Pharmacists routinely prescribe Pharmacist Only Medicines for minor ailments such as chloramphenicol (Chlorsig) for bacterial conjunctivitis in humans. But what can you do if someone asks for a Schedule 3 medicine for animal use?
To answer this question, there are a few things which pharmacists need to work through.
Is the substance in Schedule 3?
The Poisons Standard entry for chloramphenicol in Schedule 3 states ‘for ophthalmic use only’. Unlike some substances, the Schedule 3 entry for chloramphenicol is not limited specifically to human use.
Can pharmacists legally supply Pharmacist Only Medicines for use in animals in my state or territory?
Yes, unless you are in Victoria (see Box 1). State and territory regulations generally do not restrict the provision of Schedule 3 medicines to human patients. Some regulations specifically refer to animals as possible patients. Other jurisdictions don’t refer to patients at all but do refer to purchasers or customers.
In Victoria, Pharmacist Only Medicines may only be supplied for a person under the care of the pharmacist.
Do I need to check if the medicine is indicated and the dose is safe?
Yes. When prescribing or dispensing medicines, pharmacists must determine the medicine is safe, appropriate and will be effective for the patient. This obligation extends to patients who are animals.
Pharmacists must confirm therapeutic need exists when prescribing Pharmacist Only Medicines. In the case of bacterial conjunctivitis in dogs, this would be difficult given it is rare, and that most pharmacists do not have expertise in differential diagnosis of eye conditions in canines.
The Merck Veterinary Manual is available for free online access where doses of a medicine for specific animals can be confirmed.
In the case of ocular chloramphenicol, there is no specific guidance, so further research is needed. You may also reach out to a vet directly to learn more about safety and efficacy.
What other obligations do I have?
Medicines in Schedule 3 are registered with the TGA for human use, not animal use. Therefore, animal use of these medicines is considered off-label and obligations around informed consent and explaining limitations apply.
In NSW, supply of Schedule 3 medicines must be consistent with a recognised therapeutic standard.
What if I’m not confident? Am I obliged to prescribe a Pharmacist Only Medicine for an animal?
No. While pharmacists must always act in the interests of their patients, pharmacists should not practise outside their own personal scope of practice, which includes any gaps in knowledge, skills, accountability or authority. In these cases, referral to a vet is more appropriate.
So, what’s the answer?
Supplying Pharmacist Only Medicines for animals is complicated. It is permitted by regulation (except in Victoria), but outside of individual scope of practice for most pharmacists as few currently have specific knowledge and expertise to prescribe for animals. Script or no script, pharmacists still need to work through the considerations of safety, efficacy and off-label use.
Box 1 – Relevant state and territory regulations
Medicines Poisons and Therapeutic Goods Regulation 2008
|NSW||Clauses 18, 23
Poisons and Therapeutic Goods Regulation 2008
Medicines Poisons and Therapeutic Goods Act 2012
|QLD||Sections 154, 161
Medicines and Poisons (Medicines) Regulation 2021
Controlled Substances (Poisons) Regulations 2011 (SA)
Poisons Regulations 2018
Drugs, Poisons and Controlled Substances Regulations 2017
Medicines and Poisons Act 2014 (WA)