Urgent and Emergency Veterinary
Compounding Guidance
After discussion with the Minnesota Veterinary Medical
Association, and based on staff analysis and recommendations,
the Board adopted the following position statement
at its March 4, 2015 meeting.
“The Minnesota Board of Pharmacy will temporarily
exercise enforcement discretion by not requiring a
pharmacy to become licensed as a manufacturer when it
compounds and distributes a limited supply of veterinary
products that are needed in urgent or emergency situations;
where the health of an animal is threatened, or
where suffering or death of the animal is likely to result,
from failure to treat.”
The Board also issued the following guidance, pursuant
to Minnesota Statutes §214.108, which states that a
“health-related licensing board may offer guidance to
current licensees about the application of laws and rules
the board is empowered to enforce.” Note that this guidance
will remain in effect only until the Board can
promulgate appropriate rules related to this issue.
1. Pharmacies licensed by the Board can already
compound and dispense drugs, pursuant to a patientspecific
prescription received in advance of the
dispensing, provided that such compounding and
dispensing is done according to Minnesota Statutes
§151.253 and the applicable rules of the Board.
(Note that only those pharmacies that have selected
the nonsterile and/or sterile compounding licensing
categories are allowed to compound drugs.) Compounding
done pursuant to a patient-specific
prescription is not the subject of this guidance.
2. The Board will exercise enforcement discretion and
not take action against a pharmacy that, in good
faith, provides a compounded drug to a veterinarian,
at wholesale and without first receiving a patientspecific
prescription, only when:
a. The compounded drug is needed to treat animals
in urgent or emergency situations; that is, where
the health of an animal is threatened or where
suffering or death of an animal is likely to result
from failure to treat.
b. Timely access to a compounding pharmacy is
not available, as determined by the prescribing
veterinarian.
c. There is no Food and Drug Administrationapproved,
commercially manufactured drug that
is suitable for treating the animal; or there is a
documented shortage of such drug.
d. The compounded drug is to be administered by
a veterinarian or a bona fide employee of the
veterinarian; or dispensed to a client of a veterinarian
in an amount not to exceed what is necessary
to treat an animal for a period of five days.
e. The pharmacy is licensed by the Board as a
drug wholesaler. (Except that a pharmacy may
distribute compounded drugs as described in
this guidance until June 1, 2015, without being
licensed as a drug wholesaler.)
f. The pharmacy has selected the sterile or nonsterile
compounding licensing category.
g. The pharmacy is appropriately registered by the
United States DEA when providing compounded
products that contain CS.
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