Mr. T.J. Flanagan:

I thank the Chairman. I am joined today by Mr. John O'Gorman, ICOS dairy committee, and Mr. Ray Doyle, ICOS livestock services executive. Mr. O'Gorman is a dairy farmer from south Tipperary and also the chairman of the Dairygold Co-operative Society. Mr. Doyle leads our policy efforts in animal health and animal welfare. I will defer to my colleagues in a moment but I will first make some brief opening comments on the matters at hand.

ICOS has long been involved in the development of the regulatory regime for animal remedies in Ireland. From the 1999 report of the Irish Medicines Board, which is a predecessor to the Health Products Regulatory Authority, HPRA, recommending that access to intramammary antibiotics "should be on the basis of informed choice such as that available from a properly established and audited mastitis control programme or herd health programme."

The European Communities (Animal Remedies) Regulation SI 786/2007, schedule 8, formally recognises the status of a co-op mastitis control programme as a recognised structure within which a vet is in a position to make an appropriate assessment on the treatment needs of dairy cows with regard to intramammary remedies. The same regulation provides the exemption for antiparasitic remedies to allow them to stay prescription free on the basis that there was, at the time, no evidence of the development of resistance in cattle.

We are now faced with a new challenge with the HPRA recently recommending that antiparasitic products can no longer avail of the aforementioned exemption due to the proven evidence of anthelmintic resistance in cattle, which was first demonstrated on Teagasc farms. This will result in those medicines becoming prescription only. The members should be in no doubt that shifting this group of medicines from the current merchant and co-op route of supply, or responsible persons in licensed merchants, LM, to prescription only, will result in a significant shift in sales from co-ops and merchants.

This will result in economic loss and the undermining of the economic basis for the stores network, as well as a substantial increase in the cost for end users. Co-ops want to reduce rather than to increase the sales of medicines, but they do want to be able to sell medicines to their members. Footfall generated in small rural branches by the sale of animal health products is an important part of their activities and if it were to be lost branches would undoubtedly close. It is the view of ICOS that the simplest solution to this change would be to investigate the potential to extend the right to prescribe those medicines to the responsible persons who now work in co-ops and merchants, as provided for in the directive. We will, however, need to substantially enhance the data gathering and controls associated with that activity so we can reduce usage, halt the development of resistance and protect those valuable medicines. The Department of Agriculture, Food and the Marine and the European Commission have rejected this proposition. Pending a definitive view from the Office of the Attorney General, and being conscious that time is very tight, we must prepare contingency strategies. Mr. Doyle will go over those in a moment.

In parallel, the world has changed regarding the use of antibiotics, and the co-ops have shown great leadership in driving down the usage of dry cow tubes especially. Using the mastitis control programme, as set out in schedule 8 of the 2007 regulations, we have seen substantial reductions of sales in dry cow tubes, a move towards selective dry cow therapy and many co-ops banning the use of critically important antibiotics. We accept that substantial changes will need to occur in the mechanics of prescribing dry cow tubes, with the likely necessity of moving to 100% milk recording to get a dry cow prescription.

The concept of a specialist or consultant vet working out of a co-op laboratory, with access to the data on milk recording, bulk milk, sensitivity and detailed reports on dairy hygiene and other audits, continues to be robust and scientifically sound. Unfortunately, one stakeholder, the Veterinary Council of Ireland, has taken what we see as being a view more appropriate to a representative body than a regulator and has thus far rejected the concept of a co-op specialist vet. We call on the Department to do what it did in 2007 and to recognise the strategic importance of the co-ops, large and small, in animal health and to ensure that the Veterinary Council of Ireland does not exceed its remit in this regard. I will hand over to my colleague, Mr. O'Gorman, now.