gnr - savc discussion do…  · web viewthe south african veterinary council has under section...

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1 Legend: 1. This document contains all the comments received (written or otherwise) regarding the rules on facilities and medicines. 2. It is a work document, so it may contain language and spelling errors. Those will be attended to in the final editing of the rules. 3. The definitions refer to the rules only, and must be read in the context in which they are found in the rules . 4. Red lettering indicated suggested insertions. 5. Deletions indicate suggested deletions from the text. 6. Most comments are added in blocks beneath the relevant rules, with the name of the person making the submission, or show on the right-hand side of the document. 7. Please bear in mind that these are the minimum standards, not the gold standard. 8. Please indicate your comments by using the Comments function under Review and add your name beneath the comment. It will make it easier to keep track of the new comments. GOVERNMENT GAZETTE, 9 NOVEMBER 2015 No. 39380 R. 1082 2015 DEPARTMENT OF AGRICULTURE VETERINARY AND PARA-VETERINARY PROFESSIONS ACT, 1982, AS AMENDED ACT No. 19 OF 1982, AS AMENDED RULES RELATING TO THE PRACTISING OF VETERINARY PROFESSIONS as amended by Notice Government Gazette Date

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Page 1: GNR - SAVC discussion do…  · Web viewThe South African Veterinary Council has under section 30(1) of the Veterinary and Para-Veterinary Professions Act, 1982 (Act No.19 of 1982)

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Legend:

1. This document contains all the comments received (written or otherwise) regarding the rules on facilities and medicines.

2. It is a work document, so it may contain language and spelling errors. Those will be attended to in the final editing of the rules.

3. The definitions refer to the rules only, and must be read in the context in which they are found in the rules.

4. Red lettering indicated suggested insertions.5. Deletions indicate suggested deletions from the text.6. Most comments are added in blocks beneath the relevant rules, with the name of the

person making the submission, or show on the right-hand side of the document.7. Please bear in mind that these are the minimum standards, not the gold standard.8. Please indicate your comments by using the Comments function under Review and

add your name beneath the comment. It will make it easier to keep track of the new comments.

GOVERNMENT GAZETTE, 9 NOVEMBER 2015 No. 39380

R. 1082 2015

DEPARTMENT OF AGRICULTURE

VETERINARY AND PARA-VETERINARY PROFESSIONS ACT, 1982, AS AMENDED

ACT No. 19 OF 1982, AS AMENDED

RULES RELATING TO THE PRACTISING OF VETERINARY PROFESSIONS

as amended by

Notice Government Gazette DateR1066 13230 17 May 1991R1473 15981 23 September 1994R34 23027 18 January 2002R731 23453 31 May 2002R343 27464 15 April 2005R249 28631 24 March 2006R868 32298 12 June 2009R482 35414 8 June 2012

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R374 36337 12 April 2013R874 36779 30 August 2013

It is hereby made known for general information that:-(a) The South African Veterinary Council has under section 30(1) of the Veterinary and Para-

Veterinary Professions Act, 1982 (Act No.19 of 1982) withdrawn the rules relating to the practising of veterinary professions, as published in Government Gazette number 8402, GNR.189, on 1 October 1982, as amended from time to time;

(b) The Minister of Agriculture, Forestry and Fisheries, has under section 30(3) of the said Act approved the withdrawal of the said rules;

(c) The South African Veterinary Council has under section 30(1) of the Veterinary and Para-Veterinary Professions Act, 1982 (Act No.19 of 1982) to substitute the rules relating to the practising of veterinary professions referred to in (a) above, with the rules relating to the practising of veterinary professions as set out in the Schedule hereto;

(d) The Minister of Agriculture, Forestry and Fisheries, has under section 30(3) of the said Act approved the said substitution of the rules; and

(e) The said substitution shall come into operation on the date of publication.

L. HAVINGARegistrar: South African Veterinary Council

SCHEDULE

INDEX

1. Definitions .....................................................................................................................4

2. General Services............................................................................................................11

3. Exception in respect of Rule 2........................................................................................11

4. General Principles.........................................................................................................12

5. Issuing of certificates.....................................................................................................14

6. Records at veterinary facilities.......................................................................................17

7. Acceptance and payment of commission........................................................................19

8. Covering ........................................................................................................................19

9. Estimate of fees.............................................................................................................20

10. Use of veterinary medicine............................................................................................20

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11. Supersession.................................................................................................................26

12. Intrusion........................................................................................................................ 26

13. Advertising....................................................................................................................26

14. Identification of veterinary facilities where clinical services are rendered.......................27

15. Requirements for prescriptions or orders for medicines..................................................28

16. Printing on professional stationery................................................................................29

17. Animal Transport Vehicle...............................................................................................29

18. Compliance.....................................................................................................................30

19. General structural requirements for clinical veterinary facilities....................................30

20. General procedural requirements..................................................................................31

21. General requirements at clinical veterinary facilities......................................................32

22. Diagnostic Imaging..........................................................................................................34

23. General requirements for anaesthesia............................................................................35

24. Requirements for invasive surgical procedures................................................................37

25. Mobile animal services for private practitioners practising from a registered physical veterinary facility and Compulsory Veterinary Community Services facilities ..................38

26. Compulsory Veterinary Community Service Facilities and Regulatory Service Facilities ..40

27. Structural and procedural requirements for small animal hospitals/clinics......................44

28. Structural and procedural requirements for hospitals for equines..................................44

29. Structural and procedural requirements for hospitals for production animals.................46

30. Behavioural Consultancy................................................................................................47

31. Veterinary Laboratory....................................................................................................51

32. Research Animal facilities..............................................................................................53

33. Facilities for Herd health practice: Ruminant, Wildlife, Poultry, Pigs and Aquatic............60

34. Facilities for Industry and other consultancies................................................................63

35. Non practising facility....................................................................................................64

36. Veterinary shops: General structural requirements........................................................65

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37. Veterinary shops: General procedural requirements......................................................65

38. Sale of merchandise.......................................................................................................66

39. Lodging of complaints...................................................................................................66

40. Preliminary investigation..............................................................................................66

41. Inquiry into professional conduct...................................................................................67

42. Procedure at inquiry into professional conduct..............................................................68

43. Accessibility to Inquiry into professional conduct...........................................................70

44. General.........................................................................................................................70

45. Reporting of impairment or of unprofessional conduct..................................................70

46. Research, development and use of chemical or biological capabilities...........................71

47. Repeal and transitional arrangements.............................................................................71

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1.Definitions

Unless the context otherwise indicates, words and phrases in these Rules shall have the meaning assigned thereto in the Act, and-

“Act” means the Veterinary and Para-Veterinary Professions Act, 1982, Act No.19 of 1982 as amended, and the regulations made there under;

“animal” means any living organism, except humans, having sensation and the power of voluntary movement and requiring oxygen and organic nutrients for its existence;

“animal transport vehicle” means a vehicle equipped to safely transport animals;

“authorised person” means a person authorised in terms of the Act, Section 23(1)(c);

“autogenous vaccine” means a non-registered veterinary vaccine prepared from biological material or cultures derived from a lesion or disease of an animal or animals and intended for use in the flock or farm where the material was procured or where appropriate permission was obtained from DAFF??;

“autogenous vaccine” means a non-registered veterinary vaccine or medicine individually tailored for a patient or group of patients and prepared from biological material or cultures derived from a lesion or disease of an animal or animals and intended only for use in a herd or flock on a farm where the material was procured or where appropriate permission was obtained from DAFF??;

V-Tech

Single strain of a bacteria- need vaccines now, multiple farms.

AL: Vets must be given power to take decisions, even if rules in place. OB concurs. Internationals do not have a vcp relationship and easier to contain. Should trust vets professional opinion.

Definition epidemiological unit-Rather use this definition: means a group of animals with a defined epidemiological relationship that share approximately the same likelihood of exposure to a pathogen. This may be because they share a common environment (e.g. animals in a pen), or because of common management practices. Usually, this is a herd or a flock. However, an epidemiological unit may also refer to groups such as animals belonging to residents of a village, or animals sharing a communal animal handling facility. The epidemiological relationship may differ from disease to disease, or even strain to strain of the pathogen.

Legaldirector, 2016-11-09,
Adjacent herds to be included, (International practice)
V-TECH, 2017-01-26,
Department of Agriculture, Forestry and Fisheries.
Legaldirector, 2016-11-09,
Per agreement with DAFF?
Legaldirector, 2016-11-09,
Adjacent herds to be included, (International practice)
V-TECH, 2017-01-26,
only for use in a herd or flock on a farm
V-TECH, 2017-01-26,
individually tailored for a patient or group of patients
Legaldirector, 2016-11-09,
Per agreement with DAFF?
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“client” means a person who uses the professional services of a veterinarian or para-veterinary professional;

“client consent” means consent given by the owner or authorised representative of the patient subsequent to the veterinary professional informing the owner in a manner understood by a reasonable person of some or all of the following:

(i) the presumptive diagnosis; and

(ii) the available treatment options and expected prognosis;

(iii) an estimate of the expected fees for the rendering of the service chosen by the client, unless the client declines;

“complaint” means a complaint, charge or allegation of unprofessional, improper or disgraceful conduct against a respondent;

“complementary, alternative and integrative medicine” means a heterogeneous group of non-mainstream preventive, diagnostic, and therapeutic philosophies and practices. Complementary medicine is used together with conventional medicine, whilst alternative medicine is used in place of conventional medicine. Integrative medicine involves bringing conventional and complementary approaches together in a coordinated way;

“complementary, alternative and integrative medicine” means a heterogeneous group of non-mainstream alternative preventive, diagnostic, and therapeutic philosophies and practices. Complementary medicines may be is used together with conventional medicine, whilst alternative medicines are is used in place of conventional medicine. Integrative medicine involves bringing conventional and complementary approaches together in a coordinated way;

Medicines Group

“complementary, alternative and integrative medicine” means a heterogeneous group of non-mainstream preventive, diagnostic, and therapeutic philosophies and practices. Complementary medicine is used together with conventional medicine, whilst alternative medicine is used in place of conventional medicine. Integrative medicine involves bringing conventional and complementary approaches together in a coordinated way;

VN: Follow definition in Act 101.

If homeopathy not regulated, everyone can treat animals.

V-TECH, 2017-01-26,
Traditional complementary medicines such as homeopathy are not based in science. Is such practice permitted by the Veterinary Act/Council which rests in science? See SAVC website. If so, the definition should follow the Medicines Act definition. See Section 38 of the Medicines Act: 38. Operation of Act in relation to other laws. - The provisions of this Act shall be in addition to and not in substitution for any other law which is not in conflict with or inconsistent with this Act.
Legaldirector, 2016-11-09,
Look at Act 101 definition-now registered Regulations still outstanding_Dr LotterAct 36 v Act 101Look at definition health supplements-To be published by end Nov.
Legaldirector, 2016-11-09,
Requirement consumer protection act
Legaldirector, 11/09/16,
Can be representative or trainer?
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“compounding” means to prepare, mix, combine, package, and/or label a non-registered medicine(s), or to mix or combine a registered medicine with a non-registered medicine for dispensing as a result of a prescription for an individual patient, as defined by Rule 1, by a pharmacist or a veterinarian authorised in terms of the Medicines Act. Compounded medicines are not intended as a replacement for a registered medicine or stock remedy, or for the treatment of a patient for more than 30 consecutive days from the date of compounding. The latter however does not preclude a veterinarian from continuing treatment for a period longer than 30 days, provided that a new batch of medicine is compounded for the patient in question every 30 days, except if the stability of said compounded product has been proven by accepted stability trials;

Suggestion: Follow Act 101 definition- precludes vets right ito vet Act, abdicating to Act 101????

“compounding” means to prepare, mix, combine, package, and/or label a non-registered medicine(s), or an analogue of a registered medicine in a different concentration, size or volume as the registered product to mix or combine a registered medicine with a non-registered medicine for dispensing as a result of a prescription for an individual patient or group of patients, as defined by Rule 1, by a pharmacist on veterinary prescription or directly by a veterinarian authorised in terms of the Medicines Act. Compounded medicines are not intended as a replacement for a registered medicine or stock remedy, and may not be used or for the treatment of a patient for more than 30 consecutive days from the date of compounding for stability reasons. The latter however thus does not preclude a veterinarian from continuing treatment for a period longer than 30 days, provided that a new batch of medicine is compounded for the patient in question every 30 days. , except if the stability of said compounded product has been proven by accepted stability trials; Excluding veterinary (autogeneous) vaccines???? Act 101 patient specific- Rule as it gives vets more rights. Or production of an autogenous vaccine in a registered facility??

Large scale production-quality of production regulated, as opposed to quality of chemicals

Facility to be GMP positive (Dr Lotter)-parallel process

John-Council decision no compounding for food producing animals

Withdrawal periods-must be withdrawal trials to justify per species

Vinny-Withdrawal guidelines

Medicines Group

“compounding” means to prepare, mix, combine, package, and/or label a non-registered medicine(s), or to mix or combine a registered medicine with a non-registered medicine for dispensing as a result of a prescription for an individual patient, as defined by Rule 1, by a pharmacist or a veterinarian authorised in terms

V-TECH, 2017-02-01,
The Draft Regulations under the Medicines Act proposes a definition for compounding:"compound" means to prepare, mix, combine, package and label a medicine(a) by a pharmacist for an individual patient;(b) for dispensing as a result of a prescription for an individual patient by a person licensed in terms of section 22C (1)(a) of the Act; or(c) for dispensing as a result of a prescription for an individual animal by a veterinarian licensed in terms of section 22C (1)(a) of the Act.This is at odds with the SAVC proposed definition and the time period specified in the current regulations which limits the 30-day supply to sale by a pharmacist in the retail trade i.e. sale of compounded medicines by a pharmacist to his or her clients in his or her community pharmacy. The rule must be brought in line with the Medicines Act and not stand in conflict to it. Only Section 14(a) is applicable to a veterinarian and not 14(b) which covers a pharmacist:Medicines Act Section (4) The provisions of subsection (1) (Sale of medicines called up for registration and not registered) shall not apply in respect of the sale of any medicine- (a) compounded in the course of carrying on his or her professional activities by a pharmacist, veterinarian or person who is the holder of a licence contemplated in section 22C(1)(a), for a particular patient in a quantity not greater than the quantity required for treatment as determined by the medical practitioner, pharmacist, practitioner or veterinarian; or (b) compounded by a pharmacist in a quantity not greater than that prescribed by regulation for sale in the retail trade, subject to the conditions likewise prescribed or in a quantity for a particular person or animal as prescribed by a medical practitioner or a dentist or a veterinarian or a practitioner or a nurse or other person registered under the Health Professions Act, 1974, and referred to in section 22A, as the case may be, There is no restriction placed on the veterinarian about the time the prescribed medicine may be used under his/her care.
Legaldirector, 2016-11-09,
Who controls, where registeredStandards applicable?Animal Diseases Act, labs regulated by DAFF
Legaldirector, 2016-11-09,
Consider option
Legaldirector, 2016-11-09,
Stay in, unanimous
Legaldirector, 2016-11-09,
From date of manufacture (Dr Lotter)-Efficacy & sterility, stability (batch specific), welfare of patient
Legaldirector, 2016-11-09,
Suggestion to remove-
Legaldirector, 2016-11-09,
Exclude mixing
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of the Medicines Act. Compounded medicines are not intended as a replacement for a registered medicine or stock remedy, or for the treatment of a patient for more than 30 consecutive days from the date of compounding. The latter however does not preclude a veterinarian from continuing treatment for a period longer than 30 days, provided that a new batch of medicine is compounded for the patient in question every 30 days, except if the stability of said compounded product has been proven by accepted stability trials;

“consultancy” means an interaction between a veterinarian and an owner, farmer, client or group of clients where animals may be examined away from a registered physical facility; treatment protocols drawn up, medicines prescribed and/or provided and professional advice given regarding an ongoing health, production concern/entity or animal behaviour;

“consultation” means an interaction between a veterinarian and an owner in accordance with the ‘veterinarian-client-patient relationship’ concerning an animal patient, where the patient is examined or assessed for a fee;

“consulting room” means a veterinary facility that complies with all the general requirements set out in Rules 18, 19, 20, 21 & 22;

“Council” means the South African Veterinary Council;

“extra-label use” means the use of a medicine registered under either the Medicines Act or the Stock Remedy Act in an animal in a manner that is not in accordance with the approved labelling or package insert. This includes, but is not limited to, re-formulation for ease of administration, use in species not listed in the labelling, use for indications (disease and other conditions) not listed in the labelling, use at dosage levels, frequencies, or routes of administration other than those stated in the labelling;

“extra-label use” means the use of a medicine registered under either the Medicines Act or the Stock Remedy Act in an animal in a manner that is not in accordance with the approved labelling or package insert. This includes, but is not limited to, re-formulation for ease of administration, use in species not listed in the labelling, use for indications (disease and other conditions) not listed in the labelling, use at dosage levels, frequencies, or routes of administration other than those stated in the labelling;”

Medicines Group

“extra-label use” means the use of a medicine registered under either the Medicines Act or the Stock Remedy Act in an animal in a manner that is not in accordance with the approved labelling or package insert. This includes, but is not limited to, re-formulation for ease of administration, use in species not listed in the labelling, use for indications

Legaldirector, 2016-11-09,
Or mixing of registered meds-Get wording from Vinny
Legaldirector, 2016-11-09,
Internationally known as concurrent use-must be approved -two registered products
Legaldirector, 2016-11-09,
Or mixing of registered meds-Get wording from Vinny
Legaldirector, 2016-11-09,
Internationally known as concurrent use-must be approved -two registered products
V-TECH, 2017-01-26,
In the Medicines Act as it stands, this (licensing) was not a requirement but introduced under the MEDICINES AND RELATED SUBSTANCES AMENDMENT ACTNO. 14 OF 2015 [ASSENTED TO: 24 DECEMBER, 2015] [DATE OF COMMENCEMENT: TO BE PROCLAIMED]. The licensing requirement is also omitted in Section 22A of the Medicines Act. The compounding definition is misplaced as it restricts the right of the veterinarian and indirectly pharmacists (over which the SAVC has no jurisdiction) to compound a medicine per his or her professional discretion. Arguably, a compounded intermediary medicine is not a Category C medicine but a category B medicine under Regulation 25 - Category B = Medicines which cannot normally be administered without further manipulation as it may be used as a dispensary stock item that requires further manipulation (compounding) for preparing a medicine for an animal patient or group of patients under the care of the veterinarian. The products are treated as intermediaries and essential for a well-equipped dispensary that offers a comprehensive professional service to animal patients. Furthermore, a veterinarian cannot function without the use of compounded medicines for in-practice use in the field. The off-label use of human medicines provides no comfort as in many cases the required concentration for effective and convenient therapy is lacking. Alternatively, compounded medicines are an exception to the Medicines Act – Section 14(4) and permissible.Category C (veterinary medicine) means a Medicines intended for veterinary use which are, without further manipulation, ready for administration, including packaged preparations where only a vehicle is added to the effective medicine. These are commercially available veterinary medicines.Compounded veterinary medicines are prepared by a veterinarian or pharmacist for a patient or group of patients in a veterinary practice setting and considered an exception to the Medicines Act (S 14(4)) and do not require registration. The discretionary right of a vet to decide what medicine is in the best interest of his/her patients should not be tampered with or influenced while misconduct is a separate matter. Furthermore, like pharmacist under the Pharmacy Act, vets have a statutory right to compound medicines This compounding right is not a privilege and supported by the professional statutes. Compounding is a long-standing practice in the vet and pharmacy profession. Due to species variation and the limited number of available registered veterinary medicines, compounding forms an integral part of the profession of a veterinarian. With respect, the SAVC should proceed with circumspection and re-consider the implication of this definition considering the current need for these compounded medicines and the diverse veterinary practices in South Africa. One size fits all is inappropriate. Perhaps an administrative guideline is called for to delineate the various veterinary practices t clarify the mischief guarded against and so clarify the position to the satisfaction of all stakeholdersOne of the main purposes of the Medicines Act is to control the manufacture (licensing) of medicines made commercially available where a direct relationship between the patient and the medicine does not exist. Manufacturers (precluded by the Pharmacy Act), unlike a pharmacist or vet may not accept responsibility for a patient in a contractual professional relationship. Professional Councils (Pharmacy and Veterinary Councils) control the conduct of the professionals under their jurisdiction and not the commercial sale of medicines which rests with the MCC. With deference, compounding is an exception to the Medicines Act.
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(disease and other conditions) not listed in the labelling, use at dosage levels, frequencies, or routes of administration other than those stated in the labelling;”

Medicines Group

“food-producing animal” is an animal that is fed, bred, kept or utilised for the production of food for human consumption, including an animal that is not used for human consumption, but which animal belongs to a species that is normally used for human consumption in the community; and has been verified by the attending veterinarian as such.

“food-producing animal” is an animal that is fed, bred, kept or utilised for the production of food for human consumption, including an animal that is not used for human consumption, but which animal belongs to a species that is normally used for human consumption in the community;

Medicines Group

“food-producing animal” is an animal that is fed, bred, kept or utilised for the production of food for human consumption, including an animal that is not used for human consumption, but which animal belongs to a species that is normally used for human consumption in the community;

Medicines Group

“house or farm call” means when a veterinary professional leaves his/her physically registered base practice to render a professional service to his/her clients in a vehicle suitably equipped for that type of practice; Travels to a locality convenient to the client

“house or farm call” means when a veterinary professional leaves his/her physically registered base practice to render a professional service to his/her client in a vehicle suitable for that type of practise;

Medicines Group

“house or farm call” means when a veterinary professional leaves his/her physically registered base practice to render a professional service to his/her clients in a

Legaldirector, 2017-02-02,
Superfluous??????Remove???
Legaldirector, 2016-11-09,
Remove
V-TECH, 2017-01-26,
This definition needs clarification. Does this mean any animal consumed by humans, be they domesticated or wild?
Legaldirector, 2016-11-09,
Remove
Legaldirector, 2017-02-02,
Consumer safety paramount
V-TECH, 2017-01-26,
What is the purpose of this definition?Medicines Act 19. Prohibition on sale of medicines which do not comply with prescribed requirements and furnishing of information regarding medicines to the council. - (1) No person shall sell any medicine unless it complies with the prescribed requirements.There are difficulties with this definition. The SAVC may be supporting the sale of a registered medicines for “off-label” use which is not permissible without the authority of the MCC. The registration licence is restricted to human medicines. If indicated for animals, it should be so registered. AMDUCA (separate statute) in the USA specifically permits such a statement but an exception does not so exist in South Africa. Medicines are licensed based on species, substances and claims. Sellers of medicines may not “expand” the indications or species without MCC’s permission. On the other hand, vets are not restricted by the package insert specifications, only the licence holder is. Medicines have effects, few are licensed as a “claim”. Some of these “effects” may be required by a veterinarian in his or her discretion within a professional practice and be species specific. Forcing a positive performance to only use a registered human medicine is ill advised in a practice setting as the facts are not known and the medicines not evaluated by the MCC for that purpose.
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vehicle suitably equipped for that type of practice;

“impairment” means such a level of physical or mental impairment, which includes substance abuse or addiction, that may affect the practice of veterinary science to such an extent that the welfare of the patients, the interest of a client and/or the image of the profession may be compromised;

“inquiry body” means an ad hoc committee of the Council acting under powers delegated to it by the Council in terms of section 12 of the Act to preside at inquiries;

“invasive surgery” means surgery that is performed intra-abdominally, intra-cranially, intra-thoracically, musculo-skeletally or of the cardio-vascular system;

“invasive surgery” means surgery that is performed intra-abdominally, intra-cranially, intra-thoracically, musculo-skeletally or of the cardio-vascular system;

Medicines Group Orthopedic & spinal must have separate theatres- Louis Coetzee (gold standard, not achievable by rural facilities

Enter body cavity, must be in theatre-AF

Add intra-ophthalmic surgery??

“invasive surgery” means surgery that is performed intra-abdominally, intra-cranially, intra-thoracically, musculo-skeletally or of the cardio-vascular system;

Minor surgery-

Routine surgery-spays, castrations, laparotomies, trauma (emergencies)

Should be able to justify why you went in, discretion of the vet & professional knowledge application.

“investigation committee” means a committee appointed by Council in terms of Section 12 of the Veterinary Act to evaluate and screen complaints against professionals;

“Medicines Act” means the Medicines and Related Substances Act, 1965, Act No.101 of 1965;

V-TECH, 26/01/17,
Does this not apply to most surgical procedures?
Legaldirector, 02/02/17,
Should dehorning or detusking of elephants be included?
Legaldirector, 09/11/16,
Take out?
Legaldirector, 02/02/17,
Should not be taken out for horses
V-TECH, 2017-01-26,
When considering the armamentarium of medicines needed by vets for field trips, it is obvious that they need a range of medicines suited to their practice which in the case of wildlife vets will include high concentrations of drugs used to immobilise animals where commercial products are not available.
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“medicine” means a medicine or veterinary medicine as defined in section 1 of the Medicines Act.;

“medicine” means a medicine or veterinary medicine as defined in section 1 of the Medicines Act.;

Add to 21(4) that stock remedies may be kept with meds in the dispensary

“mobile animal service” means a veterinary practice facility, which is registered with the Council in the name of the principal of the base veterinary facility from which it operates;

“mobile theatre” means a vehicle or trailer, which could consist of either a self-propelled facility or be mounted on a base which is transported to a site, and which is appropriately equipped to perform sterilisations and other surgical procedures in a controlled environment to indigent or isolated communities;

“non-practising facility” means a facility where no veterinary services will be rendered or medicines sold for direct or indirect gain. The veterinarian does not practice, but requires access to medicines regulated under the Medicines Act for use solely on his/her own animals;

“off-site storage of records” means the keeping of copies of all records saved in electronic format on disc or similar storage device, in another location, as well as keeping such records in cloud storage devices (where data is maintained, managed and backed up remotely and made available to users over the Internet);

“OIE guidelines” mean directives or guidelines by the World Organisation for Animal Health regarding the control of animal diseases;

“over-servicing” means the supply, provision, administration, use or prescription of any treatment or care (including diagnostic and other testing, medicines and devices) which is medically or clinically not indicated, unnecessary or inappropriate under the circumstances or which is not in accordance with current acceptable treatment protocols and procedures by the reasonable veterinarian, with due regard to the health and welfare interest of the patient;

“owner” means any person over the legal age having the possession, charge, custody or control of an animal for which veterinary services are rendered, or the owner’s representative;

“owner” means any person over the legal age having the possession, charge, custody or control of an animal for which veterinary services are rendered, or the owner’s representative;

V-TECH, 2017-01-26,
Needs clarification.
Legaldirector, 2017-01-23,
Medicines GroupSuperfluous
Admin, 2017-01-29,
There seems to be a misconception about the “mobile” definition. This would be a vehicle from which procedures, operations and examinations are performed.Definitions:“mobile animal service” means a veterinary practice facility, which is registered with the Council in the name of the principal of the base veterinary facility from which it operates; [The mobile service would be registered in the name of the same principal as the physical facility from which the mobile facility operates].“mobile theatre” means a vehicle or trailer, which could consist of either a self-propelled facility or be mounted on a base which is transported to a site, and which is appropriately equipped to perform sterilisations and other surgical procedures in a controlled environment to indigent or isolated communities.
V-TECH, 2017-02-01,
Are stock remedies to be treated as “medicines” as well?
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“patient” means an individual animal or group of animals as a unit examined and/or treated, operated or consulted on by a veterinary professional in accordance with a ‘veterinarian-client-patient’ relationship; Can include wildlife, must be consultation

“patient” means an individual animal or group of animals as a unit examined and/or treated, operated or consulted on by a veterinary professional in accordance with a ‘veterinarian-client-patient’ contractual relationship;

“principal” means the veterinary professional in whose name the veterinary facility is registered and who takes responsibility for minimum standards of the facility, or his/her appointed agent who must be a registered veterinary professional;

“principal” means the veterinary professional in whose name the veterinary facility is registered and who takes responsibility for minimum standards of the facility, or his/her appointed agent who must be a registered veterinary professional;

“production animal” means an animal whose products are used by humans and/or which may enter the food chain for consumption;

“production animal herd health facility” means a base facility where no clinical work is done and where the primary service is rendered essentially from an equipped vehicle to ruminant livestock, wildlife, poultry, pig or aquatic production units;

“products” means animal related products, including all edible tissue;

“registered facility” means a veterinary facility which complies with the minimum standards as applicable to the category of service rendered there, and is registered with Council;

“registered person” means a person registered in terms of the Act;

“regulations” means the regulations promulgated in terms of the Act;

Legaldirector, 2017-02-02,
Change to “will” and add verified by the attending veterinarian
V-TECH, 2017-01-26,
Perhaps “Responsible veterinarian” as it is more descriptive?
V-TECH, 2017-01-26,
Try … within…. contractual
Legaldirector, 2017-01-23,
Animals intended to be caughtClient to keep records of meds used-provide to vet, don’t give meds if they don’tMedicines Group
Legaldirector, 2017-02-02,
Replace with epimidiological unitGet definition Dr Fleming
Legaldirector, 2017-01-23,
Animals intended to be caughtClient to keep records of meds used-provide to vet, don’t give meds if they don’tMedicines Group
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“research animal facility” means any facility or area where animals may be used, maintained or bred for scientific purposes, including for research, testing, teaching, validation, production or observation;

“respondent” means a person registered or authorised in terms of the Act against whom a complaint, charge or allegation of unprofessional, improper or disgraceful conduct has been lodged;

“Rules” means the Rules promulgated in terms of Section 30 of the Act;

“sale” means selling by wholesale or retail means, and includes import, offer, advertise, keep, expose, transmit, consign, keep for sale or authorise, direct or allow a sale or possess for purposes of sale, and barter for exchange or supply or dispose of to any person whether for a consideration or otherwise; and sell and sold have corresponding meanings;

“scope of practise” means the scope of work which a veterinary professional or para-veterinary professional may perform by law or chooses to restrict himself/herself to, and defines the minimum standards of the facility that will be registered for that purpose;

“Stock Remedy Act” means the Fertilizers, Farm Feeds, Agricultural Remedies and Stock Remedies Act 1947, Act No. 36 of 1947, or any relevant Act it may be substituted with;

“stock remedy” means a substance registered as such and intended or offered to be used in domestic animals, livestock, poultry, fish or wild animals (including wild birds), for the diagnosis, prevention, treatment or cure of any disease, infection or other pathological condition, or for the maintenance or improvement of health, growth, production or working capacity, but excluding any substance in so far as it is controlled under the Medicines Act;

“unprofessional conduct” means unprofessional, dishonourable or unworthy conduct on the part of a veterinary professional including, inter alia, the following acts and omissions:

“unprofessional conduct” means unprofessional, dishonourable or unworthy conduct on the part of a veterinary professional including, inter alia, the following acts and omissions:

(i) failure to comply with the Act, the regulations and/or Rules promulgated under the said Act, and/or the Code of Conduct and/or guidelines issued by Council from time to time;

(ii) a contravention of the provisions of the Medicines Act and/or the regulations promulgated under it;

Legaldirector, 2017-02-02,
Remove 1 to 4OJ: Opinion- Council should not enforce 101. Must be found guilty in court
V-TECH, 2017-02-01,
As a matter of style perhaps this definition should find a place elsewhere.Any act of breaking the laws of the country must be viewed as unprofessional conduct. Over and above that the Council can issue guidelines of other behaviour of vets that will be viewed as unprofessional. Alternatively list unprofessional conduct in another section in the rules
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(iii) a contravention of the provisions of the Stock Remedies Act and/or the regulations promulgated under it;

(iv) failure to comply with any other relevant legislation;

(v) issuing any certificate which is not in compliance with the relevant Rules;

(vi) without reasonable cause or excuse, failing to perform professional work, or work of a kind commonly performed by a registered veterinary professional, with such a degree of skill, care or attention, or of such a quality or standard, as in the opinion of the Council may be expected of the reasonable veterinarian or specialist, as the case may be;

(vii) neglecting to give proper attention to his/her clients and/or patients or in any way failing to attend to patient welfare while under the veterinarian’s care without valid reason;

(viii) Unjustifiably performing professional services outside the scope of his/her education, training and/or experience, regard being had to both the extent and limits of his/her professional expertise;

(i) unjustifiably performing professional services beyond the scope of his/her education, training and/or experience, regard being had to both the extent and limits of his/her professional expertise;

Get consent.

performing professional services outside the scope of his/her education, training and/or experience, regard being had to both the extent and limits of his/her professional expertise;

Holly scary rule!!! No vet must ever try something for the first time? If you do an orthopaedic op for first time, are you then unprofessional?

A Lewis

I would disagree with the interpretation of the rule as being innovative. Being innovative involves being prepared and ensuring that there is good chance of success. Legal matters such as ethics approval for experimental procedures

Legaldirector, 2016-11-04,
Delete per JvHDelete (viii).THis is covered by(vi)The reasonable veterinarian will inform the client e.g. that HE HAS NEVER DONE THE PROCEDURE,WILL CONSULT OTHER PROFESSIONALS, WILL ATTEND COURSES, WILL READ UP ETC.
Legaldirector, 2016-11-09,
Notify client & note in clinical notesInformed consent
Legaldirector, 2016-11-09,
Keep this clause.
V-TECH, 2017-01-26,
Circumstances dictate the conduct, hence justification. As an example, an emergency may order otherwise. The test is an objective one. Don’t overwrite.
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and owner consent should also be considered.

V Naidoo

(ii)[(ix)] failure to provide follow-up care and/or advice as required in terms of the veterinarian-client-patient relationship;

(iii)[(x)] the dispensing, distribution, manufacturing, prescription or administration of any prescription medicine, or compounded vaccine or medicine, or any one or more medicines in combination, or the extra-label use of a medicine, in the absence of a ‘veterinarian-client-patient ‘relationship;

Make an exception for wildlife vets (patients not seen yet)???? Client must keep records for submission to vets-make sure used for intended purpose.

How does this work with game capture? I mean if you give drugs to a game capture person you know and trust, but you don’t know the kudu he is working on, you only know he is hoping to work on kudu do you have a relationship?A LewisThe veterinary client relationship needs to be considered in terms of act 101. With the owner entrusting the animal to the driver as the guardian as an example, a vet can most certainly prescribe a drug for the driver to administer to the animal. Concern would only come into play if this is for animals not under the vets care as say for some other future use.

However in the case of a game capturer for which the vet has no relationship with the owner of the animal, then it is illegal in terms of Act 101 to hand over the drug. The vet needs to ensure that the S5/6 drugs are properly used and handled. The vet is not meant to be the wholesaler to game capturers.

V Naidoo

(iv)[(xi)] failing to adequately supervise his/her staff;

failing to adequately supervise train, instructor supervise within practical limitations his/her staff,

Medicines Group

So if your staff picks up a buffalo and drops it and it breaks its teeth, you were in the helicopter and did not adequately supervise?

Legaldirector, 2017-02-05,
V-TechNegligence or duty of care is what this is about. The test is an objective one. Each case must be evaluated on its own merits when taking into consideration the surrounding circumstances. It should be left open ended. It is call the adjudicating committee takes once they have heard all the facts.Negligence (duty of acre) means failure to act with the prudence that a reasonable person would exercise under the same circumstances.
Legaldirector, 2017-02-05,
V-TechA private law contractual relationship exists between the vet and the person to whom he/she is providing the service which includes the drugs. The relationship is ongoing until the vet is satisfied the therapeutic objective has been achieved. The drugs in question must be used under the supervision of the prescribing vet but this does not mean that the vet must administer the drug himself or be present during the administration process. This is impractical as many drugs are administered for example to children or the elderly by their guardians especially when treating chronic conditions and so for animals. The vet, however, must be accessible to the person administering the drug in the event of an adverse reaction. The owner of the animal has a right to terminate the contract with the vet.In the absence of a professional relationship, the vet is trading in drugs. This seems to be the mischief that needs curtailing. If so, it should be written directly?
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A Lewis

(v)[(xii)] failure to provide an itemised account when requested to, within the period set out in Rule 9(3);

(vi)[(xiii)] treating a client in a disrespectful and/or discourteous manner, unless justifiable reasons exist;

(vii)[(xiv)] over-servicing a patient;

(viii)[(xv)] incompetence, gross negligence or any form of negligence in the practising of the veterinary profession;

Most vets working with wildlife for the first couple years would all be guilty of this!!! So start booking the hearing so long.A Lewis

(ix)[(xvi)] the inability to practise with reasonable skill and safety due to a physical and/or mental disability, including deterioration of mental capacity, loss of motor skills, or substance abuse to a sufficient degree to diminish the person’s ability to render competent patient care and welfare;

(x)[(xvii)] fraud or dishonesty in making any kind of application to Council or the reporting of any test for disease in an animal or in charging for a test that was not performed or services not rendered;

(xi)[(xviii)] in any way directly or indirectly assisting, allowing or enabling an unqualified person and/or unregistered person to perform professional work for gain which by law only a veterinarian and/or a para-veterinary professional is allowed to perform, unless such a person or persons are part of the support team of a veterinarian and performing specific tasks under guidance and/or direct supervision by the veterinarian;

Book my hearings so long as my truck drivers all give drugs to animals on route, my capture team gives drugs iv to animals daily! Then what about when I do a rumenotomy on buffalo, and my lay staff helps?A Lewis

xv) referring work, the performance of which is reserved by law to a veterinarian, specialist veterinarian or para-veterinary professional to a person not registered with Council unless practical circumstances where the involvement of lay persons may be beneficial to the survival/management of patients prevail to a person not registered with Council;

J V H, 2016-09-24,
Insert
Legaldirector, 2017-01-23,
Check numbering
User, 2016-09-05,
Please refer to the comment above
Legaldirector, 2016-11-04,
JvHAddPractical situations e.g Caesarian on a farm where the farmer is instructed to give an injection intravenously while the vet is doing surgery, waking up 10 buffalo at the same time, giving essential azaperone en route to a rhinoceros
Legaldirector, 2017-02-05,
For gain is the crux. A vet may not pass off another person not qualified as a vet to perform professional vet services. The latter group are service providers to the vet and their conduct is permissible under vet supervision.For gain is the crux. A vet may not pass off another person not qualified as a vet to perform professional vet services. The latter group are service providers to the vet and their conduct is permissible under vet supervision.V-Tech
Legaldirector, 2017-02-05,
Perhaps repetitive and can find a place elsewhere.V-Tech
Legaldirector, 2017-02-05,
V-TechThe negligence test is not based on the super specialist skill but on average so there is scope for the learning process. However, cavalier conduct is not acceptable.
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Book more hearings for all the old hand wildlife vets, we all have referreddarting/capture treatment of animals by experienced game capturers that are more experienced than the "legal" vets.A Lewis

(xii)[(xix)] non-payment after demand of any fee, levy or other charge payable to the Council;

(xiii)[(xx)] failure to comply with an order, requirement, request, sentence or sanction of the Council and/ or the Registrar or any official appointed by the Council or the Registrar to perform any function in furtherance of the Council’s objectives;

(xiv)[(xxi)] failure to submit to an inspection of a veterinary facility required by Council;

(xv)[(xxii)] failure to provide any records required to be kept in terms of the Medicines Act;

(xvi)[(xxiii)] practising from a facility, without client consent, which is not registered or does not comply with the minimum standards set out in the Rules;

Graduating from vet school means nothing! Registering a vet practice means everything! How is a young vet supposed to start up? There are tons a young vet can do and remain professional without all the stuff and work their way up to it.A Lewis

(xvii)[(xxiv)] practising outside the scope of registration for a registered facility, without client consent, unless justifiable reasons exist;

(xviii)[(xxv)] being convicted of being involved in any criminal or illegal activity, if it relates to the practising of the veterinary professions or is deemed to bring the profession into disrepute;

Who is going to determine if it is going to bring profession into disrepute?

A Lewis

(xix)[(xxvi)] to permit himself/herself to be exploited in a manner which may be detrimental to the patient without client consent, detrimental to the client, client, the public or the profession, or allow bias, conflict of

Legaldirector, 2017-02-05,
This is not a call the client can make, delete. This is about a conflict of interest. Perhaps it should be cleaned up.V-Tech
Legaldirector, 2017-02-05,
Lies within the discretion of the SAVC. Test is an objective one and follows a peer review procedure. Old wise guys/gV-Tech
Legaldirector, 2017-02-05,
This is not a call the client can make. If the client is dissatisfied with the vet’s service, he/she must lay a complaint with the SAVC for investigationV-Tech
Legaldirector, 2017-02-05,
We suppose the vet needs a practice domicile so the SAVC can serve on him or her?V-Tech
Legaldirector, 2017-02-05,
Agree, not permissible.V-Tech
Legaldirector, 2017-01-23,
The client cannot consent to this. It is illegal.
Legaldirector, 2017-02-05,
… or other legislation.V-Tech
User, 2016-09-05,
I would like a better explanation than being offered here. What exactly is being referred to the capturers for treatment. This sounds like there is confusing between prescription of treatment versus referral. Assuming that this is within the bounds of bone fide client relationship, a vet can certainly prescribe treatments.
Legaldirector, 2017-02-05,
This alludes to an emergency situation where any person can intervene to assist the animal until help arrives. Should be removed as it forms part of our common law. V-Tech
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interest or influence of others, to compromise professional judgment; and

All the vets that work for game capture companies or only work for one farmer are in this boat? So what does SAVC suggest these people do? How else does a young, or can’t stand on their own person, contribute to industry?A Lewis

(xx)[(xxvii)] any other conduct which in the opinion of Council constitutes unprofessional conduct, based on peer review.

This is the most crazy open ended thing I have ever read. Council does not even represent vets in all fields appropriately so how can they decide this?This a crazy blanket statement that if great if council is unbiased and transparent, and represent all industries equally, unfortunately Council is currently none of these so we must put something into place to build confidence in Council. This will also encourage vets to feel like that can actually be part of their professions futureA Lewis

“veterinarian-client-patient relationship and vet game capture/ support team relationship” means the following:

[(i)] the veterinary professional has assumed the responsibility for making professional judgments and/or treatment regimes regarding the health of a patient or patients or improvement in the production of the animal or animals, at the request of the client; in wildlife this means a trust relationship exists between the team and the vet to allow the vet to make professional judgements and/or treatment regimes regarding the health of animals the team might reasonably encounter or improvement in the production of the animal or animals at the request of the game capture team or client

(i)[(ii)] the veterinary professional has sufficient personal knowledge to initiate at least a general or preliminary assessment of the condition of the patient(s) by virtue of a consultation with the client or his representative; and

(ii)[(iii)] clinical records are maintained.

“veterinary hospital/clinic means a veterinary facility where veterinary services are available at selected times and wherein examination, diagnostic, prophylactic, medical, surgical and extended accommodation services for hospitalised animals are provided;

J V H, 2016-09-24,
This addition I think is superfluous
Legaldirector, 2017-02-05,
Not relevant to the conduct of a vet and the relationship with the SAVC, remove. A vet may consult with whom he likes but ultimately makes the professional call and accepts responsibility for it. The SAVC has jurisdiction over vets and those registered under the Act and no other person.V-Tech
Legaldirector, 2017-02-05,
Although integral to the game capture process, the SAVC does not have jurisdiction over these people. Only a vet can contract in an “official” capacity to provide veterinary services.V-Tech
Legaldirector, 2017-02-02,
Add contractual???Loophole-Will have to prove contract
Legaldirector, 2017-02-05,
The purpose of the SAVC is to protect the public against the vets. They do not represent the vets. They police the conduct of vets and take action against them if they step out of line/V-Tech
Legaldirector, 2017-02-05,
This is the lawyers catch all phrase and permissible as the decisions of the SAVC are reviewable in the High Court.V-Tech
Legaldirector, 2017-02-05,
Act responsibly as trained and not be unduly influenced by laypersonsV-Tech
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“veterinary laboratory” means a facility which has the specific purpose of diagnostic and/or research testing, any mobile service unit linked to the permanent facility, and in-house laboratories that form part of a veterinary facility where the service is not only rendered for the facility’s own requirements;

In wildlife next to the animal screening tests (CA) and the prep tests (gamma TB) can be conducted

A Lewis

“veterinary medicine” means any substance or mixture of substances, other than a stock remedy or farm feed to be registered in terms of the Stock Remedies Act, used or purporting to be suitable for use or manufactured or sold for use in connection with vertebrates, for the treatment, diagnosis, prevention, mitigation, modification or cure of any disease, infection or other pathological condition, or for the maintenance or improvement of health, growth, production or working capacity, or for curing, correcting or modifying any somatic or organic function, or for correcting or modifying behaviour;

"veterinary professional" means a person registered to practise the veterinary profession as a veterinarian or veterinary specialist;

“veterinary shop” means a facility registered with Council and identified as a veterinary shop, owned solely by a registered veterinarian who sells veterinary products and animal related products, including pharmaceutical products, including but not limited to ‘veterinarian only’ products for which the manufacturer has limited the sale to veterinary professionals, to the public, excluding medicines in terms of the Medicines Act registered as schedule 1 and higher;

“veterinary shop” means a facility registered with Council and identified as a veterinary shop, owned and manned solely by a registered veterinarian who sells stock remedies and veterinary medicines falling under schedule 0 and other products and animal related products, including pharmaceutical products, including but not limited to ‘veterinarian only’ products for which the manufacturer has limited the sale to veterinary professionals, to the public, excluding medicines in terms of the Medicines Act registered as schedule 1 and higher;

Medicines Group

“veterinary vaccine” means a biological veterinary medicine derived from biological agent(s) used for the prevention of a disease in an animal or group of animals and/or the prevention of the spread of disease to the general animal population; and

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“wildlife” means all non-domesticated species of animals, whether free-living or kept in captivity.

Wildlife means feral animals, captive wild animals and wild animals. Feral animal is an animal of a domesticated species that now lives without direct human supervision or control. Captive wild animal is an animal that has a phenotype not significantly affected by human selection but that is captive or otherwise lives under direct human supervision or control, including zoo animals and pets. Wild animal is an animal that has a phenotype unaffected by human selection and lives independent of direct human supervision or control

OIE definition

How can SAVC use the OIE regulations and then not use their definition of what is wildlife?

A Lewis

This is a major issue the new listing of the all the wildlife species under the animals protection act makes them all livestock! I think the entire unique thing that needs to built into the definition is that the wildlife vet never works alone and that the special team/support is the functional unit and then how this unit functions to capture animals we happen to call wildlife it the part that needs to be defined and allow special rules to facilitate it to happen in a professional manner. Don't have a good answer. Wildlife work is when a team of people with the vet ultimately responsible for the animal welfare to works together to capture animals. The unique relationship exists when team work between the vet and trained wildlife capture support staff/team is required to capture animals. Wildlife is defined as any patient that you have to look off for longer than 45 minutes.

A Lewis

SERVICES PERTAINING SPECIALLY TO THE VETERINARY PROFESSION

2. General Services

(1) For the purposes of the Act the following shall be deemed to be services which pertain specifically to the veterinary profession, which only a registered veterinary professional may render:

(a) the diagnosis, prescribing treatment, advising on measures for the prevention of, or advice on a disease, physiological or pathological condition in an animal;

Legaldirector, 2017-02-05,
Some of these services may be subject to another Act. All Acts should be scanned to establish whether this clause is limited by these Act. See Pharmacy Act and Regulation etc.GNR.1158 of 20 November 2000: Regulation relating to the practice of pharmacy18. Community or institutional pharmacy. - Except as provided for in the Medicines Act, the following services pertaining to the scope of practice of a pharmacist may be provided in a community or institutional pharmacy— the provision of animal health care services which includes: the compounding and dispensing of prescriptions written by veterinarians and ensuring the optimal use of veterinary medicines; the immunisation of animals; the handling of minor and/or self-limiting ailments in animals; and the provision of information and education regarding the promotion of animal health.Secondly, these services must be offered for gain.V-Tech
Legaldirector, 2017-02-05,
This goes to the interpretation of statutes and government policy. It does seem the policy needs rev-visiting. This is achieved through consultation and the issuing of a policy guideline. What mischief Is the government trying to alleviate and are the vet rules the correct place for its achievement. V-Tech
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(b) chemical restraint of an animal, which includes general, standing, and/or regional anaesthesia, chemical immobilisation or sedation, (with the exception of sedation and tranquillization with the medicines listed in Rule 10.3)

(c) any dental, medical or surgical procedure on an animal;

(d) the prescribing or dispensing of medicine or the administration of a diagnostic substance to an animal;

(e) the use of any veterinary device or apparatus on an animal, that is limited to use on an animal that is either sedated or anaesthetised, or that poses a risk to the public or is used specially in the provision of veterinary procedures;

(f) use of alternative, and integrative therapies on an animal;

(g) use of any procedure for reproductive management, including but not limited to the diagnosis or treatment of pregnancy, fertility, sterility or infertility; or

(h) determination and certification of the identity, health, fitness or soundness of an animal.

3. Exception in respect of Rule 2:

(1) The provisions of Rule 2 (1)(g) shall not be construed so as to prohibit the procedures allowed in terms of the Animal Improvement Act, Act 62 of 1998, provided that all requirements of the said Act are met;

(2) The provisions of Rule 2(1)(c) & 2(1)(f) shall not be construed so as to prohibit the procedures allowed in terms of a para-veterinary professional’s registration and scope of practice under the Act.

CONDUCT OF PERSONS PRACTISING VETERINARY PROFESSIONS

4. General principles

(1) A veterinary professional must base his/her personal and professional conduct thereon that he/she is a member of a learned and honourable profession and is required to act at all times in such a manner as will maintain and promote the prestige, honour, dignity and interests of the profession and of the persons by whom it is practised.

(2) All persons practising veterinary professions are working towards the same common good cause, whether they are in private practice or in the service of an employer, and they must co-operate with each other and with the authorities concerned to promote that cause.

Legaldirector, 2017-02-05,
This appears to now be a repeat the objectives of listing “unprofessional conduct” in the definitions. The objective of giving guidance to vets as to what is viewed to be unprofessional conduct should be combined in one section and focus on general principals. Additional guidelines can be issued as and when necessary by Council to highlight more specific conduct that is viewed to be unprofessionalV-Tech
Legaldirector, 2017-02-02,
Use
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(3) As a professional a veterinarian is required to comply with the following fundamental principles:

(a) Integrity: To be honest and ethical.

(b) Professional Competence:

(i) To maintain the professional knowledge and skill required to ensure that a client receives competent professional services based on current developments in practice, legislation and techniques and act diligently and in accordance with applicable technical and professional standards benchmarked against what is expected of the reasonable veterinarian considering the circumstances and geographic and demographic realities at hand;

(ii) To comply with continuing professional development (CPD), which enables a veterinary professional to develop and maintain the capabilities to perform competently within the professional environment; and/or

(iii) To keep record of CPD hours obtained to ensure CPD requirements are met to ensure that registration with Council is maintained.

[(c)] Professional care: To give due importance to the welfare of the patient: The veterinary professional may, as far as it is within his/her professional ability, not refuse or discontinue treatment to an animal without valid reason; valid reasons include but are not limited to: dangerous animals, verbal abuse, physical violence, and history of non-payment by the owner, non-familiarity with particular species. Where there are financial constraints, the only treatment that a veterinary professional will ever be obliged to offer at a discounted rate or free of charge, for the sake of animal welfare, is euthanasia, which may includes shooting of wild animals. with a rifle.

Allows all wildlife vets to deny care

A Lewis

(c)[(d)] Confidentiality: To respect the confidentiality of information acquired as a result of professional services and the relationships emanating therefrom, and, therefore, not disclose any such information to third parties without proper and specific authority, unless there is a legal or professional right or duty to disclose, nor use the information for the personal advantage of the veterinary professional or third parties.

Legaldirector, 2016-11-04,
JvHShould not be an excuse to any wildlife vet.
Legaldirector, 2017-02-05,
Is this all necessary. Issue is about professional abandonment which is unjustifiable. Suggest we leave it there and allow a misconduct inquiry to decide if the conduct was justifiable and therefore reasonable. Were steps taken to transfer the patient etc.V-Tech
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(e) Professional conduct includes but is not limited to:

(i) To be informed and comply with all the legal directives which are relevant to the practice of his /her profession and which include the Act, its regulations and Rules, the current Code of Conduct and Practise, the Medicines Act and its regulations, as well as all other relevant legislation;

(ii) To avoid any action that the veterinary professional knows or ought to have known that may discredit the profession;

(iii) To be morally obliged to serve the public to the best of his/her ability and in the light of acceptable scientific knowledge, with due consideration of patient welfare and the environment;

This is such a can of worms. Help public but does not help animal? Help farmer make money at the expense of the animals? This should rather read “to use a one health type of approach to juggle all aspects to try and do your best in the current environment”.

A Lewis

(iv) To refrain from expressing criticism through which the reputation, status or practise of a colleague in the profession is or could be undermined;

(v) Not to permit himself/herself to be unjustifiably exploited in a manner which may be detrimental to the patient, client, the public or the profession;

Same as previously mentioned with regard to vets that work for game capture companies and farmers under contract etc

A Lewis

(vi) The place at or from which a person practises a veterinary profession must be registered with Council and must comply with the applicable general minimum standards for that veterinary facility;

(vii) The principal of a registered facility must inform the Council within thirty (30) days of any changes to the identity or address of the principal; if the principal should pass away, Council should immediately be informed. If the role of principal is not transferred to another veterinarian immediately, all scheduled medicines must be placed under the auspices of the Medicines Control Council, a locum sought as quickly as possible and either the scheduled medicines destroyed or responsibility handed over to the locum; and/or

Legaldirector, 2017-02-05,
This may be misplaced and find a better home elsewhere.V-Tech
Legaldirector, 2017-02-05,
UnjustifiablyV-Tech
Legaldirector, 2016-11-04,
I could easily justify working with a lion breeding project but depends on how and who reads this rule as the outcome of the poor vet who decides to help the lion breeder. So obviously this rule is dependant on luck of the drawA Lewis
Legaldirector, 2017-02-05,
Do you mean morally or ethically? Does the clause add any value? What does it hope to achieve? This is the reason for the rule under discussion. It seems void for vagueness.V-Tech
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(viii) A veterinarian must inform Council within thirty (30) days of entering into employment or partnership at another registered facility.

5. Issuing of veterinary certificates

(1) Certificates or other documents, which are issued by veterinary professionals in their professional capacity, must contain facts which are professionally verifiable, save for the historical information and identity supplied by the owner, which must be stipulated as such.

(2) A veterinary professional may only certify those matters of which -

(a) He/she has personal knowledge; must state variability if applicable.

[(b)] He/she does not acknowledge variability in parameters or insufficient scientific data;

[(c)] Can be ascertained by him/her personally; or

(b)[(d)] Are the subject of a supporting certificate from another veterinary professional or delegated para-veterinary professional, who acted under that veterinarian’s instruction and who has personal knowledge of the matter in question and is authorised to provide such a supporting document.

(3) The certificate referred to in Rule 5 (1) must:

(a) Be prepared with care and accuracy;

(b) Be legible;

(c) Be unambiguous and easy to understand;

(d) Be produced on one sheet of paper or, where more than one page is required, these must be consequentially numbered and initialled;

(e) Contain dates that are clear and correct and cannot be misinterpreted; and

(f) Not attest to future events.

(4) All certificates thus issued must indicate –

[(a)] The name and residential address of the owner or perceived of the animal concerned;

Legaldirector, 2017-02-05,
What happens if these parameters are presentV-Tech
Legaldirector, 2017-02-02,
Separate rule for product certification, Dr Neethling to provide input. Meat in abattoirs
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(a)[(b)] The address of the premises where the animal is kept, if different from the owner’s;

(b)[(c)] The breed, sex, colour and age of the animal;

[(d)] Name or identification of the animal as reported by the owner or owners or perceived owner(s);

(c)[(e)] Any positive identification of the animal such as tattoo numbers, body markings, microchip number and date of micro-chipping where possible; reported identification should be verified by the veterinarian before certification

(d)[(f)] The purpose for which the animal is certified (e.g. hacking, racing, etc.), if applicable;

What is wildlife according to OIE? Then our local law regarding ownership of wildlife? Then if you have exception of animals in your farm? How do you own a wildlife animal that is not on your property? Therefore if you don’t own it, how can you write a certificate about it? So how on earth must a wildlife vet write a certificate?

A Lewis

(e)[(g)] The date of issue of the certificate as well as the date of examination of the animal; and

(f)[(h)] For vaccination certificates the following are also required –

(i) The batch number and expiry date of the vaccine which has been used;

(ii) The name of the vaccine or its self-sticking label; and

(iii) The date of vaccination of the animal concerned.

(5) Any certificate or other document which is issued in a professional capacity by a veterinary professional must be signed by such a veterinary professional personally.

(6) When issuing a certificate, a veterinary professional must ensure that -

(a) The certificate contains his/her signature and in clear, legible lettering, his/her name, qualifications, registration number and the physical address of the registered facility and, where applicable his/her official or practice stamp;

(b) An exception to 5(6)(a) is allowed for pre-printed vaccination and export certificates where the printed space does not allow for all the information and only the required detail must be filled in;

(c) He/she completes any manuscript portions in ink;

Legaldirector, 2016-11-04,
Alex. LewisThe p3 exception permit and or WR# (in case of buffalo) or if non of these exist then the nat con permit. This leads into the whole TOPS debacle .....which needs to be dealt with
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(d) The certificate contains no deletions, other than those, which are indicated on the face of the certificate to be permissible, and subject to such deletions being initialled by the certifying veterinary professional;

(e) No correction fluid to be used on a certificate; and

(f) No blank spaces on any certificates exist that may be used by another person to alter the original.

(7) All vaccination record cards must indicate –

(a) The name and residential address of the owner/breeder of the animal concerned;

(b) The breed, sex, colour and age of the animal;

(c) The name or identification of the animal as reported by the owner;

(d) Any positive identification of the animal such as tattoo numbers, body markings or microchips numbers;

(e) The batch number and expiry date of the vaccine which has been used;

(f) The name of the vaccine or its self-sticking label; and

(g) The date of vaccination of the animal concerned.

(8) Students and Para-veterinary professionals may not sign certificates, provided that a record of vaccination may be signed if these are not intended to be used as travel documents or for any other official purpose.

(9) A veterinarian may not authorise any person to sign a certificate on his/her behalf.

(10) Original certificates should always be issued, and a copy made for own records, except for vaccinations, of which a clinical record must be kept.

(11) Copies of certificates issued by a veterinary professional must be retained for a minimum period of five years from the date of issuing.

(12) When required, a facsimile or electronic copy of a certificate will be acceptable, provided that a witness is available to verify the contents of the facsimile or electronic copy (e.g. in court).

Wildlife insurance requires step on and step off certificate emailed immediately. So if witness signs on Ipad is that ok?

A Lewis

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(13) Certificates should not require veterinary professionals to certify that there has been compliance with the laws of some other country, unless the provisions of the law are set out clearly on the certificate.

So what does a vet do if some certificate for export of animals to Mozambique requires a vet to break this rule? Otherwise the animals won’t get exported and the whole public will suffer thus breaking rule 4.3.e.iii

A Lewis

(14) Laboratory result reports communicated by the veterinarian (who received the samples) or person delegated by the veterinarian to clients shall contain the minimum following information, as applicable:

(a) date sample was collected, date received, date completed, and date of release of results;

(b) client information and geographical information;

(c) animal identification as submitted, including species, breed, gender and age;

(d) clinical history;

(e) tests performed;

(f) final results and/or diagnosis;

(g) further actions and recommendations;

(h) specific method used;

(i) accreditation, where applicable;

(j) international standard, where applicable;

(k) performance characteristics of the test; diagnostic sensitivity, diagnostic specificity: where this is not available, it must be clearly indicated that the test is not validated, and the performance is not known; and

(l) signature of person authorizing the release of the results and the date.

6. Records to be kept at veterinary facilities

(1) The attending veterinary professional must maintain records, including the records required in terms of the Medicines Act, regardless of where the animals were seen, for each animal or group of animals which are legible, accurate and permit prompt retrieval of information.

Admin, 2017-01-29,
[Dr Erasmus- wildlife] Often records consist of:a)A diary of diagnosis / treatment (initiated when the appointment for the veterinarian to visit the farm is made).b)Notes made on a smart phone or tablet.c)Practice invoice with farm address / details generated after the visit, containing detail of medicines used, quantities, advice given, management suggestions, etc. This invoice is retained as a hard copy or is Cloud based (digital records acceptable).d)Recording of medicines used on groups of animals is allowed, eg bleed a herd of Buffalo – records total mg’s or ml’s used.e)Records to be kept for 3 years according to the Self-evaluation Form of Minimum Standards Rules 23-33 vs Rule 33 Facilities for Herd Health says 5 years.f)Medicine registers are often kept on Excel and printed out as a PDF document from a PC on a monthly / quarterly basis.Comment: Forms have been amended, the requirement is five yearsIWS
Legaldirector, 2017-01-23,
Dr Marwick
Legaldirector, 2017-01-23,
Dr Marwick
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(2) Records must contain the following information for individual animals as applicable-

(a) The date or period of the examination or consultation;

(b) Name of the veterinarian who treated the patient;

(c) Client’s identification;

(d) Patient name or other forms of identification, as well as the specie, breed, gender and age;

Problem with physical identification of individual patients (similar patients) in hospital.Each animal individually to be identified.Vet responsible to develop SOP to deal with identification, ensure staff aware of SOP.

Inspectors 31 Jan 2017

(e) Clinical information for the purposes of continuous care and assessment;

(f) Vaccination record;

(g) Special procedures;

(h) Diagnosis;

(i) Treatment and scripts issued; and

(j) Discharge instructions.

(3) Records must contain the following information for production animals, including wildlife, as applicable-

(a) The date or period of the examination or consultation;

(b) Client’s identification;

(c) Species & breed; for wildlife species and sex, age group and/or colour if relevant;

(d) Procedures or treatment performed. For groups of animals a general description of the type of herd-work and bulk use of medicine are acceptable, but the use of schedule 5 and 6 wildlife capture medicines, must be recorded with care; and

To expect a wildlife vet to make entries for every animal darted in a day is totally unrealistic. I don’t know of any wildlife vets who can comply with the rules. All meds used on a farm at a date should be enough. If I dart 100 buffalo to bleed in one day I will need a full time personal assistant to fill in register. The point is control and accountability of the drugs, so if vet uses 1mg on 1 animal at one farm or uses 800mg on 100 animals on one farm it is all one herd so one patient? SAVC must make a stand on this one to help wildlife vets comply as we are all in breach of the rules because the rules are unrealistic and impossible to do. What on earth

Legaldirector, 2017-02-05,
It seems the wildlife vets have a point. The regulations under the current Act were written a long time ago and a carryover from previous statutes. It is unlikely that the drafters had the scenario painted in mind when deciding on appropriate measures. The SAVC should re-look the controls required together with the stakeholders.V-Tech
Admin, 2017-01-29,
Lotter iws 4.3.2Identification of patients in hospital –
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does "care" mean?

A LewisThis is a requirement of Act 101/65. The act requires the use in every animal to be recorded. The regulations to the Act have been in place for a long period of time. So until the vet council petitions for a change in Act 101/65, there is no deviation. For the record: I would oppose such a change, as it is an immediate declaration that the profession is unable to keep proper records. I would find it hard to believe that we can convince the MCC/SAHPRA that we can be trusted to use highly scheduled medicines, yet find it hard to made a note of it.

This is a requirement of Act 101/65. The act requires the use in every animal to be recorded. The regulations to the Act have been in place for a long period of time. So until the vet council petitions for a change in Act 101/65, there is no deviation. For the record: I would oppose such a change, as it is an immediate declaration that the profession is unable to keep proper records. I would find it hard to believe that we can convince the MCC/SAHPRA that we can be trusted to use highly scheduled medicines, yet find it hard to made a note of it.

V Naidoo

(e) Instructions to client in general, if applicable and abnormal observations.

(4) All records referred to in Rule 6(2), radiological images and the interpretation thereof, laboratory and pathology results must be retained by the principal of the veterinary facility for a period of five years from the patient’s last visit, with the exception of ultrasound images where only the findings must be recorded.

(5) Records must contain the following information for in house diagnostic laboratory work as applicable:

(a) date sample was collected, date received, date completed, and date of release of results;

(b) client information and geographical information;

(c) animal identification as submitted, including species, breed, gender and age;

(d) clinical history;

(e) tests performed;

(f) personnel doing the preparation and analysis;

Records to be maintained. F to j to be removed for in house labs. Rework, scrutinise all from f onwards.Calibration (maintenance records) to be kept. Anaesthetic & X-ray rules.

Inspectors 31 Jan 2017

Admin, 2017-01-29,
4.5.19Rule 6 [3] (e):“abnormal observations” - should read “observations of the abnormal”“Rule 6 [3] Records must contain the following information for production animals, including wildlife, as applicable: (e) instructions to client in general, if applicableand abnormal observations
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(g) method followed, deviations if any, reasons for deviation and reasons why results can still be accepted;

(h) consumables and reagents including name, batch number, and expiry date;

(i) results of quality control samples;

(j) environmental conditions, if abnormal, or other critical information required by the standard operational procedure;

(k) original findings; and

(l) reports.

(6) Records referred to in Rule 6(4) relating to a complaint, charge or allegation lodged with Council in terms of section 31(1) of the Act must be presented to Council within seventy two (72) hours of being requested to submit such records, or as otherwise arranged with Council.

(7) Proper security arrangements must be made to protect medical and other clinical records from loss, fire, alterations, additions, supplements or unauthorised use; electronic records must be backed up on a daily basis and electronic backups should be stored off-site.

How must electronic records be kept so changes can’t be made?

A Lewis

(8) Any alterations, additions and/or supplements to any records, clinical or otherwise, must be entered as a supplement to said record and must be dated and clearly defined as such, if permitted by the system.

(9) (a) The principal of a veterinary facility will be responsible for confirming the identity of the attending veterinary professional to Council, where a complaint is lodged against his/her veterinary facility.

(b) The principal of a veterinary facility will be responsible for providing the records referred to in Rule 6(5), should a complaint be lodged against a veterinarian no longer in the employ of the principal of the facility, subsequent to the date on which the complaint originated.

(c) Should the principal of a facility fail to comply with the provisions of Rule 6(9)(a) he/she will be held accountable for any unprofessional conduct arising from such a complaint.

Legaldirector, 2017-01-23,
DR MarwickThese can be kept as a rule (a) to (c) but not included in the Facilities for herd health practiceComment: Sub rule 9 is applicable to all veterinarians, otherwise chaos would reign.
Admin, 29/01/17,
4.5.18Rule 6 [5]:Sub-paragraphs (h), (i) and (j) are unnecessary and impractical for a practice. They apply to a veterinary laboratory, not a practice.“Rule 6 [5] Records must contain the following information for diagnostic laboratory work (if) applicable:(h)consumables and reagents including name, batch number, and expiry date;(i)results of quality control samples; (j)environmental conditions, if abnormal, or other critical information required by the standard operational procedure; “Comment: The Rule states if applicable.
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7. Acceptance and payment of commission

(1) Subject to Rule 7(2) a veterinary professional may not -

(a) Accept any commission or bonus, incentive, gift or cash from any person, company or institution as a consideration for referrals of any clients by such veterinary professional to such person; and/or for buying or promoting certain products;

(b) Share with any person, fees charged for a service unless -

(i) Such sharing is commensurate with the extent of such other person's participation in the rendering of the service concerned; or

(ii) He/she is a veterinary professional associated with the veterinary professional as a partner, shareholder, employee or locum tenens; and/or

(c) Charge or accept any fee for the same examination of or work on an animal from both the buyer and the seller of that animal or both the insurer and the owner of that animal, unless upon specific instructions to the contrary from the buyer and seller.

In wildlife often the buyer and seller share the capture fee or vet fees etc. so what now?

A Lewis

I would like a legal opinion on this. I was under the impression, that one had to represent only one party. Shared fees implies representing both parties legally…Is this really correct?

V Naidoo

(2) The provisions of Rule 7(1) shall not be so construed as to prohibit a veterinary professional -

(a) From introducing a loyalty scheme to all clientele of for a particular practice, provided that the loyalty scheme does not include the payment of money;

(b) From paying to a debt collection agency any commission in respect of debts which are collected by such agency on his/her behalf; or

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(c) From accepting any royalty or similar compensation in respect of an article or product to which he/she holds the patent rights or registration under the Medicines Act or Stock Remedy Act.

8. Covering

(1) A veterinary professional may not enter into a partnership or allow any shareholding or interest in his/her veterinary practice with another person, unless that person is registered with Council as a veterinary professional or para-veterinary professional. This does not prevent a veterinarian to be a partner in a venture in his personalcapacity, but his veterinary business must be located outside this business and bill the venture for veterinary services delivered

Any halfway good wildlife practice needs a helicopter to provide care to wildlife. Must we all hire vets to fly? Can't they be partners? Good game personnel that know and understand and have experience with wildlife are not usually vets, so to run a wildlife practice without such a person is impossible now?

A Lewis

(2) A veterinary professional may:

(a) Offer an appointment in his/her practice to another professional;

(b) Employ another person in a professional capacity at his/her practice; or

(c) Share his/her waiting and consulting rooms with another person involved in practising in the veterinary field.

(3) Any appointment, employment or sharing anticipated in Rule 8(2) is subject to the condition that:

(a) Patients may not be over-serviced for the purposes of increasing any commission, benefit or incentive to the veterinarian; and

(b) Sufficient bio-security measures, according to relevant health and safety legislation and including isolation facilities, are in place to ensure that the wellbeing of humans and animals are not at risk.

9. Estimate of fees

(1) A veterinary professional must inform the client in charge of an animal in respect of which a service is to be rendered of the approximate fee which he/she intends to charge for such service:

Legaldirector, 2016-11-04,
Alex LewisWe need to look at the point of the regulation. It is to make things professional and the best for the client and patient. There are unprofessional capture teams yet the majority also want all the same things we do, we are joined at the hip and to deny that is counter productive The vet is still the responsible person and accountable to Council But allow the vets to provide a better team work and better service The call should be up to the responsible person the vet. Only each vet will know if that relationship will work and be better
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(a) As soon as practically reasonable after the patient was examined;

(b) In the event of an emergency as soon as the patient is stabilised; and

(c) When a service is required in addition to the original service anticipated.

(2) Fees for standard procedures may be advertised in the reception area, in which event an estimate of fees need not be given to the client.

(3) The veterinarian must, on an ongoing basis, unless if an emergency, keep the client up to date with the costs and inform the client if more expenses are to be incurred in treating the patient successfully.

(4) Any veterinary professional claiming payment from a person in respect of any service rendered by him/her must furnish such person with an itemised account as soon as possible but not later than 30 days after the service was rendered.

10. Use of veterinary medicineWe have some general comments specific to Rule 10 and important to note in the context of what we are trying to achieve with the document. A few anomalies about medicines in animals has developed over time and are inaccurate. 1) That it is acceptable to use human medicines with “off-label” claims if a suitable registered veterinary medicines is not available.

There is no justification in the assumption that use of an “off label” medicine is safer to use than a compounded medicine that has been specifically prepared by a pharmacist in a suitably equipped facility on the instruction of a veterinarian for the in-practice use of the compounded medicine. It is arguably unwise for the SAVC to suggest a medicine registered for human use can be trusted over a medicine compounded, after consultation between a pharmacist and a veterinarian while taking the specific circumstances of the use the medicine into account, for a specific patient. In the latter circumstances, both professionals take responsibility for the performance of the medicine and the safety of the patient. This is in steep contrast to the “off-label” use of a registered medicine used where the registration holder accepts no responsibility for the use of their medicine outside its registered indications, leaving the veterinarian solely responsible and liable for the performance of the medicine and the potential harm it may cause to the patient. 2) The “concurrent use” of registered medicines in the same dosage vehicle by a veterinarian/farmer/nutritionist is preferred above a medicine compounded with the same active ingredients by a pharmacist on the instruction of the consulting veterinarian.

Furthermore, the risk of potential interaction/incompatibility between medicines together with the lack of controls with the former are inexplicably ignored together with the advantage of collaboration of two professionals with the latter. In most cases, the mixing of the two medicines and the administration are often left to lay persons. Even more so, in the case of Stock Remedies that can be purchased without prescription by animal owners. P a g e 3 | 3

3) Medicines should be compounded in a Pharmaceutical GMP Certified facility in order to ensure good quality.

Admin, 2017-01-29,
4.5.4 c)Availability of capture medicines essential (deaths are result of alternative medicine use). “Lending” from/selling to other veterinarians a reality. Iiws4.5.5Lay staffAdministering and handling of medicines by lay staff on the ground on darted animals whilst the veterinarian is in the helicopter.eg S6 Butorphanol in Impala as a respiratory stimulant (may dispense Stresnil, Haloperidol, Perphenazine, Clopixol to farmers with prescription).4.5.6Safe keepingLocking medicines in a vehicle overnight vs carrying medicines in and out daily. Carrying scheduled medicines in a vehicle – practicalities – Badger box!
Admin, 2017-01-29,
All wildlife vets have to mix/compound medicines.Registered 101’s with Registered 101’s.Registered 101’s with Registered Act 36 (eg Ketamine and Hyalase plus active [ingredient] medicine). Even Registered with unregistered products. IWS
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Pharmaceutical GMP Certified facilities are designed to manufacture large quantities of registered medicines for commercial sale outside the professional contractual relationship. Manufacturers are not equipped to compound and dispense small quantities of patient specific medicines prescribed by medical doctors/veterinarians. The difference in the two methods of preparation may lead to quality and control problems. This anomaly questions the judgement of professionals involved in the process of prescribing and compounding medicines for the benefit of their patients, and will place the responsibility of dispensing in an environment not equipped to deal with it. 4) That a vet may only request a pharmacist to compound a 30 day supply of medicines.

This provision in terms of the current regulation 4 is applicable to a pharmacist for sale of a compounded medicine in the retail trade. The regulation applies to a period of 30 days from date of dispensing to the patient or caregiver. In the case where a veterinarian contracts the services of a pharmacist to compound a medicine on his or her behalf, this provision does not apply and the decision should be made based on available data on the stability of the compounded medicine and the treatment regimen of the patient and its location.

V-Tech

(1) Whenever a veterinary professional, administers medicine to an animal or prescribes the administering thereof, he/she must satisfy him/herself that the administering thereof is justified with due allowance for the benefits and risks which that medicine may hold for –

(a) The animal to which it is administered, including withdrawal times of residues where relevant in the animal and/or the effect on the environment;

(b) The person by whom it is administered; and

(c) The consumer of the products of that animal if residues of the medicine concerned should be present in those products.

(d) Current medicines???

(2) To tranquilise, sedate, chemically immobilise or anaesthetise wildlife, any schedule 5 or 6 medicine to be administered parenterally, must be administered by a veterinary professional personally

Authorise para-vets (extend registration), employed by or reporting to the veterinarians or in the same organisation by the veterinarians, to administer schedule 5 & 6 – direct supervision by vet on site and in contact by radio??? Location & operation base

Personal opinion ON WORKSHOP DOCUMENTObviously I have a wildlife slant with my comments. We as wildlife vets are continually being forced into grey areas regarding some of our rules, as we

Legaldirector, 2017-02-05,
Is this realistic in the game capture industry. These drugs are administered remotely. Surely it is sufficient if the drug is administered under the professional supervision of a veterinarian in the immediate vicinity of where the animal is expected to come down. Immediate or direct supervision should be sufficient. Direct access to the downed animal is more important than delivering the drug.V-Tech
Legaldirector, 2017-02-05,
Needs an explanation.V-Tech
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often choose patient and capture support team welfare over these certain rules. These rules certainly fit a general vet model but have very little practicality in our speciality.

I have made a few comments in blue on a few points but address here in more detail Rule 10.

I have 16 years of 100% Wildlife experience. The way the wildlife industry has grown makes the end user Rule 10 completely impractical and without merit. We potentially can dart up to 100 animals in a day. It can increase the risk to the animals we are moving. We are often risking our client’s animals due to this amendment. This is part of their continued disgruntlement with our profession. At least we are addressing the lack of experienced vets and not releasing so many inexperienced and quite frankly dangerous new graduates. It’s a good start. We cannot expect a client to allow such a vet to practice on their animals.

1) I agree 100% that the drugs should only be in our care/ responsibility but the actual person who administers can be a trained/ trusted marksman. We are presently allowing wholly incompetent graduates to pull the trigger whereas experienced darters are not allowed. I question whether trigger pulling is in fact a veterinary procedure.

2) Situations where this rule simply does not work:

- Multiple animals to dart from the chopper . Vet needs to process (there are a lot of procedures to carry out on these animals (scanning/measuring/ tranquilizing) and waking up as soon as possible. To push a herd if the darting and processing is slow is risking animals. To allow another person to process and tranquilize I feel is worse than allowing someone to pull a trigger. The whole operation is quicker and more efficient. There are many stories of jobs where the vet doesn’t even touch an animal and just darts. This is not advisable.

-- Walk and stalk situations are often better carried out by a trained

person not the vet. A good marksman is often more safety aware than a vet and is trained with normal firearms. So to suggest they won’t understand the danger of the drugs yet they work with bullets is nonsensical!

-- The terrain may not allow landing of the chopper near animal. Vet on

ground is preferable.-- Ground darting/ multiple guns are sometimes required in order to get

the animals. Especially cow calf darting.

- Ambush situations in camps are often more successful with two guns

- Some vets suffer from air sickness: I know of at least 3 vets who suffer from this but are completely competent otherwise. To use a marksman is important.

- I know of several injured vets who could not lift the gun properly and dart efficiently due to an injured arm. Also a couple of colleagues with injured legs unable to go in the chopper but able to work. What are we meant to do in such situations? The shortage of vets who do wildlife often doesn’t allow many other options. Many clients would still like to see their trusted vet able to delegate but still be on site.

- Pregnant vets! (Not meaning to play a gender card but it’s there!) It

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gets to a point (I have experience) that it is not ideal to get into a chopper. I would not want another vet as I was wholly competent otherwise.

There are many more situations, and when one is on a capture operation sometimes decisions must be made quickly for the sake of the animal/ people, etc.Captures and wild animals often do not follow a text book or understand our rules.

The carrying out of a darting operation although the end responsibility of the vet in charge, involves a support team. Without a team the success rates decrease. This is unlike any other area of veterinary medicine. This is a unique specialization and we work as a functional unit. There is a trust and these teams are mostly extremely experienced, ethical and professional. Many of these teams have been instrumental in training up wildlife vets when there was no program in place at OP. There are exceptions as there are in our profession!

Although it is often NOT necessary for another darter, in my experienced professional opinion there are cases that merit a trusted marksman. I think we are able to make this decision. I love darting but I also realize the merits of a marksman to the success of some captures.

The darts are drawn up before the darting. Emergency drugs also given in the case of a problem. Vet should be on radio to confirm various questions if necessary.

Numerous experienced colleagues agree that this rule is not practical within our area of expertise. I hope they will also make their voices heard.

This rule is a severely limiting factor in certain jobs. And the substance of the rule is without base. I feel very strongly on this point. This has been my life for 16 years so I can comment on the problems this rule has brought.

Dr E Rambert

Mixing of medicines: All wildlife vets have to mix/compound medicines. Registered 101’s with Registered 101’s.

Registered 101’s with Registered Act 36 (eg. Ketamine and Hyalase plus active [ingredient] medicine).

Even Registered with unregistered products.

4.5.4 Availability of medicines: a) In higher concentrations than standard use, eg Diazepam.

b) Certain medicines, eg Ketamine is essential for veterinary use – need to secure this medicine for the profession.c) Availability of capture medicines essential (deaths are result of alternative

medicine use). “Lending” from/selling to other veterinarians a reality.

4.5.5 Lay staffAdministering and handling of medicines by lay staff on the ground on darted animals

whilst the veterinarian is in the helicopter.eg S6 Butorphanol in Impala as a respiratory stimulant (may dispense Stresnil, Haloperidol, Perphenazine, Clopixol to farmers with prescription).

4.5.6 Safe keepingLocking medicines in a vehicle overnight vs carrying medicines in and out daily.

Carrying scheduled medicines in a vehicle – practicalities – Badger box!

Legaldirector, 2017-02-05,
Agree.V-Tech
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Inspectors 31 Jan 2017

(3) Notwithstanding the provisions of 10(2) a veterinary professional may prescribe, sell, or dispense the following substance(s) or medicine(s) to a client within a ‘client-patient-veterinarian’ relationship for the purposes of the treatment of a specified patient on condition that the requirements of the Medicines Act are complied with and said substance/medicine may only be made available for a reasonably acceptable period, but in any event for no longer than thirty (30) days consecutive treatment at a time:

This needs to have a clause to allow for the client patient vet relationship to apply to game capture teams.

We must be allowed to give to game capture teams for the year otherwise we will be writing new scripts for them monthly.

A Lewis

(a) Perphenazine enanthate;

(b) Haloperidol;

(c) Zuclopenthixol acetate;

(d) The list of drugs that can be used as "beneficial" drugs needs to be determined by the vet not the SAVC as there are several situations that these drugs won’t help.

(e) A Lewis

I would like to see the extended list, with proper data supporting their use. I don’t see reason why the list can’t be lengthened with good published supportive data.

V Naidoo

(f) Diazepam; and/or

(g) Azaperone.

User, 2016-09-05,
No, you have to do every time. Act 101/65 does not give the vet the right to wholesale, nor does it give permission to treat when the animal/herd is not yet identified. These are highly schedule drugs for a reason. The rule is in place to prevent this exact abuse of the vets right to dispense. Either way, the vet act can’t override the per client clauses of Act 101/65
Legaldirector, 2017-02-05,
In terms of Section 22A of the Medicines Act: 22A. Control of medicines and Scheduled substances. (16) Notwithstanding anything to the contrary contained in this section— any medicine or scheduled substance may be possessed by a medical practitioner, dentist, veterinarian, practitioner, nurse or other person registered under the Health Professions Act, 1974, or under the Veterinary and Para-Veterinary Professions Act, 1982, for the purposes of administering it in accordance with his or her scope of practice;So a vet has a discretion and latitude about the quantities of drugs he needs for his practice provided when challenged, he can provide evidence that the quantities are reasonable. In other words, the vet may stock up on drugs in line with his practice needs.It is impermissible to denude a veterinarian of the tool of his trade (drugs) and so hinder his/her ability to practice his profession.V-Tech
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(h) Medazolam

(i) ACP

(j) Or any other drug that the wildlife veterinarian can justify ids needed for the animals. Delete a & e, keep only f

Obviously none of the comments I made before were read or understood what I wrote or the SAVC just does not care/accept reality. Let me try again....how must I wake up 10 buffalo in a boma after darting them? I am one and the buffalo are 10! IV is the best wake up as major reduction in chances to vomit. So can a lay person use a schedule 5-6 under vet supervision? High and mighty vet is in helicopter, lowly lay people are driving with buffalo bull on back of bakkie through the bush to boma, bull starts to wake up or stops breathing what must they do? Driver drops off rhino in Namibia into a camp with other rhino, the rhino must be fully awake so the effects of the M5050 that were so good during the transport must now be reversed, must the driver inject the Naltrexone or let the other rhino fill the new arrivals with horns?

A Lewis

(4) A veterinary professional must inform the owner of an animal to which medicine is administered, fully with regard to -

(a) The application and effect of and precautionary measures in connection with that medicine, including the dangers of using non- registered medicines;

(b) The period, if any, during which the products of that animal are to be withheld from human consumption and or use; and

(c) The period, if any, (also referred to as the detection time) during which the animal should not be entered for sports competitions where prohibited substance rules apply.

(5) When using or prescribing a medicine that has been compounded, veterinarians must comply with the following:

(a) Ensure that a suitable registered veterinary medicine or any combination of such medicines, as defined in the Medicines Act, or stock remedy, as defined in the Stock Remedy Act, or any relevant Act it may be substituted with, is not available for sale within the Republic of South Africa in a suitable concentrationsize, volume and concentration; including extra-label medicine use; If the combination of registered products with individual actives to obtain a fixed dosed combination e.g. Mixing drugs in the food/water is possible, this is sufficient grounds to use the registered products first

[(b)] Ensure that where there is no registered veterinary medicine available, a veterinarian may only compound medicine in a quantity/volume due not greater than the quantity required for treatment of the patient for a period of not more

Legaldirector, 2016-11-09,
Agreed
User, 2016-09-05,
Nothing stops a vet from prescribing these meds in a bona-fide client relationship is in place. As above, the driver is the legal guardian of the animal while it has been transferred into his care by the owner
Legaldirector, 2017-02-05,
Yes, the layperson is not “selling” the drug (criminal offence) but administering it under vet supervision. It happens everyday in life with a host of human drugs..V-Tech
User, 2016-09-05,
The antagonists are schedule 4, as far as I know. Legally the reversal agents are not listed as sedatives/Tranquilisers.
User, 2016-09-05,
There have been a number of other vets who provided the opposite argument.
Legaldirector, 2017-01-23,
This is open to extreme abuse, if accepted
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than 30 days, ; to sfor stability reasons. The latter does not preclude a veterinarian to issue a repeat prescription of the said drug for up to six months if it is necessary (not schedule 6).

30 Days are way too short for wildlife applications, for example just to catch and test and move buffalo can take 3-4 months from the start of testing until delivery.A Lewis

This is good dispensing practice. The 30 days is to protect the animal from the drug. In all the arguments all that comes out, is the inconvenience to the animal. Never once has there been mention that the drugs can be dangerous and that instabilities can occur. These are highly valuable animals, which should translate to more prudent drug use from the veterinary side.

V Naidoo

(b) Ensure that the preparation labelling of the medicines is done in labelling in accordance with Rule 21(4)(l);

(c) Ensure that there is a documented system for compounding in place and inform the Council, on its request, on the therapeutic efficacy and effect of such compounded medicine, the purpose and circumstances under which and the manner in which such compounded medicine should be used;

(d) Ensure that a compounded product does not contain substances as prohibited in terms of Section 36A of the Medicines Act or Stock Remedies Act in South Africa;

(e) Ensure that the purity of the medicines is guaranteed by procuring such medicines from a manufacturer(s) accredited for Good Manufacturing Practice, should the veterinarian personally compound the medicines;

(f) Should the compounding of medicines be outsourced to a third party, the veterinarian must make use of a registered compounding facility with the correct licensing to perform such compounding, who can contractually guarantee the purity of the ingredients, and must issue the third party with a compounding order specifying the product, quantity, packaging and labelling;

(g) Retain full responsibility for the product even when it is compounded by a third party, unless such third party commits a manufacturing error;

(h) Comply with all aspects of Section 22A of the Medicines Act;

(i) Ensure that the compounded products are not advertised or promoted as veterinary medicine trade name products or displayed for sale to the general public;

Legaldirector, 2017-02-05,
These are community pharmacies as registered under the Pharmacy Act. Manufacturers are precluded from making up prescriptions for patients. Compounded practices are not licensed separately in South Africa. It falls within the scope of practice of a community pharmacy.V-Tech
Legaldirector, 2017-02-05,
There is a disconnect here – does the clause mean active ingredient? Active ingredients are usually not sourced from GMP licensed facilities; it is not their business.V-Tech
Legaldirector, 2017-01-23,
JvHExcept when compounding takes place in a dart for immediate administration thereafter
Legaldirector, 2017-02-05,
But proof to the contrary will negate this argument. Each drug must be assessed on its own merits, generalities do not apply when limiting rights. The veterinarian using the drug accepts responsibility for any harm it may cause and is liable.V-Tech
Legaldirector, 04/11/16,
A Lewis30 Days are way too short for wildlife applications, for example just to catch and test and move buffalo can take 3-4 months from the start of testing until delivery
Legaldirector, 05/02/17,
See comments above. The 30-day restriction is only applicable to a pharmacist and not a vet. Stability studies may indicate otherwise, the period could be shorter than 30-days or longer.V-Tech
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(j) The use of compounded medicine is not intended to circumvent the registration requirements of the Medicines Act and/or the Stock Remedy Act;

(k) Inform the owner of the lack of quality control and possible deficiencies in efficacy of the compounded product;

(l) Ensure that compounding is not done in the absence of a ‘veterinarian-client-patient’ relationship; and/or

(m) No compounded veterinary medicines or actives may be imported without approval from the Medicines Control Council.

(6) A veterinarian may only use compounded veterinary medicine for a food producing animal(s), including wildlife intended for human consumption, subject to the following:

(a) The use of the compounded medicine is limited to tranquilisation or immobilisation, the emergency management of a new disease/condition or the management of a disease/condition to which no local registered product exists, or is not readily accessible at the time, as restricted by the conditions in Rule 10(5)(a) to 10(5)(g) above;

(b) The reason for compounding is not an attempt to enhance growth promotion in any food producing species in the absence of disease;

[(c)] The withdrawal period associated with its use as prescribed by the veterinarian must be approved in writing by the Food Safety and Security Committee of the Council or the Veterinary Clinical Committee of the Medicines Control Council, as the case may be, in accordance of the requirements of the Foodstuffs, Cosmetics and Disinfectants Act, Act 54 of 1972, either do a trial or hundred and twenty (120) days, or otherwise ten times the half-life of the medicine, unless another withdrawal period is set by one of the two Committees;

Another option: An animal cannot be slaughtered for human consumption until such time as the withdrawal period has been approved

(c)[(d)] The food produced by said animal is unsuitable for human consumption until such time that the withdrawal time is approved by either or both of the Committees listed in Rule 10(6)(c), unless any one of the conditions in Rule 10(6)(c) is met;

(d)[(e)] Medicines prohibited for use in food producing species as set out in Rule 10(11) may not be used in compounded medicines; and

(e)[(f)] It is not intended for continued, sustained and/or frequent use on any one farm, by any one farm owner, by any one farm manager, by any one veterinarian or by any one person as this constitutes manufacturing, unless the use of the compounded medicine is reasonably justifiable and substantiated by facts.

Legaldirector, 2017-02-05,
It is extremely important that we get commitment of the turnaround time for approval by these two committees since an animal welfare issue may arise if slaughter is delayed.V-Tech
Legaldirector, 2017-02-05,
This rule must also apply to the extra label use of any Medicines (human or veterinary).V-Tech
Legaldirector, 2017-02-05,
When legislation is written that rely on the functions of a committee or council, it is normal practise that the functionality of the comittes are properly defined. These two committees will require special skills in order to evaluate any information that the prescribing veterinarian will submit to them to get approval. We need clarity on how the committees will be made up, what the qualifications of the members of these committees are and how the information should be submitted to the committees as time is of the essence. How will disputes be handled and by whom?When legislation is written that rely on the functions of a committee or council, it is normal practise that the functionality of the comittes are properly defined. These two committees will require special skills in order to evaluate any information that the prescribing veterinarian will submit to them to get approval. We need clarity on how the committees will be made up, what the qualifications of the members of these committees are and how the information should be submitted to the committees as time is of the essence. How will disputes be handled and by whom?V-Tech
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(7) When a veterinarian compounds a veterinary medicine, it must be done from a registered suitable facility, unless the circumstances dictate otherwise.

(8) A veterinarian may only compound, or have compounded on his/her behalf an autogenous vaccine, subject to the following:

(a) The veterinarian or third party contractor must be in possession of a permit in accordance with Section 20(b) of the Animal Diseases Act 1984, Act 35 of 1984;

[(b)] The autogenous vaccine needs to be handled like any other biological medicine controlled by the Pharmacy Medicines Act;

(b)[(c)] The production may only be undertaken or prescribed by a veterinarian for use in a particular patient in accordance with sections 14(4) and 22A(5)(e) of the Medicines Act;

(c)[(d)] An autogenous vaccine may only be used for a disease or strain of a disease for which there is no suitable veterinary vaccine or combination thereof registered and/or sold and/or available for sale in the Republic of South Africa;

(d)[(e)] The use of an autogenous vaccine is restricted to the specific farm where the infectious agent was identified. If grounds exist for the use of an autogenous vaccine on adjacent and non-adjacent farms, then an application in terms of section 20 of the Animal Diseases Act (Act 35 of 1985) must be submitted for approval;

(e)[(f)] In a disease outbreak situation the mass use of an autogenous vaccine may only commence in accordance with the requirements of section 20 of the Animal Diseases Act (Act 35 of 1985) and section 21 of the Medicines Act; and

(f)[(g)] The general sale of any autogenous vaccine to neighbouring farms or other districts/provinces must meet the requirements for general sale of a medicine in accordance with the Medicines Act and the Animal Diseases Act.

I have the following comments on Section 10 (8) on page 34:(b) The autogenous vaccine needs to be handled like any other biological medicine controlled by the Medicines Act

Veterinary vaccines for production animals are registered in terms of the Fertilizers, Farm Feeds, Stock Remedies and Agricultural Remedies Act (Act 36/1984). Autogenous vaccines are specific vaccines intended for emergency and restricted use (time and/or locality). They are defined as safe non-spreading products derived from specific pathogens isolated from a specific epidemiological unit and are used under veterinary supervision in that specific epidemiological unit only. There is currently no provision made in terms of Act 36/1947 for the registration of autogenous vaccines. Guidelines for the restricted registration of autogenous vaccines in terms of Act 36/1947 were already drafted in 1996 by Dr Robert Sykes, Dr A C E Pienaar and Dr C Paterson, based on EU and USDA requirements for autogenous vaccines.  These guidelines were discussed and accepted by the industry, but were never gazetted. SAAHA was asked last year to draft guidelines for the registration of autogenous vaccines, which was done and submitted to the Registrar: Act 36/1947.

Autogenous vaccines play an important role to maintain the health of production animals. Situations are frequently encountered where animal disease cannot efficiently be controlled by the available registered vaccines. This is a world-wide phenomenon, particularly in the

Legaldirector, 2017-02-05,
Does this not break the professional contractual relationship and amount to trading in medicines and not offering a professional service?V-Tech
Legaldirector, 2017-02-05,
Should this read …preparation…?V-Tech
Legaldirector, 2017-02-05,
This should be described as it places a restriction on the vetV-Tech
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intensive animal production industries. The increased prevalence of such problems may be ascribed in part to the marked intensification of farming methods for poultry and pigs in particular, but to variable degrees also for cattle (feedlot and dairy) and sheep.  The widespread use of commercial vaccines applies selection pressure, encouraging the survival of mutants or variants that are different from the commercial vaccine strains.

Some diseases are caused by multiple serotypes and no commercial vaccine can ever cover all possible serotypes. In such instances, problem-specific or herd-specific vaccines can solve the problem.

In the case of a serious outbreak of a hitherto unknown condition with serious economic and/or zoonotic implications, an emergency autogenous vaccine can be manufactured once the causal agent has been isolated and provisionally characterised. The manufacture and use of autogenous vaccines are thus recognised by regulatory authorities across the world, including the USA (USDA), EU, Canada and Australia.

These guidelines are an attempt to align South Africa’s requirements for the manufacture and use of autogenous vaccines, with the requirements of regulatory authorities around the world. It is by no means meant to circumnavigate the registration process in terms of Act 36/1947.

It also makes sense that ‘autogenous vaccines’ are handled in terms of the same Act as the one according to which veterinary vaccines are registered. A veterinary vaccine is a very different entity to a ’medicine’ and needs to be handled by veterinary input rather than a pharmacist. It is thus important that the Directorate of Animal Health (DAFF) has an input in the manufacture of autogenous vaccines, together with the Registration Authorities for Veterinary Vaccines, Act 36/1947. This is currently the case, with Section 20 approval by DAFF, together with the new guidelines  for Act 36/1947.

It is important, in the interest of animal health and food security, that autogenous vaccines are controlled in a practical way.

Regards

Dr C PienaarRegulatory Affairs Official

2)

(9) If a veterinarian compounds a veterinary medicine, he/she must do so from a registered facility, suitable for compounding, unless the circumstances dictate otherwise.

(10) Extra label use: A veterinarian may use a registered medicine, veterinary medicine or stock remedy in a manner other than stated on the approved label or package insert, provided that there is justifiable reason for doing so. The veterinarian takes full responsibility for the supervision of the preparation, application and outcome of the application/administration of the said medicine, and must be available to advise or intervene if there are any aberrant reactions to the said application/administration. If there is reason to expect any such aberrant reactions from the extra label use, the veterinarian must first explain his/her reasons to the client, and receive permission from the client to proceed.

Same withdrawal periods as for compounded medicine

(11) The following medicines are prohibited for use in food producing animals:

Legaldirector, 2017-02-05,
See comments above and possible contravention of the Medicines Act. Also it is important that Rule 10 6 c also apply to extra label use of MedicinesV-Tech
Legaldirector, 05/02/17,
This paragraph is open ended, what purpose does it hope to achieve?V-Tech
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(a) Phenylbutazone;

(b) Chloramphenicol;

(c) Aristolochia spp. and preparations;

(d) Carbadox;

(e) Cefuroxime*;

(f) Chloroform;

(g) Chlorpromazine;

(h) Colchicine;

(i) Dapsone;

(j) Diethylstilboestrol;

(k) Ipronizadole;

(l) Metronidazole;

(m) Nitrofurans (including Furazolidone);

(n) Organic arsenicals; and

(o) Phoxim.

*The new maximum residue limit (MRL) applies for use in cattle only.

(12) Administration of phenylbutazone must comply with the following conditions:

(a) The patient must be identified by an electronic microchip;

(b) All records must be kept as prescribed by the Medicines Act for Schedule 6 medicines;

(c) The veterinarian must obtain a written undertaking signed by the owner, that he/she will:

(i) prevent the patient from entering into the food chain when it dies and that, at that time, proof will be submitted that it was buried, burned or fed to carnivores, subject to the condition that irrespective of the method of disposal, it is incumbent on the veterinarian to ensure that any such disposal poses no danger to the environment or the predators and/or vultures therein.

(ii) that a further written undertaking will be obtained from any third party that is contracted to remove the carcase from the premises, that the carcase will

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be buried or burned; and that such signed undertaking will be submitted by the owner to the treating veterinarian;

(iii) that, if the animal is sold on, the responsibility of the seller will be taken over by the buyer who will give a written undertaking to the same effect, and which must be submitted to the treating veterinarian;

(iv) that, if the treatment of the animal is taken over by another veterinarian, copies of the written undertakings must be forwarded to same; and

(v) that defaulting on the given undertaking will be seen in a serious light as public health is at stake.

(d) The veterinarian must file these undertakings with the relevant clinical records for a period of five years after the death of the animal;

(e) Non-compliance with Rule 10(12) constitutes very serious unprofessional conduct and on conviction may attract the maximum published fine and/or removal from the register to practice as a veterinarian; and

(f) This Rule will become operative when the conditions set out in Rule 47(3) are met.

11. Supersession

(1) A veterinary professional may only examine or treat any patient currently being treated by a colleague in the profession, or give advice regarding the diagnosis or treatment of that patient, if so requested by the client/owner of the animal concerned. In such a case, the veterinary professional must take steps to notify the original attending veterinarian thereof as soon as possible to obtain the particulars of the current treatment of that animal in order to protect the best interest of the patient.

(2) The original attending veterinarian who is informed by the second attending veterinarian that he/she has taken over the treatment of an animal, must provide all relevant information to the second attending veterinarian, provided that the original attending veterinarian’s account is fully paid, unless it is an emergency, in which case the welfare of the patient overrides any other interests.

(3) If the client presents the animal for a second opinion or treatment without informing the attending veterinarian that the patient is under treatment by another veterinary professional or if the client specifically requests the veterinarian not to contact the original attending veterinarian, the second attending veterinarian is not obliged to comply with Rule 11(1), provided that a record is kept of the instructions by the client.

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12. Intrusion

(1) If a veterinary professional has obtained any confidential information regarding the nature and extent of the practice of a colleague in the profession, such veterinary professional may not use such information to promote his/her own practice.

(2) If a veterinary professional renders professional services to an employer, he/she may not use his/her association with or the registered intellectual property of such employer in any manner whatsoever to promote his/her own practice at the expense of those of his/her colleagues in the profession.

Not sure I understand. If a young vet goes and works for a game capture team as is the norm, they learn all the ins and outs how to dart, how to work out of chopper, which trailers to use for which species which drugs to use etc. When they leave the game capture team and start their own practice what now? Nothing in this whole document acknowledges the roll of game capture teams in the training of wildlife vets, they are as important as small animal vet think rule 12 is.

A Lewis

(3) Contravention of Rules 12(1) & 12(2) for own gain is a serious offence which may lead to deregistration.

13. Advertising

(1) A veterinary professional may advertise his/her services, facilities, products and prices or permit another person to do so without limitation on the size, format, artistic or literary style: Provided that the advertisement complies with the provisions of these Rules and may in no way compromise or impair any of the following, namely:-

(a) The client’s freedom to consult a veterinary professional of his/her choice; and

(b) The good reputation of the veterinary profession.

(2) All advertising by a veterinary professional must be in good taste with regard to content, prominence and medium and may not be offensive to any cultural, religious or linguistic community or be contrary to the spirit of the Code of Conduct of the Advertising Standards Authority of South Africa and the Code of Conduct of Practise issued by the Council.

(3) An advertisement of Scheduled medicines must comply with Sections 18, 18A and 18B of the Medicines Act. Scheduled medicine may only be advertised to a person authorised to be in possession of the said schedule’s medicine.

Legaldirector, 2017-02-05,
That is how we all gained our skills, from our colleagues. In turn, as they gain wisdom so shall they pass on their knowledge. This is how a profession grows and matures. That is how we all gained our skills, from our colleagues. In turn, as they gain wisdom so shall they pass on their knowledge. This is how a profession grows and matures. V-Tech
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(4) An advertisement describing a specific veterinary animal care service direct to the public must contain the telephone number of the veterinary professional concerned as well as information regarding emergency and out-of-hours service, if required.

(5) Advertisements may not -

(a) Be misleading in any respect;

(b) Compare the quality of services, products, merchandise and/or foodstuffs provided, the standards of facilities and/or the knowledge or expertise of a veterinary professional with that of another veterinary professional or the veterinary profession generally, nor may it claim to be superior in any respect; or

(c) Criticise the quality of services, products, merchandise and/or foodstuffs provided by another veterinary professional.

(6) No veterinary professional other than a specialist registered as such with the Council may claim or imply that he/she is a specialist or an expert in a particular field in any advertisement.

(7) A veterinary professional may advertise that he/she has a particular interest in a certain species, provided that the advertisement indicates that the veterinary professional is a practitioner with such a particular interest.

(8) Only a registered veterinary specialist may advertise that he/she has a special interest or expertise in a species, discipline, organ or procedure.

14. Identification of veterinary facilities where clinical services are rendered The name of the facility should indicate in which category the facility falls.

(1) A veterinary facility must be identified by means of an identification board, if clinical services are rendered from the facility.

(2) An identification board referred to in Rule 14(1) must contain at least the following –

(a) The type of registered veterinary facility;

(b) The consulting hours;

(c) A telephone number of the veterinary facility;

(d) After hours contact number, if applicable; and

(e) The name(s) of the veterinarian(s) working at that facility, - Not necessary

Suggestion: Just display the name of the principal

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(3) If a veterinary professional moves to a veterinary facility at a new address, a notice to this effect, stating the new address of his/her veterinary facility may be displayed at his/her old address for a maximum period of six months.

(4) If a veterinary professional takes over the practice of a colleague in the profession and opens a veterinary facility at an address other than that of his/her predecessor, a notice to this effect, stating the address of his/her veterinary facility may be displayed at the address where the veterinary facility of his/her predecessor was situated for a maximum period of six months.

(5) A veterinary facility may be identified by means of a direction board, which must comply with the provincial or municipal regulations governing direction boards.

15. Requirements for prescriptions or orders for medicines

Often need to issue a prescription for multiple animals/herds.Register needs to record multiple animals for a volume(ml) or mg’s of medicine.Missed darts/double darts are recorded as medicine used.Newsletter re requirements

Inspectors 31 Jan 2017

(1) Every prescription, or order for a medicine of Schedule 5 and higher, must be written in legible print, typedwritten or computer generated and signed electronically in person by a veterinarian and must at least state the following:

(a) The name, qualification and registration number of the veterinarian;

(b) The name, address, and registration number of the facility involved;

(c) The name and address of the person to whom the medicines are delivered;

(d) The date of issue of the prescription or order;

(e) The approved name or the proprietary name of the medicine;

(f) The dosage form;

(g) The strength of the dosage form and the quantity of the medicine to be supplied: Provided that in the case of Schedule 6 substances the quantity to be supplied must be expressed in figures as well as in words: Provided further that where the prescriber has failed to express the quantity in figures as well as in words, the veterinarian or pharmacist dispensing the medicine may, after obtaining confirmation from the prescriber, insert the words or figures that have been omitted;

Admin, 2017-01-29,
4.5.8Prescriptions:[Dr Erasmus]Often need to issue a prescription for multiple animals/herds. Register needs to record multiple animals for a volume(ml) or mg’s of medicine. Missed darts/double darts are recorded as medicine used.IWS
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(h) In the case of a prescription, instructions for the administration of the dosage, frequency of administration and the withdrawal period in the case of medicines for food producing animals;

(i) The species, age and sex of the patient, if applicable; and

(j) The number of times the prescription may be repeated, with the exception of Schedule 6 compounds which may not be repeated without a re-consultation.

(k) If an electronic signature is used, the document must be protected to prevent the abuse of such a signature

(2) A veterinarian may not issue a prescription to a client on which the name or address of a pharmacist or pharmacy appears, except if using pre-printed prescription forms for ordering medicines scheduled in terms of the Medicines Act from a duly registered wholesaler.

(3) Prescriptions must have a unique number and must be issued in duplicate with the copy attached to the patient record and kept for a period of five years.

(4) Practices with electronic records must attach a scanned copy of the prescription to the patient records and these must be kept for a period of five years.

Don’t get it. I write a script on Ipad, it is saved on Ipad. I get 10 bottles of M99 then I use some for a buffalo bull, must I now copy the script onto each case that ever uses any of the mg out of those ten bottles, and if an animal needs drugs from five different scripts must I now put a copy of each script with this animal? This sounds unrealistic.

A Lewis

16. Printing on professional stationery

(1) A letterhead must contain the following particulars:

(a) Name of the registered facility;

(b) Physical registered address of the facility;

(c) Registration number of the physical facility;

(d) Telephone number; and

(e) The names and registration numbers of the partners or directors of the veterinary facility.

VEHICLES

User, 2016-09-05,
Agree. For general practice scripts stocking the practice, the script needs to be kept as part of the practice record. For scripts written per patient, these need to be appended to the patient record.Act 101/65 does not allow for electronic scripts alone. Not to sure, if the pharmacy allowing for this, is operating legally.
Legaldirector, 05/02/17,
Note: The prescription that a veterinarian issues to the community pharmacy to compound a medicine for them is in actual fact an instruction to compound and supply the medicine to the vet and not the client and can therefore be on the pre-printed pad of the pharmacy-TEch
Legaldirector, 2017-02-05,
Relevant health care legislation should be updated to clarify the use of electronic signatures.V-Tech
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17. Animal Transport Vehicle

An animal transport vehicle must be constructed in such a way as to facilitate comfort, be easily sanitized, as well as minimize injury, stress and escape, suitable to the species being transported and comply with relevant legislation. (AF)

Suggestion: An animal transport vehicle or crate must comply with SANS norms and standards

MINIMUM STANDARDS FOR VETERINARY FACILITIES

18. Compliance with Rules

(1) Clinical veterinary facilities, excluding the following facilities as contemplated in Rules 26, 30, 31, 32, 33, 34 and 35: compulsory veterinary community service and regulatory service facilities, behavioural consultancy, veterinary laboratory, research animal facilities, facilities for herd health practice, facilities for industry and other consultancies and non-practising facility must comply with Rules 18, 19, 20, 21, 22 and 23.

(2) Facilities contemplated in Rules 27, 28 and 29 for small animal hospitals/clinics, hospitals for equines and production animals must, in addition to the requirements of Rules 18, 19, 20, 21, 22 and 23, comply with those requirements or exemptions as listed under that sub-category.

[(3)] A clinical veterinary facility must comply with Rule 24 if any invasive surgery is performed, except in the case of production animals, equines and wildlife, except if the surgery is being performed at a registered facility??????. Consider carefully, if cow brought into small animal facility, it cannot be accommodated in theatre.

(3)[(4)] Where prescribed minimum requirements are not met, an explanation with a motivation and a standard operating procedure (SOP), if required by Council, must be submitted to Council to indicate what procedures are in place to guarantee that the welfare of the patient is still accounted for. Such SOP must be re-submitted every five years, and signed by all veterinarians and relevant staff of that facility.

[(5)] All veterinary facilities must be registered with Council. Should a clinical veterinary facility not meet the minimum standards set out in the Rules, its registration may be suspended for such a period as Council deems fit period required to ensure compliance with the minimum standards.

Legaldirector, 01/02/17,
Accepted at Meds Workshop
Legaldirector, 23/01/17,
Dr Marwick’s suggestion
Legaldirector, 2017-01-23,
Dr Marwick’s suggestion
Legaldirector, 2017-01-23,
Dr Marwick’s suggestion
Legaldirector, 2017-02-01,
Suggestion accepted at Meds Workshop
J V H, 24/09/16,
Alex LewisWith the formalization of the vet capture team relationship the WTA rules for wildlife capture and transport vehicles and helicopters
J Van Heerden, 28/10/16,
But these are outdated---retain original sentence
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19. General structural requirements for clinical veterinary facilities

[(1)] A clinical veterinary facility at or from which a person practises a veterinary profession, (except for non-practising facilities), , must -

(a) Be a permanent structure. (This is not intended to exclude buildings, which are factory produced and site assembled, e.g. a prefabricated building or a container as the word "permanent "relates to the materials used and not the building itself);

(b) Have a source of good general lighting, which is also adequate to ensure the completion of a procedure in progress;

(c) Have adequate ventilation;

(d) Have a dispensary as provided for in Rule 21(4);

(e) Have a fire extinguishing apparatus in accordance with the requirements of the Occupational Health and Safety Act 1993, Act 85 of 1993, which meets the requirements of the relevant local authority;

4.3.2 Fire extinguishers “Rule 19 General structural requirements for clinical veterinary facilities (e) Have a fire extinguishing apparatus in accordance with the requirements of the Occupational Health and Safety Act 1993, Act 85 of 1993, which meets the requirements of the relevant local authority;”

Extinguisher bought from shelf, not mounted & sign posted, hidden. No escape plan. Newsletter insert to educate

Inspectors 31 Jan 2017

Rather list all acts relevant

(f) Be so constructed as to minimise the escape of an animal and to ensure the effective, safe and comfortable confinement of animals at all times; and

(g) Be registered with Council.

(1)[(2)] Subject to any requirements of a local or other authority, a veterinary facility must consist of -

(a) A reception and office area;

(b) A waiting room for clients with access to toilet facilities; and

(c) One or more examination rooms.

Legaldirector, 2017-01-23,
Dr Marwick-Duplication
Admin, 2017-01-29,
Lotter: IWS – all facilities
Legaldirector, 2017-01-23,
Per Dr Marwick
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(2)[(3)] The internal walls and floor surfaces, shelves and tables of a veterinary facility must be of such a nature that they can be properly cleaned and disinfected so as to maintain optimum hygienic conditions.

(3)[(4)] The drainage and washing water of a veterinary facility must run into an adequate sewer and/or septic tank and must comply with the requirements of local authorities.

(4)[(5)] The veterinary facility must have a direct public entrance unless the facility is not intended to provide services to the public but to a specific organisation or other entity.

(5)[(6)] Provision must be made at a veterinary facility for the storage and disposal of carcasses in a hygienic manner, which will ensure that health risks are minimised.

(6)[(7)] Provision must be made at a veterinary facility for a hygienic, insect and rodent free environment within the facility as well as where therapeutic and nutritional products are stored.

(7)[(8)] Adequate facilities must be available for the preparation of food and washing and cleaning of all equipment.

20. General procedural requirements

(1) Personnel must be trained in the basics of aseptic technique, animal handling and welfare and such training must be relevant to the scope of practise.

(2) Personnel responsible for the operation of sophisticated equipment and apparatus must be suitably qualified and adequately trained within their scopes of practise.

Monitoring equipment, X-ray & ultrasound

(3) A veterinary professional must clinically examine animals accepted into a veterinary facility as and when needed, but at least daily, and appropriate records pertaining to monitoring of patients in hospital should be entered into the clinical record. Nature & severity of procedure

(4) The telephone of a veterinary facility of which the number is used in all official communication (shown in the telephone directory, signboards, advertisements and correspondence), must be answered at all times, and the use of an automatic answering service outside the normal consulting hours is permissible for this purpose, provided that it states the normal consulting hours of that practice and refers the client to another telephone number, where the veterinary professional on duty can be reached or to the address and telephone number of an after-hours veterinary facility.

Legaldirector, 2017-01-23,
Per Dr Marwick
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21. General requirements at clinical veterinary facilities

Develop standards for PAHC facilities

No animals to be kept overnight in Cons rooms

(1) A veterinary facility must comply with the following requirements, where applicable -

(a) Radiological services must be rendered at the facility, or be accessible;

(b) Have suitable equipment to determine the weight of patients accurately;

(3)Only minor surgical procedures, excluding intra-abdominal, musculo-skeletal, intra-cranial, cardio-vascular or intra-thoracic surgery may be performed at a consulting room. If such surgery is performed at a consulting room, the provisions of Rules 23 and 24 must be complied with.

[(2)] A veterinary facility must comply with the following requirements where applicable -–

4.3.3 Isolation facility “Rule 21 (2) An animal with a highly infectious disease may not be hospitalised at a veterinary facility, unless facilities for the isolation thereof exist. “ May not realise animal is infectious. Amend to as soon as diagnosed???? Need not be a highly infectious disease, but suspected or diagnosed infectious disease. Amend.“Rule 32 (4) Subject to any requirements of a local or other authority, a research animal facility must consist of: (d) Isolation facility with adequate biosecurity measures, if needed.”Isolation facility: Small animals, as long as clinic is able to isolate animal in a cage in an area available (room or outside, provided adequate shelter is provided), accessible to treat patient.Refer to rule 18(4) SOP

Inspectors 31 Jan 2017

(c) Radiological Diagnostic imaging??? services must be rendered at the facility, or be accessible;

(d) Have suitable equipment to determine the weight of patients accurately;

Legaldirector, 2016-11-04,
JvHHow can this be enforced? Rumenotomies and caesarians for example are routinely conducted on farms, in the veld but now at his clinic he needs,,,
Legaldirector, 2016-11-04,
JvHDifficult for wildlife & equines
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(e) An emergency service can be rendered to stabilise patients; patients may be referred where necessary;

(f) Resuscitative cardiopulmonary medicines as well as intravenous fluids and administration sets must be readily available for emergencies;

(g) Suitable sterilising equipment, or access thereto, for the effective sterilisation of surgical packs and other equipment;

(h) Have adequate storage for sterilised packs and employ acceptable techniques to indicate the effectiveness and expiry of sterilisation;

(i) Routine laboratory equipment within the facility, to be able to make a diagnosis, suitable to the species being treated. Equipment relevant to the scope of practice & relevant level of service provided. including at least a microscope, centrifuge, glucometer and refractometer, or reasonable access to such a laboratory service must be available; Basic equipment

CPD article as to why the equipment is required & does not exclude other equipment needed.

[(j)] In the case of a referral veterinary facility or a veterinary facility where advanced surgical procedures are performed, have an alternate power supply to allow the veterinary facility to function in the event of a power failure and to meet the requirements of local authorities a and make sure refrigeration is maintained;

Refrigerator log book to be maintained (minimum maximum thermometers)??? Capable of being checked.

(j)[(k)] Post mortem examinations must be able to be performed at the facility or reasonable access to such a service must be available, which includes referral of the client to the nearest veterinary pathology laboratory;

(k)[(l)] Have facilities and equipment or access thereto for the hygienic disposal of medical and biological waste to prevent the contamination of the veterinary facility as well as the environment and/or to prevent harm to personnel or the public;

(l)[(m)] A dispensary as set out in Rule 21(4) should be present at the facility to enable dispensing of relevant medicines for patient treatment according to the Medicines Act and the Code of Good Pharmacy Practise; and

(m)[(n)] The veterinary facility must be manned by a person registered to practise a veterinary profession during the consulting hours specified on a notice board, with the proviso that rural practitioners should indicate their office hours and an invitation to make an appointment, whilst not necessarily being in attendance during the indicated office hours.

(2)[(3)] An animal diagnosed with a highly infectious disease may not be hospitalised at a veterinary facility, unless facilities for the isolation thereof exist.

Admin, 2017-01-29,
Lotter IWS
Admin, 2017-01-29,
Lotter IWS
Legaldirector, 2017-01-23,
Per Dr Marwick
Legaldirector, 2017-02-01,
Necessity in small animal practice
Legaldirector, 2017-02-01,
Necessity, for neonates
Admin, 2017-01-31,
(Or access!)only micr & access to all else needed – all categories
Legaldirector, 2017-01-23,
Per Dr Marwick
Legaldirector, 2017-02-01,
Accepted proposal-Meds Workshop
Legaldirector, 2017-02-01,
Must have microscope
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(3)[(4)] Except in the case of equines, production animals or wildlife, only minor surgical procedures, excluding intra-abdominal, musculo-skeletal, intra-cranial, cardio-vascular or intra-thoracic surgery may be performed at a consulting room. If such surgery is performed at a consulting room, the provisions of Rules 23 and 24 must be complied with.

(4)[(5)] The dispensary must comply with the following, which must be read in conjunction with the Medicines Act:

(a) It must be a separate room dedicated to the storage of medicines within the practice;

(b) An application for temporary exemption from Rule 21(4)(a) may be submitted, provided that the application is fully substantiated.

(c) If medicine is stored in a cupboard in the consulting room, the following will apply:

i. All reference to temperature, climate control and practicality in Rules (d ) to (r) below will equally apply to the room in which the cupboard is located;

ii. The cupboard must be locked at all times when a veterinarian is not present;

iii. Only schedule 2 to 4 medicines may be stored in this cupboard. Schedule 5 and higher medicines must be locked in a safe as prescribed by the Medicines Act; and

iv. The amount of medicine stored must be limited to two containers each of a maximum of fifty medicines.

Rule 21 (4) The dispensary must comply with the following, which must be read in conjunction with the Medicines Act: (c) If medicine is stored in a cupboard in the consulting room, the following will apply: (iv) The amount of medicine stored must be limited to two containers each of a maximum of fifty medicines.” To be scrapped - quantities

Inspectors 31 Jan 2017

(d) Light conditions, temperature and humidity within the dispensary or medicine room must comply with the requirements for the storage of medicine, other pharmaceutical products, and packaging materials;

(e) The working surface area in a dispensary must be sufficient to accommodate the volume of prescriptions dispensed;

(f) All medicines must be stored at the prescribed temperature;

(g) A wash hand basin must be accessible, which may be in another room;

Admin, 2017-01-29,
ERASMUS IWS; van Niekerk IWS
Legaldirector, 2017-01-23,
Per Dr Marwick
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(h) No medicines may be stored on the floor;

(i) Schedule 5 and higher scheduled medicines must at all times be under direct supervision of veterinary professionals and locked away in a safe when a veterinarian is not on the premises;

(j) Storage areas must be large enough to allow orderly arrangement of stock and proper stock rotation;

(k) A suitable means of counting tablets and capsules. This equipment must be cleaned regularly so that cross-contamination between products is avoided;

(l) Refrigerator must be accessible (even in another room): must be equipped with a suitable thermometer and capable of storing medicines at temperatures between 2°C and 8°C C and must be monitored daily. The refrigerator must be cleaned, defrosted and checked regularly to ensure efficient running. This refrigerator must be used only for storing pharmaceutical products;

(m) A suitable range of dispensing containers for medicine;

(n) Dispensed medicines must be sold, and correctly labelled in a package containing the following information:

(i) the proprietary name, approved name, or the name of each active ingredient of the medicine, where applicable, or constituent medicine;

(ii) the name of the owner, as well as the name of the patient, if available, for whose treatment such medicine is sold;

(iii) the directions for the use of such medicine;

(iv) the name and business address of the dispensing veterinarian; and

[(vi)] (v) date of dispensing.

Dispensing of medicines (on prescription) by veterinarian to a farmer a reality (especially in the pig industry)!Scheduled 1-4 medicines left on the farm/or delivered to the farm, for use by the farm manager.Valium impregnated maize meal – comment?Have to dispense to game capturers? – Haloperidol, Stresnil to sedate animals.Printing of labels for dispensed drugs in accordance with prescription regulations / requirements including practice number and SAVC registration.

Inspectors 31 Jan 2017

Dispensing of medicines (on prescription) by veterinarian to a farmer a reality (especially in the pig industry)!Scheduled 1-4 medicines left on the farm/or delivered to the farm, for use by the farm manager.Valium impregnated maize meal – comment?Have to dispense to game capturers? – Haloperidol, Stresnil to sedate animals.Printing of labels for dispensed drugs in accordance with prescription regulations / requirements including practice number and SAVC registration.

Admin, 2017-01-29,
“Rule 21 (4) (n) Dispensed medicines must be sold, and correctly labelled in a package containing the following information:(i)the proprietary name, approved name, or the name of each active ingredient of the medicine, where applicable, or constituent medicine;(ii)the name of the owner, as well as the name of the patient, if available, for whose treatment such medicine is sold;(iii)the directions for the use of such medicine;(iv)the name and business address of the dispensing veterinarian; and(v)date of dispensing. “Dispensing of medicines (on prescription) by veterinarian to a farmer a reality (especially in the pig industry)! Scheduled 1-4 medicines left on the farm/or delivered to the farm, for use by the farm manager.Valium impregnated maize meal – comment?.(infused/ intsilled?)Have to dispense to game capturers? – Haloperidol, Stresnil to sedate animals.Printing of labels for dispensed drugs in accordance with prescription regulations / requirements including practice number and SAVC registration
Legaldirector, 2017-01-23,
Per Dr Marwick
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Inspectors 31 Jan 2017

(o) Empty, time expired/or broken containers of medicines must be disposed of as legislated for dangerous substances in legislation controlling these substances;

(p) Records of medicines purchased need to be kept for a period of 5 years;

(q) The receipt of medication for restocking of the dispensary is the responsibility of the veterinarian, and not the lay persons at the practice; and

Rule 21 (4) The dispensary must comply with the following, which must be read in conjunction with the Medicines Act: (q) The receipt of medication for restocking of the dispensary is the responsibility of the veterinarian, and not the lay persons at the practice; and”

Vet notified of delivery – has to set aside a time/day – make him/herself available to receive.Some couriers will leave them with lay persons, other not.Some couriers carry medicines in “non-fragile containers”, eg Thianil, Captivon. Arrange with local pharmacy to receive scheduled meds

Inspectors 31 Jan 2017

(r) Have access to the pharmacological reference sources, and in the case of compounding, access to protocols for the compounding of medication.

22. Diagnostic imaging

(1) Imaging facilities suitable and adequate for the needs of the type of practice or veterinary facility or access thereto must be provided and be readily available within a reasonable time. Operation and maintenance of diagnostic imaging facilities and equipment must comply with the manufacturer’s requirements.

(2) Suitable facilities for the processing, recording and viewing of diagnostic images, including but not limited to radiographs or ultrasound must be available, as well as for the filing and storage of radiographic images.

4.3.4 Location [placement/where situated in the practice] of x-ray room “Rule 22 (3) Structural requirements for facilities where radiation equipment is installed, as well as user safety precautions for the use of this equipment must comply with the relevant legislation.”AE: Request Dept Health certificate to certify equipment. Check for barium plaster, or radiation dosimeters to be submitted to SABS for testing.Council has a responsibility regarding safety critical matters to ensure

Legaldirector, 2017-01-23,
Dr MarwickSuitable facilities for the processing and viewing of diagnostic images, including but not limited to radiographs or ultrasound must be available, as well as for the filing and storage of radiographic images.
Admin, 2017-01-29,
ERASMUS IWS Vet notified of delivery – has to set aside a time/day – make him/herself available to receive. Some couriers will leave them with lay persons, other not.Some couriers carry medicines in “non-fragile containers”, eg Thianil, Captivon. (AP: which schedules?)
Admin, 2017-01-29,
Iws ERASMUS
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compliance. Suggestion: Declare compliance. Does not go far enough.Communicate Dept Health regarding Council’s responsibilities and include a minimum list of requirements to comply with legislation.

Inspectors 31 Jan 2017

(3) Structural requirements for facilities where radiation equipment is installed, as well as user safety precautions for the use of this equipment must comply with the relevant legislation.

(4) When portable x-ray machines are used, specific precautions need to be taken to protect staff, bystanders, other animals and the environment from the detrimental effects of accidental exposure to irradiation.

(5) An imaging logbook must be kept listing the identity of animal and owner, by numerical number or chronologic order, exposure figures and anatomical position. A logbook is not required should the veterinarian have an electronic data system, which is backed up regularly on an alternate system. Any diagnosis made must be recorded in the patient records.

(6) Each radiograph must have a permanent identification legibly exposed in the film emulsion (or printed on the exposure by the computer software programme) and must include the identity of the animal and the owner, practice identity, date, and positioning indication.

(7) The use of self-adhesive labels for the identification of radiographs is not permissible.

(8) In the absence of a special agreement between the radiographer (veterinary professional) and client, a diagnostic image remains the property of the veterinary professional or the veterinary facility where the image was taken.

(9) A copy of the diagnostic image must be released as soon as possible upon the request of another veterinary professional, provided he/she has been instructed by the owner to make such a request and furthermore that the expenses incurred in producing the diagnostic images are settled.

(10) If an original image was handed to the requesting veterinary professional, a receipt of the transfer may be insisted on and such image must be returned to the original veterinary professional as soon as possible.

(11) The client or the owner of an animal is entitled to a copy of the image and a written report.

Legaldirector, 2017-01-23,
Deletion per Dr Marwick
Admin, 2017-01-29,
Lotter IWS
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23. General requirements for anaesthesia, if applicable

[(1)] All animals must undergo a pre-anaesthetic clinical examination, if at all possible. with the exception of wildlife and feral cats. If it is not possible to perform a clinical examination, observation animals should pre-anaesthetic clinical examination, the wildlife or feral cat should preferably be observed prior to anaesthesia, if possible.

[(2)] Where possible. Aadequate facilities must be provided for the safe induction and recovery from anaesthesia., if possible.

[(3)] All persons administering anaesthetic agents & inducing anaesthesia must be qualified or authorised by Council to do so and be competent in the efficient use of all anaesthetic facilities and equipment, provided that a veterinary para-veterinary professional, within his/her scope of practice may administer anaesthesia on the instructions of a veterinarian, with the exception of wildlife, which only a veterinarian personally may anaesthetise in accordance with Rule 10. If there is a vet capture team relationship delegated members can under direct supervision of the responsible vet administer anaesthesia

Poor wildlife vet. He must do all this high and mighty stuff alone but other vets get help. This is crazy and unfair, must change.

A Lewis

[(4)] The monitoring, maintenance and recovery from anaesthesia must be effected under the direct supervision of a veterinary professional or para-veterinary professional, within his/her scope of practice, who must be on the premises. Exclude large animals(Prod animals, & equines & wildlife)

[(5)] The same person may not do surgery, monitoring and maintenance of general anaesthesia, unless circumstances dictate otherwise and unless monitoring equipment is available. Exclude large animals (Prod animals, & equines & wildlife)

(1)[(6)] Equipment for anaesthesia, either inhalation or parenteral, and facilities adequate and appropriate for the needs of the relevant practice and veterinary facility must be provided at all times.

(2)[(7)] An appropriate range of clean, functional endotracheal tubes must be available. Not applicable to wildlife, horses & prod animals

(3)[(8)] Medical oxygen must be available at all times for inhalation anaesthesia maintenance as well as to meet any other emergency situation. Not applicable to wildlife, horses & prod animals

Admin, 2017-01-29,
Lotter IWs
Legaldirector, 2017-01-23,
Dr Marwick
Legaldirector, 2017-01-23,
Dr Marwick
Legaldirector, 2017-02-01,
Should not be deleted, must corroborate rule 10(2)
CLIVE MARWICK, 2016-09-25,
Will this not be sufficient for this section
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4.3.5 Oxygen

“Rule 23 (8) Medical oxygen must be available at all times for inhalation anaesthesia maintenance as well as to meet any other emergency situation.” Deletion to be debated- get wording from Minette

Is oxygen an absolute essential? Can resuscitate with Ambubag. Oxygen generator??

Why not ordinary oxygen, not medical oxygen?

Medical oxygen not readily available in rural areas.

DS: Get safety legislation re oxygen.

Inspectors 31 Jan 2017

(4)[(9)] Storage for all explosives, such as gas or oxygen, must be provided for in accordance with the relevant legislation.

[(10)] A means to provide artificial ventilation (not a ventilator) ????must be preferably available in the event of an emergency. Not applicable to wildlife, horses & prod animals

(5)[(11)] Lock-up facilities must be available for scheduled medicines in accordance with the relevant laws.

(6)[(12)] Where applicable, equipment for the control of body temperature must be provided.

(7)[(13)] Anaesthetic equipment must be adaptable for the variation in body weight and the species range in which it is intended for use.

(8)[(14)] Active or passive anaesthetic gas scavenging equipment must be in use according to relevant legislation.

(9)[(15)] All anaesthetic equipment must be properly maintained and serviced at regular intervals.

(10)[(16)] All animals must be monitored after surgery and may only be discharged once adequately recovered from anaesthesia, i.e. all animals must be fully conscious and ambulatory, unless otherwise discussed and agreed to with the client.

24. Requirements for invasive surgical procedures.

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4.3.6 Location [positioning/ situation/ placement] of theatre and door / thoroughfare“The theatre must be of an adequate size and situated so that there is no thoroughfare;”May not be relevant to large animals & wildlife.Nature of the game.Amend to no thoroughfare during operating procedures. Accepted.Define thoroughfare: No clients & non-essential staff????

Inspectors 31 Jan 2017

(1) The facility must comply with the following:-

(a) One or more rooms for the treatment and pre-operative preparation of patients, which must be conveniently close to the operating room;

(b) A separate room which is equipped as an operating room and has:

(i) Adequate general lighting, as well as an adequate light source for procedures;

(ii) A surgical table with an impervious operating surface that can be easily cleansed and disinfected;

(iii) An adequate supply of oxygen;

(iv) A gas anaesthetic apparatus or a means of effectively administering oxygen through an endotracheal tube, ambu-bag or mask;

(v) A means of viewing radiographs; and

(vi) Adequate ventilation.

(2) The operating room must be of adequate size and there must be an adequate supply of sterile equipment, drapes and instruments at all times.

(3) There may be no thoroughfare through an operating room during a surgical procedure being performed.

(4) The operating room may not be used as a storage room.

(5) Patients should be prepared in a separate room convenient to the theatre (operating room) but not in the same place as where surgery takes place.

(6) Only final preparation of the patient may be done in the operating room.

(7) Aseptic conditions must be maintained in the operating room.

(8) There must be appropriate autoclave equipment or other suitable sterilising equipment or techniques, or access thereto, for the effective sterilisation of surgical packs and other equipment and have adequate storage for sterilised packs and employ acceptable techniques to indicate the effectiveness and expiry of sterilisation.

Legaldirector, 2017-02-01,
Accepted-Meds workshop
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(9) Suitable scrubbing up facilities must be available.

25. Mobile animal services for private practitioners practicing from a registered physical veterinary facility, including and mobile Compulsory Veterinary Community Services facilities

Services rendered from a service vehicle, mostly in the field. Mobile unit must be registered (directly linked) in the same name as the base facility.

Inspectors 31 Jan 2017

[(1)] These facilities and services must:

(a) Be registered in the name of the principal of the physical veterinary facility registered with the Council and operate under the same name as the registered physical facility, except if the mobile animal services are rendered for the purposes of Compulsory Veterinary Community Services, in which case the facility must be registered in the name of the Director or Deputy Director, who is a veterinarian in public service in the relevant Province;

(b) Function as an integral part of the registered physical facility to visit clients, except if the mobile animal services are rendered for the purposes of Compulsory Veterinary Community Services;

(c) Be operated by personnel registered with the Council;

(d) Have access to the clinical records kept in terms of the Act and the Medicines Act at the registered physical address; and

(e) Comply with the requirements of adequate record keeping and back-up.

(1)[(2)] A service delivery vehicle must comply with the following structural and procedural requirements where applicable, the vehicle:

(a) Must be suitable for use on roads and terrain as indicated;

(b) Have an acceptable standard of construction and appearance and be maintained in a clean and sanitary condition;

(c) Be constructed of materials that are impervious and that can be cleaned and disinfected;

(d) Carry a supply of water;

(e) Maintain secure storage of scheduled medicines in accordance with relevant legislation;

Admin, 01/31/17,
Must have same name= registered in name of same principal
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(f) Have a fridge or cold box with a minimum/maximum thermometer that can keep all pharmaceuticals at the correct temperatures as indicated;

(g) Have a source of light as applicable;

(h) Have a cold storage system that can maintain 5°C for the transport and storing of all biological products;

(i) Have equipment for the disposal or collection of all waste including carcasses, if required;

(j) Have adequate equipment to ensure basic bio-security and to clean and disinfect overboots between farms;

(k) Carry an appropriate range of medicines, equipment and protective clothing, according to the type of service and species serviced, in a manner that is consistent with professional standards, while ensuring occupational safety;

(l) Have access to a means of communication to contact the base facility; and

(m) Have adequate equipment for:

(i) Humane physical and chemical restraint as applicable to the species involved;

(ii) Adequate diagnostic equipment including sample collection equipment;

(iii) Adequate equipment for administration of medicine;

(iv) Post mortem equipment;

(v) Equipment necessary for obtaining and transporting of biological specimens for diagnostic or other purposes;

(vi) Surgical equipment, including at least one sterilised surgical pack and means of between-farm disinfection of equipment; and

(vii) Equipment to deal with emergencies, including a relevant obstetric kit, and means of humane euthanasia.

(2)[(3)] Mobile operating rooms must additionally comply with the following structural and procedural requirements where applicable:

(a) Be constructed from strong resilient materials that can resist rough roads and severe weather conditions and must be able to be secured against theft;

(b) The access/entrance to the theatre must be of such a nature that neither personnel nor animals are endangered;

Admin, 2017-01-29,
b.Sharps containersRule 25 (3)(i); 26 (2) (l) (v); 31 (1) (l); 31 (12) (i).
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(c) The internal walls and floor surfaces, shelves and tables should be constructed of impervious materials that can be properly cleansed and disinfected so that hygienic conditions can be maintained;

(d) Have appropriate/adequate ventilation;

(e) Have an adequate light source;

(f) Carry a supply of water adequate for the operational needs of the facility if access to clean water is not available;

(g) Maintain secure storage of scheduled medicines in accordance with relevant legislation and manufacturer requirements;

(h) Have facilities to store medicines at recommended temperatures;

(i) Have facilities and equipment, or access thereto, for the hygienic disposal of soiled dressings, sharps, animal tissue and any other contaminated or unwholesome matter or objects to prevent the contamination of the facility or environment according to relevant legislation;

(j) Carry an appropriate range of medicines, instruments and theatre clothing;

(k) Carry an adequate supply of medical oxygen, endotracheal tubes or ambubag to manage an emergency;

(l) Have suitable scrubbing facilities or access to such facilities;

(m) The theatre must be of an adequate size and situated so that there is no thoroughfare during a surgical procedure being performed;

(n) Have appropriate equipment, or access thereto, for the effective sterilization of surgical instruments;

(o) Have adequate storage for sterilized packs and employ acceptable techniques to indicate the effectiveness and expiry of sterilization;

(p) Must be operated by personnel registered with the South African Veterinary Council;

(q) Aseptic conditions must be maintained in the theatre;

(r) Comply with the requirements of Rules 23 & 24 if surgical procedures requiring general anaesthesia are performed; and

(s) Arrangements must be in place for appropriate post-operative care and monitoring, should an emergency or complications arise post- operatively.

Admin, 2017-01-29,
Lotter IWS
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26. Compulsory Veterinary Community Service Facilities & Regulatory Service FacilitiesTo be aligned to other veterinary facilities by DAFF. Golden standards in relation to private facilities.Suggestion: same standard as private facilities

(1) A veterinary facility where a regulatory service is being rendered must:

(a) Be registered with Council in this category;

(b) Consist of, but not limited to, a fully furnished office which must be maintained at an acceptable standard and appearance that is consistent with the professional image and appeal;

(c) Have general office equipment (or access to) such as a computer, fax, telephone, photocopier, effective internet connection and emails;

(d) Have a dispensary in accordance with Rule 21(4), if medicines are dispensed;

(e) Have a fridge or a similar equipment with a minimum/maximum thermometer for storage of thermo-sensitive pharmaceuticals and other biological products at recommended temperature(s) where such products are used;

(f) Have a microscope immediately available, relevant chemicals/ stains, and any other equipment necessary to scientifically, reliably and professionally execute duties associated with the type of veterinary service being rendered at the facility;

(g) Have an appropriate range of medicines, instruments and protective clothing available, where applicable;

(h) Have appropriate equipment for the recording, reporting, auditing and filing of various diseases, cases, events, and clients, according to Rule 6, OIE guidelines and other relevant legislation;

(i) Have access to the relevant scientific and/or legislative information resources necessary for effective retrieval of the information needed to enable the making of sound decisions based on scientific knowledge;

(j) Have additional equipment/ resources that are necessary for the type of veterinary services rendered;

(k) Have a post mortem area (or access to one) that is well equipped to perform a post mortem appropriately and to facilitate a reliable diagnosis, where applicable;

(l) Have facilities and equipment or access thereto for the hygienic disposal of animal tissue and any other contaminated or unwholesome matter or objects to prevent the contamination of the veterinary facility as well as the environment;

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(m) Adequate facilities must be available for the washing and cleaning of all equipment;

(n) Where applicable, have equipment (or access to) that is necessary for obtaining and transporting of biological samples/ specimens for diagnostic or other purposes;

(o) Have access to a reliable courier service that can deliver specimens (including transport of full carcasses) and other materials to the appropriate laboratories or destinations; and

(p) Have access to a reliable vehicle that is equipped for the veterinary professional to perform relevant types of services.

(2) For Compulsory Veterinary Community Service, the base facility must comply with the following requirements – as applicable to relevant scope of practice:

(a) Be registered with Council in this category;

(b) Have an external and internal neat appearance;

(c) Have an office where clients and representatives can be received and interviewed, with access to toilet facilities;

(d) Have a dispensary in accordance with Rule 21(4) if applicable, with safe storage for all scheduled medicines;

(e) Have refrigeration facilities for cold storage of biologicals, medicines and biological samples as needed;

(f) Have facilities for the safe storage of biological samples if applicable;

(g) Have a vehicle which is capable of reaching clients in remote areas;

(h) Have the necessary equipment for basic diagnostic procedures, including microscope, refractometer, glucometer and centrifuge;

(i) Have appropriate equipment for the recording, reporting, auditing and filing of various diseases, cases, events, and clients, according to Rule 6, OIE guidelines and other relevant legislation;

(j) Have access to relevant scientific and/ or legislative information resources necessary for effective retrieval of information needed to facilitate the making of sound decisions based on scientific knowledge;

(k) Have a post mortem area (or access to one) that is well equipped to perform a post mortem appropriately and to facilitate a reliable diagnosis, where applicable;

(l) If post mortems are done at the facility the following must be in place:

Admin, 01/29/17,
Erasmus insp ws; or KEEP it? State won’t send to lab?
Legaldirector, 02/05/17,
All medicines are Scheduled, do you mean S1 and higher?V-Tech
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(i) All surfaces, shelves and tables must be of such a nature that they can be properly cleansed and disinfected;

(ii) The drainage and washing water must run into an adequate sewer and/or septic tank and must comply with the requirements of local authorities;

(iii) The veterinary facility must have a direct public entrance;

(iv) Provision must be made at a veterinary facility for the storage and disposal of carcasses in a manner, which will ensure that decomposition will not cause a health risk before being disposed of, and that odours are contained;

(v) Have facilities and equipment or access thereto for the hygienic disposal of animal tissue, sharps and any other contaminated or unwholesome matter or objects, to prevent the contamination of the veterinary facility, harm to personnel as well as the environment; and

(vi) Adequate facilities must be available for the washing and cleaning of all equipment.

(m) All personnel must be trained in aseptic techniques; and

(n) All personnel must be trained in the safe handling of animals, animal welfare and the danger of zoonotic diseases.

(3) A service delivery vehicle must comply with the following structural and procedural requirements where applicable, the vehicle:

(a) Must be suitable for use on roads and terrain as indicated;

(b) Have an acceptable standard of construction and appearance and be maintained in a clean and sanitary condition;

(c) Be constructed of materials that are impervious and that can be cleaned and disinfected;

(d) Carry a supply of water;

(e) Maintain secure storage of scheduled medicines in accordance with relevant legislation if applicable;

(f) Have a fridge or cold box with a minimum/maximum thermometer that can keep all pharmaceuticals that are indicated to be stored at the correct temperature if applicable;

(g) Have a source of light if applicable;

(h) Have a cold storage system that can maintain 5°C for the transport and storing of all biological products if applicable;

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(i) Have equipment for the collection and disposal of all waste including carcasses, if required;

(j) Have adequate equipment to ensure basic biosecurity, including equipment to clean and disinfect overboots between farms;

(k) Carry an appropriate range of medicines, equipment and protective clothing, according to the type of service and species serviced, in a manner that is consistent with professional standards, while ensuring occupational safety;

(l) Must carry at least the following:

(i) Equipment for humane physical and chemical restraint if applicable;

(ii) Adequate diagnostic equipment including sample collection equipment and a means of estimating body weight, if applicable;

(iii) Adequate equipment for medicine administration if applicable;

(iv) Post mortem equipment;

(v) Equipment necessary for obtaining and transporting of biological specimens for diagnostic or other purposes;

(vi) Surgical equipment, including at least one sterilised surgical pack and means of between-farm disinfection of equipment if applicable; and

(vii) Equipment to deal with emergencies, including a relevant obstetric kit, and means of humane euthanasia if applicable.

MINIMUM REQUIREMENTS FOR HOSPITALS/CLINICS

27. Structural and procedural requirements for small animal hospitals

(1) A small animal hospital must comply with Rules 18, 19, 20, 21, 22, 23 and 24.

(2) A ward in which patients are kept must -

(a) Have a separate cage of adequate size for each patient;

(b) Be of such a material so as to prevent self-injury of the patient;

(c) Have proper means to identify each patient; and

(d) Be adequately ventilated and, if necessary, heated or cooled.

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(3) Animals hospitalised overnight must be adequately monitored having due regard to the animal’s condition. If such monitoring is not available, the client should be informed accordingly. Vet to be contactable.

4.3.7 Overnight monitoring of hospitalised patientsAn extract from the Code of Conduct and Practice for veterinarians is annexed as Annexure 1 for ease of reference.

4.6.6 CoC- Acceptable Rule 23- Update CoC with rule.

Inspectors 31 Jan 2017

(4) An area in which patients can be exercised indoors or outdoors must be designed and constructed in a manner that will minimise escape and facilitate the maintenance of hygiene.

Equine hospital

28. Structural and procedural requirements for hospitals for equines

(1) An animal hospital for equines must, in addition to the requirements of Rules 18, 19, 20, 21 22, and 23 and consist of -

(a) One or more examination rooms or undercover areas equipped with hand washing facilities and diagnostic equipment for the physical, endoscopic, ophthalmic and cardiac examination of the patient;

(b) A transportation system to be used in the transportation of equines to and from the area used during induction of general anaesthesia and surgery; and

(c) A separate room that is equipped as an operating room and has the following:

(i) An adequate light source;

(ii) A surgical table with an impervious operating surface that can be easily cleansed and disinfected;

(iii) A gas anaesthetic apparatus;

(iv) An adequate supply of medical oxygen;

(v) A means of viewing radiographs; and

(vi) Adequate ventilation.

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(2) Adequate facilities must be provided for the safe induction and recovery from anaesthesia. In the case of equines, the area to be used during the administration of general anaesthesia and for the recovery from such must be padded with a material that is impervious and can be easily cleansed and disinfected, and which covers the whole floor area as well as the wall to a height of at least two metres.

(3) Aseptic conditions must be maintained in the operating room.

(4) Have appropriate autoclave equipment or other suitable sterilising equipment, or access thereto, for the effective sterilisation of surgical packs and other equipment and have adequate storage for sterilised packs and employ acceptable techniques to indicate the effectiveness and expiry of sterilisation.

(5) Suitable scrubbing-up facilities must be available.

(6) Only final preparation of the patient must be done in the operating room.

(7) There may be no thoroughfare through an operating room while it is in use and it may not be used as a storage room.

(8) The operating room must be of adequate size and there must be an adequate supply of equipment, drapes and instruments at all times.

(9) An area for the safe loading and off-loading of patients, as well as a crush pen with a waterproof and washable floor surface, must also be provided at the examination area.

(10) The stable in which patients are housed must be adequately ventilated and arranged in such a manner that each patient is kept separately.

(11) Construction and procedures must be aimed at minimising the spread of contagious diseases.

(12) An area in which patients can be exercised, and is designed and constructed in such a manner as to minimise escape and injury and promote the maintenance of hygiene.

(13) Any material, which poses a fire hazard for the patients at an equine hospital, must be stored away from stables, and if it is kept in an adjoining room, such a room must be separated from the stables concerned by means of a fire partition wall.

(14) Animals must be monitored after hours by suitably trained personnel or the owner must be advised that the animal will not be monitored overnight.

Production animal hospital and/or clinical facilities

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29. Structural and procedural requirements for hospitals for production animals

(1) An animal hospital for production animals must, in addition to the requirements of Rules 18, 19, 20, 21, 22 and 23 consist of –

(a) One or more examination rooms or undercover areas with hand washing facilities and adequately equipped to perform diagnostic and standing surgical procedures;

(b) If orthopaedic and/or sophisticated surgery is performed, a separate room which is equipped as an operating room and has the following -

(i) Adequate general lighting, as well as an adequate light source for procedures;

(ii) A surgical table with an impervious operating surface that can be easily cleaned and disinfected;

(iii) A relevant gas anaesthetic apparatus;

(iv) An adequate supply of medical oxygen;

(v) A means of viewing radiographs; and

(vi) Adequate ventilation.

(c) Adequate facilities for safe induction and recovery from anaesthesia.

(2) Aseptic conditions must be maintained in the operating room.

(3) Have appropriate autoclave equipment or other suitable sterilising equipment, or access thereto, for the effective sterilisation of surgical packs and other equipment and have adequate storage for sterilised packs and employ acceptable techniques to indicate the effectiveness and expiry of sterilisation.

(4) Suitable scrubbing up facilities must be available.

(5) A loading ramp for the safe loading and off-loading of patients, as well as a crush pen with a non-slip and washable floor surface must be available at such animal hospitals for production animals.

[(6)] The penstalls in which patients can be kept either singly or in groups, must be constructed in such a manner that they are kept comfortably, with sufficient space, food, water and ventilation, minimise escape and injury, promote maintenance of hygiene.

(6)[(7)] Construction and standard operating procedures must be aimed at minimising the spread of contagious diseases.

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(7)[(8)] An area in which patients can be exercised, and is designed and constructed in a manner which will minimise escape and injury and promote the maintenance of hygiene. Exercise camp or area???

(8)[(9)] Any material which poses a fire hazard for the patients at a production animal hospital must be stored away from any stalls, and if it is kept in an adjoining room, such a room must be separated from the concerned patients by means of a fire partition wall.

(9)[(10)] Animals must be monitored after hours by suitably trained personnel or the owner must be advised beforehand that the animal will not be monitored overnight.

3.During the handling and use of any immobilising agent the following safety measures must be in place to prevent accidental exposure:

(a) Suitable first-aid kit with resuscitation equipment and appropriate quantities of suitable antidotes, readily available;

The clause should be applicable with respect to production animals & wildlife as well.

Dr R Burroughs

Suggestion

The SAVC should approve/accredit a first aid course for veterinarians ANDVETERINARY PARA-PROFESSIONALS using above-mentioned highly scheduledmedicines

The course should be compulsory for veterinarians working with these medicines or at least be a strong suggestion.

Dr C Marwick

30. Veterinary Behavioural Consultancy“Consultancy needs not be inspected, UNLESS the consultant dispenses medicines. In this instance the facility needs to be physically inspected. The signed self-evaluation, photos of safe, cupboard and fridge and CPD requirements would still apply to those Consultancies that don’t dispense.”

Dr A Erasmus

Rules to be adapted to provide that a vet nurse can have a behavioural consultancy

Legaldirector, 2017-01-23,
What do we understand under suitably trained personnelOr only sporadically monitored
Legaldirector, 2017-01-23,
Dr MarwickMove to general requirements
Legaldirector, 2017-01-23,
Dr MarwickMore applicable to small animals & equines
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Sr Emmy-Lou Rivers

(1) The veterinary behaviourist can consult clients in one of the following ways:

(a) At his/her own behavioural facility (Category A);

(b) At a registered veterinary facility in agreement with the veterinarian in charge of the said facility (Category B); and

(c) At the client’s home (house call) (Category C).

(2) On application for the registration of a veterinary behavioural facility the veterinarian must indicate in which of the ways referred to in 30(1) consultations will be performed: (a) and/or (b) and/or (c).

(3) The veterinarian in charge of the behavioural facility must be competent in animal behavioural medicine and must be registered with the South African Veterinary Council

(4) An animal behavioural facility that is registered with the South African Veterinary Council as such a facility, may only render animal behavioural services.

(5) The animal behavioural facility may be part of a veterinary facility which is registered with South African Veterinary Council and complies with the minimum standards to be registered as a hospital, clinic or consulting room. In this case the veterinary behaviourist may perform veterinary procedures which fall under that registration.

(6) Category A: An animal behavioural facility at or from which a veterinarian practices a veterinary profession must:

(a) Be a permanent structure. (This is not intended to exclude buildings, which are factory produced and site assembled, e.g. a prefabricated building as the word "permanent "relates to the materials used and not the building itself);

(b) Have a good source of general lighting.

(c) Have adequate ventilation;

(d) Have a fire extinguishing apparatus, which meets the requirements of local authorities;

(e) Be so constructed as to minimize the escape of an animal and to ensure the effective and safe confinement of animals at all times; and

(f) Have equipment to determine the weight of patients adequately.

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(7) Subject to any requirements of a local or other authority, an animal behavioural facility must consist of:

(a) A reception and office area

(b) Waiting room for clients with access to toilet facilities

(c) One or more consulting rooms

(8) The internal walls and floor surfaces, shelves and tables of an animal behavioral facility must be of such a nature that they can be properly cleansed and disinfected so that hygienic conditions can be maintained.

(9) The drainage and washing water of an animal behavioral facility must run into an adequate sewer and comply with the requirements of local authorities.

(10) The animal behavioral facility must have a direct public entrance.

(11) Provision must be made at a behavioural facility for a hygienic, insect and rodent free environment within the facility as well as where therapeutic and nutritional products are stored.

(12) Adequate facilities must be available for the preparation of food and washing and cleaning of all equipment.

(13) A signboard below the identification board of the veterinary facility indicating that only animal behavioural veterinary services are being rendered from the premises and the extent of these services.

(14) The telephone at a number or alternative number that is indicated in an official telephone directory in respect of a veterinary facility is answered at all times, and the use of an automatic answering service outside the normal consulting hours is permissible for this purpose as long as it states the normal consulting hours of that practice and refers the client to either a telephone number, cell phone number of the veterinary professional on duty or to the address and telephone number of an after-hours veterinary facility.

(15) Have access to the relevant scientific information resources necessary for effective retrieval of the information needed to enable the making of sound decisions based on scientific knowledge;

(16) An animal behavioural facility must have the necessary facilities and or equipment in order to ensure that a complete basic physical examination can be performed.

(17) A dispensary service for its own requirements can be rendered at the facility, and must be maintained as well as administered in accordance with Rule 21(4).

(18) To aid in the diagnosis of an animal behavioural problem or to exclude medical causes for animal behavioural problems it may be necessary to obtain blood or urine samples for laboratory analysis. The animal behavioural facility must, either:

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(a) Have basic equipment to allow sample collection, proper storage facility for the sample and have access to a laboratory for sample analysis; or

(b) Refer the owner to his/her usual veterinarian for sample collection and analysis.

(19) In some instances, euthanasia of an animal may be indicated for behavioural reasons. Should the facility offer euthanasia, the facility must:

(a) Have lock-up facilities available for scheduled medicines in accordance with the relevant laws; and

(b) Keep proper records of the medicines used.

(20) Provision must be made at a veterinary facility for the storage and/or disposal of carcasses in a manner, which will ensure that decomposition will not cause a health risk before being disposed, and that odours are contained.

(21) Should the animal behavioural facility not offer euthanasia, the client will be referred to his/her usual veterinarian for the procedure.

(22) Animals will not be admitted to the animal behavioural facility. Should overnight observation of the animal be needed the owner will be referred to his/her usual veterinarian for hospitalisation.

(23) Records must be maintained as per Rule 6.

(24) Diagnostic imaging will not be done at the animal behavioural facility.

(25) In a case where diagnostic imaging is needed to aid in the diagnosis for a behavioural case, the client will be referred to his/her usual veterinarian for the procedure.

(26) No surgical procedures may be performed at an animal behavioural facility.

(27) In the case where an animal requires a surgical procedure to aid in the treatment of an animal behavioural case, the owner of the animal will be referred to his/her usual veterinarian for the procedure.

(28) Category B: If a registered clinical veterinary facility is used for behavioural consultations, it is subject to the following:

(a) The veterinary behaviourist may make use of a registered veterinary facility as long as that facility can provide:

(i) A consultation room that enables a lengthy consultation, with comfortable seating for the client and the behaviorist;

(ii) A consultation room free from excessive noise or interruptions that could disturb the behavioural consultation;

(iii) A consultation room where the veterinary behaviourist can execute the consultation in a confidential manner;

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(b) The veterinary behaviourist must comply with Rules 30(14) and (15): General procedural requirements and Rule 30(23): refer Rule 6 Records at veterinary facilities.

(29) 30(29) Category C: If a behavioural house call is made, it is subject to the following:

a) The veterinary behaviourist must comply with Rules 30(14) and (15): General procedural requirements and Rule 30(23): refer Rule 6 Records at veterinary facilities

b) An office is required where:

(i) The office must form part of a permanent structure, be hygienic with surfaces that can be kept clean;

(ii) Records can be kept;

(iii) Clients can be consulted should clients wish to see the veterinary behaviorist (without the patient);

(iv) Medicines prescribed for behavioural medicine must be stored in accordance with Rule 21(4);

(v) Equipment and products used in behavioural medicine can be kept

(c) The vehicle used for house and or farm consultations must be maintained in a clean and sanitary condition.

(d) The vehicle must contain those items of equipment that are necessary for the veterinary professional to perform physical examinations and treatment consistent with the standards of the profession to perform an animal behavioural consultation.

31. Veterinary Laboratory

SpecimensThe system of identifying specimens, through processing and reporting must be

included in the check list. Peet Delport: Basic principle to identify specimens from receipt to when they go out.

Put in inspection checklist

4.4.2 LaboratoriesDAFF approval, identification of samples from receiving to testing, reporting to

disposal.Any diagnostic testing for controlled & notifiable diseases must be SANAS ISO17025?

Accredited & DAFF accredited, can ask for extension, DAFF approval to fall away. Must supply SANAS _____ & DAFF approval. Make sure added to checklist.

Inspectors 31 Jan 2017

Admin, 2017-01-29,
IWS4.4.1SpecimensThe system of identifying specimens, through processing and reporting must be included in the check list.4.4.2LaboratoriesDAFF approval, identification of samples from receiving to testing, reporting to disposal.
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(1) A veterinary laboratory at or from which a registered person renders a laboratory service must:-

(a) Be a permanent structure and any mobile unit operated from the facility shall be linked to permanent facility (see section on mobile units);

(b) Have an external and internal neat appearance;

(c) Have signage that complies with regulations of the local authority and where applicable also meets any regulation and / or Rules set by the Council;

(d) Have separate areas for receiving members of the public and samples;

(e) Have access to toilet facilities for members of the public;

(f) As far as possible separate laboratory areas to prevent cross contamination of samples;

(g) Have, where applicable, appropriate facilities for the storage of samples in order to prevent degradation of samples before testing;

(h) Have facilities meeting the applicable regulations for the safe storage of chemicals and pharmaceuticals;

(i) Have facilities for the safe storage of scheduled medicines, if applicable;

(j) Have applicable equipment available to carry out the required tasks;

(k) Have adequate facilities available for the washing, cleaning and sterilisation of all equipment;

(l) Have proper facilities and containers for the storage of disposed hazardous waste including but not limited to sharps, chemicals, used test kits, biological samples, etc. prior to collection by a licensed waste removal company as per regulations of the local authority;

(m) The internal walls, floors and work surfaces shall be of such a nature that they can be properly cleansed and disinfected in order to maintain hygienic conditions and prevent contamination of samples;

(n) The drainage and washing water of a veterinary laboratory shall run into an adequate sewer and comply with the requirements of local authorities;

(o) Where applicable make provision for the storage and disposal of carcasses in a manner that will ensure that they will not start to decompose before they are disposed of;

(p) Where an on-site incinerator exists for the disposal of carcasses the incinerator shall be licensed according to the relevant environmental regulations;

(q) Where applicable have animal housing that complies with relevant legislation;

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(r) Where applicable ensure that personnel are trained in the safe and humane handling of animals;

(s) Employ personnel who are in possession of the applicable prescribed qualifications and are registered at the Council to perform the testing;

(t) Provide personnel with protective clothing and protective equipment applicable to the level of risk involved; and

(u) Have fire extinguishing apparatus which meets the requirements of the local authorities and is suited for the types of fire hazard based on the activities at the laboratory.

(2) Mobile laboratory units must:-

Trying to get wildlife vets to do buffalo testing for the state, so doing gamma test preparation is needed as must be at lab in 8 hours so how must a vet link his gamma prep lab that is simple mobile unit to which main lab? We already do the training at OVI.

A Lewis

(a) Be linked to a permanent facility and cannot be registered as an individual facility, unless in case of wildlife conducting next to animal screening tests or prep testing

(a) Be linked to a permanent facility and cannot be registered as an individual facility;

(b) Be identified as a part of the permanent facility by listing the vehicle registration number at the time of applying for facility registration;

(c) Comply with all applicable traffic regulations;

(d) Be operated while in transit by a person with a driver's permit applicable to the type of vehicle;

(e) Have a fire extinguishing apparatus which meets the requirements of the local authorities and is suited for the types of fire hazard based on the content of the mobile unit;

(f) Have facilities for the safe transport and storage of chemicals and reagents that adhere to the regulations applicable to the transport of the chemicals and / or reagents;

(g) Meet all the relevant regulations for transport of chemicals if applicable;

J V H, 24/09/16,
Alex Lewis
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(h) Have proper facilities for the storage of the sample types to be tested;

(i) Have containers that meet the relevant regulations for disposal of hazardous waste including but not limited to sharps, chemicals, used test kits, biological samples, etc. until it can be discarded at or from the permanent facility; and

(j) Have applicable equipment available to carry out the required tasks.

(3) The laboratory must comply with the following procedural aspects:-

(a) The Laboratory must have a documented manual for Good Laboratory Practices (GLPs) stipulating the GLPs relevant to that Laboratory;

(b) The Laboratory must have documented standard operating procedures for all tests performed at the facility;

(c) Where international or national standardised methods exist these must be used, unless reasonable ground for deviation exist;

(d) The Laboratory must have a documented maintenance schedule for all equipment used in testing of samples and evidence that maintenance is done;

(e) The Laboratory must have a documented calibration schedule for all applicable equipment used in testing of samples and evidence that calibration is done; and

(f) The Laboratory must have a documented procedure for the retention of records including laboratory results that indicate how records will be secured, protected from loss and alterations, protected from unauthorised use and what the retention period will be.

(4) In addition to the minimum standards listed the following also apply as far as testing of patient samples and/or other samples are concerned:-

(a) Any analysis performed to certify or confirm diagnosis of a controlled animal disease must be accredited by SANAS according to the latest version of the ISO 17025 standard and upon accreditation of the analysis the laboratory facility must be approved by the Department of Agriculture, Forestry and Fisheries to perform the analysis; and

(b) Any in-house analyser used for testing patient samples must:-

(i) Be maintained and service according to a documented schedule and evidence that this is done must be kept; and

(ii) Be calibrated at a set and documented interval to ensure that the analyser can still detect all analytes accurately and evidence of the calibration shall be kept.

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32. Research Animal Facilities:

(1) Application for facility registration must include a detailed description of the work that will be conducted and where indicated other Rules which may be applicable for certain procedures (for instance mobile facility for off-site work) or motivation for exemption from the minimum requirements referred to in Rule 31.

(2) Where prescribed minimum requirements are not met, an explanation with a motivation and a standard operating procedure (SOP) must be submitted to Council to indicate what procedures are in place to guarantee that the welfare of the patient is still accounted for. Such SOP must be re-submitted every five years, and signed by all veterinarians and relevant staff of that facility.

(3) A research animal facility must:

(a) Be a permanent structure, not excluding . (This is not intended to exclude buildings, which are factory produced and site assembled, e.g. a prefabricated building or a container as the word "permanent "relates to the materials used and not the building itself);

(b) Have a source of good general lighting, which is also adequate to ensure the completion of a procedure in progress; light intensity in animal rooms must be adjustable and provision made for timed light cycles

(c) Have adequate ventilation;

(d) Have a fire extinguishing apparatus in accordance with the requirements of the Occupational Health and Safety Act 1993, Act 85 of 1993, which meets the requirements of the relevant local authority;

(e) Be so constructed as to minimise the escape of an animal and to ensure the effective and safe confinement of animals at all times; and

(f) Be registered with the SAVC.

(4) Subject to any requirements of a local or other authority, a research animal facility must consist of:

(a) A reception and office area and/or area where suppliers and / visitors can wait without direct access to animals;

(b) One or more examination or procedure rooms;

(c) Animal housing rooms; and

(d) Isolation facility with adequate biosecurity measures, if needed; and.

(e) Sufficient and adequate animal biosecurity level (ABSL) areas appropriate to the type and number of research activities conducted in the facility;

Admin, 2017-01-31,
Move to new point from 5 (other structural requirements)
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[(5)] The internal walls and floor surfaces, shelves and tables of a veterinary facility must be of such a nature that they can be properly cleaned and disinfected so as to maintain hygienic conditions.

[(6)] The internal walls and floor surfaces, shelves and tables of a research animal facility must be of such a nature that they can be properly cleaned and disinfected so as to maintain hygienic conditions.

(5)[(7)] The drainage and washing water of a research animal facility must run into an adequate sewer and/or septic tank and/or collection tank and must comply with the requirements of local authorities.

(6)[(8)] Provision must be made at a research animal facility for the storage and disposal of carcasses and other waste in a manner, which will ensure that health risks are minimised.

[(9)] Provision must be made at a research animal facility for a hygienic, insect, wild-bird and wild-rodent free environment within the facility as well as where therapeutic and nutritional or husbandry products are stored.

(7) Storage areas for nutritional or husbandry products must be provided apart from animal housing rooms with a dedicated storage area for non-scheduled therapeutic products

(8)[(10)] Adequate facilities must be available for the preparation of food and washing and cleaning of all equipment.

(9)[(11)] A research animal facility must comply with the following general procedural requirements:

(a) Personnel must be trained in the basics of hygiene, aseptic technique and biosecurity and such training must be relevant to the scope of practise;

(b) Personnel responsible for the operation of sophisticated equipment and apparatus must be adequately trained within their scopes of practise;

[(c)] Daily health-checks and welfare monitoring of animals housed at the research facility must be conducted by SAVC-registered or SAVC-authorised personnel, which must be followed up by weekly health and welfare monitoring by the veterinarian in charge; and with legible daily records of such kept adjacent to the animals rooms in a neat, retrievable system for ease of access by all personnel and for auditing purposes;

(c) Routine husbandry records must include room temperature, humidity and light intensity readings;

(d) All laboratory and diagnostic facilities must have a biosecurity program as well as an emergency/containment program and/or SOP for each designated area of the facility, these programs must be audited and records must be kept.

Admin, 2017-01-31,
Duplicated. See point 31 (f) and (h)
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(12) A research animal facility must comply with the following general requirements, where applicable:

[(a)] Have equipment to accurately determine the weight of animals accurately;

[(b)] Ability to provide an emergency service can be rendered to stabilise animals and/or for euthanasia;

[(c)] Resuscitative cardiopulmonary medicines and items for fluid therapy as well as intravenous fluids and fluid administration sets must be readily available for emergencies;

[(d)] Appropriate autloclave equipment or other suitableSuitable sterilising equipment must be available, or access thereto, to be done adequately for the effective sterilisation of cages, food, water, bedding, surgical packs and other equipment;

[(e)] Have adequate storage for sterilised itemspacks and employ acceptable techniques to indicate the effectiveness and expiry of sterilisation;

(a)[(f)] Routine laboratory equipment within the facility, or reasonable access to such a laboratory service must be available;

(b)[(g)] In the case of a research animal facility where invasive surgical procedures are performed, have an alternate power supply to allow the facility to function in the event of a power failure and to meet the requirements of local authorities;

(c)[(h)] Post mortem examinations should be performed at the facility or reasonable access to such a service must be available;

(d)[(i)] Have facilities and equipment or access thereto for the hygienic disposal of medical and biological waste and sharps to prevent the contamination of the research animal facility as well as the environment and to ensure the health and safety of personnel;;

(e)[(j)] Have facilities for the safe storage and use of relevant medicines for patient treatment and procedures in accordance with the Medicines Act; and

[(k)] Adequate biosecurity measures must be in place whenfor dealing with contagious diseases or genetically modified organisms.

(13) Only minor surgical procedures, excluding intra-abdominal, musculo-skeletal, intra-cranial, cardio-vascular or intra-thoracic surgery may be performed in a procedure room unless such procedure room complies with Rule 24.

[(14)] Animals must, unless circumstances dictate otherwise, be euthanased in areas separate from animal housing areas, using appropriate euthanasia methods forper species and life-stage. Where circumstance does not allow for the animal to be removed, appropriate measures must be in place (such as screens or sedation) to minimise the distress to any other animal in the housing area.

Admin, 2017-01-31,
move to procedural requirements – point 11
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(14)[(15)] The storage of medicine must comply with the following:

(a) Light conditions, temperature and humidity must comply with the requirements for the storage of medicine, other pharmaceutical products, and packaging materials;

(b) All medicines must be stored at the prescribed temperature;

(c) Schedule 5 and higher scheduled medicines must at all times be under direct supervision of a veterinary professional or para-veterinary professional, within the scope of practise of that para-veterinary professional, and locked away when the veterinary professional or para-veterinary professional is not on the premises;

(d) Storage areas must be large enough to allow orderly arrangement of stock and proper stock rotation;

(e) A refrigerator must be available and must be equipped with a suitable thermometer and capable of storing medicines at temperatures between 2°C and 8°C, if so indicated. The refrigerator must be cleaned, defrosted and checked periodically to ensure efficient running. This refrigerator must be used only for storing pharmaceutical products;

[(f)] Empty, time expired/or broken containers of medicines must be disposed of as legislatedspecified for scheduled and dangerous substances in legislation controlling these substances; and

(f)[(g)] Records of medicines purchased and prescribed or used need to be kept for a minimum period of five (5) years.

(16) If diagnostic imaging is done, the facility must comply with Rule 22.

(17) Structural requirements for facilities where radiation equipment is installed, as well as user safety precautions for the use of this equipment thereto must comply with the relevant legislation.

(18) A research animal facility must comply with the following general requirements for anaesthesia:

(a) All animals must undergo a pre-anaesthetic clinical examination;

(b) All persons administering anaesthesia must be registered or authorised by Council to do so, per animal species, and must be competent in the efficient use of all anaesthetic facilities and equipment, provided that a para-veterinary professional, within his/her scope of practice may administer anaesthesia on the instructions of a veterinarian, with the exception of wildlife, which only a veterinarian personally may anaesthetise in accordance with Rule 10(2);

[(c)] The monitoring, maintenance and recovery from anaesthesia must be effected under the direct supervision of by a veterinary professional, or para-veterinary

Admin, 2017-01-31,
Contradicts with (b) above – other persons may be authorised to administer anaesthetics
Admin, 2017-01-31,
Contradiction within sentence; contradicts with (c) below; requires rewording
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professional or authorised person????, within his/her scope of practice who must be on the premises;

[(d)] Adequate facilities must be provided for the safe induction and recovery from anaesthesia.

[(e)] The same person may not do surgery, as well as monitoring and maintenance ofadministering general anaesthesia, unless circumstances dictate otherwise and appropriate vital signs monitoring equipment for monitoring vital signs, such as a pulse oximeter or an Apalert™apalert is available;

[(f)] Equipment must be provided for the safe induction, maintenance and recovery from anaesthesia, either inhalation or parenteral, including equipment for the control of body temperature; andanaesthetic facilities must be adequate and appropriate for the relevant specie and the needs of the research animal facility must be provided at all times;

(c)[(g)] An appropriate range of clean, functional endotracheal tubes, face masks or nose cones must be available for the relevant species as required for inhalant anaesthesia;

[(h)] Medical oxygen must be available at all times for the maintenance of inhalation anaesthesia maintenance as well as to meetprovide for any other emergency situation;

(d)[(i)] Storage for all explosives, such as gas or oxygen, must be provided for in accordance with the relevant legislation;

(e)[(j)] A means to provide artificial ventilation must be available;

(f)[(k)] Lock-up facilities must be available for scheduled medicines in accordance with the relevant laws;

[(l)] Where applicable, equipment for the control of body temperature must be provided;

[(m)] Anaesthetic equipment must be adaptable for the variation in body weight and the species range in which it is intended for use;

(g)[(n)] Active or passive anaesthetic gas scavenging equipment must be in use according to relevant legislation;

(h)[(o)] All anaesthetic equipment must be properly maintained and serviced at regular intervals; and

[(p)] All animals must be monitored after surgery and not left unattended, untilunless adequately recovered from anaesthesia.

[(19)] A research animal facility must comply with the following general requirements for surgery, if invasive surgery is done:

Admin, 2017-01-31,
Move to behind (e) above
Admin, 2017-01-31,
Moved to (f); alternative : move under (f)
Admin, 2017-01-31,
Consider splitting into 2 points
Admin, 2017-01-31,
Point duplicated in (f) below thus remove
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(a) One or more rooms or areas for the treatment and pre-operative preparation of patients, which must be convenient to the operating room; and

(b) A separate room or demarcated area appropriate to the species involved and the procedure performed which is equipped as an operating room and has:

(i) An adequate light source;

(ii) A surgical table with an impervious operating surface that can be easily cleansed and disinfected;

(iii) A gas anaesthetic apparatus where relevant;

(iv) An adequate supply of oxygen; and

(v) Adequate ventilation.

(c) Aseptic technique must be employed as it applies to the operating area, animals and the operating team

[(20)] The operating room/area must be of adequate size and there must be with an adequate supply of sterile equipment, drapes and instruments at all times.

(20)[(21)] There may be no thoroughfare through an operating room.

(21)[(22)] The operating room may not be used as a storage room.

(22)[(23)] Patients should be prepared in a separate room or area convenient to the operating room but not in the same place as where surgery takes place.

(23)[(24)] Only final preparation of the patient may be done in the operating room or area.

(24)[(25)] Aseptic conditions must be maintained in the operating room.

[(26)] Have appropriate autoclave equipment or other suitable sterilising equipment, or access thereto, for the effective sterilisation of surgical packs and other equipment and have adequate storage for sterilised packs and employ acceptable techniques to indicate the effectiveness and expiry of sterilisation. Sterile instruments and materials with acceptable techniques to indicate effective sterility must be used; the expiry period for the method of sterilisation must be observed

(25)[(27)] Suitable scrubbing up facilities for the surgical team must be available.

(26)[(28)] Animal housing rooms in which animals are kept must comply with appropriate animal housing, husbandry and environmental enrichment standards in accordance with the relevant SA National Standard (SANS) for the housing of laboratory animals, or, in the absence of a specific SANS, to the internationally accepted standard;

(27)[(29)] Cages and/or enclosures must:

a) Be of adequate size for each animal or group of animals;

Admin, 2017-01-31,
Reposition in document together with similar points – structural requirements
Admin, 2017-01-31,
Move to point 3
Admin, 2017-01-31,
Duplicated in 12 (d) and (e) thus replaced
Admin, 2017-01-31,
Points 20-27 applies to requirements for invasive surgery ie point 19
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b) Be of such a material so as to prevent self-injury of the animal;

[c)] Favour maintenance of hygiene; and

[d)] Be adequately ventilated and, if necessary, heated or cooled;.

c) Not be in proximity to ultrasonic noise, appropriate to the specie; and

d) Be clearly and legibly marked on e.g. cage cards for ease of identification of the animal/s and study with additional information as required to assist in routine monitoring.

(30) Appropriate environmental enrichment programmes for all species, including exercise where relevant must be available. Exercise areas must be designed and constructed in a manner that will minimise escape and facilitate the maintenance of hygiene.

(31) A research animal facility must comply with the following ethical and additional standards:

(a) Access control must be in place to restrict access to authorised personnel only;

(b) Adequate bio-exclusion and bio-containment protocols and standards must be in place;

(c) All personnel performing procedures on animals must be registered or authorised by the Council, with sufficient registered veterinary and registered para-veterinary professionals to supervise all authorised personnel adequately;

(d) Animal welfare must be guaranteed in accordance with the relevant SANS, or in the absence of a specific SANS, the internationally accepted standard;

(e) Daily welfare monitoring of experimental animals by SAVC-registered or authorised persons with increased welfare monitoring frequencies as determined by an Animal Ethics Committee depending on expected or known study severity

(f) Weekly reports and data collection sheets of breeding and stock animals completed by animal attendants and technicians to be inspected regularly (at least fortnightly) by the designated registered veterinarian or registered para-veterinarian

(g) Animals found dead or in distress must be reported to a registered veterinarian or registered para-veterinarian to investigate circumstances and should include a post mortem where appropriate

(h) Regular veterinary health and welfare examinations of all animals by a designated registered veterinarian, or registered para-veterinarian reporting to the designated veterinarian, at a frequency depending on the nature and severity of the procedure and or studies conducted at the said facility

Admin, 2017-01-31,
Move to 31 – Ethical stds
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[(e)] Welfare inspections must be conducted at appropriate intervals by registered Animal Welfare Organisations with deficiencies addressed adequately and timeously. , regular (at least weekly) veterinary health and welfare examination of animals, and at least daily welfare monitoring of experimental animals by registered or authorised persons with increased welfare monitoring frequencies as determined by Animal Ethics Committee depending on expected or known study severity;

(i)[(f)] Prior to initiating any scientific activities, approval must be obtained from an Animal Ethics Committee, which must conform to SANS 10386:2008 and if such activity could impact on human health, be registered with the National Health Research Ethics Council (NHREC).

(j)[(g)] The Department of Agriculture, Forestry and fisheries (DAFF) compliance certification for BioSafety Level 3 or higher laboratories;

[(h)] A DAFF permit in terms of Section 20 of Animal Diseases Act 1984, Act no 35 of 1984 must be obtained from the Department of Agriculture, Forestry and Fisheries where relevant;

(k)[(i)] Nature Conservation and other permits where relevant; and

(l)[(j)] Approvals in terms of the Genetically Modified Organisms Act 1997, Act no 15 of 1997 where relevant.

(m) A registered veterinarian should always be available to deal with veterinary emergencies, including after-hours.

(n) A registered veterinarian should, at least annually, review animal health and welfare protocols or SOPs in the facility, including the identification and management of animals in pain, suffering, distress or lasting harm.

(o) The registered veterinarian who has oversight of animal health and welfare should at all times have access to all animals in the facility.

Recordkeeping at Research Animal Facilities

The principle attending veterinary professional is responsible for ensuring records are maintained, must maintain records, including the records required in terms of the Medicines Act, for each animal or group of animals which and are legible, accurate and permit prompt retrieval of information.

Records must contain the following information for individual animals as applicable:

Animal number, species, breed/strain, gender, age, colour (if relevant), origin and baseline weight;

Animal ethics approval registration number and title of study;

Admin, 2017-01-31,
Ref Rule 6: Almost the entire rule is not appropriate for research animal facilities. Replace with more appropriate record keeping rules
Legaldirector, 2017-02-01,
Theresa will give input
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Name and contact details of Principle Investigator and researcher;

Date and findings of clinical examination on arrival at facility

Date of start of experiment and of each procedure(s) performed

Clinical information for the purposes of continuous care and assessment pertinent to specie;

Type of procedures or treatments performed

Indication of regular welfare monitoring, as least once daily, with signatures of registered or authorised welfare monitors

Regular weight checks (at least weekly); more frequently in accordance with the animal ethics approved protocol

Date and type of veterinary intervention including clinical signs necessitating treatment, treatment given, date and name of attending veterinarian/para-veterinarian

Date and time of death indicating, where appropriate, if found dead (FD), died during/soon after procedure(DP/AP), euthanased due to experimental endpoint (EE) or humane endpoint (HE) or if died or euthanased for any other reason (DO)

All records referred to in Rule 6(2) and (5), radiological images and the interpretation thereof, laboratory and pathology results must be retained by the principal of the veterinary facility for a period of five years from the patient’s last visit, with the exception of ultrasound images where only the findings must be recorded.

Records of post mortems and laboratory tests must contain the following information

Animal identification, species, breed/strain, gender, age, origin of animal, location in facility, and weight at time of sampling/death;

AEC approval registration number, title of study, Principle Investigator; start date of study, date at time of post mortem/sampling

Procedures performed, treatments received and clinical findings prior to post mortem/sampling indicating dates;

Laboratory tests performed, type of sample/tissues collected, date taken, date sent to external laboratory (where applicable), date tests completed and the results thereof

Gross (macroscopic) findings of post mortem examination

Laboratory results and reports received

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Records referred to in Rule 6(4) and (5) relating to a complaint, charge or allegation lodged with Council in terms of section 31(1) of the Act must be presented to Council within seventy two (72) hours of being requested to submit such records, or as otherwise arranged with Council.

Proper security arrangements must be made to protect medical and other clinical records from loss, fire, alterations, additions, supplements or unauthorised use; electronic records must be backed up on a daily basis and electronic backups should be stored off-site.

Any alterations, additions and/or supplements to any records, clinical or otherwise, must be entered as a supplement to said record and must be clearly defined as such.

The principal of a veterinary facility will be responsible for confirming the identity of the attending veterinary professional to Council, where a complaint is lodged against his/her veterinary facility.

The principal of a veterinary facility will be responsible for providing the records referred to in Rule 6 (4) and (5), should a complaint be lodged against a veterinarian no longer in the employ of the principal of the facility, subsequent to the date on which the complaint originated.

Should the principal of a facility fail to comply with the provisions of Rule 6(9)(a) he/she will be held accountable for any unprofessional conduct arising from such a complaint.

Should the principal of a facility fail to comply with the provisions of Rule 6(9)(a) he/she will be held accountable for any unprofessional conduct arising from such a complaint.

33. Facilities for Herd Health Practice: Equine, Ruminant, Wildlife, Poultry, Pigs, and Aquatic

“Rule 33 (1) The base facility must comply with the following requirements – as applicable to the relevant scope of practice: (i) have a laboratory for basic diagnostic procedures, including microscope, and reasonable access to equipment required to make a diagnosis refractometer and centrifuge, or reasonable access to;”About in-house laboratories.Refractometer & centrifuge necessary for small animal practice, but may not be necessary for large animals or herd health facility.Should have access to refractometer & centrifuge???Microscope essential, refractometer & centrifuge (access to it if required)-for herd health facilitiesWithin scope of practise must ensure have essential equipment relevant to species treated. Vet responsible to have the equipment on hand.Setting minimum standards, not comprehensive standards.Check in all facility types to maintain consistency.

[Dr Erasmus- wildlife]

Legaldirector, 2017-01-23,
A need established.
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Often records consist of:

a) A diary of diagnosis / treatment (initiated when the appointment for the veterinarian to visit the farm is made).

b) Notes made on a smart phone or tablet.

c) Practice invoice with farm address / details generated after the visit, containing detail of medicines used, quantities, advice given, management suggestions, etc. This invoice is retained as a hard copy or is Cloud based (digital records acceptable).

d) Recording of medicines used on groups of animals is allowed, eg. bleed a herd of Buffalo – records total mg’s or ml’s used.

e) Records to be kept for 3 years according to the Self-evaluation Form of Minimum Standards

Rules 23-33 vs Rule 33 Facilities for Herd Health says 5 years.

f) Medicine registers are often kept on Excel and printed out as a PDF document from a PC on a monthly / quarterly basis.

Inspectors 31 Jan 2017

Sharps clause to be included

(1) The base facility must comply with the following requirements – as applicable to the relevant scope of practice:

(a) Be registered with Council in the relevant category;

(b) Have an external and internal neat appearance;

[(c)] Have an office to keep records & medswhere clients and representatives can be received and interviewed with access to toilet facilities;

All my clients have nice lodges. I have never needed to have a meeting or a toilet for my clients. This is not needed to wildlife practice.

A Lewis

(c)[(d)] Have a dispensary in accordance with Rule 21(4) with safe storage for highly scheduled medicines;

How exactly must one lock drugs in car?

A Lewis

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In a locked box, in a locked compartment in the car e.g. boot. If a boot is not available, than have a locked canopy with break-proof windows or guards attached.

V Naidoo

(d)[(e)] Have refrigeration facilities for cold storage of vaccines, medicines and biological samples as needed;

(e)[(f)] Have facilities for the safe storage of records and medicine registers;

(f)[(g)] Have facilities for the safe storage of biological samples if applicable;

(g)[(h)] Have a service delivery vehicle which can reach clients in remote areas; refer Rule 25(2)

(h)[(i)] Have a laboratory for basic diagnostic procedures, including microscope, refractometer and centrifuge, or reasonable access to;

(i)[(j)] Have appropriate recording and communication equipment for the recording, reporting, auditing and filing of various diseases, cases, events, and clients, according to Rule 6, OIE guidelines and other relevant legislation;

(j)[(k)] Have access to the relevant scientific information and/ or legislation necessary for effective retrieval of thereof to enable the making of sound decisions based on scientific knowledge;

(k)[(l)] Have a post mortem area (or access to one) that is well equipped to perform a post mortem appropriately and to facilitate a reliable diagnosis, where applicable;

(l)[(m)] If post mortems are done at the facility the following must be in place:

(i) All surfaces must be of such a nature that they can be properly cleansed and disinfected;

(ii) The drainage and washing water must run into an adequate sewer and/or septic tank and must comply with the requirements of local authorities;

(iii) The veterinary facility must have a direct public entrance;

(iv) Provision must be made at a veterinary facility for the storage and disposal of carcasses in a manner, which will ensure that decomposition will not cause a health risk before being disposed, and that odours are contained;

(v) Have facilities and equipment or access thereto for the hygienic disposal of animal tissue and any other contaminated or unwholesome

Legaldirector, 2016-11-04,
We really need to be more specific--what is a well-equipped post mortem area?JvH
Legaldirector, 04/11/16,
in the case of wildlife the drugs must be removed from the vehicle and locked up if the vehicle is left unattended Unless a tracking device with a tamper alarm connected to a response team is connected to the lockable storage inside the vehicle JvH
Legaldirector, 05/02/17,
Is this detail necessary? Should the safekeeping of the drugs not be left to the vet and his or her discretion depending on the circumstances?Is this detail necessary? Should the safekeeping of the drugs not be left to the vet and his or her discretion depending on the circumstances?V-Tech
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matter or objects, to prevent the contamination of the veterinary facility as well as the environment; and

(vi) All personnel must be trained in the safe handling of animals and the danger of zoonotic diseases.

(m)[(n)] All personnel must be trained in aseptic techniques; and

(n)[(o)] There must be adequate facilities for the safe cleaning and disinfecting of all equipment.

(2) A service delivery vehicle must comply with the following structural and procedural requirements where applicable:

(a) Must be suitable for use on roads and terrain as indicated;

(b) Have an acceptable standard of construction and appearance and be maintained in a clean and sanitary condition;

(c) Be constructed of materials that are impervious and that can be cleaned and disinfected;

(d) Carry a supply of water;

(e) Maintain secure storage of scheduled medicines in accordance with relevant legislation;

(f) Have a fridge or cold box with a minimum/maximum thermometer that can keep all pharmaceuticals at the correct temperatures as indicated;

(g) Have a source of light as applicable;

(h) Have a cold storage system that can maintain 5°C for the transport and storing of all biological products;

(i) Have equipment for the collection and disposal of all waste including carcasses, if required; Hygienic collection & disposal of biological waste & sharps

(j) Have adequate equipment to ensure basic biosecurity, including equipment to clean and disinfect over boots between farms;

(k) Carry an appropriate range of medicines, equipment and protective clothing, according to the type of service and species serviced, in a manner that is consistent with professional standards, while ensuring occupational safety;

(l) Must carry at least the following equipment – as applicable to the services rendered:

(i) Humane physical and chemical restraint as applicable to the species involved; Shooting acceptable

Legaldirector, 2017-02-01,
Not relevant to vehicle. Farmer will remove carcass
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(ii) Adequate diagnostic equipment including sample collection equipment;

(iii) Adequate equipment for administration of medicines and in the case of wildlife animals efficient and effective darting equipment in good working order;

(iv) Post mortem equipment;

(v) Equipment necessary for obtaining and transporting of biological specimens for diagnostic or other purposes;

(vi) Surgical equipment, including at least one sterilised surgical pack and means of between-farm disinfection of equipment;

[(vii)] Equipment relevant to the type of practice to deal with emergencies, including a relevant obstetric kit, and means of humane euthanasia; and

How do you kill wildlife humanely? Can we get a letter from SAVC to help us get gun licenses like the professional hunters did with the firearms guys?

A Lewis

(vii)[(viii)] Adequate medicine.

(3) During the handling and use of any immobilising agent the following safety measures must be in place to prevent accidental exposure:

(b) Suitable first-aid kit with resuscitation equipment and appropriate quantities of suitable antidotes, readily available;

3a. Resuscitation kit may involve an Ambu-bag, and suitable mouth pieces that are used by paramedics for mouth to mouth resuscitation. What however is defined as a suitable fist-aid kit, and what should it contain?

Individual capture course spend much time on emergency procedures and first-aid kits, but there is no uniformity of what this should be, and not every veterinarian in South Africa who uses these drugs has done a Capture Course or a First Aid course. This is currently a requirement in both Namibia and Zimbabwe, but not in South Africa, where most of these immobilizing drugs are used. I believe this should be a legislated part of being able to do wildlife practice.

Dr R Burroughs

Suggestion: Dr Marwick

Totally impractical--scrap rule

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Propose: The veterinarian using highly-scheduled substances should at all times instruct at least one or more of the bystanders/assistants on how and what medication to administer in case of accidental exposure to said medicines

(a) An assistant (or bystander) that is adequately trained and experienced to administer first-aid and the required antidote when necessary;

[(b)] If at all possible an assistant or bystander that is adequately trained and experienced to administer first-aid and the required antidote when necessary or the attending persons must at least be instructed in the basic life-saving treatment , should an accident happen and be given telephone numbers to call

This is crazy as the SAVC and SAVA have prevented us from sending lay people on dangerous drugs courses that are now only for vets, how must these assistants get trained?

A Lewis

One can train a person on how to administer a S4 antidote without needing them competent in the darting.

V Naidoo

3b. There are no training courses in South Africa that are recognized by the SAVC to enable a back-up to a veterinarian, other than possibly a veterinary nurse. Paramedics are not employed by veterinarians to be on standby. This clause does not reflect reality. A bystander may be instructed by the vet as to what to do or expect, but may have no experience in handing a syringe or giving an IV injection.

Dr R Burroughs

Suggestion

The SAVC should approve/accredit a first aid course for veterinarians ANDVETERINARY PARA-PROFESSIONALS using above-mentioned highly scheduledmedicines

The course should be compulsory for veterinarians working with these medicines or at least be a strong suggestion.

Dr C Marwick

(b)[(c)] The correct equipment and protective gear rubber gloves and protective eye wear to minimise the risk of spillage and accidental exposure; and

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3c. The use of protective equipment such as gloves IS NOT RECOMMENDED. These drugs are not absorbed through intact skin, and gloves make the handling and filling of darts more dangerous. If someone is going to inject themselves, that needle will penetrate the gloves and the skin. Goggles are cumbersome, and not used in the field. I wear glasses, so my field of vision will be limited, and the goggles will irritate me and distract from the filling of the darts or handling the drugs in a small needle and syringe.Must make sure backup staff knows about emergency treatment

Dr R Burroughs

Controversy about safe use of drugs and protective wear--the latter may in fact increase the chances of exposure

Propose: The veterinarian at all times remain responsible for the safe handling of medicines and the prevention of spillage thereof

Dr Marwick

Protection

a. GlovesWildlife practitioners tell me that working with gloves actually increases the risk of spillage due to reduced sensitivity of their hands during handling of drug vials. “Rule 33 (3)(c) the correct equipment, protective rubber gloves and protective eye wear to minimise the risk of spillage and accidental exposure; and”

b. Protective eyewear “Rule 33 (3)(c) the correct equipment, protective rubber gloves and protective eye wear to minimise the risk of spillage and accidental exposure; and”

c. Protective wear “Rule 33 (2) A service delivery vehicle must comply with the following structural and procedural requirements where applicable: (k) carry an appropriate range of medicines, equipment and protective clothing, according to the type of service and species serviced, in a manner that is consistent with professional standards, while ensuring occupational safety;”

Inspectors 31 Jan 2017

(c)[(d)] Enough water for immediate washing in case of spillage.

3d. Accepted, and should be present.

Dr R Burroughs

Comment: Dr Marwick

Acceptable

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(4) When administering anaesthesia to wildlife, the provisions of Rule 23 must be complied with to the extent possible under the prevailing circumstances.

The wildlife vet can't be the only one to use the drugs and the assistant trained to use the stuff. So the assistant breaks the rule when they save the vet's life. If vet dies I would love to be fly on the wall. Crazy - need to change.A Lewis

Antidotes are S4 medications

V Naidoo

4.5.12 Instruments & Equipment

a. Sterility of instruments / packsRule 21(e) “suitable sterilising equipment, or access thereto, for the effective sterilisation of surgical packs and other equipment; “

Follow manufacturer’s guidelines.

b. Sharps containers Rule 25 (3)(i); 26 (2) (l) (v); 31 (1) (l); 31 (12) (i). Will hard container suffice, can’t put hand into? Francois D: Regulations clear, non-negotiable.

c. Additional equipment – add microchip scanner, a stretcher for game (owner should have them- bio security threats if moved to another farm), suitable to species. Binoculars????Recommendation: Newsletter for farmer to have own stretcher & Kopdoek? Heleen GrobbelaarRule 33 (2) (l) “Must carry at least the following equipment – as applicable to the services rendered “

d. Wildlife veterinarians - Emergency kit. Rule 33(2) (m) “Must carry at least the following equipment – as applicable to the services rendered: (vii) equipment to deal with emergencies, including a relevant obstetric kit, and means of humane euthanasia; and “

e. Resuscitation equipment “Rule 33(3) During the handling and use of any immobilising agent the following safety measures must be in place to prevent accidental exposure: (a) suitable first-aid kit with resuscitation equipment and appropriate quantities of suitable antidotes, readily available;

(b) an assistant (or bystander) that is adequately trained and experienced to administer first-aid and the required antidote when necessary: (c) the correct equipment, protective rubber gloves and protective eye wear to minimise the risk of spillage and accidental exposure; and(d) enough water for immediate washing in case of spillage.”

f. Rule 33 2 (vi) Change sterile pack to sterile set. Suggestion: Chemical sterilisation acceptable. Check all disciplines to see if applicable.

The requirements to have a set of autoclaved instruments in a drape is questionable. Drop one instrument during a Caesarean section and the autoclaving is null and void. Flies and dust are also a challenge. Many rural veterinarians boil the instruments at the practice after use and then rely on chemical sterilization with Savlon and F10 or Semifluid. [Dr van Niekerk]TL: Not too prescriptive. Formalin tablets need 18 hours of exposure & equipment to be rinsed with sterile water

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g. Centrifuges / Refractometer“Rule 33 (1) The base facility must comply with the following requirements – as applicable to the relevant scope of practice: (i) have a laboratory for basic diagnostic procedures, including microscope, refractometer and centrifuge, or reasonable access to;”

“Is a refractometer a compulsory requirement for a HHP practitioner? How many production animal veterinarians actually use a refractometer??” [Dr van Niekerk]

4.5.13 Office where clients can be received“Rule 33 (1) The base facility must comply with the following requirements – as applicable to the relevant scope of practice: (c) have an office where clients and representatives can be received and interviewed with access to toilet facilities;”

No clients received. Same for large animals (herd health). Suggestion, need a room (office) with a safe & a fridge.

4.5.14 Service delivery vehicle should have a canopy -not necessarily, temperature control“Rule 33 (2) A service delivery vehicle must comply with the following structural and procedural requirements where applicable: (b) have an acceptable standard of construction and appearance and be maintained in a clean and sanitary condition;”

4.5.15 Theatre facilities for wildlife Needs to be adapted.Thoroughfare

4.5.16 Security arrangements to protect records Section 6 (7).

4.5.17 Minimum standards for a boma.Lot of surgery done in boma (often forms part of theatre), part of the practice. Water & food provided, must shelter animals, suitable for species.

On farms, food & water, shade to be supplied. Hospital boma’s as part of a wildlife practice????

Inspectors 31 Jan 2017

34. Facilities for Consultants in Industry and other consultancies“Consultancy needs not be inspected, UNLESS the consultant dispenses medicines. In this instance the facility needs to be physically inspected. The signed self-evaluation, photos of safe, cupboard and fridge and CPD requirements would still apply to those Consultancies that don’t dispense- Act 101.”

Dr A Erasmus

(1) The base facility must comply with the following requirements – as applicable to relevant scope of practice:

(a) Be registered with Council in this category;

(b) Have an external and internal neat appearance;

(c) Have an office where clients and representatives can be received and interviewed, with access to toilet facilities;

Legaldirector, 2017-02-01,
Accepted-Meds workshop
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(d) Have a dispensary in accordance with Rule 21(4), if applicable;

Consultancies with these facilities need to be inspected.

Dr A Erasmus

(e) Have refrigeration facilities for cold storage if applicable;

(f) Have facilities for the safe storage of biological samples if applicable;

(g) Have a laboratory equipped according to scope of practice;

(h) Have appropriate recording and communication equipment as needed for reporting;

(i) Have access to the relevant scientific and/ or legislative information resources necessary;

(j) Have a post mortem area (or access to one) that is well equipped to perform a post mortem appropriately and to facilitate a reliable diagnosis, where applicable;

(k) Have facilities and equipment or access thereto for the hygienic disposal of animal tissue and any other contaminated or unwholesome matter or objects, to prevent the contamination of the veterinary facility as well as the environment;

(l) All personnel must be trained in aseptic techniques;

(m) There must be adequate facilities for the safe cleaning and disinfecting of all equipment; and

(n) All personnel must be trained in the safe handling of animals and the danger of zoonotic diseases.

(2) A service delivery vehicle must comply with the following structural and procedural requirements where applicable:

(a) Have an acceptable standard of construction and appearance and be maintained in a clean and sanitary condition if applicable;

(b) Be constructed of materials that are impervious and that can be cleaned and disinfected if applicable;

(c) Maintain secure storage of scheduled medicines (medicines) in accordance with relevant legislation if applicable;

(d) Have a fridge or cold box with a minimum/maximum thermometer that can keep all pharmaceuticals at the correct temperatures as indicated;

(e) Have equipment for the collection and disposal of all waste, if required;

Legaldirector, 2017-02-01,
Not necessarily necessary for all staff to be trained.Clinical personnel only????
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(f) Have adequate equipment to ensure basic biosecurity, including equipment to clean and disinfect over boots between farms;

(g) Carry an appropriate range of medicines equipment and protective clothing, according to the type of service and species serviced, in a manner that is consistent with professional standards, while ensuring occupational safety; and

[(h)] Must carry adequate medicine.

35. Non-practising facility (Retired veterinarians only-consultants to industry treating own animals)

I do not believe that a “non-practicing” facility needs to be inspected! These Vets are treating their own animals and are not dispensing any medicines. It should be sufficient for them to: 1. Complete this self-evaluation form, signing it to confirm that they comply in every way with the minimum standards. (Give an affidavit if necessary)2. Send photos of their safe in which they store their scheduled medicines and of the lock-up cupboard for their other medicines, of the fridge they store their biological in, and 3. They remain subject to CPD audits.It seems futile to waste personal and financial resources on this category of facility.

Dr A Erasmus

(1) The base facility must comply with the following requirements:

(a) Be registered with Council in this category;

(b) Have facilities for the safe storage of highly scheduled medicines, if applicable;

(c) Have refrigeration facilities for biologicals if applicable;

(d) Have appropriate equipment for the recording and filing of all orders, scripts and usage of medicines and any diseases or events, as needed according to relevant legislation; and

(e) Have access to the relevant scientific and/ or legislative information resources necessary.

(2) The non-practising facility will be registered and such registration will be maintained, subject to the following:

(a) The registered veterinarian must provide proof to the Registrar that he/she is up to date with the requirements of continuing professional development upon request;

(b) Payment of the applicable annual maintenance fees; and

Legaldirector, 2017-01-23,
Dr Erasmus
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(c) The registered veterinarian undertakes to use any medicines purchased on his/her own animals only, and does not do any work for anyone else or for a fee. (sign affidavit?)

MINIMUM STANDARDS FOR VETERINARY SHOPS

“I do not believe that it is necessary to do routine inspection of    Veterinary shops. If they are part of a veterinary consulting room, clinic or hospital, the inspector can look through the shop as part of the vet facility inspection and maybe make comment on the evaluation form. (as has been done in the past).This would be necessary because it influences the vet facilities appearance and standard.”

Dr A Erasmus

33 inspectors inspected 124 facilities. Issues re state facilities, not ready, had 10 month extension, concern. 136 still to be inspected within cycle. Feedback from inspectors important to improve rules and assists council to take better decisions.Awareness process, especially re medicine contraventions (R 10 m fine or 10 years).Council received a lot of positive feedback re inspections, feather in cap.Inspectors engaged beforehand, went the extra mile.Ensure that checklist to be completed is the correct checklist for the kind of facility, check that correctly registered with Council. Mobile services rendered from a base facility, from a vehicle. Not a mobile facility.Identify impractical rules, amend or delete.Identify deficiencies, such as equipment, needed or not needed.Identify needs of profession and align with rules, practical suggestions to policy makers.LH: Online to update forms in Dropbox

Inspectors 31 Jan 2017

36. General structural requirements

(1) A veterinary shop must -

(a) Be a permanent structure. (This is not intended to exclude buildings, which are factory produced and site assembled, e.g. a prefabricated building as the word "permanent "relates to the materials used and not the building itself);

(b) Have adequate lighting and ventilation;

(c) Have internal walls and floor surfaces that are neat and constructed of impervious materials to ensure that hygienic conditions can be maintained.

(d) Have sufficient storage space to ensure hygienic, insect and rodent free storage of all items stocked in the veterinary shop; and

Anthony Erasmus, 2016-09-02,
Should the Veterinary Shop be regulated? Regulations with minimum standards such as these are what set us apart from the regular “corner pet shop” It should be a professional entity , in appearance, service level, knowledge of staff, superior products available only to the vet. Nutritional companies have been taken on by the Competition Commission on several occasions about this policy of supplying their foods to vets only, and have won every time. They have won because they will only supply to a vet, because a vet has the knowledge about the science behind the food in every bag, has trained staff that are able to give the best advice to the owner with no consequent harm to the pet. The Veterinary shop is in a position to recommend the best quality product because they stock those brands that the pet shop can’t.The term veterinary shop of course includes all those veterinary owned retail outlets that are known by other names other than Vetshop . e.g. PetzRus,Petsmart etc.Location: I believe that the veterinary shop should remain an independant , recognizable entity. Within another retail outlet is acceptable as long as the independence is retained.
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(e) Have provision for the display of merchandise in or on neat and attractive display cabinets, shelving, counters and tables that have impervious surfaces that can be properly cleaned and disinfected.

Eukanuba: Administer online scenario,vets go online, place order, IAMS will administer process to deliver to client (logistical service)AE: Suggestion: Same rules as vetshops, excluding Act 101s & vet prescription diets & any products listed as for use by or under supervision of a vet.AdV: Idea behind Vetshops vets to be available to give advice.JA: Special diets cannot be excluded, Act 36.AE: Online vetshop must be registered as such.Online shops may only be called a vetshop if registered in the name of a vet, comply with rules (minimum standards).

Inspectors 31 Jan 2017

37. General procedural requirements

(1) Only a veterinarian may have a financial interest in and own a veterinary shop.

(2) No staff employed at a veterinary shop that are not qualified as a veterinary professional or para-veterinary professional, may give any advice whatsoever regarding the products on sale, unless they have completed a minimum training course acceptable to Council to ensure that they are adequately and appropriately trained and qualified to offer a professional service to the public;

(3) Attendance certificates must be kept for each staff member as proof of completion of the acceptable training course.

(4) Any consultation or service requests of a veterinary clinical nature should be referred to a registered veterinary facility.

(5) Veterinary or para-veterinary professional supervision at a veterinary shop is essential with active and visible participation in the activities of the veterinary shop.

Should Vetshops be inspected. Vet should fill in self-evaluation form, accept with photographs.CM: Inspect attached vetshop (on-premises), not lone standing Vetshops.Non-presence of vet, must be contactable only.Prescription diets only to be sold if vet or para vet on premises.Costly exercise for council & vets, Vetshops marginal in profit.LH: E-mail to vets, no clinical services to be rendered from Vetshop.Inspection forms: Add do you have a vetshop & prescription foods. Declaration compliance.

Inspectors 31 Jan 2017

Anthony Erasmus, 09/02/16,
Yes, a definite regular veterinary presence in the shop is essential, with the Vet or Nurse seen to be actively involved. This is why a Vet in Port Elizabeth, owning shops in Gauteng (for example) is questionable.
Anthony Erasmus, 09/02/16,
Unfortunately not many training course are available. In-house training by the Veterinarian and/or Vet Nurse may need to be considered!
Anthony Erasmus, 09/02/16,
This implies that a Veterinary Shop is 100% veterinary owned. No part-ownership by a lay person is allowed. Rule 8 (1) provides that a vet may not allow any shareholding in his practice. A veterinary shop is a veterinary business and should be included in this rule.
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38. Sale of merchandise

(1) The following products may be sold at a veterinary shop:

(a) Medicines that are registered as schedule 0 medicines in terms of the Medicines Act;

(b) Stock remedies registered without any conditions for sale or use in terms of the Stock Remedies Act, or any relevant Act it may be substituted with; and

(c) Any other veterinary pharmaceutical products including products for which the manufacturer has limited the sale to veterinary professionals.

(2) Stock remedies registered with restricted requirements such as for “use by or under the control of a veterinarian only” in terms of the Stock Remedies Act, or any relevant Act it may be substituted with, may only be sold if a veterinarian has advised on the suitability of the stock remedy and is present in the veterinary shop at the time of the sale.

(3) No medicines registered as schedule 1 or any higher schedule in terms of the Medicines Act may be sold from a veterinary shop.

(4) No live animals are to be kept for sale or sold at a veterinary shop.

PROCEDURE AT INQUIRIES INTO PROFESSIONAL CONDUCT

39. Lodging of complaints

A complaint must be in writing in the form of a sworn affidavit, signed in the presence of a commissioner of oaths or police officer and be addressed to the Registrar.

40. Preliminary investigation

(1) On receipt of a complaint, the Registrar must advise the respondent of the complaint and forward a copy thereof to the respondent.

(2) The Registrar must inform the respondent that he/she may furnish a typewritten explanation, in the form of a sworn and signed affidavit, before a date, not earlier than one (1) calendar month from the date of the request, or as otherwise agreed on request of the respondent upon substantiation, to the Council.

(3) The respondent must be warned that such an explanation may be used in evidence against him/her.

(4) The respondent must be informed of his/her right to refuse to answer any allegations, which might incriminate him/her; and

Admin, 2017-01-29,
6.Clinical records (un-supplemented) must be submitted within 5 working days.
Admin, 2017-01-29,
4.Mediation of certain types of complaints (classified) should be considered to be added to Rule 40.5.The system in place at the HPSCA, namely an ombudsman, during the preliminary investigation, should be considered, to the extent that if the matter is settled by the ombudsman, the matter goes no further. Such a procedure must be time-line specific and confidential.
Admin, 2017-01-29,
Summary notes on the Review Committee meeting held on 6 October 2016 (Outcomes of the Disciplinary Workshop)1.The identity of the person who brings a complaint to the attention of Council, should under certain circumstances not be made known.2.Rule 39 should contain a clause limiting the filing of a complaint to 12 months of the event giving rise to the complaint.3.Rule 39 should contain a clause that allows for a complainant to file a condonation application if the complaint is not filed within 12 months of the event giving rise to the complaint.
Anthony Erasmus, 2016-09-02,
I do not believe that it is necessary to do routine inspection of Veterinary shops. If they are part of a veterinary consulting room, clinic or hospital, the inspector can look through the shop as part of the vet facility inspection and maybe make comment on the evaluation form. (as has been done in the past).This would be necessary because it influences the vet facilities appearance and standard.
Anthony Erasmus, 09/02/16,
This includes all the Veterinary prescription diets (foods) that should be under the control of the vet or nurse and should only be “prescribed “to animals in which a diagnosis by a vet has been made of the specific illness for which the food is intended – unless of course if the vet or nurse is present in the shop at all times.
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(5) The respondent must be informed that he/she is entitled to seek legal representation prior to filing such an affidavit.

(6) On receipt by the Registrar of an explanation, it must be submitted to an investigation committee, and if no explanation is received, the Registrar must report this to the investigation committee.

(7) The Registrar or the investigation committee may at any stage cause further investigation to be made.

(8) If further information is sought from the respondent he/she must be advised of -

(a) his/her right to refuse to answer any questions and furnish any information which might incriminate him/her; and

(b) that he/she is entitled to legal representation during such consultation or discussion.

(9) If an investigation committee resolves that a complaint, even if substantiated, does not constitute unprofessional, improper or disgraceful conducts it must take such action as it may think fit and report such action to the Council.

(10) If the complainant is not satisfied with the outcome of the investigation committee's preliminary finding, the evidence at hand must be referred to Council for a decision whether or not an inquiry into professional conduct should be held.

(11) If it appears to an investigation committee that an inquiry should be held into the conduct of a respondent, it must direct the Registrar to arrange for the holding of an inquiry into professional conduct.

41. Inquiry into professional conduct

(1) On receipt of a directive to hold an inquiry the Registrar must summons the respondent by means of a notice addressed to the respondent stating where and when the inquiry into the professional conduct will be held and enclosing a charge as formulated by the Investigation Committee.

(2) The notice must be served on the respondent or mailed to him/her at his/her registered address by prepaid registered post, delivery by the sheriff of the Court or if agreed in writing, served by e-mail, provided that receipt of the summons is telephonically confirmed.

(3) If witnesses are summoned at the instance of the respondent the Registrar may require the respondent to deposit a sum of money sufficient to cover the costs thereby entailed, and the Registrar may pay such costs from the amount deposited.

(4) Should the respondent be found not guilty, the full deposit in rule (3) above must be refunded to the respondent.

Admin, 2017-01-29,
7.Excluding criminal acts and gross misconduct, investigations should centre around the main complaint. 8.If the main complaint is not substantiated, and peripheral misconduct is evident, guidance should be provided as to how to deal with it (correct the behaviour), subject to point 7.
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42. Procedure at Inquiry into professional conduct

(1) In an inquiry into professional conduct held in terms of Section 31 of the Act the procedure must be as follows -

(a) The respondent or, if he/she is not present, his/her legal representative must be asked by the chairperson of the inquiry body to plead guilty or not guilty to the charge and that plea must be so recorded;

(b) If the respondent, or his/her legal representative, refuses or fails to plea directly to the charge, this must be recorded and a plea of not guilty must be entered, and a plea so entered must have the same result as if it had in fact been so pleaded;

(c) The pro forma complainant must be given the opportunity of stating his/her case and of leading evidence in support thereof;

(d) The respondent must thereafter be given the opportunity of stating his/her case and of leading evidence in support thereof;

(e) The inquiry body may, in its discretion, allow further evidence to be led or a witness to be recalled by either the pro forma complainant or the respondent or by both after their cases have been closed;

(f) After the parties have closed their cases, the inquiry body may in its discretion call further witnesses or recall a witness to be questioned by the members of the inquiry body and thereafter by the pro forma complainant and then by the respondent or his/her legal representative;

(g) After all evidence were presented, the pro forma complainant must be allowed to address the inquiry body on the evidence and the legal position;

(h) Thereafter the respondent must likewise be allowed to address the inquiry body, where after the pro forma complainant must be allowed to address the inquiry body in reply;

(i) After the evidence of a witness has been given, the opposing party is entitled to cross- examine the witness, where after the chairperson of the inquiry body may put questions to the witness and allow other members of the inquiry body to put questions to the witness;

(j) Before re-examination, further cross-examination must be allowed arising from questions put by the chairperson and other members;

(k) The person who led the evidence must thereafter be entitled to re-examine the witness, but must confine his/her re-examination to matters on which the witness was cross examined or on which the chairperson or other members put questions to the witness;

Admin, 2017-01-29,
14.It should be considered to allow expert witnesses to sit in and cross-examine the other expert witnesses. It would add depth to peer review.15.If representation by fellow veterinarian is allowed, then that veterinarian cannot act as expert witness, as it would give rise to a conflict of interest
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9.Bundles at inquiry to be made available to the inquiry body members prior to the inquiry, unless objected to.10.A discovery process should be formalised.11. In complex matters, a pre-trail meeting should be held to agree to common cause facts and facts in contention, to shorten the time of the inquiry.12.Objections to documents intended to be submitted must be dealt with as points in limine at the commencement of the inquiry.13.The value of the adversarial system as opposed to inquisitorial system should be investigated for consideration
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(l) If the respondent and his/her legal representative are not present at the inquiry into professional conduct, it must proceed in the respondents’ absence and a plea of not guilty must be entered, unless the respondent has in writing pleaded guilty to the charge against him/her, in which event it must be entered as his/her plea;

(m) All oral evidence must be taken on oath or affirmation by the chairperson of the inquiry body;

(n) Evidence on affidavit may be admissible: Provided that the opposing party may object to such evidence if he/she is not given the opportunity of cross-examining the witness.

(2) Upon the conclusion of a case the inquiry body must deliberate thereon in camera.

(3) If the respondent is found not guilty of the charge against him/her, he/she must be advised accordingly.

(4) The inquiry body may make a finding of not guilty even if the respondent has pleaded guilty.

(5) If the inquiry body has, regarding any charge, determined that sufficient facts have been proved to its satisfaction to support the charge, it must decide whether the charge so supported constitutes unprofessional, improper or disgraceful conduct and it must announce its finding.

(6) If the respondent is found guilty the pro forma complainant must furnish details to the inquiry body of previous convictions of the respondent under the Act, if any and may address the inquiry body and lead evidence regarding a suitable penalty to be imposed.

(7) The witnesses concerned may be questioned by the respondent and members of the inquiry body.

(8) The respondent may thereafter address the inquiry body and adduce evidence in mitigation of the penalty to be imposed and the witnesses concerned may be questioned by the pro forma complainant and members of the inquiry body.

(9) Thereupon the inquiry body must deliberate in camera upon the penalty to be imposed, and the chairperson must then inform the respondent of the inquiry body's decision regarding the penalty.

43. Accessibility to Inquiry into professional conduct

(1) The proceedings at an inquiry into professional conduct is open to the public, provided that-

Admin, 2017-01-29,
17.Dr Peter Ardington suggestion to liaise with the Faculty regarding the testing of ethical knowledge, so that students to know what is expected of them in practice, should be followed up. 18.Rules & ethics need to be inculcated at student level, day one competencies should include ethics.19.The curriculum from UP regarding ethics should be obtained and disseminated to attendees of the workshop for input.I made these notes as well:Advocacy: there must be a road show (to profession & public?) to ascertain standards are met (rest = mishaps) Education of tribunal members** must have professional conversation iso legal conversation (peer review vs court of law ) – this will need changing of the Act### Review definition of unprofessional, improper and disgraceful conduct in the RulesThen align penalties to suitWhat the VDA said in their newsletter – but not at the workshop ‘If you cannot go to the legislation and read the full details of what would constitute a transgression, there is no lawful basis on which you can be convicted.’ This is a general principle of law.This relates to a court case in USA but may e used against us; do we/ the IC discuss?
Admin, 2017-01-29,
16.The disciplinary offences should be graded as serious, less serious and minor- The DLA to draft the document and submit to the IC for comment
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(a) Any decision of the inquiry body in respect of any point arising in connection with or in the course of an inquiry may be arrived at in camera;

(b) Any evidence adduced during an inquiry into professional conduct may, on good cause shown, in the discretion of the inquiry body, be heard in camera; and

(c) The inquiry body may, on good cause shown, in its discretion, order that no person may at any time in any way publish any information, which would probably reveal the identity of any particular person other than the respondent.

44. GENERAL

(1) The Council may, on written application, and at its own discretion, grant exemption from the provision of specific Rules.

(2) Any application for exemption from the provision of a specific Rule for the purposes of compulsory veterinary community service must be lodged with the Council, on behalf of the Minister, by the National Director for Compulsory Veterinary Community Service after consultation with the Provincial Coordinators for Compulsory Veterinary Community Service.

45. Reporting of impairment or of unprofessional conduct

(1) A student or veterinary professional must;

a) Report impairment or suspected impairment in another student or veterinary professional to the Council if he/she is convinced that any student or veterinary professional is impaired;

b) Report his/her own impairment or suspected impairment to the Council if he/she is aware of his/her own impairment or has been publicly informed, or has been seriously advised by a colleague to act appropriately to obtain help in view of an alleged or established impairment;

if such a level of physical or mental impairment has been identified that the welfare of the patients, the interests of the clients and/or the image of the profession will be compromised.

(2) A student or veterinary professional is obliged to report any unprofessional, illegal or unethical conduct by another student or veterinary professional or para-veterinary professional, particularly where it involves the employment of unregistered professionals or where an animal’s welfare may be compromised.

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46 Research, development and use of chemical or biological weapons capabilities

(1) A veterinary professional who is or becomes involved in research, development or use of chemical or biological weapons capabilities must obtain prior written permission from Council to conduct such research, development or use.

(2) A veterinary professional must provide at least the following information when applying for written approval:

(a) Full particulars of the nature and scope of such research, development or use;

(b) Whether the clinical trials pertaining to such research have been passed by a professionally recognised research ethics committee;

(c) That such research, development or use is permitted in terms of the World Medical Association’s Declaration on Chemical and Biological Weapons; and

(d) That such research, development or use is permitted in terms of the applicable international treaties or conventions to which South Africa is a signatory.

Repeal and transitional arrangements

(1) The Rules relating to the practising of the veterinary profession published on 1 October 1982, as amended from time to time, are hereby repealed.

(2) Any inquiry or review application in terms of the Rules referred to in (1) pending before an Inquiry Body, Council or a High Court immediately prior to the commencement of these Rules must be conducted and finalised under the procedures prescribed by those Rules as if they were not repealed.

(3) Rule 10(12) comes into operation on the date that Government Notice no 609, published in the Government Gazette no 37898 on 7 August 2014, is revoked by notice in the Government Gazette by the Registrar of Medicines in terms of the Medicines Act or any Act it may be substituted with.