Pennsylvania Veterinary Controlled-Substance Log Requirements

Controlled-substance records

Veterinary medical records: at least 3 years from the last treatment date. Pennsylvania State Board of Veterinary Medicine rules require a separate veterinary medical record for each patient, herd, or group, as appropriate; the record must accurately, legibly, and completely reflect evaluation and treatment and identify the treating individual after each chart entry. Scope: the recordkeeping section does not apply to laboratory animal practice. For production animals, the rule substitutes Federal recordkeeping requirements (including 9 CFR) for the minimum-content list below; the section's separate-record and 3-year retention requirements state no production-animal exception. For animals other than production animals, minimum record content includes patient/client identifiers, vaccination and medical history, exam dates, diagnosis, laboratory and radiology findings, medical/surgical treatment, drugs administered/prescribed/dispensed including dosage, and anesthesia details for surgical/dental procedures. Client communication — the client's consent to or rejection of recommended diagnostic tests, treatments, and drugs — must be documented for any patient except a production animal. Records must be maintained for at least 3 years from the date the patient was last treated. ¹

Controlled-substance records: every practitioner licensed to administer, dispense, or distribute controlled substances must keep a record showing the amount administered/dispensed/distributed, date, patient name/address, and for a veterinarian, the owner name/address; the record must be kept 2 years and open for inspection. Persons registered or licensed to manufacture, distribute, or dispense controlled substances under the Act must also keep records and inventories in conformity with federal recordkeeping, order-form, and inventory requirements plus any additional Department regulations. Where a veterinary patient chart contains controlled-substance information, keep it for the longer applicable period. ²

Inventory and state-specific controls

No separate Pennsylvania controlled-substance registration for ordinary licensed veterinary practitioners. Pennsylvania's Drug, Device and Cosmetic Act defines "practitioner" to include a veterinarian licensed, registered, or otherwise permitted to dispense, administer, distribute, or conduct research with controlled substances in professional practice. The Act's annual registration requirement is written for manufacturers, distributors, and retailers, and then states that nothing in that section requires registration of a practitioner registered or licensed by the appropriate State board. A Pennsylvania veterinary practice therefore keys its ordinary controlled-substance authority to the Pennsylvania veterinary license plus the federal DEA registration, not a second Pennsylvania CS practitioner registration. ^{3 4}

Veterinary prescribing/dispensing authority: a veterinarian may prescribe, administer, or dispense a controlled substance, other drug, or device only in good faith in the course of professional practice and not for use by a human being; the veterinarian may cause a controlled substance, other drug, or device to be administered by a professional assistant under direction and supervision. ⁵

Dispensing label: when a drug or device is dispensed by a pharmacist pursuant to a prescription order, the label must include the pharmacy name/address and any applicable federal registration number, the patient name or, for an animal, the owner's name and the animal species, the prescribing practitioner's name, and prescription serial number/date; controlled-substance labels also require the transfer-warning sentence. For in-office veterinary dispensing, use the federal/DEA dispensing label rules plus the veterinary-board medical-record detail below. ⁵

Pennsylvania Act 17 of 2024 added xylazine and listed metabolites to Schedule III, but then states xylazine is not a controlled substance when used for enumerated veterinary and lawful animal-drug purposes, including dispensing or prescribing for, or administering to, a nonhuman species a drug containing xylazine that has been approved under 21 U.S.C. § 360b (new animal drugs) or is authorized under 21 U.S.C. § 360b(a)(4) — the federal extralabel-use provision. The same act added a secure-storage rule: a veterinarian must comply with the Pharmacy Act storage/protection provision for xylazine. ⁶

PDMP context

Pennsylvania's PDMP is the PA PDMP under the ABC-MAP Act (Act 191 of 2014). The Department of Health's PDMP guidance says pharmacies and dispensing prescribers must submit all Schedule II-V controlled-substance dispensation information to the PDMP no later than the close of the subsequent business day after dispensing. It also says the ABC-MAP Act requires pharmacies and dispensing practitioners to report all Federal and Pennsylvania Schedule II-V controlled-substance dispensations. ⁷

Veterinarians are excluded from the PA PDMP. The PDMP's own Q&A excludes veterinarians from both operative definitions: the prescriber definition ends "The term does not include a veterinarian," and the statutory exclusion list inside the dispenser definition — the first question of the Dispenser Q&A — includes "A veterinarian". The registration answer states that all licensed prescribers lawfully authorized to distribute, dispense, or administer controlled substances in Pennsylvania must register with the program and adds "This does not include veterinarians". The Q&A's xylazine answer applies the exclusion directly to veterinary practice: the scheduling of xylazine "does not pertain to veterinarian dispensations, prescriptions, or administrations," and dispensations, prescriptions, or administrations of drugs containing xylazine to non-human species "are not reported to the PA PDMP". A Pennsylvania veterinary practice therefore does not register with, report in-office dispensing to, or carry a query duty under the PA PDMP. ⁷