TBVME BAM and MK Kit Usage Guidance

Summary of Issue

The Board is aware of the increased use of “BAM” and “MK” kits, especially in treating deer herds. Since these kits contain controlled substances, common prescribing practices often violate Board rules, state statutes, and federal regulations. The Board provides the following compliance guidance and best practices.

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Compliance

Even strict adherence to these guidelines cannot prevent complaints. TBVME must investigate any complaint it receives. However, compliance with this guidance will be considered during the review process.

There are also federal regulations that govern controlled substance prescribing. Contact your local DEA field office for further clarification.

What Are “BAM” and “MK”?

BAM:

• Butorphanol – A DEA Schedule IV opioid analgesic.
• Azaperone – A tranquilizer that reduces motor activity and causes sedation.
• Medetomidine – An α-2 agonist with sedative and analgesic properties.

MK:

• Medetomidine (5mg/ml) – Provides α-2 adrenergic agonist effects.
• Ketamine HCL (150mg/ml) – DEA Schedule III paralytic.
• Atipamezole – A reversal agent for medetomidine.

Veterinarian Use

Common reasons to sedate/anesthetize cervids include:

• Regulatory testing (CWD, TB, Brucellosis)
• Semen collection
• Artificial insemination
• Antler removal
• Illness or injury

Best Practices

1. Maintain a valid veterinarian-client-patient relationship (VCPR).
2. Visit the herd at least annually to maintain that relationship.
3. Only prescribe if medically necessary and therapeutically indicated.
4. Prescribe only the amount needed for the specific occurrence.
5. Educate clients that drugs are for their herd only, not for resale or use in other herds.
6. Inform clients about withdrawal periods if animals may be harvested.
7. Consider using a signed form confirming the above points, and retain it in the patient’s record.
8. Patient records should include:
   • Animal/herd identity
   • VCPR details
   • Farm visits, diagnosis, treatments
   • Prescribed drugs

Applicable Statutes and Rules

Texas Health and Safety Code Chapter 481 – Texas Controlled Substances Act

• Defines controlled substances and their legal use.
• Controlled substances must be prescribed for a valid medical purpose.

Texas Occupations Code Title 4 Chapter 801

• Section 801.351: Defines and requires a valid VCPR for practicing veterinary medicine.

Texas Administrative Code

• Rule 573.41 – Use of Prescription Drugs
  • Requires a VCPR and therapeutic indication.
• Rule 573.44 – Compounding Drugs
  • Allows compounding only with valid VCPR and for a specific medical condition.
  • Requires proper labeling and limits on sale/promotion.
• Rule 573.45 – Extra-Label Use
  • Requires extended withdrawal periods and recordkeeping for food-producing animals.
• Rule 573.52 – Patient Recordkeeping
  • Details minimum documentation standards and record retention.
• Rule 573.43 – Controlled Substances Registration
  • Requires DEA registration and compliance with state/federal law.

Federal Regulations

CFR Title 21 §1306.04 – Purpose of Prescription

• Controlled substance prescriptions must be issued for legitimate medical purposes.
• Cannot be used to stockpile for future general dispensing.

CFR Title 21 §530.5 – Veterinary Records

• Veterinarians must maintain legible, detailed, and accessible records for extra-label use.
• Records must include:
  • Drug name and active ingredients
  • Condition treated
  • Species, dosage, treatment duration
  • Number of animals treated
  • Withdrawal periods

CFR Title 21 §530.20 – Extra-Label Use in Food-Producing Animals

• Allowed only if no approved alternative exists or it is clinically ineffective.
• Requires:
  • Valid diagnosis and VCPR
  • Extended withdrawal period
  • Identity tracking of animals
  • Safety measures to prevent illegal residue in food supply