Animal Therapy Services
Only a Kentucky-licensed veterinarian, or a person who is working under the direct supervision of a licensed veterinarian, can perform certain alternative services in the Commonwealth. The practice of veterinary medicine, as defined by the Kentucky General Assembly in KRS 321.181, covers a wide range of activities that may be performed to treat, correct, change, or prevent an animal’s deformity, defect, injury, or other physical or mental condition. “Manipulation” of an animal, which includes the services listed below as specific activities that the law regards as the practice of veterinary medicine.
- Animal Massage Therapy
- Animal Acupuncture
- Animal Rehabilitation (a.k.a. non-human physical therapy)
- Laser Therapy
A person who is not a Kentucky-licensed veterinarian can provide these services in the Commonwealth only under limited circumstances. An animal’s owner, or the owner’s employee, may provide these services without a license. In addition, a trainer, sales agent, or herdsman can provide these services under instruction and direct supervision from a Kentucky-licensed veterinarian, provided there exists a veterinarian-client-patient relationship. Other limited circumstances are listed in KRS 321.200.
Please contact the Board at Vet@ky.gov for more on requirements on the particular service you would like to offer.
Industrial Hemp Derived Products / CBD use in Animals
In regard to veterinarians or clinics, the Board cautions that selling, prescribing, or advising on the use of cannabidiol (CBD) in animals is at your own risk in the event a patient has an adverse reaction.
Background information on CBD:
- In 2018, the U.S. Congress passed the 2018 Farm Bill descheduling industrial hemp from the Controlled Substances Act. The farm bill assigns regulatory responsibility for industrial hemp to states with a USDA approved plan and sets minimum requirements for a state regulatory framework.
- The regulation of CBD and other industrial hemp extracts remains with the U.S. Food and Drug Administration (FDA) under the Federal Food, Drug, and Cosmetic Act (FD & C Act). There still exists a big gray area on whether CBD extract is a supplement or a drug. Until such time as FDA issues a clear statement(s) in writing or federal law is clearly updated to define extract products as either a supplement or a drug, Kentucky will continue to view CBD as a supplement and treat it accordingly. (40 KRS 218A.010(27) – scroll down to definition # 27).
- The regulation of industrial hemp grain and all extracts, including CBD, in animal feed remains with the Association of American Feed Control Officials (AAFCO) and the Feed Program of University of Kentucky Division of Regulatory Services. The AAFCO released a statement on industrial hemp in May 2019 which discusses food ingredients, and clearly states that CBD is seen as a drug and not approved as an animal feed ingredient. The UK Feed Program does not currently allow the use of any hemp products including hemp seeds, hemp oil, or hemp seed meal in products intended for the feeding of animals, except for the feeding of hemp seed to wild birds. Please see the UK Feed Program Policy on Use of Hemp Products in Animal Feed for more information.
- The Kentucky Department of Agriculture (KDA) is a world leader in Industrial Hemp growing and processing. In 2019, KDA approved more than 42,000 acres and 2.9 million square feet of greenhouse space for hemp cultivation. The Commonwealth also boasts over 100 processors, most of whom are focused on CBD production.
- Cornell University has completed some research with CBD and dogs and found that it helped. The study titled Pharmacokinetics, Safety, and Clinical Efficacy of Cannabidiol Treatment in Osteoarthritic Dogs” by Gamble, Boesch, Frye, et al., was published in Frontiers in Veterinary Science in July 2018.
- In Kentucky, pursuant to 40 KRS 218A.010(27), CBD products are legal when derived from industrial hemp (Cannabis sativa L. with a tetrahydrocannabinol (THC) concentration of not more than 0.3% on a dry weight basis).
- There is no prohibition in Kentucky for carrying this product in a store or clinic as a product with an off-label use.
In Kentucky, veterinarians and the general public can learn more about industrial hemp from the Kentucky Department of Agriculture Hemp Program.