) Draft Board Response to Pet Owners
Schultheiss - Vet 072413
Thank you for providing comments in reference to the HB 986 State
Board of Pharmacy – Sterile Compounding – Permits, Chapter
HB 986 applies to sterile compounding only. Many compounded pet
medications are not sterile under USP <797> and HB 986 does not
apply to those compounds.
The purpose of HB 986 and the pending regulations is to ensure the
quality and safety of the drugs that pets receive.
Until the new sterile compounding laws become effective (both State
and federal), veterinarians may continue to compound and
dispense sterile products in accordance with applicable standards of
practice. Veterinarians may compound a limited quantity of a
particular medication in anticipation of immediate future need
as based on previously documented prescriptions filled for
that medication. Veterinarians who wish to engage in sterile
compounding after the implementation of the new Maryland law
must obtain an additional permit from the Board of Pharmacy and
comply with certain minimum standards. Veterinarians who
compound non-sterile products do not require an additional permit
from the Board.
If using a pharmacy, a pharmacy would have the ability
to compound in anticipation of receipt of a patient specific
prescription. Any compounded prescription that is dispensed must be
pursuant to a patient specific prescription. See COMAR 10.34.19.08.
This regulation may provide a solution to some veterinarian
concerns. The veterinarian should work with the pharmacy to
arrange availability in emergency situations.
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