Conselho Federal de Medicina Veterinária wants Anvisa to regulate the prescription of medicinal cannabis for animal use
Professional council recognizes the therapeutic properties of cannabis in animals, but states that professionals still do not have legal certainty to prescribe
By Manuela Borges
The Legal Technical Advisor of the Federal Council of Veterinary Medicine (CFMV), Rodrigo Montezuma, in an exclusive interview with the Sechat portal, explained that the Collegiate Board Resolutions (RDCs) of the National Health Surveillance Agency (Anvisa) only restrict the use of cannabinoids to human use. The CFMV's guidance is for professionals interested in prescribing cannabis-based treatment to seek legal support and protection to avoid jeopardizing their professional activities.
Check out the full interview below.
- Can veterinarians currently prescribe medicinal cannabis or is there still a legal gap on the subject?
The Federal Council of Veterinary Medicine has been urging Anvisa to fill this gap that currently restricts the prescription of cannabinoids only to human doctors. Today, veterinarians are still in this gap of possibilities or not, for the use of these products in animals.
- While Anvisa's Resolutions limit the prescription of cannabinoids only for human use, on the other hand, does the Agency's Ordinance 344 allow veterinarians to prescribe controlled substances, correct?
Exactly, and cannabinoids are included in Anvisa's Ordinance 344. The text states that professionals registered in the Medicine, Veterinary Medicine, and Dentistry Councils can prescribe and dispense the substances contained therein (Ordinance 344) with a reservation for doctors, group C medicines. However, these cannabinoid-based substances that are being widely used - not discussing the therapeutic effects - are limited. For now, due to Anvisa's RDCs, they are restricted to human use and importation for personal use. So far, no RDC has expanded the use of cannabis beyond doctors, and we have been urging Anvisa for a clearer position on this matter.
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- Currently, what are the procedures to import a veterinary medicine?
Initially, if the medicine is exclusively for veterinary use, the process is all done through the Ministry of Agriculture, Livestock, and Supply (MAPA). Obviously, with no issues regarding substances prohibited in the country. If the substance is allowed, registration with MAPA is sufficient.
- If a veterinarian prescribes cannabis today, what risks could they be facing?
This is an extremely important question! The recommendation that the Federal Council of Veterinary Medicine has been passing on is that veterinarians using this type of treatment seek legal certainty in prescribing, to avoid any kind of problem, especially with the law. So, define your patient's problem well, take the case to court for judicial authorization of the product, which is currently restricted to doctors.
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- Is the Federal Council of Veterinary Medicine working to end this legal uncertainty?
Exactly, we are collaborating with PL 369/2021, authored by Federal Deputy João Carlos Bacelar (Pode/BA), which addresses the use of cannabinoids in veterinary medicine, and we have already urged Anvisa by official letter to expand the range of professionals on the same terms as Ordinance 344, which allows not only doctors but also dentists and veterinarians to prescribe the substances contained in the text. Considering that the therapeutic effects of cannabis are extremely relevant and numerous benefits have been reported for patients, veterinary medicine also wants to use this type of substance for its patients.
- In other words, the Federal Council of Veterinary Medicine supports the regulation of cannabis and recognizes the plant's therapeutic properties?
Definitely! In addition, our institutional and legally established role is to ensure the safety of professional practice. This is the main role that CFMV plays in the country, not only in oversight but also in verifying the regulations for full professional practice.
- Even the Regional Council of Veterinary Medicine of São Paulo has created a working group to contribute to this agenda of cannabis for veterinary use, right?
Not only there, but it is gaining momentum there. We have been promoting this issue for over a year because the therapeutic properties of the plant are evident, and what we need now is precisely legal certainty in professional practice.
What Anvisa says:
Anvisa is the Brazilian agency responsible (for medical and scientific uses) for substances subject to special control in Brazil - in accordance with the UN Conventions of 1961, 1971, and 1988 - listed in the 1998 Regulation 344 of the Regulatory Agency.
According to the note sent by Anvisa's press office, although the registration of veterinary medicines is a competence of MAPA, cannabis derivatives are restricted in List “E” of Regulation 344/98 of the Agency, and this includes only possibilities for prescription for human use.
For veterinarians to be able to prescribe the medicine, according to Anvisa, the category would have to be included in the forecast of List “E” of Regulation 344/98, and after this change, the products would still have to comply with MAPA's specific regulations on the veterinary medicinal use of cannabis derivatives (if they are not actually medicines), or the registration of veterinary medicines with cannabis derivatives, according to the decision of that ministry.
Watch the full interview: