SOLICITOR Matthew Austin of Hayes Solicitors Dublin, gave a detailed presentation on the some of the controversial aspects of Animal Remedies Regulations 2007 and on how the enforcement methods used through the Department of Agriculture Task Force inspections in recent years are affecting equine vets in practice, horse owners, trainers, and ultimately the welfare of horses.
In the course of the discussion that followed, some of the points made included:-
Concerns were expressed that notwithstanding the fact that all EU countries are bound by the same EU Veterinary Medicines Directive, the interpretation and enforcement of this same Directive by the Irish authorities in the Department of Agriculture, Food and the Marine differs significantly to that in other EU countries. This places Irish vets at a major disadvantage to their veterinary colleagues in other EU countries in their day-to-day work treating, advising and caring for the horses under their care. An additional consequence being that it can put Irish horses racing or competing abroad at a disadvantage, due to unavailability of essential medicines to their vets in Ireland vis-a-vis their EU counterparts.
While vets strongly support the position that the use of certain drugs should not be permitted in racing or in competition horses, it was felt that the enforcement system in place of the Animal Remedies Regulations is over-robust to the point of being impractical in clinical terms and in the extreme and petty on relatively trivial issues.
To this end, it was felt that the bases for and the enforcement methods used are over and above the standard reasonable interpretation of the Regulations. It was seen to be lacking in understanding of the practical clinical aspects of equine veterinary practice and particularly in the areas of protecting the welfare of the horse.
Concerns were also aired regarding the growing list of unavailability of essential medicines in Ireland. For example, the loss of Flunixin, the clinically most effective painkiller for visceral pain in horses, in addition to being a lifesaving drug for horses recovering from colic surgery, colitis and septicaemia. The implications for their survival, recovery and the welfare of such cases would be seriously challenged. The probability of extra unnecessary pain to the animals in question is an inevitable consequence without the availability of Flunixin.
To address this, the UK Veterinary Medicines Directorate have relaxed controls on Flunixin for equines, provided it is used in non-food animals and with some additional caveats. It is hoped that Ireland’s HPRA, equivalent to the UK VMD, will follow suit in taking this approach to the Flunixin issue, in the interests of the welfare of horses.
A further aspect of the increasing list of unavailability of equine medicinal products in Ireland is the expiry of product license and the manufacturers’ inability to foot the extra costs in license renewal for use in Ireland, as the numbers of horses is insufficient in this country to justify it. Consequently, while these products are legally approved and authorised in other EU countries, they are not freely available in Ireland. Again, the loss of most of these products would have serious implications for the welfare of the horse.
POSSIBLE CHANGES
The discussion also included reference to a possible imminent change of Category for the product ‘Bute’ or phenylbutazone which would ultimately mean that ‘Bute’ would be changed from its current status where the horse is stamped out of the food chain for life, to a six-month withdrawal post-use period. This possible change is currently under discussion, but in the interim, the law relating to the use of ‘Bute’ remains unchanged in Ireland.
Some issues regarding horse passports were also raised. The possibility of categorising all horses as non-food animals, unless the individual owner decides otherwise (along with the owner undertaking the onus and personal responsibilities adhering to the strict accompanying requirements) is also under consideration by the relevant authorities. Discussions within stakeholder groups are ongoing currently on this matter.
The extension of the legally acceptable period for registration of foals from six to 12 months was discussed and acknowledged as a positive change and a more practical approach provided it is enforced through a practical workable system for owners. This change in the Regulations means that horses can be up to one-year-old before they are registered.
In his presentation, Matthew Austin also placed specific emphasis on the importance of the legal requirements to keep up-to-date records of all medicines used in treating horses. The onus to do this is the responsibility of both the treating vet and the owner of the horse to maintain separate records for a period of five years under the Animal Remedies Regulations 2007.