Mr. Ollie Ryan:

The ILMA welcomes EU Regulation 2019/6 for veterinary medicinal products and has no issue with the stated objectives aimed at reducing the administrative burden, enhancing the internal market and increasing the availability of veterinary medicinal products while guaranteeing the highest level of public and animal health and environmental protection. Furthermore, the Health Products Regulatory Authority, HPRA, task force report into antiparasitic resistance has highlighted the need to address effectively antiparasitic-resistance measures for cattle, sheep and horses using a multi-stakeholder approach.

The ILMA also welcomed the support for responsible persons, RPs, we employ at all licensed merchants' outlets from the Chief Veterinary Officer, CVO. In his letter to the EU in June 2020, he not only affirmed that the existing route of supply and distribution were not associated with increased resistance and environmental damage but also that the RPs undertake a professional, internationally recognised qualification and training regime.

The committee is acutely aware of the consequences of failing to include the RP in the prescribing of antiparasitic medicines and has worked tirelessly with Ministers and stakeholders to find the solution. The stark reality of these warnings was underlined by the Irish Co-operative Organisation Society, ICOS, last week, with the collapse and loss of more than 90% of intermammary sales to private vet practices and virtually no vet prescriptions given to farmers to use at co-operative stores, effectively creating a monopoly in this market. This windfall of new businesses will multiply at least tenfold if antiparasitic medicines are allowed to go down the same vet-only prescribing channel. Recognition of anti-competitiveness and accessibility was also noted in the CVO’s letter to the EU. He stated that if sales of these products were undertaken largely by veterinarians, the current competitive environment for these products would be significantly weakened.

The ILMA, as a stakeholder, has agreed that antiparasitic medicine prescriptions will be entered onto the national veterinary prescription system, NVPS, once the technology is available and working and that licensed merchants and RPs will invest time and money into systems compatible with the programme. To this end, NVPS-prescribing terminals should be installed at all licensed merchants’ premises and the required technology training undertaken. Continuing professional development programmes will also be introduced to ensure the best and most up-to-date advice is given to farmers on antiparasitic-resistance methods.

Close examination of the RP professional qualification, introduced in 2012, emphatically proves that the RP was meeting all EU-required criteria to avail of the derogation Article 105(4) at the time of its entry into force. The qualification consists of an intensive, 100-hour course, with four hours of practical and written exams, and is accredited to an internationally recognised standard and approved by the Department of Agriculture, Food and the Marine. As part of the course, a comprehensive prescribing protocol was introduced to help guard against the rising number of reports and trials showing anthelmintic resistance in cattle and sheep and environmental issues that needed urgent addressing. The Department moved swiftly to include in the qualification many prescribing responsibilities on the dispenser, including record-keeping and all other information relevant to the sale and use of the appropriate products. To this end, it is clear the Department accepts that the RPs are professionals.

In summary, the Department must retain a level playing field in the prescribing and dispensing of antiparasitic medicines and ensure they adhere to the expressed wishes of Irish MEPs, the recommendation of the HPRA report and the advice of the CVO, coupled with the unified support of all the stakeholders.

Compliance with the directive to enhance the internal market and increase the availability of veterinary medicinal products will thus met in full. The RP must remain able to advise and deliver a consistent message on antiparasitic resistance measures, help preserve the life of the existing groups of available wormers and introduce responsible use measures across entrenched farming practises. A holistic multi-pronged approach is nothing short of imperative if Ireland is to effectively address antiparasitic resistance. A fresh solution has been offered to the Department that stakeholders believe has no legal impediment to its implementation and this is the only route of travel to resolve this outstanding issue.