Mobile veterinary practice and federal drug restrictions

Mostly, when I took my cats to the vet, I would cram them into a carrier while they protested and drive them to a clinic. It was a rough trip for them, so rough that at one point I called a travelling vet to come see them at home. What a difference: they were more confident in their own territory, and got to deal with the stressful physical exam without having first been stressed by a car ride and a wait in a room full of dogs. More and more small animal mobile practices are cropping up these days. Of course, a significant percentage of large animal practices have always been mobile. It is prohibitively expensive to transport cows to a clinic, hugely stressful for the animal, and may be impossible if the cow is too sick to walk. Most horses are also treated on site rather than at a clinic, except for referral cases which are seeing specialists.

So in my mind, mobile practice is good for small animals and essential for large ones. Unfortunately, the Controlled Substances Act, passed by Congress in 1970, limits where controlled substances can be carried. The act apparently has not been applied to mobile veterinary practices until recently, but the Drug Enforcement Agency (DEA) appears to be changing its practice this year, as mobile veterinarians in California report that they have received notices that their activities are illegal.

Mobile veterinarians, both small and large animal, routinely carry controlled substances for pain relief and euthanasia. Non-controlled alternatives do exist, but are much less effective. For example, one cow vet reported that to remove a cow’s eye, he was no longer able to use sedation or powerful systemic pain relief in the form of an opioid, but would have to rely on local anesthesia (lidocaine), which he felt was insufficient to manage the animal’s discomfort during the procedure. Another cow vet reported that he was falling back to using a .22 Magnum for euthanasia.

The regulations do allow for veterinarians to carry the amount of medication that they expect to need during the current day for a planned procedure. This does not allow for unplanned procedures (the animal who unexpectedly requires euthanasia) or unexpected increases in dosage (the animal whose pain is clearly not controlled by the expected amount of medication, or, worse, who requires more than the expected amount of euthanasia solution). Veterinarians also cannot predict how much sedation and pain relieving medications to bring for a day in a mobile spay neuter clinic, to which animals may arrive without appointments.

The DEA contends that only Congress has the power to change the wording of the Controlled Substances Act. Obviously, we can ’t expect such change to happen any time soon. In the meantime, we can wait and see how the DEA proceeds.

JAVMA News
Journal of the American Veterinary Medical Association
June 15, 2012, Vol. 240, No. 12, Pages 1384-1407
doi: 10.2460/javma.240.12.1384