Texas Vet Clinic Inspection Checklist

Controlled substances and PDMP

Texas requires no separate state controlled-substance registration. Texas eliminated its state controlled substances registration effective September 1, 2016: the state-registration subsections of Health and Safety Code §481.061 were repealed by S.B. 195 (2015), and the section — now titled "Federal Registration Required" — provides that a person "registered with or exempt from registration with the Federal Drug Enforcement Administration" may handle controlled substances in Texas to the extent the DEA registration authorizes. Your DEA registration is the only controlled-substance registration this practice needs. The Texas Board of Veterinary Medical Examiners (TBVME) rule on point simply requires compliance "with all requirements of the federal Drug Enforcement Administration (DEA) regarding controlled substance registration" and with related state and federal law. ^{1 2}

Storage standard. TBVME requires all Schedule I–V stock to be "stored in a securely locked, substantially constructed cabinet or security cabinet" and bars access to CS storage areas "except those authorized agents required for efficient operations". Apply this standard in the storage and security section. The rule text as archived also requires a written list of all persons with access to CS storage areas, with the dates individuals are added or removed — keep the access list current. ^{3 4}

Reporting when you dispense: Texas places Prescription Monitoring Program (PMP) reporting duties on pharmacies, not on veterinarians. The statute requires "each dispensing pharmacist" to send dispensing data to the Texas State Board of Pharmacy by the next business day; the board's rule implements this as a pharmacy duty, and the board states that "all Texas-licensed pharmacies are required to report all dispensed controlled substances records". A veterinarian dispensing from clinic stock in the course of practice is not a pharmacy and is not required to report those dispensations to the Texas PMP — but must keep the dispensing records required by this SOP and by TBVME rule (see the records-retention section). ^{5 6 7 8}

Workplace safety and x-ray

Texas does not operate an OSHA-approved state plan. Federal OSHA states: "Texas is not an OSHA-approved State Plan, and is under federal OSHA jurisdiction which covers most private sector workers within the state". The federal requirements in this plan are therefore the applicable occupational safety standards for a private Texas veterinary practice — there are no state-plan additions to layer on top. ⁹

Texas registers veterinary x-ray machines through the DSHS Radiation Control Program under 25 TAC §289.233: "apply for registration with the agency within 30 days after beginning use of the radiation machine"; mobile services need authorization before providing service. ^{10 11}

Apply with DSHS forms RC 226-2 (machine application), RC 226-1 (business information), RC 42-R (Radiation Safety Officer designation), and RC 204 (Radiation Machine Source Unit). ¹¹

Records and sharps

Controlled-substance records — 5 years. Texas veterinarians "shall maintain at their place of business records of all scheduled drugs listed in the Texas Controlled Substances Act in their possession. These records shall be maintained for a minimum of five years." The record must be per-drug, "complete, contemporaneous, and legible," and show date of acquisition, quantity purchased, date administered or dispensed, quantity administered or dispensed, client and patient name, and a running balance on hand. The CS log in this kit captures all six elements — keep completed logs, invoices, and inventories for five years, not the federal two. ⁸

Patient medical records and radiographs — 3 years after the last visit; TBVME's inspection standards (22 TAC §§573.52/573.53) require individual records to be "maintained at the veterinarian's place of business" and to be complete, contemporaneous, and legible. ^{12 13 4}

Veterinary clinics are squarely covered by Texas's medical-waste rules: the DSHS "special waste from health care-related facilities" rules apply to "clinics, including but not limited to medical, dental, veterinary", so sharps generated by the practice are regulated medical waste under 30 TAC Chapter 326 (TCEQ). The "animal waste" category is narrower — waste from animals intentionally exposed to pathogens — so ordinary animal waste is not medical waste, but your sharps always are. ^{14 15 16 17}

Generator class: 50 lb or less of medical waste per month makes you a Small Quantity Generator (SQG); more makes you a Large Quantity Generator (LQG). ¹⁸