The Humane Society of the United States (HSUS) works at the legislative level to encourage all states to implement a law called "direct licensing", that allows animal care and control agencies to possess and administer controlled substances to provide for euthanasia of shelter animals when needed. There are many existing variations of this law. However, true "direct licensing" is a state law that allows the agency to register with the Drug Enforcement Administration (DEA) to obtain and administer controlled substances without requiring a veterinarian to be on staff. The registration is usually in the name of the director of the agency, which is the most effective option, as there is more reason to ensure that the drugs are properly accounted for, secured, and administered if the person accountable is the agency's leader.
Some states have a variation of direct licensing that does not allow the animal care and control agency to have its own DEA registration, but rather a relationship with a local veterinarian who signs on as medical director and allows the agency to use the veterinarian's license to possess and administer the controlled substances. This approach creates significant responsibility and culpability on the part of the veterinarian, who is responsible for the method of administration, ensuring shelter staff is properly trained, and for periodically examining the records that account for the substances used. It can create obstacles for shelters if local veterinarians are unwilling to participate in this type of arrangement.
Furthermore, some direct licensing laws do not allow access to pre-euthanasia drugs, such as ketamine, which are sometimes necessary to ensure a humane and safe euthanasia process. Others may contain clauses that actually render the law ineffective. An example of this would be a loophole or unclear language regarding the designated state regulatory body for controlled substances in shelters.
The authority to possess and administer controlled substances is serious, and all parties involved must be fully aware of their role and responsibility. When controlled substances are stolen, unaccounted for, or improperly administered, it risks the reputation and public perception of shelter and veterinary personnel and increases the possibility that access to controlled substances might be rescinded. The HSUS urges that written protocols be put in place to ensure accountability, oversight, and proper use of controlled substances so all parties can ensure a humane death for the animals in our charge when necessary.
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