehicle, but using a secure, lockable glove compartment or a secure container chained to the inside of the vehicle (e.g. passenger seat) would also be acceptable. Examples of secure containers include car safes, laptop safes and lockable cash tins.  

When transporting Schedule 2 controlled drugs, veterinary surgeons should avoid leaving the secure container unattended. Where this is unavoidable, the vehicle and container should remain locked and the time unattended kept to a minimum. Wherever possible, controlled drugs should be returned to the controlled drugs cabinet at the practice for storage overnight. Where this is not possible, controlled drugs may be stored in locked vehicle, but they should be inside a locked receptacle secured to the structure of the vehicle and kept out of sight. For more information, see VMD Guidance Controlled drugs: Veterinary medicines and RCVS Guidance on Controlled Drugs. 

Chapter 4 of the supporting guidance to the Code of Professional Conduct 

4.34 Schedule 2 controlled drugs, such as methadone, fentanyl, and ketamine, are subject to safe custody requirements and legally must be kept in a secure cabinet to prevent unauthorised access. Although quinalbarbitone is not legally subject to the same safe custody requirements, it is an RCVS requirement that ALL Schedule 2 drugs are locked away equivalent to safe custody.