AVA Submission to the Proposed amendment to the Poisons Standard - 3.4 Lidocaine

20 Jan 2022

The AVA supports the amendment, and a return to a prescription-only Schedule 4 categorisation of all forms of injectable lidocaine.

A summary of reasoning follows:

  • The AVA was deeply concerned by the decision to make the injectable anaesthetic drug lidocaine available as an over-the-counter product on the S5 Schedule, effective 1.10.21.
  • The TGA committee based much of their approval on the assumption that the drug was “in a bottle with a tamper resistant cartridge which can only be dispensed through a rubber ring applicator” and thus not a threat to public health.
  • The AVA contends that this argument is flawed, as the product is in fact NOT sufficiently tamper-resistant to meet the criteria for Schedule 5:
    • We have provided video evidence separately demonstrating that the cartridge that is applied to the NumOcaine bottle can be easily twisted off by hand or removed with a teaspoon.
    • Alternatively, the lidocaine can be dispensed independently of ring application by activating the pump on the applicator and dispensing the liquid into another receptacle.
  • These risks were considered manageable by the veterinary profession when lidocaine was restricted through S4 scheduling. The recent S5 scheduling opens the door for unrestricted access to lidocaine, placing animal welfare and public health at risk. These risks are detailed in the submission and include:
    • risks of toxicity in target and non-target species
    • animal welfare risks due to inappropriate use by lay operators, for example to perform illegal acts of veterinary science (target and non-target species)
    • diversion of use to mask pain and injury in performance animals eg horses and greyhounds
    • use to perform illegal procedures on humans eg illegal body “modifiers”
    • addition to illegal human street drugs such as cocaine
    • use in human suicide.
  • The AVA also refutes the statement in the September 2021 scheduling decision that the need for veterinary prescription may lead to “logistical difficulties” and “reduced uptake of the product”. There is no impediment to supply by veterinarians, nor was this substantiated by the former applicant.
  • A third flaw in the September 2021 scheduling decision was the argument that “Allowing nonprescription access to injectable lidocaine could …lead to a significant increase in animal welfare”. It does not appear that the TGA committee consulted with animal welfare experts to assess the veracity of that claim. In fact, the research and field experience to-date suggest the pain relief offered by this system is modest and short-lived at best. Given the nature and extended duration of pain associated with use of rubber rings, it can be argued that other methods of castration and tailing are preferable from an animal welfare perspective.

Read thhe full submission here.