Veterinarians Act

Feedback deadline was: October 4, 2018

This consultation is now closed.

In 2013, the College of Veterinarians of Ontario (CVO) began work to modernize the Veterinarians Act (VA) as few amendments have been made since its proclamation in 1990. Subsequently, a broad research and consultation resulted in, Achieving a Modern Approach to the Regulation of Veterinary Medicine in Ontario, a report proposing 19 amendments that were approved by CVO’s Council at its December 2017 meeting. The amendments have since been shared with the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA) for review.

In Ontario, both veterinarians and pharmacists are involved in dispensing, compounding and selling of drugs for animals, creating an overlap within scopes of practice. As CVO works to modernize the VA, there is recognition of the need to ensure that pharmacists can continue the longstanding practice of dispensing, compounding and selling medication to animal owners. However, the changes being considered would prevent pharmacists from prescribing, adapting any drug or substance to or for an animal. The rationale for this is that animal toxicity is different than human, making pharmacist interpretations and recommendations beyond a veterinary prescription a significant risk to animals.

The Ontario College of Pharmacists (OCP) is seeking feedback regarding the changes to the VA that impact the pharmacy profession. This will inform a productive dialogue between OCP and CVO with a shared goal of public safety and risk reduction in care delivery. Results of the consultation will be provided to CVO to inform its work.

Review the proposed amendments here.

Question to Guide Your Feedback:

Do the proposed modifications to the Act adequately and appropriately address the risks associated with the involvement of pharmacists with veterinary prescriptions?

Read The Feedback
  • Other - POSTED October 4, 2018

    Dear Registrar, The ACPC is pleased to provide its commentary on the consultations that the OCP has solicited with respect to changes as described in the CVO and its impact on the compounding pharmacy scope of practice. Our underlying premise with respect to the comments herein is that we agree – both veterinarians and pharmacists are involved in dispensing, compounding and the sale of prescription medications and drugs for animals, which invariably creates an overlap within scopes of practice. Our Association, ACPC, is national in focus and pan-provincial in scope. We believe the interests of the profession of Compounding Pharmacists are inextricably linked province by province by virtue of the work we do. In the case of this issue, our profession ‘" in particular ‘" works closely with veterinarians and, as such, we agree with the CVO that our professions collectively enjoy a solid history of collaboration and collegiality. Of course, we agree too that that our mutual existence is and ought to be rooted in good regulation. Our comments herein offer recommendations that may run counter to what has been proposed and we endeavour not to hold back from sharing our thoughts on this matter in the context of the work we do in veterinary medicine and the collaboration between pharmacy and veterinarians. As always, we are available to discuss this further at our mutual convenience. Again, thank you for the opportunity to provide our perspective. Sincerely, Marc Kealey Executive Director C: ACPC Board of Directors ACPC Comments in response to OCP collaborative consultations ‘" ‘Achieving a Modern Approach to the Regulation of Veterinary Medicine in Ontario’  Introduction ACPC is Canada’s national voice for Compounding Pharmacy. One need only undertake cursory investigation of the profession to note that the profession has tentacles in myriad of scopes of practice including veterinary medicine. As such, we could not agree more with the comments made by CVO that our two professions enjoy a solid history of strong collaboration and collegiality. Moreover, there is recognition and agreement that because our two professions work collaboratively within a highly regulated environment that, indeed, the public benefits. Notwithstanding that pharmacists ‘" most specifically compounding pharmacists – have offered opinion on CVO working groups over the decades, we have worked on myriad issues like Quality Assurance all in the context of Modernizing the Act. To this date, the profession is committed to continue those efforts. As further context, we know that the Veterinarians Act has had little modification since it was proclaimed in the early 1990’s under the massive regulatory professions review process at that time. While the CVO has moved to modernize its Act recently, it cannot be understated that compounding pharmacy has been a collaborative part of the veterinary profession on several aspects because we’re so involved with veterinary medicine and, indeed, with veterinarians. One big concern, moreover, has to do with the current process undertaken by the CVO to modernize ‘" a process seemingly embraced by the OCP ‘" and that is this issue of risks to veterinary practice. We were heartened that the review and subsequent recommendations, related to shifting veterinary practice in the province of Ontario, contemplates an exemption for the pharmacy profession in the area of the dispensing, compounding and sales of medications. In fact, Pharmacists dispensing medications to animal owners has been common practice in Ontario ‘" and across Canada for that matter. The following are immediate concerns the ACPC has with modifications attached thereto. ACPC Concerns and Recommendations It is on this matter that ACPC operates in an environment where the expanding role of pharmacists in human medicine can and should equally apply to animals. For that reason, we will seek assurances that the language in the soon to be modernized new Act maintains the current role and definition of pharmacists with animals and appropriately clarifies where boundaries might exist. We agree with CVO that perhaps boundaries could be based on knowledge, competency, and risk to animals. But of course, that presupposes that compounding pharmacists in the space are not adequately trained ‘" we take exception to this because we are well trained. More specifically because compounding pharmacists, in particular, receive and fill veterinary prescriptions, we work closely with prescribing veterinarians to ensure issues like toxicity never present risk nor minimize nor mitigate against results like the death of an animal. Compounding Pharmacists ‘" as highly trained professionals are dedicated to public safety and to risk reduction in patient care delivery. To that end, we are suggesting that within the amendments to the Act we propose the following: 1. The proposed ‘definitions’  for inclusion in the Act should raise concerns because, we believe, the proposed definitions may become the operative terms used whenever they appear or are used in the context of the Veterinarians Act. We’re confused by this because two of the terms listed on page 2 of this review document are defined. For example, if an owner gives consent to the dispensing pharmacist to demonstrate how to get the animal to ‘ingest’  a dose, should that be permitted? We believe it should be and is akin to ‘informed consent.’  In practice with humans, for example, such actions were prohibited and flaws were recognized and amendments were proposed and accepted to permit such actions in terms of things like educational training. Furthermore, we believe that these kinds of standards ought to be in place for animal patients, when the owner requests demonstration. Otherwise, the patient may not get the dose at all and the whole thing may become NEGATIVE for the patient , which we submit is NOT in patients’ best interests. We’re confused as to why the Act even needs to define ‘pharmacist’  at all. Pharmacy Acts in every province in Canada do not define ‘Veterinarian.’  Why? Because we understand that this definition is covered by existing statutes federally. In fact, the addition of ‘pharmacist’  in the Veterinary Act presents a risk of compromising or confusing the existing definitions that appear elsewhere. To that end, to have the definition read; Pharmacist ‘means a member of the Ontario College of Pharmacists’  creates more complexity. For example, given that prescriptions can be filled from across Canada in accredited pharmacies, narrowing the definition to Ontario would not cover cases where pharmacists in other province or territories are involved in veterinary care. As an example: their exclusion for adapting by a pharmacist would then only apply to an Ontario pharmacist, allowing for the very risk the CVO perceives could occur if, as they see it, a member in good standing under the CVO issues a prescription which, in turn, may be filled in another province (e.g., a Quebec pharmacy from a veterinarian in Ottawa where the owner is resident in Quebec; or similarly between northwestern Ontario and Manitoba). This is of concern to ACPC and, in our opinion, requires more consultation. To wit, an owner in another province finds a reputable Ontario pharmacy to prepare the prescription from its veterinarian. Under this definition a pharmacist in that province would not be governed by the statute as suggested by CVO because said pharmacist may not a ‘member of the OCP.’  As such, non-Ontario pharmacists who are authorized to prescribe, and/or adapt a prescription, could go ahead whereas an Ontario pharmacist could not. The CVO proposed definition even varies from what is contained in the DPRA – ‘pharmacist’  means a person registered as a pharmacist under the Pharmacy Act, 1991; As such, ACPC recommends using the definition as described in the Food and Drug Regulations: To wit – pharmacist means a person who; (a) is registered or otherwise entitled under the laws of a province to practise pharmacy, and (b) is practising pharmacy in that province; (pharmacien) Respectfully submitted this 4th day of October 2018.

  • Other - POSTED October 4, 2018

    By E-mail Registrar Lum-Wilson: Re: Consultation — Veterinarians Act Summit Veterinary Pharmacy Inc. (SVP) welcomes the opportunity to comment upon this consultation posted on the OCP website. As a pharmacy that specializes in the preparation of prescribed veterinary medications compounded to meet the orders of the prescriber, as well as via commercial dosage forms, and with a staff complement that includes veterinarians, we believe we can offer valuable feedback to assist the College in this area. We have noted that of the 17 or so comments posted to date, many state generally that they feel pharmacists do not have the training to be involved in veterinary prescriptions. Respectfully, we disagree. There are many pharmacists who undergo post-graduate training to specialize in this field of practice and are therefore well-positioned to carry out this practice. Those comments should not be seen to speak for the profession as a whole. Standards of practice for pharmacist require that a pharmacist not practice in an environment where they do not have adequate qualifications to carry out those duties. As such, while there may be those who should not be involved, there are also those who SHOULD be involved due to their advanced training. As a comparator, should pharmacists who have not taken advanced geriatric management courses, or expanded diabetic care courses, be precluded from dispensing any such prescriptions? As the consultation references a letter dated October 31, 2017, from Registrar Robinson at the CVO to yourself, we believe the content of that letter is the focus upon which feedback is desired. As to the question on the website of ‘Do the proposed modifications to the Act adequately and appropriately address the risks associated with the involvement of pharmacists with veterinary prescriptions?’ , we would take issue with that because first, we do not perceive there to be ‘risks’  given our expertise, that are any more prevalent than for any other prescriptions filled by a pharmacy. We struggle with why this is an issue for the OCP to address as it involves another profession’s regulatory environment; it should not impact upon pharmacy practice, just as pharmacy legislation does not intrude into modifying veterinary practice. However, the consultation letter raises numerous concerns that we shall address in our comments that follow. The OCP website summary re the consultation further states: ‘…the changes being considered would prevent pharmacists from prescribing, adapting any drug or substance to or for an animal…The…(OCP) is seeking feedback regarding the changes’  to the VA that impact the pharmacy profession.’  With that statement front-of-mind, along with Registrar Robinson’s letter, our comments follow. (Ltr, p1): ‘Pharmacists dispensing medications to animal owners is a longstanding practice in Ontario.’  In fact, this is a longstanding practice in CANADA, not just Ontario. Federal legislation has been quite clear in identifying that a pharmacist licensed to practise in a province/territory (P/T) of Canada may fill a prescription issued by a prescriber licensed to practise in a P/T of Canada. As well, all provincial pharmacy regulatory authorities are signatories to NAPRA’s ‘Mobility Agreement for Canadian Pharmacists’  (signed July 6, 2009, in particular section 4 thereof). This was clarified by Registrar Deanna Williams (OCP) in the May/June 2007 issue of OCP’s Pharmacy Connection (p.20). (Ltr, p2): ‘We (CVO) do not, however, support pharmacists, regardless of training, prescribing any drug, adapting a veterinary prescription, or administering an drug or substance by injection, ingestion, or inhalation, to or for an animal.’  Ontario Regulation 202/94 (sections 36-38) authorizes a pharmacist to adapt or renew a prescription subject to specific legislated requirements. These include that there has been a prescription issued which then allows (per discretion) renewing the prescription not exceeding the original prescribed quantity (with refills) or a six month supply (whichever is lesser). There are also prescribed requirements for notice to then be given afterwards to the original prescriber. This ensures continuity of care and that patient best interests are respected. Adapting a prescription can include a change to dosage form to ensure compliance, and so per this suggestion by the CVO, that would not be allowed. It is disturbing that the CVO would approach the OCP with a view to ‘supporting’  this concept when the patient has already been established on a medication regime and for whatever the reason might be (usually continuity of care absent a new prescription being available), cannot exercise their legal right to renew the prescription for the patient (whether human, or animal). SVP would request that the OCP consider this matter very seriously and not condone this rationale. That includes where the animal owner requests the pharmacist’s assistance in administering a dose to the patient (or requires demonstration of how to properly administer a dose), to not agree to the CVO’s position in that respect. Why would the OCP allow a special situation for one class of patients where the regulatory provisions of O/R 202/94 cannot be applied? Why would these actions be permissible for humans, but not for animals, as patients (i.e., a higher standard for animals than for humans)? It would become a nightmare for pharmacists to have to consider where O/R 202/94 applies and where it does not (due to individual provincial legislation that tries to override the Ontario legislation). (Ltr, p2): ‘…a drug used in an animal that is not specifically labelled for use in animals, must be dispensed with a veterinary prescription as it is considered off label drug use,…’  In reality, veterinarians purchase human-approved drug products every day and use them ‘off-label’  in their patients. If they do not have such product in inventory, they issue a prescription (or purchase from a pharmacy) which then is filled at the pharmacy. Either way, there is a prescription involved in this process, and the prescriber has complete control over the accuracy of what goes to the patient. Who fills that order becomes irrelevant, if it is done per the prescription direction. That also applies whether the prescription is being filled by a veterinarian or a pharmacist, either in or outside Ontario. As well, pharmacists have difficulty in getting a distributor of veterinary medicines to sell products to them, as they exclude pharmacists and sell only to veterinarians. When a veterinarian does not have the drug on hand for an instant need, they turn to pharmacies for assistance. Again, any ‘risk’  is considered because it is (once again) the veterinarian issuing the prescription. The CVO recently adopted a revised ‘Practice Standard’  for its members regarding ‘Prescribing a Drug’  and in that document, actually permit a member of the CVO to issue an oral prescription to an out-of-province veterinarian, but NOT TO A PHARMACIST. Their rationale: ‘…there is an increased risk of potential harm if oral prescriptions were to be given to pharmacists outside of Ontario’s jurisdiction. It is important to note that these rules apply only to the provision of oral prescriptions.’  So…Ontario pharmacists are reliable in accepting an oral prescription, but not our Canadian colleagues outside Ontario? But a non-oral prescription is…no problem? There is no logic to this perceived risk, although it is great fear-mongering and ultimately puts the patient in the middle of an ‘increased risk’  (not supported by evidence) of ‘potential harm’  excuse in not getting expeditious access to necessary medications. That creates a dilemma where provincial borders have patients on one side, prescribers on the other. No can do? Ottawa/Gatineau; northwestern Ontario/Manitoba; the picture is clear. This cannot be condoned by the OCP in considering ‘patient best interests’ . As such, no re-wording of the Act should be accepted that would compromise federal standards and laws pertinent to the practice of pharmacy. Pharmacists are quite well-qualified to receive oral prescriptions, and know what the requirements are for the order to be a legal order. Often, the prescribers are ‘short on details’  and have to be asked for that additional information. Some jurisdictions even permit pharmacy technicians to receive prescriptions, so the qualifiers have been met and provided the prescriber gives the necessary details, there is no ‘increased risk’  by having a non-Ontario pharmacist receive an oral prescription from an Ontario veterinarian. DEFINITIONS We question why the CVO should be defining terms relevant to pharmacy practice in its veterinary legislation. Of the nine terms, only 3 are new; the rest already exist in either the Veterinarians Act, or Regulation 1093. ‘Pharmacist’  is well-defined in federal legislation and is consistent across the country (refer to Food & Drug Regulations section C.01.001). However, the CVO proposal creates an exclusion for anyone other than an Ontario pharmacist, as it is not consistent with the federal definitions: ‘pharmacist’  means a person who (a) is registered or otherwise entitled under the laws of a province to practise pharmacy, and (b) is practising pharmacy in that province;’  Federally, the term ‘prescription’  is not a ‘direction from a member’  (of CVO), but ‘from a prescriber.’  SVP urges the OCP to convey to the CVO that the above definitions be used rather than the proposed definitions of ‘pharmacist’  and ‘prescription.’  Creating variance in definitions only serves up confusion, when over the years there has been a movement to consolidate these definitions for national consistency. The ‘adapt’  definition is a copy of what appears in O/R 202/94 (s.31), and the letter goes on under ‘Application’  to NOT permit a pharmacist to prescribe, adapt, renew, administer, or make a therapeutic substitution. Therapeutic substitution is not permitted under the pharmacy regulation, so it’s not an issue; but as we well know, if you get the prescriber’s consent to change the prescription, it’s perfectly legitimate and not such ‘substitution.’  If the definition of ‘pharmacist’  as proposed by the CVO was recognized, then given its stance taken re ‘oral prescriptions to outside Ontario’  this would preclude any non-Ontario pharmacist from receiving an oral prescription from an Ontario member of CVO. But a written order would be fine, which includes a fax (and ultimately soon, an e-prescription). How can speaking directly with the prescriber, clarifying at that time any issues, be more dangerous than receiving a faxed prescription with no interaction? And why should a visitor to Ontario with a pet alongside, be able to see an Ontario member of CVO and then take a prescription back to their province and have it filled, but the reverse be prohibited? Thank you for your attention to these comments and again, for the opportunity for us to provide them to you, to assist in the consultation. Summit Veterinary Pharmacy Inc.

  • Other - POSTED September 24, 2018

    I work in a specialized veterinary pharmacy. We do have the necessary knowledge to practice the expanded scope with respect to prescriptions for animals. However, I recognize that most pharmacists do not have the required knowledge to do so. I think the best course of action is for OCP to educate pharmacists that there are significant differences in these patient populations (which they have already been doing) and that pharmacists must be careful not to practice in an area where they are not proficient or they will potentially be subject to disciplinary action. I don’t think limiting all pharmacist’s scope of practice "across the board" is the right solution to this problem.

  • Other - POSTED September 24, 2018

    The proposed changes are reasonable and practical. If a pharmacist wants to pursue education in veterinary medicine they should consult with CVO.

  • Other - POSTED September 17, 2018

    I welcome the opportunity to take on roles in veterinary pharmacy and would ensure no decisions would compromise the safety of the animal. Pharmacists are in a position to share in the care of animals with veterinarians and increase safety and efficacy with proper training.

  • Other - POSTED September 17, 2018

    I think pharmacists should stay off veterinarian prescriptions. There is zero education from the faculty when I was in school and in continue education during my practice.

  • Other - POSTED September 12, 2018

    The changes are unreasonable and not practical. Even though an animal dosing could be different than a human, pharmacists usually dispense the medications which are with in the maximum recommended dose for all population. There should be a clause where dispensing some medications should not be allowed but the ban should not be implemented for all the medications.

  • Other - POSTED September 11, 2018

    Proposed changes are reasonable. I studied in Qc province and we had a course on basic vet pharmacotherapy for feline and canine. It was very informative and helpful for my current practice. A more advanced CE would be useful for the proposed changes and access to convenient vet references as well.

  • Other - POSTED September 19, 2018

    I completely agree with the CVO’s recommendations: pharmacists should not be able to prescribe or adapt therapy for animals as we lack the expertise to do so. We received no special training in veterinary medicine.

  • Other - POSTED September 5, 2018

    Adaptations: must leave room for specific and common situations like substituting 2x250mg tabs for 1x500mg if necessary and appropriate. Renewals: careful clinical judgement must rule the day where continuity of care may be critical, so leave room for that. OTC recommendations: careful clinical judgement must be used (and allowed) especially when a veterinarian advises the client to purchase a product OTC and then the client (naturally) asks the pharmacist for input. Specific knowledge base: some pharmacists ARE educated in animal healthcare and this needs to be recognized and accounted for.

  • Other - POSTED September 4, 2018

    The proposed changes are reasonable. Don’t have any concern.

  • Other - POSTED September 4, 2018

    Pharmacists must be able to continue to adapt and renew for animals. Suppose a dog is on seizure medication and the vet has not approved a refill yet, the aminal could have a seizure without continuity of care – which could be provided by a pharmacist extension. For adaptations, prevention of adaptation would include something as simple as stopping a pharmacist from changing a prescription from 500mg tabs to 2X250mg tabs because 500mg is unavailable on the market due to a backorder.

  • Other - POSTED August 31, 2018

    Pharmacists should have the opportunity to adapt formulations when providing the equivalent dosage, after having accessed pharmacokinetic/dosing information for the particular species. Agreed that formal education and specialization in this area should be the norm for people practicing in this setting. As a pharmacist and an animal owner my understanding of the pharmacokinetics and pharmacology of the medications prescribed broader than the vets.

  • Other - POSTED August 31, 2018

    I would welcome the opportunity to broaden my knowledge in animal medication management. Being competent in helping people choose OTCs for their animals, would be a win win for all, including the animals.

  • Other - POSTED August 30, 2018

    In my opinion pharmacists and pharmacy students are not sufficiently educated in the variation in kinetics and treatment that occurs in the veterinary population to provide advanced recommendations or feel comfortable adjusting prescriptions. Simply put it is not our area of expertise. I am happy to see CVO and OCP collaborating for the betterment of both our practices but I believe that for pharmacists to apply advanced scope of practice to this population additional training should be mandated. I am fortunate to have a close working relationship with a veterinarian and can discuss recommendations with her prior to contacting the prescribing veterinarian but this is not common for most practices. I strongly encourage OCP to look into, or work with OPA to look into providing CE on Veterinarian care prior to advocating with CVO to enhance our practice within the animal population.

  • Other - POSTED August 30, 2018

    I know pharmacists who work in vet pharmacy. They do not have knowledge on animal medicines. I feel like they are just practising like pharmacy technicians who will dispense what the vet prescribed, but they are not able to input their clinical judgement. My personal opinion is if we don’t educate pharmacist on vet medicine, only the vet should prescribe, adapt, administer and dispense, and a registered phm tech can help at the dispensing part.

  • Other - POSTED August 30, 2018

    I believe that pharmacists are trained in human medication and treatment but are not trained in the use of medications in animals. Pharmacists are not trained in animal physiology or pharmacokinetics. Pharmacists should not be prescribing medications for animals.

  • Other - POSTED August 30, 2018

    I never offer counselling, recommendations, or any advice to pet/animal owners because I have zero formal education on veterinary medicine. I appreciate the cost savings and specialty mixtures we are able to provide in dispensing animal Rxs but I would need education if I was expected to practice an expanded scope that included animals.

  • Other - POSTED August 28, 2018

    It is important that pharmacists are trained into aspects of veterinary medicine. They are still the first to be asked for proper recommendation of OTC products for animals. I am not sure if it is legal right now for pharmacists to make an OTC recommendation in Ontario without a veterinarian’s consent. I believe this needs to be addressed as well in the amendments and if proper training or continuing education is enough to provide them with this ability considering that the toxicity profile of some OTC products differ from humans to animals. It seems to me from the letter that Veterinarians are hesitant to pharmacist counseling and prefer to have questions referred back to them. There is an obvious lack of veterinary pharmacy education in pharmacy schools curricula that is basically reflecting on limiting the scope of pharmacist practice in this area. I believe the college need to step up to cover this gap through continuing education, certification, and working with pharmacy schools in the province. With proper education/certification I believe the current extended scope of pharmacy practice can reach to animals and it should with proper regulations in place.