Irish Equine Veterinary Association (IEVA) recently published a consultation statement on the proposed Statutory Instrument to the Veterinary Medicinal Products, Medicated Feed and Fertilisers Regulation Act 2023 which reads as follows:

The Irish Equine Veterinary Association (IEVA) are providing this submission to the consultation process to outline our concerns regarding the proposed Statutory Instrument to the Veterinary Medicinal Products, Medicated Feed and Fertilisers Regulation Act 2023.

Veterinarians in Ireland are registered and regulated by the Veterinary Council of Ireland, and are legally bound to practice acts of veterinary medicine in adherence to the Code of Professional Conduct for Veterinary Practitioners.

Veterinarians provide a highly educated and knowledgeable level of expertise unmatched within the Irish agriculture, livestock and companion animal industries. Veterinarians day to day work centres primarily on the obligation to prioritise animal welfare.

Veterinarians, like all professionals involved with public and animal health and welfare, are acutely aware of the importance of supporting One Health principles, and more specifically, our role in reducing antimicrobial and antiparasitic resistance and the environmental impact of these products.

These principles are implemented on a daily basis by veterinarians in practices all across Ireland and throughout the European Union. The success of One Health requires us to think global and act local.

Responsible use of antimicrobials and anti-parasitics promotes targeted and specific use which ultimately results in a significant reduction in use and acknowledges the environmental health element of one health policy.

Specific to the Code of Professional Conduct for Veterinary Practitioners is the Client Practice Patient Relationship (CPPR). The importance of this CPPR cannot be overstated. Veterinarians are in the unique position of knowing the current health and resistance profiles of individual herds. They are the ‘local’ cog in the global, one health initiative.

Without significant veterinary input and responsible stewardship of the available veterinary medicines, the one health initiative will not succeed.

The Irish Equine Veterinary Association have significant concern regarding the introduction of a Statutory instrument that not only is in stark contrast to One Health guidelines and EU Directives, but potentially undermining the Legislative framework and Code of Professional Conduct upon which Irish veterinarians are bound to practice under, and ultimately compromising animal welfare and causing negative public health outcomes.

We thank you for considering our submission. We would be happy to contribute to further discussions surrounding this important topic and exploration of the points raised.

Email: info@irisheva.ie

A vet’s response to the EU vet medicine changes

I WISH to voice the very real concerns veterinary surgeons have with respect to the proposed Statutory Instrument aimed to dilute and inhibit the core objectives of the Act. In order to adequately address these concerns, it is firstly important to understand what Regulations the Statutory Instrument aim to achieve.

The Act which was due to be implemented on January 28th 2022 aims to bring about changes in legislation so as to modernise the rules on authorisation and use of veterinary medicines. These changes were introduced by the EU so as to combat resistance to drugs which we use to protect animals under our care against disease for example bacterial diseases (antibiotics) and worm related diseases (anthelmintics/de-wormers).

One important change is that de-wormers will now become Prescription Only Medicines (POM) so as to prevent them from being overused, misused and ultimately becoming redundant due to resistance. The new rules have been implemented successfully in parts of Europe consequently protecting these drugs.

Arguments and lobbying

The implementation of this Act entirely has unfortunately been delayed in Ireland due to lobbying which commenced before the original applicable date. Examples of arguments and lobbying against the Act can be reviewed on www.oireachtas.ie. They include concerns regarding “the impact upon the point of sale”, “the direct loss of jobs relating to the sale of drugs” presently not under POM status, and “the ongoing sale of drugs to buffer employment levels in rural towns where there is no employment”.

Some arguments also encompassed a perceived “financial burden on farmers”. These are all extremely short-sighted and concerning arguments because our One Health (the health of humans, animals and the environment) across Ireland and Europe should not be compromised or traded off for the financial gain of companies selling de-wormers and other animal medicines presently without POM status. The argument that farmers will be at a further loss is also futile because the entire Act aims to reduce unnecessary and untargeted use of de-wormers - a chronic and costly practice.

It seems that the proposed Statutory Instrument will dilute the conditions set out for Prescription Only Medicines therefore allowing for the picture to remain the same. The economic argument for the introduction of the Statutory Instrument, that the cost to farmers and horse owners will be increased due to the need for prescriptions in order to obtain the medications in question is incorrect.

Diluting the conditions

In fact, the rules already implemented in other parts of Europe will not only contribute to better health of farm animals and equids but will simultaneously reduce costs to farmers because the use of these drugs will be protected under POM status, therefore the drugs under the umbrella of the Act will be used in an accurate and targeted manner under the due diligence of your veterinarian who understands the relationships between time of year, worm life cycles, animal age... the list goes on. Diluting the conditions set out for these specific Prescription Only Medicines is in direct conflict with the EU regulations and what they aim to achieve.

Over the past number of years, the farms under my practice’s care have been introduced to health plans with the help of veterinary specialists in internal medicine and parasitology or PhD holders such as Siobhan McAuliffe, Sarah Ross and Nicola Walshe.

In designing health plans, we have combined the history on each farm, individual farm animal populations (with particular consideration to age groups), detailed clinical examinations and faecal worm egg count results.

This work on farm has seen a significant reduction in the use of de-wormers alongside their use now in a much more targeted manner. All of these farms have noted a reduction in worm burden associated diseases, better immune status of animals and significantly less drugs being used to combat worm burdens. It is therefore clear that the introduction of the correct legislation without a Statutory Instrument to dilute its impact, will in fact see better health, better financial results and less unnecessary drug related expense on farm.

We do hope that the Minister takes into consideration the positive impact the EU regulations will have upon my health, your health, the health of our animals - One Health.

We do hope that he will see the proposed Statutory Instrument for what it is: a pathway to allow for the ongoing sale of drugs which will only compromise health by contributing to resistance. Please allow us to progress alongside the rest of Europe.