Congress has taken action in an effort to address mobile veterinary practitioners’ inability to legally carry controlled substances outside of the principal place of business. Controlled substances cannot be taken outside of a registered location per CFR 1301.12, “A separate registration is required for each principal place of business or professional practice at one general physical location where controlled substances are manufactured, distributed, imported, exported or dispensed by a person.” This means that it is illegal for veterinarians to carry controlled substances for use on farms, in pet’s homes
, or in veterinary mobile units.
On October 12, a congressional letter was sent to the Drug Enforcement Administration (DEA) asking for technical drafting assistance on how best to resolve this situation to the satisfaction of both sides. Congressman Kurt Schrader (D-Ore.) spearheaded the effort which garnered bipartisan support from 16 members, including House Agriculture Committee leadership and members of the Agriculture, Energy and Commerce and Judiciary Committees.
The AVMA sent a letter to the DEA in April following discussions between the Sacramento, Calif., field office and veterinarians attempting to register at a residential address. While not illegal, the DEA does not like to see a residential address used as a place where controlled substances are delivered and stored. Shortly thereafter, Washington State Veterinary Medical Association had discussions with their DEA field office in Seattle. The AVMA and other stakeholders, like the United States Animal Health Association, have been involved in ongoing discussions with the DEA on this issue. DEA maintains that a statutory change is required to address this issue.
The AVMA GRD will continue to engage with Congressional offices as we work to address the issues with transporting controlled substances. Impacted stakeholders continue to offer their support in this effort as well. We will continue to keep you updated as we learn more.
If you have any questions or concerns, please contact Dr. Ashley Morgan, assistant director, AVMA Governmental Relations Division.