2016 May - From the Hospital Inspector's car
It’s business as usual since my article in December last year, however I have not been satisfied for some time now about the accuracy of recording Schedule 8 drugs, know as drugs of addiction in the Poisons and Therapeutic Goods Act 1966 (NSW).
No I’m not referring to minor discrepancies.
We all understand that when using such small amounts of S8 that it can be a challenge to reconcile the balances. I am referring to significant amounts, and when I drill down for the reasons (for these discrepancies), in most cases, it boils down to slackness in record keeping.
If we as a profession want to keep the privilege of ordering and using S8 drugs, a greater effort must be cultured into certain practices for that to remain. I have reported slack record keeping to the Board far too often – this must change!
I’ve generally found that storage of S8’s is good – it’s purely a record keeping issue.
A few things to consider – although the legislation states that stock checks must occur every March and September, this is often too long a period to rely on for an accurate reconciliation.
The practices that I have found that have accurate balances are those who perform regular stock checks.
Obviously it depends on how much of the drug is used in the practice, but if the practice is using S8’s every day, an appropriate period for a stock check could be every time a new bottle is entered into the register. I know of larger practices that stock check every week.
Check the balance on hand and make a notation in the register of the date, any adjustment (wastage) and a veterinarian to sign it off.
The law requires that the loss or theft of any drug of addiction (or S4 appendix D drug) must be reported to NSW Health. This includes any ‘expected wastage’ as above. NSW Health appreciates that losses will occur due to the small amounts being used in veterinary practices but the legislation requires that you must still report these losses.
Reporting to NSW Health is simple and involves completion of an online form: www.health.nsw.gov.au/pharmaceutical/Documents/loststolen.pdf
Another idea is to give the responsibility for keeping the register up to date to one senior ranking person.
A veterinarian must ‘sign off’ the entry, not necessarily enter the details. The hospital superintendent is ultimately responsible for the whole process.
If the practice is using substantial amounts of S8 drugs, then consider having multiple registers for the main drugs used.
I have now incorporated an audit process of every single S8 drug during my inspections. That means I shall be taking the physical stock from the safe and checking it against what is noted as the balance from the S8 register at every inspection.
Practice superintendents should not wait for my inspection before checking these themselves!
Let’s avoid red faces and a report to the Board and let’s elevate this serious issue to where it belongs.
NB: I don’t like this part but need to say it – serious offenders will be reported to NSW Health with a recommendation for appropriate action.
Hospital Inspector / Investigator