SQP stands for suitably qualified person in UK veterinary medicines legislation. This means suitably qualified to prescribe and supply animal medicines classified NFA-VPS and POM-VPS. S in VPS stands for SQP. SQPs are animal medicines advisors who register with a VMD-approved body such as Vetpol. The Animal Health Trade Associations Group Ltd created the name in 1987.
So who is a suitably qualified person in animal medicines?
A SQP is a Registered Qualified Person (RQP) working in animal health who holds an approved qualification in handling veterinary medicines. The SQP must register with a VMD-authorised body such as Vetpol.
RQP stands for Registered Qualified Person. In pharmacy and healthcare RQP means Qualified to prescribe or supply certain types of medicine and on a professional register. The Veterinary Medicines Regulations list a Suitably Qualified Person as a RQP permitted to prescribe and supply POM-VPS and NFA-VPS veterinary medicines from a registered premises.
All POM-VPS and NFA-VPS packaging and approved product literature carries the abbreviation VPS. S stands for SQP.
When was the name Suitably Qualified Person created?
The first recorded mention of SQP that we know of was when the Animal Health Trade Associations Group Ltd (company number 02140832) formed in February 1987. Companies House publishes the details. These are extracts from the relevant sections of the memorandum and articles of association:
1.b. “…to maintain a list of suitably qualified persons who could be persons nominated in respect of particular premises to be fit and proper persons authorised to sell by retail veterinary drugs not on a general sales list in accordance with the provisions of The Medicines (Exemptions from Restrictions on the Retail Supply of Veterinary Drugs) Order 1984 or any statutory amendment or modification thereof;”
2.b …”to draw up, oversee and maintain a Code of Practice for merchants selling or supplying veterinary drugs”.
2.d “…to organise suitable training courses towards a certificate of competence in the handling of veterinary drugs and other animal health products;“
Where ‘persons’ in SQP came from…who is responsible?
Medicines law wants to know what ‘person‘ is responsible for something. This normally means a human person, as opposed to a business. Regulators want to know who is responsible and accountable for supply. Legislators want to know who is going to be authorised and how?
The 1984 Order was laid before parliament in December 1984 but the legislation became effective in 1985. The order mentions ‘specially authorised persons’, not suitably qualified persons. The Order refers to ‘persons’ being registered, to registers of ‘persons’ and to codes of practice for merchants and for saddlers (11.b)(12.b). So, the legislation appears to be where ‘persons’ in SQP comes from.
Who created the SQP name?
In 1984 parliament had decided that retailers should follow codes of practice. By 1987 the members and directors of company 02140832 had decided that the name of the responsible individuals following the code of practice should be suitably qualified person. And they had decided that these ‘persons’ must undergo suitable training courses to be competent to handle veterinary drugs. So the Animal Health Trade Associations Group Ltd created the name in 1987 with the formation of the company. In September 1990 the company changed its name to Animal Medicines Training Regulatory Authority Ltd (AMTRA).
What did SQPs do originally?
The veterinary pharmaceutical industry agree that people in the veterinary industry supplying PML products need to be suitably qualified unless the product is classified AVM-GSL which means Authorised Veterinary Medicine General Sales List. Any retailer can sell an AVM-GSL product including on the internet.
From 1987 to 2005 the name SQP existed but not in legislation. The Royal Pharmaceutical Society of Great Britain (RPS) carried out inspections of premises in England, Scotland and Wales. A different body carried out inspections in Northern Ireland. But the inspections focused on the registered premises itself and less on the qualities of the person at the premises supplying the product.
Who else might be “suitably qualified” to prescribe animal medicines?
Suitable qualifications are important in healthcare generally. In the context of SQP suitable means specific training with veterinary medicines. The V and P in POM-VPS and NFA-VPS refer to vets and pharmacists. Vets and pharmacists are also Registered Qualified Persons (RQPs). In the eyes of the VMD all three groups are retailers. As with many healthcare professions vets and pharmacists have protection of title.
Veterinary Surgeons have had suitable training to be able to prescribe and supply veterinary medicines in the United Kingdom for decades before the 1984 Order. Pharmacists train primarily to be qualified for registration with the bodies governing human pharmacy. Some pharmacists do seek further training in veterinary medicines but most are busy prescribing products for humans.
Oversight of pharmacists involved with veterinary medicines
The General Pharmaceutical Council regulates pharmacists in England, Scotland and Wales. The Pharmaceutical Society of Northern Ireland regulates pharmacists in Northern Ireland. The human healthcare sector has recognised for many years that outcomes for patients prescribed medicines by healthcare professionals may be similar to those prescribed by doctors provided that these people are suitably qualified. Besides doctors other prescribers work in the field of prescribing pharmaceuticals for humans. Some pharmacists employ SQPs.
How did SQPs come to be able to prescribe veterinary medicines?
SQPs were originally trained to supply veterinary medicines. In the original 1984 order there was no mention of prescription or prescribing for PML products. The original directors of AMTRA also understood that SQPs needed training, examinations and certification of competence to supply from a registered premises. All this changed in 2005 with the introduction of a new veterinary medicines classification system in the UK under the influence of EU regulations.
The influence of EU Regulations on the UK veterinary medicine system
In 2005 the UK was part of the EU. The EU required member states to classify all veterinary medicines going into food production animals as prescription only. Across the EU this would normally mean vet only. Simultaneously dealing with the recommendations of the Marsh Report by Sir John Marsh into dispensing veterinary medicines together with the recommendations of the Competition Commission Report into the Supply of Veterinary Medicines the VMD response was to create a new medicines classification system. PML products going into food-producing animals such as cattle, sheep and horses were classified POM-VPS. PML products going into non-food producing animals such as dogs and cats were classified NFA-VPS. So VMD turned the products that SQPs were supplying into prescription medicines and put the name SQP into legislation.
Prior to the 2005 regulations there had been a grandfather clause that permitted entry to the SQP register without a requirement to sit a formal examination. The veterinary pharmaceutical industry requested the removal of this grandfather clause at about the same time. The pharmaceutical industry agreed that SQPs must always be qualified to prescribe or supply.
The name SQP is still the official name in the veterinary medicines regulations today. The EU also remains an important trading partner and the UK’s nearest neighbour.
Why are qualifications important to the medicines distribution system?
Prescription isn’t just about supplying products and getting money for them in return. To be effective advisors RQPs need to analyse risk and provide appropriate advice when they provide products. But lots of people who are unqualified also give advice on medicines. Much of that advice is damaging and probably the most current example of that is the antivax lobby. Some of the people giving out misinformation and bad advice via the internet today are even on some kind of professional register. Unqualified people also supply or prescribe medicines in other parts of the world and this creates risk to people, animals and the environment.
As with human healthcare, the veterinary medicines distribution system relies on RQPs being suitably qualified. Fundamental to this process of becoming qualified is taking exams or assessments before becoming registered. Today SQPs work in retail outlets, with pharmacies and with veterinary practices.
Qualification prior to registration as a RQP remains vital to the integrity of the medicines distribution system. That applies to both human and veterinary healthcare. The VMD maintains a Code of Practice that sets out the requirements for SQP qualification. You can find the current Code of Practice here.