Mr. Finbarr Murphy:

I thank the Chair and members of the committee. We welcome the opportunity to appear before the committee today to contribute to discussions it is having with stakeholders as part of its pre-legislative scrutiny of the veterinary medicinal products, medicated feed and fertilisers regulation Bill 2022. Veterinary Ireland is the representative body for the veterinary profession in Ireland. There are approximately 1,000 private veterinary practitioners, PVPs, engaged in farm animal veterinary practice who play a key role in the Irish agrifood industry.

Veterinary practitioners are the gatekeepers of animal health and animal welfare and, more pertinently, act as the gatekeepers in the supply of prescription only medicines, POMs. This committee has heard sales of antimicrobial intramammary products through co-ops, merchants and pharmacies have fallen by a catastrophic 90% since January 2022 as a result of the cessation of Schedule 8 of the Animal Remedies Regulations 2007, which have been repealed. Veterinary Ireland has access to the distribution data and will correct the record and outline the benefit that has been realised primarily to farmers but also to human health.

Since January 2022, the prescribing of intramammary antimicrobials has reduced by 25.3% and the prescribing of lactating cow intramammary antimicrobials has reduced by 6.5%. This not only represents a prudent reduction in antibiotics but represents a saving to Irish farmers of approximately €3.4 million in the first nine months of 2022. The sales of intramammary antibiotics containing highest priority critically important antibiotics, HPCIAs, have reduced massively. Cephaguard DC is down 73% and Cobactan LC is down 77%. The sales of critically important antibiotics in injectable form, for example, Marbocyl, have also seen a collapse anecdotally. Antiparasitic medicinal products have been designated as POM in Europe since 2007. Ireland availed of a derogation from 2007 to 2019 to allow these products to be sold over the counter under the licensed merchant, LM, category. The dispensing of these products is done by responsible persons, RPs, who are required to take a short level 6 course in handling, storage and dispensing of these products. This category of product has never been prescribed in Ireland. Any farmer or animal owner can purchase his or her product of choice over the counter in a store, pharmacy, or online shop.

The issue of antiparasitic resistance is a worldwide phenomenon and is both a public health issue and a serious issue for the agrifood industry in Ireland. Farming livestock on grazing systems is only possible where parasitic disease can be managed effectively. A study by the Department of Agriculture, Food and the Marine in 2016 outlined that 56% of worming interventions in sheep were not effective. Kelleher et alin 2017 found extremely high levels of resistance to all groups of wormers in cattle. The Veterinary Recordrecently published a report about a case of high mortality on a dairy farm in Wales where adult cows died due to inability to treat lungworm infections due to resistance. In order to address the issue of resistance we must ensure the right product is given to the right animals at the right time; that refugia is maintained through selective, targeted treatments; and that parasite control becomes a planned farm-specific procedure. The gateway to this outcome is through proper, scientific, farm-specific veterinary advice from the farmer's vet where a client practice patient relationship, CPPR, is in existence. This advice must be ongoing and monitored, take account of farm specific issues such as epidemiology, pharmacology, the clinical picture, stocking densities, buying policy and local factors. Once the farmer has a prescription for when to treat, what animals to treat and with what active ingredient, the farmer can fill the prescription from any legitimate channel in Ireland or across the EU.

The Department of Agriculture, Food and the Marine has proposed the national veterinary prescription system, NVPS, one of the aims of which is to make it as easy as possible for farmers to fill their prescriptions at their outlet of choice. Veterinary Ireland believes this development increases competition rather than diminishes it. Veterinary medicine is a restricted profession governed by the Veterinary Practice Act 2005. Only a registered veterinary practitioner can perform acts of veterinary medicine and it is illegal for others to do so. This is not anti-competitive. It is the law. Acts of veterinary medicine are very few in reality and include: diagnosis of disease and advising on disease control; prescribing veterinary medicinal products; performing surgery on animals, with certain named exemptions; and veterinary certification.

The down side of being in this seemingly privileged position is that PVPs must adhere to the rules of the Veterinary Council of Ireland, VCI, and their code of professional conduct. Failure to do so may result in a fitness to practice investigation which is the equivalent of High Court proceedings. Defending oneself in a fitness to practice investigation is particularly onerous both mentally and financially with very few having the resources to avail of their constitutional right to appeal as it is through the High Court. Only vets are subject to VCI rules. Any other actors in the field cannot be held to account by VCI. The thrust of this legislation is that all the responsibility rests with the prescribing vet.

The majority of antiparasitic medicinal products were classified as LM and therefore have never been prescribed in Ireland. The NVPS was born out of a desire to fulfil two requirements of the Department of Agriculture, Food and the Marine, namely, to comply with the obligation under Article 57 on member states to collect data on the use of antimicrobial products per species; to satisfy co-ops, merchants, and pharmacists that veterinary prescriptions would be readily available; and to allow seamless dispensing to farmers and essentially level the playing field for dispensing. The NVPS as proposed brings many more significant benefits to the Department of Agriculture, Food and the Marine, including providing evidence for improving national animal health and welfare policies; maintaining a competitive veterinary medicinal product, VMP, dispensing market; providing digital capability for distance selling; improving regulatory oversight of VMP usage and supply; and increasing international confidence in Irish food production. There is no requirement to write prescriptions electronically in Regulation 2019/6 or Regulation 2019/4. The obligation is on the member state to collect macro sales data and usage data at farm level. The Department of Agriculture, Food and the Marine, by way of derogation, has unilaterally decided to collect prescription data as a proxy for usage data. It has decided to put the NVPS into primary legislation to force PVPs to either use it or retire from practice as opposed to the normal method of consultation and agreement with Veterinary Ireland to ensure the system was fit for use and to ensure unwarranted collection of data was not placing an undue burden on already stretched PVPs. PVPs need assurances on how this data will be used, who might be able to access this data and that further additional requirements will not be thrust upon PVPs annually as was the case with the animal health computer system, AHCS.

Veterinary Ireland and the veterinary profession are proud of the key role PVPs play in the agrifood industry. Veterinary Ireland believes that PVPs will rise to the challenges posed by the implementation of the regulation in order to protect human health; animal health and welfare; the efficacy of veterinary medicinal products; and the reputation of the Irish agrifood industry. We ask this committee to ensure the Department of Agriculture, Food and the Marine engages with Veterinary Ireland to ensure a smooth and agreed integration of NVPS into veterinary practices that minimises the impact on the running of veterinary practices; enables PVPs to provide the clinical services required by the agrifood industry; and reduces the use of veterinary medicinal products prudently in compliance with the regulation.

I thank the Chair. We are happy to answer any questions.