Mr. Ray Doyle:

The VCI's regulations provide that in order to prescribe a product for any farmer, the vet has to start with a client-patient practice relationship and that has to have been established. It can be established only by the vet physically calling out to the farmer, surveying the facilities and the type of farm and production and perhaps having discussions with the farmer about his or her use of products to date. Legally, the vet cannot prescribe products until that has happened. The co-operative vets we have in house would need to call to these farmers in advance of writing the prescription, but that would simply not be possible for the number of shareholders and farmers in most of the co-operatives. That has completely hindered the process taking place to comply with the VCI regulations regarding that.

The old regulation that was in place in 2007 facilitated vets writing prescriptions, for antibiotics in particular, in a different fashion, whereby they were derogated from that. I do not want to be seen not to be supporting our duty in AMR, because we are. We are steadfastly behind the fact that we have to drive down antibiotic use but, again, we need to partition antibiotics from antiparasitic.

The threshold and knowledge required, which is the phrase the Veterinary Council of Ireland, VCI, uses itself, is much lower for the prescribing of antiparasitics than for antibiotics. Our submission comes to the fore to encourage that we provide in legislation for the responsible person to be de facto prescribing antiparasitics. We do not want and we are not seeking to develop a model where people other than veterinarians prescribe antibiotics. We are fully behind veterinarians physically visiting farms and clinically assessing animals as the correct basis for antimicrobial prescriptions.