Mr. Ray Doyle:

We still have a problem in those cases because the code of ethics from the Veterinary Council of Ireland is now precluding these vets from writing these prescriptions for the antibiotics. To return to one of the Senator's earlier questions, there is a clear differentiation between the use of antibiotics and antimicrobial resistance, AMR, on the one hand, and antiparasitic resistance, on the other.

While we can all rationalise a reduction in the use of antibiotics, and the co-operatives will be the first to say we have to greatly reduce the use of antibiotics in all food-producing animals because we all live in the same essential bacteria and we do not want resistance among humans, we cannot prescribe them. Perhaps it is going in the direction of travel it should be, whereby it is in the hands of the visiting vet and the animal is treated within a day or two. The use of antibiotics usually means there is an animal welfare issue or, potentially, a life-or-death scenario for an animal, and we would agree with the tight prescribing window. Perhaps the fact we have lost that business is a blessing in disguise, although that is not the way I mean to communicate it, in that the use of antibiotics needs to be reduced greatly on that basis. The same cannot be said, however, about antiparasitic products. It is usually not a life-or-death scenario for the animal. Rather, it is usually a loss of production and it is never so serious a situation that the product must be administered rapidly. As well as that, antiparasitic resistance is not currently a human issue.

Nevertheless, as co-operatives, we are acutely aware of the loss of production we could face from our green grass-based production model by having widespread antiparasitic resistance, and our responsible persons - this too crosses over one of the Senator's questions - are best placed to ensure that resistance does not build up with these products. Currently, when a person comes in for a product without a prescription, our responsible persons advise farmers on the active ingredient, the withdrawal period and the rotation of the product to ensure resistance does not occur. Moreover, and this also goes back to another of the Senator's questions, they are acutely aware of the locality in which they are operating. Some areas, for example, will have quite wet ground and there could be a lot of fluke issues. There could be environmental issues that are unique to the area of which the responsible person will be acutely aware, which the private veterinary practitioner might not be aware of because he or she might call there infrequently.

There is a clear distinction between antibiotics and AMR, and antiparasitic resistance, APR. We know that the responsible person is probably best placed to advise farmers on the use of antiparasitic in particular, and that is in no way meant to demean the veterinary profession. It is a simple fact that the responsible persons have access to the data that enable them, as we described in our submission, to prescribe the correct product in the correct quantity at the correct time.

On the NVPS development to date and since January, that has been a slow process. A handful of key software development companies cross over a lot of co-operatives, particularly dairy ones. To date it has been challenged and somewhat hindered in its development in that there are many hurdles to get over that people might not have thought of, and development in that regard has been slow.

The greatest hurdle to the implementation of the NVPS will be the lack of engagement by the veterinary profession in trying to make this work. It simply cannot work in the way it is currently operating, whereby the veterinary profession is more or less ignoring the system and not interacting with trying to make it work, which may be another clear demonstration that the responsible persons, through the co-operatives and their various software systems, are best placed to make it work. They currently have the software in their development and they interact with the Department in trying to create a system that accurately reflects the usage and the monitoring of who has got it. This system will probably be the template used for the fertiliser database as well.