The VMD Inspections and Investigations Team offers the following advice to members of its Accredited Internet Retailer Scheme. We reproduce it here to enable veterinary practises running internet pharmacies on Vetmart.net to understand what VMD sees as best practice in 2012 for an online veterinary pharmacy.

Much of the required information is already captured by the Vetmart.net system and there are for example links to the VMD online SAR form and Product Information database. Practices still need to include their T&Cs or links to their T&Cs.

Plain text indicates a requirement of the VMD’s Accredited Internet Retailer Scheme criteria. Italic text indicates additional features that a ‘model’ website would have.

The website

The following must be displayed:

· The name of the owner of the business.

· The address at which the business is conducted, or a correspondence address (which may be a PO box address)

· The name and qualification of the RQP responsible for the internet retail business and how to confirm the registration status of that person*.

· Information on how to confirm the registration status of the online retail premises (this will be the link from the VMD logo to the Register of Accredited Internet Retailers, once the logo is issued)*.

· Details of the internet retailer’s general complaints procedure and, if the complaint relates to veterinary medicines and a satisfactory reply isn’t received from the internet retailer, how to make a complaint to the VMD*.

· For POM-V medicines, a statement that they may only be supplied against a written prescription.

· A link to the VMD’s Adverse Event (Suspected Adverse Reaction Scheme) online yellow form* http://www.vmd.defra.gov.uk/adversereactionreporting/

· A link to the VMD’s Product Information Database* http://www.vmd.defra.gov.uk/ProductInformationDatabase/

· The Retailer’s Terms & Conditions

* These details located in one specific section on the website e.g. ‘About Veterinary Medicines’

Advertising
No POM-V or POM-VPS products advertised on the retailer’s Homepage, pages aimed at the general public (including companion animal products’ pages), or on ‘special offers’ pages.

The homepage of a website is considered to be a general public area and POM products should not be advertised on it. This includes POM-VPS products. Whilst a price list of products is not considered to be advertising, a price list should include all products in a particular category e.g. all horse wormers, not just selected ones from different product groups e.g. one dog vaccine, one horse wormer etc, as that promotes that one product over similar ones and is therefore advertising. Furthermore, to be a price list the list must contain product prices.


Further to the above advertising POMs to the general public is not permitted. This includes promoting POMs to the public by offering ‘special deals’, ‘offers of the week’ and bogofs. In relation to POM-V products, pop ups such as ‘customers who bought ‘product X’ also bought ‘product Y’, is considered promotion and therefore advertising.

Visiting a website should not result in POMs being advertised to the general public for example by popping up in their email account or on search engines e.g through the use of ‘cookies’.
No human medicines, specials or other unauthorised veterinary medicines advertised.

No claims or reference to other species/treatments etc made which are not in a product’s Summary of Product Characteristics (SPC).

Product Listings
Products classified as POM-V, POM-VPS and NFA-VPS have those classifications correctly shown.

For POM-V products a statement that a veterinary prescription is required (or words to that effect).

For medicinal sheep dips reference to the requirement for the purchaser and user to provide a Certificate of Competence number.

For Flubenvet premixture reference to the fact that it is a medicated premixture manufactured from Flubenvet 5% (POM-VPS) and not a medicinal product per se.

Flubenvet 240g and 60g pots are not POM-VPS medicinesper se, but rather medicated premixtures (POM-VPS medicines mixed with other feed materials). Schedule 5 of the Veterinary Medicines Regulations restricts the supply of medicated premixtures to the manufacturer of the product or a Category 8 Distributor of medicated feeds/premixtures. They may only supply such medicated premixtures to an approved manufacturer of final medicated feed or another Category 8 Distributor.

However, there is an exemption under Schedule 5 of the Regulations which permits a veterinary surgeon, pharmacist or a livestock/avian SQP to sell a medicated premixture from registered/approved premises, provided that:
(i) the vet, pharmacist or SQP treats the premixture as if it was a POM-VPS medicines – i.e. POM-VPS storage, prescribing, supply and record-keeping requirements apply; and
(ii) the premixture are only supplied to domestic keepers of poultry i.e. a person who keeps poultry on domestic premises, for feeding on those premises, non-food producing birds, or birds kept purely for private domestic consumption. If meat or eggs are sold by the poultry keeper, even farm gate sales, then the exemptiondoes not apply, and the user of the premixturemust beanapproved manufacturer of medicated feedingstuffs (this includes gamekeepers and shoots and particular attention is needed when selling the 240g pot).


Recommend a questionnaire/disclaimer to confirm that the customer only keeps poultry on domestic premises, for feeding on those premises - non-food producing birds, or birds kept purely for private domestic consumption and that they do not sell meat or eggs from their birds (or words to that effect).

A link from each product to its SPC on the VMD’s Product Information Database (PID). However, if a direct link to a specific SPC isn’t created then there should at least be a link to the VMD’s PID search page.

If there is a link to a datasheet/information other than the product’s SPC then, because such datasheets/information can quickly be out of date, we suggest that a note is added to the product to say that to be certain of the most up to date information, customers should check the SPC on the VMD’s Product Information Database” and provide a link to the search page or to a page on their own website which has the link. To directly link to an SPC, select the product, click on the little triangle which brings up the text ‘Click to View SPC’ then right click on that text and ‘copy shortcut’ to your website.

Information Required

Customer’s details
- the customer’s home address (for delivery)
- contact phone number and email address (in case of a query)
- if a returning customer, question about whether their or their animals details have changed [if they have – they should be required to update those details]

Questions about the customer’s animal(s)
Details to be entered on drop down/tick boxes on the website or the information captured another way e.g. by an RQP contacting the customer by phone/email (if the latter, clearly explained on the website)

The following are examples of appropriate questions:

For pets/companion animals:
- species
- breed
- weight
- age
- is the animal healthy
- is the animal pregnant or lactating
- is the animal on any other medication [if so, they should be required to provide details]
- have you used this product before on this animal [if so, confirm that the animal did not have an adverse reaction to this product]
- Do you require additional information on how to use the product [so an RQP can contact them]
- Confirm customer has read the Summary of Product Characteristics (SPC) for this product [with a link to the VMD’s Product Information Database
- Confirm that the customer will use the product in accordance with its SPC (authorisation) and it will not be resold

For food producing animals:
- as above
- the CPH number where the animals are kept
- overview of the farm (e.g. production systems, animal health plans, appropriate equipment available to use the product e.g. cattle crush, plunge dip)


For individual horses:
- as above
- worming programme used

For stables/livery yards
- number of horses
- weights (either individuals or a total weight)
- where the stables are (name and address)
- person responsible (owner/keeper of stables/livery)
- confirmation that all horse owners are allowing their horses to be wormed collectively.
- pregnant/lactating
- other medications used
- product used before
- worming programme used

Questionnaire after checkout
If the questionnaire is completed after checkout, there is an explanatory note to customers immediately prior to them confirming their order, for example:

‘When purchasing veterinary medicines classified as POM-VPS and NFA-VPS you will be required to complete a questionnaire after checkout. Veterinary medicines will not be despatched unless the questionnaire is properly completed. Our vet/pharmacist/SQP will contact you if they have any queries regarding the appropriateness of the medicine for your animal. Payment for the medicines will not be taken until the questionnaire has been assessed and the supply authorised by our pharmacist’.

Prescriptions
If the retailer has a downloadable prescription, it must comply with the requirements of the Veterinary Medicines Regulations (VMR). Checks must be carried out on the bona-fides of all prescriptions, but especially those without specific veterinary practice headings, including the retailer’s own downloadable prescriptions. Only prescriptions with a practice stamp or other authentication should be accepted. The prescriber should be contacted if there is any doubt about the authenticity of the prescription.

A statement to the effect ‘that it is an offence for a person to submit a fraudulent prescription to obtain veterinary medicines and for a person to amend a prescription unless authorised to do so by the prescriber. Any suspected cases of fraud or tampering with a prescription will be referred to the appropriate enforcement body.’

Standard Operating Procedures

SOPs are dated and signed.

SOPs detail:
· how an order is placed by a customer,
· what information is captured (online or email/phone back questionnaire ) & how the RQP assesses that information
· how customers are advised of the suitability of VMPs for administration to food producing horses
· how the RQP checks that the customer is competent to use the product
· how the RQP authorises the supply

· how the RQP advises on the safe administration of the product and any warnings or contra-indications, including the suitability for use in food-producing horses

· how the correct product is picked, packed and despatched
· the procedure for checking the authenticity of written prescriptions and what happens if there’s a query (are hard copies requested)
· the procedure for dealing with repeat prescriptions
· how ‘critical events’ such as supply of incorrect product or receipt of a fraudulent prescription (notify the VMD), are logged
· how/what special attention is given to products with the potential for abuse

· what records of supply are kept and their retention period

· how the integrity of products is maintained during transport
· that delivery agents/staff aware of any special handling and storage arrangements for products being delivered
· whether or not recorded delivery is used
· the procedure for dealing with returns

• Critical incident log kept