Pharmacy Consultants of Texas

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Veterinarians and USP 800: What to Know

Vanessa Brown

“If there’s puppies… I’m in.”

That was the answer I held back when we were hired by a veterinary hospital needing to become USP 800 compliant.

This was such a cool and enlightening experience that we felt compelled to share for two reasons:

  1. It is an area of pharmacy that is often overlooked!

  2. I hope this reaches other veterinary facilities to let them know what resources are out there.


As we have been digging the ditches and navigating USP 800 implementation in various pharmacy settings, I realize we can’t miss this very important facet of health care.


USP 800 was created to reduce an employee’s exposure to hazardous drugs. This absolutely applies to veterinary clinics and hospitals.

FUN FACT: It was a veterinarian diagnosed with thyroid cancer at a young age who helped mold what USP 800 is today. Here’s a link to an article he co-authored through the CDC and NIOSH.

All healthcare settings with hazardous drugs (HD) need these standard items: HAZCOM Program, Hazardous Drug Handling Standard Operating Procedures, Hazardous Drug List, Assessment of Risk, and documented training.

Here are the fundamental similarities compared to a “traditional pharmacy” with a few tips if you are in a veterinary setting:

  1. Large Inventory:

    • The variety and amount stocked rivals some smaller independents.

    • Stock may be stored in various shelves, carts, and rooms throughout the facility.

    • VET TIP: Find ways to identify all the hazardous drugs in your storage and place signage to make all staff aware.

  2. Compounding:

    • This is not always sent to a compounding pharmacy.

    • Splitting, crushing, and mixing manipulations may occur here more than in a retail pharmacy.

    • Training for these skills may often be on-the-job training only.

    • VET TIP: If you continue to preform manipulations on final dosage forms, create a proper training program for your techs who will be compounding.

    • TIP: You may need to consult a professional to determine what engineering requirements must occur to continue compounding manipulations. Email info@pharmacyconsultantstx.com

  3. Dispensing:

    • The key difference here is the ultimate user (the pet) must have an owner administer the medication. So there may also be some simple precautions for the owner to take, i.e. wearing gloves.

    • VET TIP: Create a slip of instructions or add to the label to notify owners of special precautions to take and then practice the delivery: “We recommend wearing gloves when handling the capsule then wash your hands after.” Know what to say if they ask why without inadvertently scaring them.

And more importantly, there were some unique differences to highlight. ALL of these increase the risk exposure:

  1. Multitasking:

    • Yes, WE all multitask, but in this setting its different: they assess, diagnose, and treat. The Vets and Techs are exposed to hazardous chemicals (cleaning), radiation (X-ray), drugs (dispensing), chemotherapy (administration) and metabolites (pet excrement).

    • VET TIP: Create possible exposure risks for each job task and develop protective procedures. Ensure staff are trained on each procedure before allowing them to perform independently.

  2. Hazardous Drug List/ Assessment of Risk:

    • The hazardous drug list the facility creates may take longer to create. WHY?

      • The NIOSH only evaluates drugs that are listed through CDER at the FDA approved for human use.

      • Until the NIOSH publishes their veterinary resource guide (which I have been told they are developing)- it is up to the FACILITY to investigate these veterinary-only medications to determine if they should be labeled hazardous or not.

      • VET TIP: Pull Package Inserts and SDS sheets for medications you suspect may be hazardous. Consider them hazardous until more information determines they are not.

      • VET TIP: Your Assessment of Risk should include how to minimize exposure risk these scenarios: Receiving, Storage, Manipulations, counting, administration, handling animal fluids (emesis), Cleaning excrement, cleaning kennels/cages.

    • VET RESOURCE LINK: NIOSH VET REFERENCES

    • What is an Assessment of Risk?

    • How do I do and Assessment of Risk?

    • NIOSH List

  3. Administration:

    • This is one of the higher risks for exposure in the workflow process.

    • Dosages for animals may be higher vs. dosing for a human, possibly increasing the severity of adverse effects in the event of a spill, skin contact, etc.

    • Giving an injection, topical or even an oral dose may be more difficult in a sick animal that is scared vs a cooperating human (screaming toddlers not included).

  4. Cleaning and Disposal:

    • Cleaning in a veterinary facility can include:

      • Animal emesis after oral administration of a HD (because dogs love eating everything they shouldn’t!)

      • Animal excrement with active metabolites after chemo administration

      • Kennels and cages that are possibly contaminated

    • VET TIP: PPE guides during the cleaning process should be added to the Assessment of Risk per for each drug.

While your board is deciding whether to enforce or not, or to defer to the state’s board of pharmacy, the onus is on the facility: Protect your staff.

Key elements:

  1. How to practically apply this in each step of your workflow

  2. Create your policies and procedures

  3. TRAIN the staff

  4. Annually keep up with the list and training.

And just for good measure. Here’s another pup pic :)

Links to References: