Does the product I am about to sell require a physical exam or a Veterinary Client Patient Relationship?
Non-prescription drugs (aka. Over the Counter drugs) can be sold by health professionals without a prescription. Any drug sold in Canada must have a DIN. Non-Prescription Drugs will only have a DIN with no “Pr” label.
If a drug also has a “Pr” on the label, it is a Prescription Drug and must only be dispensed on the basis of a prescription (for a veterinarian, both the acts of prescribing and of dispensing require a VCPR).
Health products are in a category separate from “Drugs”. To be sold in Canada, a health product must be designated as Natural Health Products (NHP) with a Natural Product Number (NPN) on its label. There are health products specifically approved and labelled for use in animals, which are labelled “Veterinary Health Products (VHPs)”.
Veterinarians, as health professionals, can sell non-prescription drugs and health products for animal use “over the counter” with or without a Veterinarian-Client-Patient Relationship. The fundamental principles for over-the-counter sales are:
1. The non-prescription drug or health product is sold in its original packaging; AND
2. It is intended for on-label use, so that the purchaser will be able to find directions for use specific to their intended animal and purpose on the packaging of the product; AND
3. No veterinary advice is provided to guide the person in its purchase or use (advice related to the diagnosis and treatment of an animal for the prevention, alleviation or correction of disease, injury, pain, defect, disorder, or other similar condition is veterinary medicine and therefore requires a VCPR).
**any drug that is not specifically labelled “For Veterinary/Agricultural Use Only” is in fact labelled for human use and therefore any intended use in an animal is by default off label and cannot be sold by a veterinarian outside of a VCPR and without a prescription.
***Likewise, of the health products, only VHPs are specifically labelled for use in animals. Any use of an NHP in an animal would be “off-label” and should not be sold OTC by a veterinarian.
- these rules apply equally to any OTC sales in a veterinary clinic – food, grooming products, pesticides… — if a member of the public receives veterinary advice that guides them to purchase the product for a purpose included in the definition of veterinary medicine quoted in #3 above, or that instructs them to use it in a manner or for a purpose not already detailed on the product label, then that sale is an act of dispensing on the basis of a prescription, and requires a valid VCPR).
- Veterinary vaccines are classified as veterinary biologics. Except for the Rabies vaccine, which must be administered by a veterinarian or under direct personal supervision, veterinary biologics are able to be sold OTC under Health Canada regulations. However, given the given the nature of these products and possible consequences of improper storage and administration, and risk of anaphylaxis, they should only be dispensed by veterinarians within the parameters of a VCPR, ensuring they are sold in their original packaging and with clear instructions on administration and outcomes.
- the above applies equally to veterinarians and their non-veterinarian staff who work at the practice under the veterinarian’s delegation and supervision