Pennsylvania Vet Clinic Inspection Checklist

Controlled substances and PDMP

No separate Pennsylvania controlled-substance registration for ordinary licensed veterinary practitioners. Pennsylvania's Drug, Device and Cosmetic Act defines "practitioner" to include a veterinarian licensed, registered, or otherwise permitted to dispense, administer, distribute, or conduct research with controlled substances in professional practice. The Act's annual registration requirement is written for manufacturers, distributors, and retailers, and then states that nothing in that section requires registration of a practitioner registered or licensed by the appropriate State board. A Pennsylvania veterinary practice therefore keys its ordinary controlled-substance authority to the Pennsylvania veterinary license plus the federal DEA registration, not a second Pennsylvania CS practitioner registration. ^{1 2}

Veterinary prescribing/dispensing authority: a veterinarian may prescribe, administer, or dispense a controlled substance, other drug, or device only in good faith in the course of professional practice and not for use by a human being; the veterinarian may cause a controlled substance, other drug, or device to be administered by a professional assistant under direction and supervision. ³

Pennsylvania's PDMP is the PA PDMP under the ABC-MAP Act (Act 191 of 2014). The Department of Health's PDMP guidance says pharmacies and dispensing prescribers must submit all Schedule II-V controlled-substance dispensation information to the PDMP no later than the close of the subsequent business day after dispensing. It also says the ABC-MAP Act requires pharmacies and dispensing practitioners to report all Federal and Pennsylvania Schedule II-V controlled-substance dispensations. ⁴

Workplace safety and x-ray

Pennsylvania does not operate an OSHA-approved State Plan. Federal OSHA applies directly to private-sector veterinary employers in Pennsylvania, so the federal baseline in this plan is the operative workplace-safety standard; there is no Pennsylvania OSHA overlay for private employers. ⁵

Pennsylvania's Department of Environmental Protection Radiation Control Division registers facilities with x-ray units. DEP says users of radiation-producing machines are required to register with the division, indicate the number and type of units possessed, designate an individual responsible for radiation safety, and pay registration fees based on facility type and number of tubes. DEP identifies Title 25 Pa. Code Chapter 216 as the registration regulations. ⁶

Pennsylvania veterinary x-ray rules add operating controls: people not necessary for the procedure must be in a shielded area or at least 2 meters from the primary beam and tubehead; mechanical supports or restraints must be used when the technique permits; necessary people who are not behind barriers or at least 2 meters away need appropriate shielding such as lead aprons and gloves, at least 0.25 mm lead equivalent; and x-ray exposures must be authorized by a veterinarian. ⁷

Records and sharps

Veterinary medical records: at least 3 years from the last treatment date. Pennsylvania State Board of Veterinary Medicine rules require a separate veterinary medical record for each patient, herd, or group, as appropriate; the record must accurately, legibly, and completely reflect evaluation and treatment and identify the treating individual after each chart entry. Scope: the recordkeeping section does not apply to laboratory animal practice. For production animals, the rule substitutes Federal recordkeeping requirements (including 9 CFR) for the minimum-content list below; the section's separate-record and 3-year retention requirements state no production-animal exception. For animals other than production animals, minimum record content includes patient/client identifiers, vaccination and medical history, exam dates, diagnosis, laboratory and radiology findings, medical/surgical treatment, drugs administered/prescribed/dispensed including dosage, and anesthesia details for surgical/dental procedures. Client communication — the client's consent to or rejection of recommended diagnostic tests, treatments, and drugs — must be documented for any patient except a production animal. Records must be maintained for at least 3 years from the date the patient was last treated. ⁸

Controlled-substance records: every practitioner licensed to administer, dispense, or distribute controlled substances must keep a record showing the amount administered/dispensed/distributed, date, patient name/address, and for a veterinarian, the owner name/address; the record must be kept 2 years and open for inspection. Persons registered or licensed to manufacture, distribute, or dispense controlled substances under the Act must also keep records and inventories in conformity with federal recordkeeping, order-form, and inventory requirements plus any additional Department regulations. Where a veterinary patient chart contains controlled-substance information, keep it for the longer applicable period. ⁹

Pennsylvania regulates medical and chemotherapeutic waste through DEP. DEP states that regulated medical and chemotherapeutic waste may be picked up or commercially delivered in Pennsylvania only by an infectious and chemotherapeutic waste transporter licensed by DEP. ¹⁰

The public DEP page links Chapter 284 as the current regulated medical/chemotherapeutic waste regulations and provides generator inspection forms, transporter lists, and a regulated medical/chemotherapeutic waste shipping log. Chapter 284's storage-container rule requires regulated medical or chemotherapeutic waste to be placed in containers that are leakproof on the sides and bottom and maintained upright, impervious to moisture, and sufficient in strength to prevent puncturing, tearing, or bursting during storage; used sharps must additionally be placed in containers that are rigid, tightly lidded, and puncture resistant. For veterinary practices: segregate used sharps into containers meeting that specification, use a DEP-licensed infectious/chemotherapeutic waste transporter for pickup or commercial delivery, and keep the DEP shipping log/manifests. ^{10 11}