Food and Drug Administration policies

DEPARTMENT OF HEALTH & HUMAN SERVICES
June 10, 1986

The Food and Drug Administration (FDA) recently conducted undercover investigations within the State of California to determine if sales of prescription veterinary drugs were being made without the benefit of a prescription or a proper veterinarian-client relationship. These investigations were prompted by complaints of illegal sales and were directed at veterinary clinics and veterinary drug distributors in widely separated areas of the state. Investigators posing as prospective customers visited a total of 21 clinics and 20 distributors where they requested prescription drugs. In most cases the requests were made to apparent clerks. However, in some cases the sales were made by the veterinarian. The FDA investigators were successful in making purchases of the requested drugs at 14 clinics and at 2 distributors. In none of these cases did a legitimate veterinarian-client-patient relationship exist. The drugs purchased during these investigations included Oxytocin, Lutalyse, Ampicillin, and Quartermaster. Of particular concern, abortive drugs were purchased during these investigations by female investigators with no cautions given regarding pregnancy.
These investigations by FDA demonstrate very loose controls over the sales of prescription veterinary drugs, particularly on the part of a number of veterinary clinics in California. The use of such drugs by lay persons without proper supervision by a qualified veterinarian poses the risk of injury to treated animals as well as the potential exposure of humans to hazardous drug residues in meat and other food products. This will not preclude additional action against pet stores, feed stores, and retail outlets. The FDA also intends to focus on these illegal sales as well.
It is the policy of the California Board of Examiners in Veterinary medicine to work with FDA in eliminating the illegal sale and/or distribution of prescription veterinary drugs within this state. We wish to emphasize the need to bring this problem under control. Letters of warning have been sent to those veterinarians who sold prescription drugs to undercover investigators. Additional illegal sales by these or other veterinarians could result in regulatory actions initiated by FDA such as seizure, injunction or criminal prosecution. The Board of Examiners may also initiate regulatory actions such as license suspension/revocation, probation or monetary fines.
Lloyd R. Claiborne, Regional Food and Drug Director
Food and Drug Administration
50 United Nations Plaza
San Francisco, CA 94102
Gary K. Hill, Executive Officer
Board of Examiners in Veterinary Medicine
1420 Howe Avenue, Suite 6
Sacramento, CA 95825