Pulse - August 2023 - 19

TOOLS FOR SUCCESS
onist-antagonist analgesic. Butorphanol is often used in place
of buprenorphine in Kitty Magic compounds for simpler, less
painful procedures. While at a lower risk for diversion than
ketamine and buprenorphine, butorphanol has misuse and
dependence potential, and as with other opioids, it can cause
a euphoric high in patients. Drug diversion is the illegal distribution
or abuse of prescription drugs or their use for purposes
not intended by the prescriber. Diversion threats are external
and internal, and the controlled substances used in Kitty Magic
are prime targets. For example, in January 2023, gunmen
ordered employees at a St. Louis veterinary clinic to open a
controlled substances locker. They specifically demanded ketamine.
One month later, a South Carolina veterinarian was
booked on charges of stealing controlled substances.
It's All in Your Wand
Like all magic, controlled substances and their properties can
be used for evil or good. A U.S. Drug Enforcement Administration
registration allowing you to work with controlled substances
is a privilege, not a right. As a veterinarian, you are responsible
for ensuring that controlled substances are used only
for the good of your patients and are protected from the evil
of misuse and diversion. Diversion can take place in any form,
so it is essential to be aware that Kitty Magic compounds are
at risk for diversion individually or in combination. Pay attention
to these controlled substances when reconciling logs and
investigating discrepancies. Along those lines, consider that
adequate security might mean going beyond the minimum
requirements. For example, federal law requires a running log
of all Schedule II drugs but does not require one for Schedule
III and IV medications. However, if you don't have a running
log, how will you know if a drug is missing? Federal law also
requires reporting all loss or theft of controlled substances.
Ergo, you must be able to identify such cases.
The Ministry of Magic
The magical government responsible for regulating and enforcing
laws in the Harry Potter series, compounded and controlled
substances have governing authorities. At the federal
level, a common misconception is that the Food and Drug
Administration or DEA regulates compounding. However,
the DEA doesn't run the compounding show. (It only regulates
and oversees the controlled substances in compounded
medications.) Furthermore, compounded drugs are not FDA
approved, so the agency does not evaluate their safety, effectiveness,
or quality. Also, the FDA doesn't inspect compounding
pharmacies unless for cause. While this article focuses on
Kitty Magic as a controlled substance, it is also a compounded
substance and therefore, a mention of compounding regulations
is necessary. Traditional compounding is regulated by
the states. Every state board of pharmacy has something to
say about it, incorporating United States Pharmacopeia standards
in some way. However, the most significant variations
result from whether a state veterinary board weighs in on
compounding by veterinarians and whether a pharmacy board
is authorized to oversee veterinarians that compound within
PULSE
AUGUST 2023
their practices. Veterinarians are empowered to prepare compounds,
but they must know their state's specific regulations.
Your Grimoire (Rules to Follow)
1 LABELING: Possessing a random drug vial simply labeled
" Kitty Magic " is illegal and unsafe. Considering that
the sedation cocktail can mean different things at different
practices, you cannot assume that everyone ordering or preparing
the medication knows what it contains precisely and
how to dose it. According to United States Pharmacopeia
compounding standards, your label must identify, at a minimum:
*
An internal lot number.
* All active ingredients and the amount or concentration
of each.
* A beyond-use date.
* The dosage form.
* The total volume in the vial at the start.
* The route of administration.
* The controlled substance schedule of the most restrictive
ingredient.
2 STORING: Once you label the vial appropriately, consider
its storage. If your concoction contains a controlled
substance in any amount, you must treat it like any controlled
substance. The storage requirements are those for
the highest scheduled drug in the compound. For example,
if your version contains butorphanol, ketamine and dexmedetomidine,
the first two ingredients are Schedule III
drugs, and dexmedetomidine is unscheduled. Therefore,
you must treat your Kitty Magic as any other Schedule III
drug. If the combination contains a Schedule II substance,
you must follow all Schedule II requirements.
3 LOGGING: Once you label and store the medication, you
must meet all the requirements for logging a controlled substance.
Here are two critical steps: ` Appropriately log the
controlled substances used to prepare the compound. For
example, if butorphanol and ketamine are involved, you
need to record each amount on the log sheets. ` Follow the
documentation requirements for preparing a compound, including
assigning an internal lot number and recording each
ingredient's lot number and national drug code. When you
do this, you can also log the vial number assigned to each
controlled substance in your compounding record. You can
then reference the internal lot number for your compound
on the log entry for the use of butorphanol and ketamine.
Are Your Eyes Spinning Yet?
Before employing the powers of Kitty Magic, remember to
take all necessary precautions to avoid stepping into the dark
side. Know the regulations and relevant laws. P
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Pulse - August 2023

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