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REVIEW QUESTIONS
To illustrate the investigative process, following are several scenarios which are
similar to those encountered by FDA. Facts have been left out to demonstrate
how alternative facts affect our compliance decisions.
1. A farmer visits a local veterinarian and describes an illness that he is seeing in
his dairy cattle. The veterinarian asks a few probing questions and
determines his cattle have pneumonia. The veterinarian prescribes a drug
and labels the drug in accordance with the PMO guidelines. Does a proper
VCPR exist?
2. A dairy inspector visits the farms and finds a properly labeled prescription
drug from a veterinarian not licensed in that state. Does a proper VCPR
exist?
3. The vet last visited the farm a year ago. He provides properly labeled drugs
to the farmer and well written informational brochures describing the diseases
for which these drugs should be used. Does a proper VCPR exist?
4. The local mobile peddler hires a veterinarian to make rounds with him. When
the peddler sells prescription drugs, the veterinarian labels them in
accordance with the PMO. Does a proper V-C-P exist?
5. The farmer's veterinarian has left a prescription for a drug with the farmer.
The farmer purchases the drug from the mobile peddler. The peddler labels
the drug in accordance with the PMO. Does a proper VCPR exist? What if
the prescription was for 5 drugs? What about 25?
6. A farmer visits his consultant veterinarian and purchases a drug from the
receptionist. The receptionist identifies the farmer as a client of the doctor.
The receptionist labels the drug in accordance with the PMO. Does a proper
VCPR exist?
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