Mr. Ray Doyle:

Over the past decade, the dairy sector has invested over €1 billion in new processing capacity, routes to market and people and systems to ensure compliance and food safety. A comparable investment has taken place at farm level. The co-operative and multi-purpose nature of the Irish dairy industry has ensured that it has developed a significant degree of vertical integration with its farmer members, and it surrounds and supports them with the systems and expertise to deliver on safe and sustainable food production. Included in this support is a huge investment in milk quality, built on animal health and welfare, including the responsible usage of all veterinary medicines. This reflects on the strategic importance of the dairy co-operative sector as a key partner of the Government in delivering on shared objectives for the public good in animal health and welfare, food safety, climate change, water quality and other objectives. It is in this context that we raise some significant concerns regarding the implementation of the new EU veterinary medicines regulation and the fertiliser register.

ICOS previously addressed the committee in spring 2021 on the issue of veterinary medicines. Unfortunately, we find ourselves in a position where our key concerns remain unaddressed. We said previously that the new veterinary medicines regulation could potentially create a dramatic shift in the veterinary medicines supply chain in favour of private veterinary practitioners and to the detriment of co-operatives, pharmacists and independent licensed merchants, LMs. We warned that the new rules would narrow the distribution channel and reduce choice. In turn, this would increase the costs of medicines, as co-operatives and LMs would be disadvantaged in the marketplace. This will undermine the sustainability of the co-operative store network as a key pillar of its offering will be weakened and footfall will be diminished. We stressed the need to find an appropriate legal solution.

Our main recommendation to the committee was to ensure the continuation of the existing LM network as a recognised route of supply, expertly administered by trained, responsible persons, to ensure maximum and fair competition and availability for farmers. We repeat these concerns here today.

We have had in the meantime the opportunity to examine the Department of Agriculture, Food and the Marine’s proposal for a national veterinary prescribing system, NVPS, and the reaction of the veterinary profession through its representative body. Since the new legislation and the new prescribing regime for antibiotics came into effect on 28January 2022, we have seen the sales of intramammary antibiotics totally collapse across all co-ops. Notwithstanding the shorter window for dispensing when it comes to antibiotics, this clearly indicates the negative impact on farmer choice of the introduction of a restrictive veterinary-only prescribing and de facto dispensing regime. This is the canary-in-the-coalmine warning for everybody concerned about the plans by the Department to proceed with the decision to up-regulate antiparasitic veterinary medicines to prescription-only.

The advice from the Department is that the new electronic NVPS will provide adequate choice for farmers. This is based on the assumption that all veterinary practitioners will collaborate with the Department and fully adopt the new system of prescribing. This has simply not happened to date. There is no evidence to suggest that the Department has been able to get vets to test the system, let alone operate it when it is up and running. Co-ops have been left in limbo as a result, spending considerable resources on new IT upgrades for a system we do not even know will be operational. We support the introduction of the new NVPS but for it to deliver on its potential it needs to work in parallel with a fit-for-purpose prescribing regime.

The Department has failed to address the possibility of legislating to allow for the continuation of the role of responsible persons as effective prescribers of antiparasitic medicines. We call on the committee and Members of the Oireachtas to ensure the Department pursues all avenues that will enable responsible persons employed by co-ops and LMs to continue to do what they have been effectively doing for many years. We understand it is legally possible to amend the 2007 legislation to retrospectively recognise and provide a legal basis for the ongoing role for responsible persons as prescribers of antiparasitic veterinary medicines. Crucially, this will provide for alignment between the prescribing and dispensing regime on both sides of the Border, protecting our all-island animal health approach and preventing the risk of the development of an unnecessary and damaging black market for veterinary medicines.

The economic impact of what we now see evolving as a highly dysfunctional prescribing regime will result in a substantial loss of jobs in co-ops and LMs in rural areas the length and breadth of the country, and a significant increase in cost at farm level, at a time when inflation is going through the roof at co-op and farm level. Co-ops and merchants have already been forced to invest significant funds in IT changes to sales software. It is ironic, as what we have seen from the lesson of intramammaries is that we may not get to use this new software. At the very least, the Department should be willing to assist with the financial burden associated with IT upgrades by providing an IT grant for the new NVPS and the fertiliser register, which we will mention later.

Notwithstanding the need to fundamentally review the direction of the Department on the position of responsible persons, and to seek clarity on the advice it says it has received from the Office of the Attorney General in this respect, other issues need to be resolved with respect to any future prescribing regime. First, in order to protect competition in the market, it is vital that the NVPS as it is being developed provides for the full availability of appropriate generic alternative medicines. Second, the Department needs to legislate, as it did with SI 786 in 2007 for mastitis control programmes, to allow for vets working as part of an approved co-op herd health programme to establish and maintain a client-patient practice relationship, CPPR.

I will hand over to my colleague, Mr. Carroll, who will speak on the fertiliser register.