New York Vet Clinic Inspection Checklist

Controlled substances and PDMP

Controlled-substance authority depends on how the New York practice is set up. New York's controlled-substances law defines "practitioner" to include a veterinarian licensed or otherwise permitted to dispense, administer, or conduct research with controlled substances in the course of licensed professional practice. For an individual veterinarian acting as a practitioner, Part 80 permits dispensing "in good faith and in the course of their professional practice only". ^{1 2}

Institutional dispenser warning: New York separately treats a "veterinary hospital" as an institutional dispenser when it is approved and certified by the Department to obtain, dispense, and administer controlled substances pursuant to practitioner orders. Part 80 says veterinary hospitals qualified for controlled-substance privileges must first obtain a Class 3 controlled-substances license from the New York State Department of Health, then obtain DEA registration. This module does not decide whether a particular independent practice is a practitioner office or a veterinary hospital/institutional dispenser. ^{1 3}

New York's prescription monitoring program is the PMP Registry. The registry covers information reported by pharmacies and by practitioners who dispense controlled substances. New York requires a practitioner who dispenses controlled substances to submit dispensing information electronically to the Department no later than 24 hours after delivery; for animal patients, the patient-name field is filled with the animal owner's name, and the report includes species code and animal name if applicable. When applicable, the practitioner must also file a zero report or obtain a zero-report waiver. ^{4 2}

Workplace safety and x-ray

New York operates an OSHA-approved State Plan for state and local government workers only. Private-sector employers and workers are covered by federal OSHA, so the federal OSHA baseline in this kit remains the operative OSHA framework for a private practice. New York does, however, impose a separate private-sector workplace-safety duty outside OSHA — the NY HERO Act, below — which a New York practice must keep on file alongside the federal OSHA documents in this kit. ⁵

NY HERO Act (Labor Law 218-b) — airborne infectious disease exposure prevention plan. New York Labor Law Section 218-b requires each private employer — "any person, entity, business, corporation, partnership, limited liability company, or association employing, hiring, or paying for the labor of any individual," excluding government employers — to establish an airborne infectious disease exposure prevention plan, either by adopting the model standard published by the Commissioner of Labor for its industry (or the general model standard) or by establishing an alternative plan that equals or exceeds the model's minimum standards. The employer must provide the plan to employees in writing (and to each newly hired employee upon hiring), post it in a visible and prominent location within each worksite, and include it in the employee handbook if the employer provides one. ⁶

New York registers radiation installations with operable or intended-to-be-used radiation equipment through the Department of Health, unless registration with the New York City Department of Health is accepted for installations under the NYC inspection program. A new installation not already registered must apply between 60 and 30 days before establishment; renewal applications are due between 60 and 30 days before certificate expiration; and operator or location changes use the same 60-to-30-day advance window. A certificate of registration is issued for a period not to exceed two years — except that the Department may issue a certificate for a longer period in order to stagger expiration dates for administrative purposes — is not transferable, must be conspicuously posted, and changes affecting registration information must be reported to the Department in writing within 10 days. ⁷

For veterinary radiographic installations, New York requires beam-restricting collimation, diagnostic protective tube housing, required filtration, and a dead-man exposure switch. During exposure, only persons required for the procedure may be in the room; mechanical supporting or restraining devices must be used when an animal must be held where practicable; animal or film holding is allowed only under clinically necessary extreme conditions; holders wear at least 0.5 mm lead-equivalent gloves and 0.25 mm lead-equivalent aprons, keep body parts out of the useful beam, and are exposure-monitored; pregnant women and persons under 18 may not hold animals or films. Portable/mobile units must have a dead-man switch cord long enough for the operator to stand at least six feet from the animal patient, x-ray tube, and useful beam. ⁸

Records and sharps

Veterinary medical records: New York State Education Department guidance says veterinary medical records must be adequate and retained for three years from the date of treatment, in original or legally reproduced form. The same guidance says original medical records or copies may be released only to, or as authorized by, the client or to individuals permitted by federal and state law. ⁹

Controlled-substance records: every veterinarian or other authorized practitioner must keep records of all controlled substances purchased and all controlled substances dispensed or administered from the practitioner's own stock. Purchase records include delivery date, drug type and quantity, and supplier name/address; disposition records include dispensing/administering date, patient name/address, and drug type and quantity. New York requires a biennial inventory for controlled substances listed in Section 3306; a federally compliant biennial inventory is deemed compliant with the New York inventory rule, and a copy must be retained with other controlled-substance records and available for inspection for at least five years. ^{10 11 12}

New York regulates sharps as regulated medical waste (RMW). DEC identifies RMW as material generated in research, production and testing of biologicals or health care, including infectious animal waste and "Needles and syringes (sharps)". DEC lists veterinarians among examples of regulated institutions. ¹³

Treatment/disposal: RMW must be properly treated to destroy disease-causing organisms before disposal at an authorized solid-waste management facility; treatment/disposal requires a permit, and sharps must be destroyed before disposal. ¹³