Learn why certain medications are under lock and key, and why your vet works hard to make sure they are available for your horse.
It’s no secret that the misuse of medications has become a public health crisis. In fact, the opioid epidemic makes headlines almost daily due to growing numbers of overdose deaths. So, what does this have to do with you and your horse? More than you might think.
In fact, fentanyl, widely considered the world’s deadliest opioid, has become even more dangerous as it is being mixed with xylazine, a sedative that many equine veterinarians reach for multiple times per day.
It turns out xylazine enhances the effect of fentanyl and increases its value on the street. It also makes opioids like fentanyl even more dangerous, in part because it’s immune to the effects of the life-saving reversal drug naloxone (Narcan). That means the bottle of xylazine you keep in your tack trunk could easily contribute to an overdose death if it were to make it to the street.
Xylazine isn’t the only drug used in horses that can be dangerous to humans—it’s just one that has recently hit the news. Other medications that your vet regularly uses to treat your horse, including ketamine, used for short-term anesthesia, and sodium pentobarbital, used for euthanasia, can also pose a threat.
Enter the Drug Enforcement Administration (DEA), the government agency responsible for overseeing these potentially dangerous medications.
In this article, I’m going to answer any questions you might have about the DEA: what it is, how it functions, and why it matters. With this information in hand, it’ll be easier to understand why your vet says no to some of your medication requests, and how hard they work to make sure your horse still gets what he needs.
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The DEA: Your Questions Answered
What is the DEA?
The DEA is a government agency that oversees laws and regulations related to medications that require restrictions to protect public health. This oversight can impact your horse life by making it more difficult to get your hands on certain medications. But it’s also critically important for keeping people safe. The DEA’s mission also includes educating the public about medications and their potential impacts. As well as supporting programs aimed at preventing drug abuse.
Why are some medications “controlled”?
Medications are selected for DEA control based on whether or not they have a legitimate medical use, their potential for abuse, and safety concerns. Safety concerns include the likelihood that they will lead to either physical or psychological addiction in people who use them.
What are the different levels of controlled medications?
Controlled substances are divided into five separate categories, called schedules. Here’s how they are divided:
Schedule 1 medications are the most heavily controlled. They have a high potential for abuse, and the potential to create severe physical and psychological addiction. They also have no current, accepted medical use. Example: heroin. (Interesting note: marijuana is currently a DEA schedule 1 substance. More on that in a minute.)
Schedule 2 medications do have a current, accepted medical use, but a high potential for abuse and development of addiction. Examples: Vicodin (hydrocodone) and fentanyl.
Schedule 3 medications have a current, accepted medical use and moderate to low potential for abuse and addiction. Example: ketamine.
Schedule 4 medications have accepted medical use and low potential for abuse or dependence. Example: Xanax.
Schedule 5 medications require the lowest level of control, with the lowest potential for abuse or dependence. Example: Cough medications with low levels of codeine (i.e., Robitussin AC).
How can marijuana be legal in my state if it’s a DEA Schedule 1 medication?
Here’s where things get really confusing. Medication control is regulated on both a state and federal level, meaning different rules apply in different states. Marijuana is a perfect example of this scenario.
Although the DEA still maintains marijuana on the list of schedule 1 medications, it’s scheduled and managed differently in some states. It’s also helpful (and confusing!) to recognize that controlled substance lists are constantly changing based on new knowledge or information about different substances.
For example, it has become widely accepted that marijuana does have some legitimate medical use, and the DEA is currently considering a change to marijuana scheduling from schedule 1 to schedule 3. Meanwhile, state laws regarding marijuana use are actively evolving. This means laws surrounding control of marijuana are not only inconsistent from state-to-state, they’re also likely to change.
In the horse world, the situation with xylazine is similar. While xylazine was not previously scheduled at all, recent issues with this medication’s involvement in overdose deaths have led both the DEA and individual states to add it to controlled substance lists.
The balancing of federal and state laws, and the potential for medications to change in status, make is especially hard to keep track of what’s required for every individual medication.
What does it take for my veterinarian to have these medications on hand?
It’s more complicated than you might think. The first step your vet must take to legally prescribe any controlled medications is to apply for a DEA number, which requires state licensure and a permit or license to prescribe controlled substances in that state.
The process varies in every state, and even though the DEA is a federal agency, your vet must apply for a separate DEA license in each state where they intend to practice. It takes between four and six weeks to complete the process and costs just under $1,000. The application process is a serious matter, and the penalties for providing false information are severe—up to $250,000 or four years in jail.
Once your veterinarian has been issued a DEA number, they have to provide it to the distributors they work with in order to obtain any supplies of a controlled medication. And once they have the medication in their hands, the rules don’t stop.
Recordkeeping and Security for Controlled Substances
Recordkeeping and security for controlled substances is a critical aspect that veterinarians must take seriously.
Then…
It is important to store any scheduled medications in a secure lockbox with limited access to a small number of people. This includes medications carried by veterinarians in their trucks, which should be kept in a locked drawer. Veterinarians maintain a controlled substance log that tracks the administration and dispensing of every drop of medication, detailing how it is given and where it goes. During a final accounting, veterinarians must be able to match the amount of each medication dispensed or administered to what they have obtained from their distributor. This recordkeeping task can be daunting.
If the accounting does not match, veterinarians can face serious consequences. The DEA can conduct audits to check compliance with anyone holding a DEA number at any time, with insufficient or inadequate records being the most common violations reported. Fines for non-compliance are steep, and veterinarians could end up owing thousands of dollars in fines or even face jail time if large amounts of controlled substances go missing without accountability.
Managing controlled substances is a major concern for veterinarians, and it is understandable why they cannot simply provide a bottle or dose of medication that falls under DEA control.
Do the Changes Mean Xylazine Will Be Harder to Get?
Yes, there is a possibility that obtaining xylazine could become more challenging. Issues related to xylazine are widespread, with fentanyl laced with xylazine being identified in 48 out of 50 states. This has prompted the U.S. government to recognize this drug combination as an emerging threat in the country, leading to increased attention from the DEA and efforts to add it to controlled substance lists. While reports indicate that the xylazine on the street has not been largely diverted from veterinary sources, industry leaders are working to ensure its availability for veterinary use. However, veterinarians may soon be required to closely monitor the distribution of xylazine down to the last drop, making it less accessible for general use.
A Week in the Life
Let’s follow the path of a controlled substance, starting from when a veterinarian places an order with their distributor, to understand the process and potential challenges.
T-5 days
You schedule a castration for your horse, requiring ketamine, a DEA schedule 3 medication. The veterinarian orders ketamine from their distributor.
(Note: Xylazine, diazepam, and midazolam may also be part of the procedure and have similar requirements. For this example, we focus on ketamine.)
T-3 days
The ketamine order arrives at the veterinarian’s office, logged in the controlled substance inventory and secured.
Red Flag warning: It is crucial to have trustworthy personnel handling ketamine to prevent diversion. Access to the controlled substance lockbox should be limited to trusted individuals.
T-0 days
On castration day, the veterinarian administers ketamine from the lockbox to your horse and records the usage in the controlled substance log.
Red Flag warning: Accurate recordkeeping is essential to ensure the logs match the actual usage of controlled substances.
T+15 days
At the end of the month, the veterinarian reconciles the ketamine administered with the amount ordered and used, maintaining accurate records.
Red Flag warning: Neglecting proper recordkeeping can lead to penalties if the DEA inspects and finds discrepancies in controlled substance logs.
Red Flag warning: Even with stringent controls, missing ketamine raises concerns about diversion and potential harm to the public. Understanding the regulations around controlled substances underscores the responsibility veterinarians have in ensuring compliance and safety.
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