AVA Lodges Submission Supporting QLD Draft Standards on S8 Medicine Storage

The AVA has lodged a formal submission to Queensland Health on the Draft Departmental Standard: Secure Storage of Schedule 8 (S8) Medicines.

The AVA strongly supports the draft Standard, particularly its explicit recognition that veterinarians may securely store S8 medicines in vehicles when practising away from fixed registered premises, provided appropriate security outcomes are met. This represents a significant and long‑standing advocacy win for the profession, especially for veterinarians working in mobile, afterhours, rural, regional and remote settings.

Key points from the AVA submission

  • Vehicle-based storage recognised
    The draft Standard appropriately acknowledges that vehicles can be a legitimate place for S8 storage when veterinarians are working in the field, aligning veterinary practice with other mobile services such as the Royal Flying Doctor Service and Queensland Ambulance Service.
  • Outcomes-focused, risk-based approach welcomed
    The AVA supports the Standard’s focus on security outcomes—restricting unauthorised access and preventing easy removal—rather than prescribing rigid, impractical measures.
  • Alignment with real-world veterinary practice
    The submission highlights that veterinarians routinely practise outside traditional premises and rely on secure vehicle storage using combinations of concealment, lockable compartments, alarms, supervision and situational risk assessment.
  • Practical clarity requested for common vehicle configurations
    Members identified the need for clearer guidance confirming that S8 medicines stored in locked containers (including fridges) within locked canopies or utility trays, in vehicles fitted with alarm systems, meet the required security outcomes—without imposing disproportionate technical or financial burdens.
  • Guidance sought for aircraft and non-road transport
    The AVA also recommended clarification on how detectability requirements apply to aircraft and helicopters used in veterinary practice, noting the need for flexible, risk-based solutions.

The AVA commends Queensland Health for constructive stakeholder engagement and responding to the AVA’s call for adopting a practical, proportionate regulatory framework that supports animal welfare, practitioner safety, continuity of veterinary services, and medicine security.

The full AVA submission can be viewed here