Attachment 06 - Canine Medical Protocols.docx
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- Diplomatic Security/Overseas Protective Operations (DS/OPO) Global Canine Services (GCS)
- Solicitation number
- 19AQMM22R0127
About this file
This document provides veterinary protocols and requirements for the Department of State's Global Canine Services contract. The contract supports the Department's global protective and security mission by deploying explosive detection canine teams to strengthen security postures abroad. The document outlines various medical services required such as annual exams, surgery, dentistry, and vaccinations. It specifies protocols for intake, phase I diagnostic testing, and phase III procedures including spay/neuter and gastropexy. Retirement age is seven years for overseas canines and nine years for domestic validator canines. The document establishes standards for facilities, controlled substances, records keeping, and licensure to ensure regulatory compliance and quality care.
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Attachment 1
| CVC Canine Wellness and Support |
| Global Canine Services (GCS) IDIQ Contract |
Attachment 6 – Canine Medical Protocols
U.S. DEPARTMENT OF STATE
GLOBAL CANINE SERVICES (GCS) IDIQ
IDIQ - ATTACHMENT 06
CANINE MEDICAL PROTOCOLS
Version: 4/26/2022
Table of Contents
| SECTION 1 | DESCRIPTORS AND SPECIFICS | 4 |
| 1.1 | Dentistry | 4 |
| 1.2 | Diagnostics – Annual | 4 |
| 1.3 | Emergent Care | 4 |
| 1.4 | Euthanasia | 4 |
| 1.5 | Fitness-For-Duty (FFD) Examinations | 4 |
| 1.6 | Health Certificate Examinations | 5 |
| 1.7 | Imaging | 5 |
| 1.8 | Laboratory Services | 5 |
| 1.9 | Post-operative Care | 5 |
| 1.10 | Prescription Medication | 5 |
| 1.11 | Preventatives | 5 |
| 1.12 | Sick call examinations | 5 |
| 1.13 | Specialist Consultation | 6 |
| 1.14 | Supplements | 6 |
| 1.15 | Surgery – Elective | 6 |
| 1.16 | Surgery – Emergency | 7 |
| 1.17 | Surgeries – Other | 8 |
| 1.18 | Vaccinations | 8 |
| 1.19 | Wellness Care | 9 |
| SECTION 2 | CONUS VETERINARY REQUIREMENTS | 9 |
| 2.1 | Intake and Arrival | 9 |
| 2.2 | Phase I | 9 |
| 2.3 | Phase II | 10 |
| 2.4 | Phase III | 10 |
| SECTION 3 | VETERINARY REQUIREMENTS FOR VALIDATOR EDCs | 11 |
| SECTION 4 | VETERINARY REQUIREMENTS FOR FERAL ANIMAL CONTROL | 12 |
| SECTION 5 | OTHER RELEVANT VETERINARY REQUIREMENTS | 12 |
| 5.1 | Controlled Substance Management | 12 |
| 5.2 | Medical records | 13 |
| 5.3 | EDC retirement | 13 |
| 5.4 | Veterinary facilities | 14 |
| 5.5 | Licensure | 14 |
SECTION 1 DESCRIPTORS AND SPECIFICS
This medical attachment contains specific terms and descriptors which the reader may require a broader understanding. These terms and descriptors are detailed in Section 1 of this document. This shall serve as a reference for specific details regarding various criteria detailed herein. For example, the term “Wellness” in Section 2 refers to various health and hygiene tasks such as bathing and trimming toenails.
1.1 Dentistry
A. This term refers to all levels of EDC dental care, from the oral examination to endodontics.
B. When required, sites should be capable of performing Comprehensive Oral Health and Treatment (COHAT) procedures, including the ultrasonic scaling of tartar, probing for pockets, and subsequent polishing of the teeth. All COHAT procedures shall be performed with the patient under general anesthesia. Dentistry also refers to the ability to perform oral examinations, extractions of diseased tooth/teeth, tooth-root abscess treatment, and dental radiography. Endodontics are authorized for EDCs when appropriate, as is specialist consultation on advanced dental cases. The use of regional anesthetic during dental or oral surgical procedures shall fall within this description.
1.2 Diagnostics – Annual
A. EDCs shall receive the following diagnostics annually: complete blood count, serum chemistry (minimum 12-part), urinalysis (stick and sediment analysis), fecal floatation, and a heartworm antigen test via an ELISA technique. Appropriate additional age-related tests are authorized, as are additional follow-up tests based on results of the above.
1.3 Emergent Care
A. Veterinary facilities shall maintain the ability to manage hospitalized patients, including 24-hour care when necessary.
1.4 Euthanasia
A. Veterinarians are required to always keep appropriate medication(s), and/or equipment on-hand, if an animal requires euthanasia. Canines will only be euthanized at the discretion of USG and in accordance with the IDIQ. Euthanasia shall only be conducted utilizing techniques authorized by the American Veterinary Medical Association (AVMA).
1.5 Fitness-For-Duty (FFD) Examinations
A. EDCs will receive a FFD examination on an annual basis. Each EDC will also receive a FFD exam not more than ten (10) days after arriving to the OCONUS task order performance location. These examinations shall include the following (at a minimum): appropriate history of diet, thirst, exercise, and work performance; determination of general appearance (e.g., eyes, ears, nose and face, mouth, gums and teeth, skin, coat, etc.), auscultation of the heart and lungs, musculoskeletal evaluation, neurologic evaluation, and abdominal palpation. The above list is not exhaustive; additional physical examination inclusions are authorized.
1.6 Health Certificate Examinations
A. EDCs will be given a physical examination and appropriate treatments in accordance with requirements set forth by the country of travel destination. Upon successful completion of this examination, appropriate health certificates (domestic and/or international) shall be administered. USDA endorsement of these certificate(s) is authorized.
1.7 Imaging
A. Imaging refers to the capability to perform and interpret radiography and ultrasonography (at a minimum). When appropriate, submission for a consultation from a radiologist is authorized.
1.8 Laboratory Services
A. This refers to the ability to run the following, at a minimum, on-site: complete blood count (CBC), serum chemistry profiles, heartworm antigen tests, Ehrlichia/Anaplasmosis/Borellia antibody testing, fecal floatation and smear, urinalysis (stick and sediment analysis). Outsourcing to off-site diagnostic laboratories is authorized when a test is both medically necessary, and on-site capabilities do not exist.
1.9 Post-operative Care
A. All surgical procedures shall be accompanied by an appropriate and comprehensive plan to mitigate pain and infection during the post-operative period. This includes the prescription of medications, bandage application and changes, and/or sedatives when appropriate. The use of therapeutic lasers and other rehabilitative modalities are authorized.
1.10 Prescription Medication
A. This refers to the prescription of a drug to appropriately treat various conditions, including acute and chronic diseases. Prescriptions shall be appropriately labeled in accordance with regulatory requirements specific to the veterinarian’s place of performance. Veterinarians shall be knowledgeable of local labeling requirements in their location; more stringent requirements shall be followed (when present) and shall supersede the above.
1.11 Preventatives
A. This refers to the administration of various preventative medications. This commonly includes heartworm/intestinal parasite and flea/tick preventatives. The veterinarian or veterinary technician shall be responsible for ensuring that these preventatives are administered at the appropriate frequency and dosage. All active GFP EDCs are required to receive both a heartworm/internal parasite and a flea/tick preventative for the duration of their working life.
1.12 Sick call examinations
A. These examinations are conducted on animals identified by any canine personnel as potentially having some type of disease, condition, or injury. At the veterinarian’s discretion, these examinations can include a full orthopedic, neurologic, ophthalmic, and/or general examination. Additional diagnostics and sampling are authorized for sick call examinations. Fine needle aspirations, skin scrapes, cytology can be performed at this time, along with other diagnostics relevant to obtaining an accurate diagnosis and/or facilitating treatment. These examinations may be accompanied by the prescription of medication(s), supplement(s), and other treatment(s) at the veterinarian’s discretion. The most common presentations sick call examinations are conducted for diarrhea, vomiting, ear disease, and lameness.
1.13 Specialist Consultation
A. Specialists can be consulted for EDC care in an effort to provide the highest level of care. Authorized specialties include, but are not limited to surgery, neurology, cardiology, oncology, ophthalmology, internal medicine, dentistry, and dermatology.
1.14 Supplements
A. This refers to non-prescription products administered as an adjunctive therapy or preventative to an acute or chronic condition. Commonly administered supplements include gastrointestinal probiotics, joint supplements, and skin supplements. Veterinarians shall remain aware of interactions between either other supplements or other prescribed medications.
1.15 Surgery – Elective
A. Elective surgeries are done in advance of a specific disease, injury, or condition; performed in an attempt to prevent a disease, diseases, condition or injury in order to improve, maximize, and/or prolong the working life of an EDC. These procedures shall be performed under general anesthesia. Elective surgeries should be followed by a thorough post-operative treatment plan to include pain management and infection prevention. Examples of elective surgical procedures, along with major conditions in which they prevent, include but are not limited to:
1. Ovariohysterectomy/ovariectomy (i.e., “Spay”) performed on EDC bitches in an effort to prevent pregnancy, malignant ovarian tumors, ovarian cysts, pyometra, and malignant mammary tumors. Spaying bitches also diminishes both the distracted work performance often seen by females while they are in heat, and the distracted work performance of other EDCs (males and females) when tasked with working around a bitch in heat. The target of a spay procedure is to remove the ovaries which produce sexual hormones needed to ovulate and maintain pregnancy. This is accomplished by removing both of the ovaries and the uterus (ovariohysterectomy), or both ovaries (ovariectomy). Either procedure is an acceptable technique to spay an EDC.
2. Castration (i.e., “Neuter”) is performed on male dogs when deemed medically appropriate to prevent or treat prostatic hyperplasia, prostatic cysts, prostatitis, and/or scrotal dermatitis. Anecdotally, neutering also helps to prevent or mitigate unwanted behavioral characteristics such as frequent urinary marking, inappropriate mating activity, and aggression. Castration is performed by removing both testicles through either a pre-scrotal or scrotal approach, with either approach being acceptable. Concurrent scrotal ablations are authorized at the veterinarian’s discretion. In the event that a testicle is retained (i.e., “cryptorchid”), the retained testicle should be removed at the same time as the testicle which is not retained.
3. Gastropexy is a surgical preventative to gastric dilatation with volvulus (GDV, i.e., “Bloat”). The gastropexy is performed numerous different ways; midline incisional approach, right paracostal approach, laparoscopically, or laparoscopic assisted. Regardless of the technique, the result is that an area of the stomach close to the pylorus sutured to the abdominal musculature. Incisions are made into both the stomach wall (non-penetrating) and abdominal musculature, and these incisions are sutured together. The incisions allow for scar tissue to develop, creating a permanent adhesion (scar) that prevents the stomach from rotating.
4. Caudectomy. Commonly referred to as a tail amputation, caudectomies are a salvage procedure to most commonly treat either refractory trauma to the tail tip, or a fractured tail. This injury is very common in EDCs due to their constant spinning within their kennel. Other conditions necessitating a caudectomy include crushing trauma (e.g. tail caught in a vehicle door), or a degloving wound to the tail tip.
5. Mass removal. Several dermal and subcutaneous skin tumors can be malignant. If malignancy is suspected, these masses should be removed at the earliest operational opportunity. Commonly seen skin malignancies include mast cell tumors, soft tissue sarcomas, and melanomas. If possible within the assigned duty location, all removed masses shall be submitted for histopathology to obtain an accurate diagnosis.
1.16 Surgery – Emergency
A. Emergency surgery shall be defined as a surgical procedure performed when required to save life, limb, or eyesight. These surgeries are conducted with minimal lead time, often on EDCs who are suffering from some degree of debilitation (dehydration, shock, etc.) from the condition requiring surgical correction. These surgeries shall be performed with the EDC under general anesthesia. These surgeries should be followed by a thorough post-operative treatment plan to include pain management and infection prevention. Examples of common emergency surgeries performed on EDCs include, but are not limited to:
1. GDV de-rotation. A surgery performed to correct GDV. In this surgery the stomach is accessed through a midline incision and rotated back into its normal anatomic position. A gastropexy shall be performed after the stomach has been returned to its normal anatomic position. The entire abdomen should be explored at the time of correction. Other procedures should be performed based abnormal findings noted during abdominal exploration. Examples include splenectomy, and resection of any area(s) of necrosis within the gastric wall.
2. Gastrointestinal obstruction. These procedures are often performed to remove an ingested foreign object, causing a mechanical obstruction. This procedure could also be necessary to correct an area of the intestinal tract which becomes paralyzed and unable to move ingesta through (functional obstruction). Common associated procedures with this type of surgery include intestinal resection and anastomosis, enterotomy and/or gastrotomy.
3. Splenectomy. This is a procedure whereby the spleen is removed. This is typically done on an emergent basis when the spleen has rotated upon itself (splenic torsion), or has an actively bleeding cyst. It is highly recommended that a gastropexy be performed at the time of splenectomy if the EDC has not been previously gastropexied. This secondary gastropexy should be performed at the veterinarian’s discretion based on the patient’s anesthetic stability, current time under anesthesia, and other relevant vital signs.
4. Exploratory laparotomy. A surgical procedure where the abdomen is entered in an attempt to identify the cause of a condition not readily diagnosable by other means. Other indications of an exploratory laparotomy include a penetrating injury into the abdominal cavity, or other nonpenetrating traumas where clinical signs indicate possible damage to either an intra-abdominal structure or the abdominal muscle wall.
5. Exploratory thoracotomy. A surgical procedure where the thorax is explored. This procedure should only be done as a heroic effort to save an EDC’s life, most commonly following a traumatic penetrating injury into the thorax (e.g., gunshot wound).
6. Enucleation. Eyes shall only be removed in refractory conditions where pain and/or infection of the eye cannot be managed medically. Other surgical ophthalmic conditions are authorized at the veterinarian’s discretion. Examples include penetrating ocular injury and/or proptosis.
1.17 Surgeries – Other
A. The following surgeries are not uncommonly performed on EDCs and shall be considered within the veterinarian’s scope of responsibilities when required. It is acceptable for specialists to perform these procedures when deemed appropriate. These procedures shall be performed at a level of sedation or anesthesia appropriate to the surgery, at the veterinarian’s discretion. Common examples include:
1. Laceration repair.
2. Wound management.
3. Toe amputation.
4. Forelimb amputation.
5. Hind limb amputation.
6. Cranial cruciate ligament repair.
7. Fracture reduction.
8. Abscess lance/flush/drain.
9. Aural hematoma repair.
1.18 Vaccinations
A. Veterinarians shall maintain vaccines in quantities sufficient in order to ensure that the EDCs are always current on the required vaccinations. Veterinarians and/or veterinary technicians shall ensure that administration is at the appropriate interval and boosted in accordance with the vaccine’s labeled instructions. Required vaccinations are chosen in order to provide immunity from various communicable diseases common to the multiple locations in which the dogs travel to or through. Required vaccinations are Rabies, Distemper/Parvo/Parainfluenza/Adenovirus, Bordetella, Leptospirosis, Lyme (Borellia), Canine Influenza Viruses H3N8 and H3N2.
1.19 Wellness Care
A. Wellness care is described as routine, non-prescription activities conducted to improve the overall hygiene of the dog, or to prevent various diseases or conditions. Examples of wellness care covered within the scope include ear cleaning, trimming toenails, routine bathing, expressing anal glands, application of pad protectant, and removing excess ocular drainage. These activities can be conducted by veterinary technicians, canine handlers, kennel technicians, trainers, and/or kennel masters who have been appropriately trained by veterinary personnel.
SECTION 2 CONUS VETERINARY REQUIREMENTS
Government Furnished Property (“GFP”) Canines are procured, trained, and deployed all within the confines of the contractor facility, with full-service veterinary care by contractor veterinarians from the time of arrival into the Program to the time of removal from the Program. This process shall be delineated into three Phases, each described below:
2.1 Intake and Arrival
A. Pre-purchase. Vendors shall submit radiographs of the dogs in advance of the facility taking delivery. Once cleared, all previous medical history shall be requested from the vendor, including vaccinations.
B. A physical examination shall be conducted on all EDCs within ten (10) business days of arrival. All newly arrived EDCs shall receive a Bordetella vaccination within forty-eight (48) hours after arrival.
2.2 Phase I
A. This phase consists of the following:
1. Physical exam, including a rectal (digital) prostate examination on intact males
2. Complete blood count
3. Chemistry panel
4. Tick-borne disease panel consisting of Anaplasmosis, Ehrlichia, and Borrelia.
5. Heartworm test – required to be negative
6. Vaccinations. All dogs will be brought current on the above vaccinations
7. Urinalysis
8. Fecal floatation.
9. Sedated radiographs of hips, spine, and elbows. A PennHIP assessment is also performed at this time.
a. EDCs with a PennHIP Distraction Index (DI) greater than 0.50 on either hip shall be recommended for medical disqualification.
2.3 Phase II
A. This phase consists of the following:
1. Physical exam
2. Vaccination for Borrelia and Leptospirosis
2.4 Phase III
A. As surgical procedures are performed in Phase III, this is only conducted once the training staff has confirmed that the dog has performed satisfactorily, and that the dog possess detection capabilities consistent with requirements to be a DS asset. Phase III is performed pre-deployment, and consists of:
1. Females shall be spayed using either the ovariectomy or ovariohysterectomy technique
2. Females shall be gastropexied
3. Males shall be gastropexied
4. Males shall only be neutered if requested by the training staff or if a medical condition exists that is best treated with castration (e.g., prostatitis or chronic scrotal dermatitis) B. Requirements of veterinary personnel include:
1. Dentistry
2. Diagnostics – Annual
3. Emergent care
4. Euthanasia
5. FFD examinations
6. Health certificate examinations conducted pre-deployment
7. Imaging
8. Laboratory services
9. Post-operative care
10. Prescription medication
11. Preventatives
12. Sick call examinations
13. Specialist consultation
14. Supplements
15. Surgery – elective
16. Surgery – emergency
17. Surgery – other
18. Vaccinations
19. Wellness care
C. Contractor veterinary personnel shall conduct a quarterly kennel inspection of all kennels used to house DS EDCs, including on- and off-site. This inspection will consist of the following at a minimum:
1. An examination of the kennel/housing facility(ies) for safety hazards and distractions that may interfere with the rest and relaxation of the canines, to include recommendation(s) if applicable.
2. A review of the adequacy of the kennel/housing facility’s structure (particularly for environmental conditions) and feeding/watering schedules, to include recommendation(s) if applicable.
3. A review of kennel/housing facility’s sanitation and cleaning procedures and food storage procedures to minimize the risk of disease transmission to the canine, to include recommendation(s) if applicable.
D. Other assigned tasks of contractor veterinary personnel can include, but are not limited to:
1. (When requested) perform site assessments, both CONUS and OCONUS.
2. Accompany procurement team members on procurement trips to perform prepurchase veterinary assessments of the potential EDC candidates.
3. Be present at the introductory brief for canine class attendees.
4. Conduct classroom training lectures and/or laboratories for canine class attendees.
a. Should veterinary personnel from a host country attend training, provide in-depth training and mentorship. Training should include (if possible) surgical observation, GDV prevention strategies (i.e., gastropexy), heat injury prevention, etc.
5. Be readily available to attend training and testing of the EDCs to monitor for signs of injury, lameness, or other underlying disease or condition.
E. Veterinary care may be provided to dogs who are disqualified from consideration. This care can extend from the time they are disqualified to the time that they depart from the contractor facility to either return to the vendor or be adopted.
SECTION 3 VETERINARY REQUIREMENTS FOR VALIDATOR EDCs
A. Validator EDCs are identified as those dogs assigned to the contractor facility who validate testing scenarios in advance of testing exercises. Contractor veterinary personnel shall determine medical fitness-for-duty both prior to consideration as a validator EDC, and annually thereafter. This will continue until the EDC’s mandatory retirement at nine (9) years of age. Initial validator EDC fitness-for duty shall be determined by contractor veterinary personnel using similar testing and examination requirements in accordance with the PWS. Once deemed medically qualified to be a validator EDC, these dogs shall be authorized the following services by contractor veterinary personnel.
1. Dentistry
2. Diagnostics – Annual
3. Emergent Care
4. Euthanasia
5. FFD examinations
6. Health certificate examinations
7. Laboratory services
8. Post-operative care
9. Prescription Medication
10. Preventatives
11. Sick call examinations
12. Specialist consultations
13. Supplements
14. Surgery – elective
15. Surgery – emergency
16. Surgery – other
17. Vaccinations
18. Wellness care
SECTION 4 VETERINARY REQUIREMENTS FOR FERAL ANIMAL CONTROL
A. As feral animal control at the canine facility is the responsibility of the local animal control agencies, the use of contractor veterinary resources in feral animals shall be kept solely to those instances where the presence of these animals around the facility pose a direct threat to the life, limb, or eyesight of EDCs present at the facility for training or validating. Veterinarians shall be authorized to utilize resources when the presence of these animals could serve as a vector for disease transmission to DS EDCs. Resources are authorized to mitigate these threats through the form of:
1. Trapping and relocation of feral cats. These cats can be spayed or neutered at the discretion of the COR, ACOR, OR CO.
2. Possible sedation and relocation of feral dogs.
SECTION 5 OTHER RELEVANT VETERINARY REQUIREMENTS
5.1 Controlled Substance Management
A. Veterinary facilities, both CONUS and OCONUS, are authorized to store and utilize controlled substances in the normal course of business. These controlled substances shall be managed as follows:
1. Veterinary personnel will prepare and employ effective controls and procedures to guard against theft and diversion of controlled substances in accordance with both the most current Drug Enforcement Agency (DEA) guidelines and 21 USC § 801 et. seq.
2. At a minimum, controlled substances will be housed within a secured container designed for this type of purpose (i.e., safe).
3. Access to controlled substances shall be restricted to only necessary veterinary personnel. An access roster shall be displayed in a discrete location within twenty-four (24) inches of the container.
4. Should local controlled substance storage guidelines be more stringent than the above, then local guidelines shall supersede this requirement. The most stringent of applicable regulations shall be followed.
5. Controlled substances shall be inventoried at a frequency of not less than monthly. Inventory reports shall be prepared for review by the COR, ACOR, OR CO.
6. Expired narcotics shall be stored in accordance with DEA regulations. The disposal of expired narcotics shall occur no later than 6 months after their date of expiration and be disposed of using methods which comply with applicable DEA guidelines for disposal/destruction.
5.2 Medical records
A. A medical record shall be established for each canine. Records shall be readily and easily accessible by all veterinary personnel working with the EDC, both CONUS and OCONUS. These records shall be accurate, kept current, and record access retained at the task order performance location for the duration of the canine’s performance under the task order. Records shall be made available to the Government upon request for examination. This medical record shall accompany the canine on every permanent transfer to or from the task order performance location. Should electronic cloud-based records be utilized, the generation of hard-copy records is not necessary so long as all necessary parties have access to this record (e.g., owning company, owning company’s veterinarian, CONUS veterinary personnel, etc.).
B. Upon EDC retirement and/or adoption, the veterinarian shall provide the adopter with a complete copy of the EDC’s medical record.
C. All medical records shall be kept for a minimum of two (2) years, or in accordance with local regulations. The most stringent record retention regulation shall be followed for a designated place of performance.
5.3 EDC retirement
A. All EDCs providing services under OCONUS task orders shall be retired on the day the canine reaches seven (7) years of age. Validator EDCs in CONUS locations shall be retired on the day the canine reaches nine (9) years of age.
B. Veterinarians shall have the authority to recommend that a canine be retired earlier because of injury or disease that renders the EDC permanently unfit-for-duty.
C. The veterinarian may also recommend the appropriateness of euthanasia in lieu of retirement if a condition is likely to leave the canine in pain or with a very poor quality of life.
D. Prior to retiring any canine, the vendor shall notify (via email) the DS/IP/OPO/WPS Division Chief through the DS/IP/OPO/WPS COR, ACOR, and CO and receive written approval before proceeding with the retirement of any EDC.
E. The following list of examples are common causes for retirement prior to the 7-years-of-age guideline; it is not inclusive.
1. Osteoarthritis and/or degenerative joint disease of the coxofemoral joint(s)
2. Osteoarthritis and/or degenerative joint disease of the spine
3. Other forms of osteoarthritis
4. Epilepsy/seizures (zero tolerance)
5. Dermatologic conditions
5.4 Veterinary facilities
A. All veterinary facilities at the contractor facility must be licensed and registered with the State’s Department of Health Professionals and adhere to guidelines set forth in order to maintain facility licensure.
B. OCONUS veterinary facilities must be appropriately sized, with supplies and equipment on-hand necessary to remain in compliance with the PWS and task order.
5.5 Licensure
A. All veterinarians and veterinary technicians shall maintain professional licensure within a minimum of one (1) state within the United States.
B. All veterinarians shall hold a DEA license in a minimum of one (1) state within the United States.
C. Facilities must be appropriately licensed with the State in which they operate and operate in such a way to maintain compliance.
D. When required by local regulations, radiography equipment must be licensed with the appropriate regulatory agency and utilized in accordance with local regulations.
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