As you will be aware, as veterinary surgeons and veterinary nurses you have legal and professional responsibilities in respect of how you conduct your activities, and this extends to your obligations in respect of veterinary medicines.
Veterinary surgeons may only supply a veterinary medicine from practice premises that are registered with the RCVS and these premises must be inspected. In addition, veterinary practices involved in prescribing, supplying, keeping records of, storing, disposing or destroying veterinary medicines that contain controlled drugs have a duty to comply with the law on the misuse of drugs and veterinary medicines.
It is recommended that, in general, medications are kept in and dispensed in the manufacturer’s original packaging. The RCVS Code of Professional Conduct states that medicinal products must be supplied in appropriate containers and with appropriate labelling. Such safeguards and best practice measures and standards exist for a very good reason (for example to protect against dispensing medicines that are out of date and to ensure medicines and wastes are discarded properly). However, despite adopting the best standard operating procedures and safe methods of work, sometimes there will be occasions when an error is made.
A dispensing error could manifest in a number of ways including: a staff member may have innocently misinformed the client regarding how to administer the medication and any warnings to accompany the medicinal product; dispensing the wrong medicine to the wrong patient; dispensing incorrectly labelled medicines (and thereby the incorrect drug strength, quantity, dosage); or stock levels incorrectly managed.
Dispensing errors can cause anything from life-threatening events to a significant financial penalty. The outcome of the error could lead to client distrust and compromised animal welfare and may result in your conduct being called into question by the RCVS.
What you should do if you make a dispensing error
We are all human; we are fallible and we make innocent mistakes. Medicines with similar sounding names, low staffing with high workload, interruptions and distractions of the workspace are all potential causes of dispensing errors.
Being aware of the potential causes of dispensing errors is important to prevent them from occurring.
All dispensing errors, including “near-misses”, should be logged and all suspected adverse events should be reported to the VMD or the company who market the medicinal product. Depending on the severity and type of error – and whether a complaint has been raised questioning your conduct or competence – it could trigger a disciplinary hearing before the RCVS. Sanctions could include being suspended and struck off the register if a veterinary surgeon or nurse is found guilty of serious professional misconduct arising from the dispensing error.
Aligned to a dispensing error is the possible suspicion of prescription misuse (which could include an alteration to an existing prescription or prescription fraud). Such suspicions can be reported to the VMD online.
Making such a report will, in most cases, require a veterinary surgeon to release confidential information about their client to the VMD. The RCVS considers that reporting cases of prescription misuse is in the public interest and in most cases a report to the VMD will be a justified breach of client confidentiality. In addition, it is considered that such a report would be within the scope of the GDPR as this allows personal data to be processed where it is necessary for the purposes of a legitimate interest, and, in most cases, it seems unlikely that this would be overridden by the interests or fundamental rights and freedoms of the relevant individual.
Thankfully, the adverse event rate is low (or at least those errors that are reported to and recorded by the VMD) and this is likely to be due to the very high standards maintained by dispensing practices generally.
It is vital to ensure that dispensing errors are correctly logged and reported. Trends can then be noted and discussed as part of the veterinary surgeons’ and veterinary nurses’ team meetings. You should ensure you collect all relevant information as to how the error came about so that measures can be implemented to ensure that a repeat of the error is minimised.