Oireachtas Joint and Select Committees
Wednesday, 11 June 2025
Joint Oireachtas Committee on Agriculture and Food
Impacts of the Veterinary Medicinal Products, Medicated Feed and Fertilisers Regulation Act 2023: Discussion
2:00 am
Aindrias Moynihan (Cork North-West, Fianna Fail)
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No apologies have been received from Deputies or Senators. It is proposed that the three different groups will appear before the committee separately and, as each group comes in, there will be an opportunity for members to raise questions. I propose to take a list of names at the start and then to follow through with the same list of names for each group of witnesses if members are agreeable on that.
Before we begin, I will read the note on privilege. Witnesses giving evidence from within the parliamentary precincts are protected by absolute privilege in respect of the evidence they give to the committee. This means that witnesses have a full defence in any defamation action taken based on anything they say in the committee meeting. However, witnesses are expected not to abuse this privilege and may be directed to cease giving evidence on an issue at the Chair's discretion. Witnesses should follow the direction of the Chair in this regard. They are reminded of the long-standing parliamentary practice to the effect that, where reasonable, no adverse commentary should be made against an identifiable a third person or entity. Witnesses giving evidence from outside the location of the parliamentary precincts are asked to note that they may not benefit from the same level of immunity from legal proceedings as witnesses giving evidence from within the parliamentary precincts and may consider it appropriate to take legal advice on this matter. Privilege against defamation does not apply to the publication by witnesses outside of the proceedings held by the committee of any matters arising from proceedings.
I remind members of the constitutional requirement that members must be physically present within the confines of the Leinster House complex to participate in public meetings. I will not permit members to participate where they are not adhering to this constitutional requirement. Therefore, a member who attempts to participate from outside the precincts will be asked to leave the meeting. In this regard, I ask that any member partaking via Microsoft Teams prior to making their contribution to the meeting would confirm that he or she is on the grounds of the Leinster House campus. Members are reminded of the long-standing parliamentary practice to the effect that they should not criticise or make charges against any person or entity by name or in such a way as to make him, her or it identifiable or otherwise engage in speech that might be regarded as damaging to the good name of the person or entity. Therefore, if their statements are potentially defamatory in relation to an identifiable person or entity, they will be directed to discontinue their remarks. It is imperative that they comply with any such direction.
On our agenda for today is an examination of the Veterinary Medicinal Products, Medicated Feed and Fertilisers Regulation Act 2023. The committee will first hear from representatives of Merchants Alliance Ireland. The witnesses are Ray Doyle, Barry Larkin, Ollie Ryan and Terence O'Shea. Members will have received the opening statement and will have had an opportunity to review it. I ask the witnesses to confine their opening remarks to two minutes and then we will proceed to questions and answers. I propose that we take six minutes per member and move on to the next group of witnesses after that with the co-operation of the members.
Is that agreed? Agreed.
Mr. Ollie Ryan:
I thank the Chair and I thank the committee for allowing us time to speak. I am a member of Merchants Alliance Ireland, which represents all the license merchants in Ireland. Over the past 20 years, we have been allowed to stock a lot of POM products, which are prescription-only medicine products that are freely available to be dispensed by a licensed merchant. Over the past 20 years, we have never received any prescriptions for those products. In the current format, we do not see a future for us in the industry. I will read out a few examples of where we are at. To use the example of mastitis or intramammary tubes sales in 2022, the rules changed for the category of products, which meant that co-op vets were no longer allowed to prescribe intramammary products for animals. In the past two and a half years, these products have been exclusively prescribed by vets. In this time, the use of these products has remained constant, not decreased, as was the intention of the regulation at the outset. Prior to 2022, co-op dispensed approximately 40% of these antibiotic tubes. However, today, though co-ops are actually allowed to dispense these products, they only dispense about 2% of them. The result here is the use of intramammary antibiotics has not reduced but the shift in route to supply has and is overwhelmingly in favour of the vets.
The Department of Agriculture, Food and the Marine and the statutory instruments acknowledge the need for vets be able to prescribe antiparasitic products in these areas where they do not clinically assess the animal. Despite this provision being the proper assessment protocol, however, the terminology and its interpretation ensures it is almost legally impossible for a vet to comply with. There have been various promises made for further clarity. However, this has been less than forthcoming since September 2024. The complexities around the terminology will likely result in increased confusion. This statutory instrument effectively eliminates licensed merchants from the animal health market.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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I thank Mr. Ryan.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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We are tight on time and with the co-operation of everybody we will try to keep to time.
Members will have received the opening statements and have had an opportunity to read them over. I will proceed for six minutes. I call Senator Paul Daly.
Paul Daly (Fianna Fail)
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I will get straight to it. We have been here before. I am a veteran of this committee and the witnesses have been here before. The last time they were here, we ended up writing a substantial report on this subject. I read Mr. Doyle's opening statement but let us get on the record that there seems to be an impasse at this stage. We went through the regulation and there was an statutory instrument, then an introduction and a deferral. There was lot going on, and nothing going on. From my reading of it, there seems to be a breakdown in the non-therapeutic side of things being highlighted in the statutory instrument or regulation. There is the issue with vaccinations and as a farmer I can state, the future is vaccinations. To quote from the aim of the regulation, it is“to stimulate innovation in and increase the availability of veterinary medicinal products". That covers the witnesses in every way. Innovation is vaccinations and it is the future. If the witnesses are knocked out of the area based on what they are saying, there is going to be less availability, and it is then going to be a monopoly. Bearing in mind that there are people with vested interests in this who we will hear from today, can the witnesses fill us in as to what has happened since we started this, how we got to where we are and how they see it being solved? As I said, the big issues I see from this submission are the non-therapeutic side, the vaccine side, the NVPS, and the fact co-ops do not seem to get prescriptions, what happened before with the antimicrobial question, and the role of vets. Why can co-ops not employ a vet to give prescriptions? Is it not the same thing? A vet is a vet.
Mr. Ray Doyle:
I thank the Senator. I will cut to the chase as we are under time pressure. The NVPS, if it was working correctly, probably should have been in excess of 20 million prescriptions a year. Within a year to date, by the end of April, only 75,000 prescriptions were uploaded onto it. Of that, 99.8% were dispensed by the vet who wrote the prescription, even though there is very little uptake with the NVPS. Therein is our point illustrated. The vet who provides a prescription will more than likely dispense the product. When it comes to us trying to hire vets, as regards the term non-therapeutic, antiparasitics are called antiparasitic treatments. If an animal is be treated, sometimes it is a therapeutic and a non-therapeutic use all in one. However, the statutory instrument is written with non-therapeutic use in mind and therefore we legally cannot get vets to comply with the statutory instrument, because they would be in contravention of the law and of the Veterinary Council of Ireland, VCI, standards. Therefore, we cannot get vets to actually work with us. To put that in context, there is €400 million a year in the veterinary medicinal market. Veterinary practitioners currently dispense €300 million worth of that. Consequently, €100 million is now divided up across the rest of the sectors.
Regarding antiparasitic use, as the regulation itself states, we need to reduce the level of antiparasitics we are selling. They need to be driven down. The only way that will happen is to increase the sales of vaccines. Currently the statutory instrument precludes us from engaging vets to write a prescription for antiparasitics as they are non-therapeutic and the Department has decided in its wisdom not to allow us to prescribe vaccines. That means even if we can get vets to write the prescriptions we are not allowed to write prescription for the vaccines, and in theory we can dispense them, but we never will. I will go back to the dry cow tube example. We can stock them legally, but why would we stock them when only 2% are now being sold?
Most co-ops have ceased to stock intramammary tubes because they do not get the prescriptions to be able to dispense the product as it is dispensed by the prescribing vet and we cannot get vets to write prescriptions legally under the current structure of the statutory instrument.
Paul Daly (Fianna Fail)
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I apologise for cutting in; I am conscious of time. I am a solution-driven person. Can Mr. Doyle give me the answers for a solution from his side of the fence? We can all work in harmony going forward.
Mr. Ray Doyle:
The solution is for all vaccines for farmed animals to be included in the protocol. The protocol must be simplified because it is very onerous; too onerous for what it is. Again, the regulation wants to gather data to provide the rationale for prescribing these products. We fully endorse that; that is what we want to do. The statutory instrument needs to be rewritten to encompass what I have said about non-therapeutic use. It needs the addition of all vaccines. We want to ramp up the sales of vaccines and decrease our sales of antiparasitics, as per the regulation itself. The regulation itself, Regulation (EU) 2019/6, which this statutory instrument is supposed to transpose, is supposed to increase competitiveness and commercialisation. It is reducing it in its current format. It is supposed to maintain supply routes of all products and maximise the availability but, and I quote directly, it is reducing it. This statutory instrument as written is contravening two objectives - three at points - that Regulation (EU) 2019/6 sets out to achieve.
Mr. Terence O'Shea:
I represent the Independent Licensed Merchants Association, ILMA, which comprises around 350 small licensed merchants and general merchants, mainly in the western seaboard and along the Border counties. We have done a fairly in-depth analysis of the way our members will end up if the statutory instrument stays as it is or if it is amended. If the amendments that we have put forward to the Department are accepted and if the statutory instrument is amended by the Minister, approximately 50 members out of a total of 350 will remain in the business over the next 12 months. If it is not changed, it will probably will be fewer than five.
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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Could Mr. Larkin briefly talk me through the potential dramatic shift in the veterinary supply chain, obviously moving away from the co-ops and the independent licensed permits?
Mr. Barry Larkin:
The first thing to say is this has been on the cards for the past four years and we are where we are, which is not much further on. The Department has put in place various different proposals in place, none of which have worked. The current proposal has been pushed out to 1 September. We are still not much further on. We feel that the shift in supply will be very similar, if not identical, to the antimicrobials or the intramammary tubes.
We have gone through those figures already. Approximately 40% were dispensed through the co-ops before the new regulation was introduced in 2022 whereas now only 2% are dispensed through the co-ops.
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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What would be the financial impact of that in terms of value?
Mr. Barry Larkin:
It will make licensed merchants totally unviable going forward. They will exit the animal health industry. If the corner shop or the rural Ireland merchant exits the animal health industry, as it was most likely one of their more profitable sectors, they will become unviable and will not be able to support the local farming community. We have heard from various other stakeholders that are going to be appearing before this committee and it seems they are going to make the same argument. If we go back to what the regulation sets out to achieve, the points are not being achieved. In terms of antimicrobial use, the whole idea of the regulation was to reduce use and become more prudent but the same amount of antimicrobials are being used today as were being used before the regulation changed in 2022. The same impact is going to happen for the antiparasitics. If we look at the regulation, it is to increase the supply and maximise the availability of products to farmers. It is a complete no-brainer. The proper assessment protocol is tailor-made to prescribe vaccines onto farm. It improves animal health and reduces the burden on antimicrobials and antiparastics.
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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I am really concerned about the economic impact in particular on rural Ireland. How many potential job losses are we looking at if we do not get a proper resolution? Obviously, the merchants are frustrated because they have been at it a long time but they are not getting a hop out of the Department by all accounts.
Mr. Terence O'Shea:
I will come back in on that point but would like to continue with the point I was making to Senator Daly. The sector that we represent, unlike Mr. Doyle, who represents ICOS, are village and small town merchants. Around 20% of their turnover is veterinary medicines but that is also around 20% of their profit. If they are forced to exit the industry due to the technicalities in the statutory instrument, their ability to generate profit drops by 20% but their insurance and their light and heat bills do not drop by 20%. Ultimately, what will happen is that the number of people supplying veterinary medicines will reduce. We believe our sector will drop to around 50 and the majority of the merchants may end up closing. These are the merchants that are available on Saturday night and are open on Sundays to supply all of the farm needs. All of us are from rural Ireland and if one travels through the villages and towns in rural Ireland, the priest is gone, the Garda station is gone, the phone box is gone, as is the pub, coffee shop and restaurant. Now we have a statutory instrument that will ultimately force the merchant out. It is very important to stress that this is not by intent but whether by accident or whatever way it has turned out, this is the outcome. We have impressed our message for almost five years on the officials in the Department of agriculture. They are quite aware of the subtle changes that need to be made to ensure that a small amount of our sector and our members remain viable and continue supplying services to more than 125,000 farming enterprises. If we end up with less than 50 merchants, that is one for every 3,500 farming enterprises in Ireland. It does not make sense.
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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I have serious worries about the unintended consequences of this particular statutory instrument and the fact that we could potentially lose hundreds, if not thousands of jobs in rural Ireland, in towns and villages like those I and other members here represent. That is something that we absolutely do not want to see happening. The service that the merchants provide to rural Ireland must be acknowledged. This situation is not acceptable.
It was mentioned earlier that the prescription business is worth €400 million per year, with €300 million of that with veterinary practices and €100 million with others. What would that have been prior to this particular statutory instrument?
Mr. Ray Doyle:
That is current sales of veterinary medicinal products, not prescriptions, but what the Deputy has just raised is a valid point. What we are proposing in terms of changes to the statutory instrument will maintain jobs in rural Ireland for our members but also for the veterinary practitioners because we have to pay for all of these prescriptions to be issued to sell what we currently retail without a prescription. We have no problem with that. In fact, we are actually endorsing the sanctity of a prescription being written by a veterinary practitioner. What we need is sales of vaccines to be able to dilute out the cost of the prescriptions and that is recycled back to the veterinary practices. Nobody is more invested, other than Veterinary Ireland itself, in keeping large animal veterinary practices alive than us. The vets keep the farmers we depend on as customers in business. We are all trying to stay in business here. That is the whole idea of our proposed amendments to it. We are all trying to survive. Nobody is trying to take advantage or to take a bit out of anyone else's mouth on this.
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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I fully appreciate our guests coming in and giving their time. I hope the Department will engage in a more positive fashion going forward.
Danny Healy-Rae (Kerry, Independent)
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I welcome the Merchants Alliance and the other two groups to the meeting. I hear what they are asking and they are being very fair. I know Mr. O'Shea very well. He has been coming to Kenmare and providing a service at the mart for many years, as well as other places. He and his likes are appreciated by the farmers. When a farmer gets up in the morning, he will have 100 different jobs to do. It was always felt that this was a valuable service in the mart, Kenmare mart in this instance, where the farmer would go to sell a few animals and bring home the usual dose of stuff, or whatever was available. I know they have been cut back with the mastitis tubes and all of that and that is sad too. I believe there is enough there for everyone. The vets are very busy and they have enough to do. Indeed, we appreciate the vets very much because our story is that we can get a vet sooner for a cow than we can get a doctor for a patient. That is the way things have gone in rural Ireland. They have enough to do and we do not want to take from their job but at the same time, we do not want to quench the merchants. I am glad I am on this committee in this Dáil because I was a constant speaker during the last two Dáil terms but was not a member. I always came into the agriculture committee because it is very important for the people I represent. Equally, our guests are very important to the people that I represent in rural places. They know that merchants are available in Kenmare mart. Those living in Kilgarvan, Castletownbere and down to Cahersiveen are all coming up to Kenmare mart. They get what they need from Terence. I certainly will not be the one to come down on them. I feel they are providing an excellent, valuable service to the people in our localities. If Mr. O'Shea would like to ask me anything, I would be glad to respond. He has asked me about this several times before.
Mr. Terence O'Shea:
I thank the Deputy. We have discussed this issue previously. The Deputy is very familiar with Kerry, the Iveragh Peninsula, the Beara Peninsula, the Dingle Peninsula, Dunmanus and all of the places where services are getting scarcer and scarcer. If one leaves Kenmare and travels to Cahersiveen or to Killorglin by the scenic route, it is over 130 km and there is only one veterinary practice. That veterinary practice provides a fantastic service. It is involved in the sale of veterinary medicines and so am I and the amazing thing about it is that there is plenty there for everybody. Everybody has enough but the idea, by accident or otherwise, that a statutory instrument can erode a business represents a clear lack of fairness and a lack of understanding of what commercially drives any business today. On numerous occasions we have invited officials in the Department to see what they are legislating. I know one can legislate from a distance but there is a failure to grasp. The most important thing that needs to be said in all of this relates to the access to prescriptions. At its invitation we met Veterinary Ireland a few years ago and it clearly set out its position.
It spoke about the large retailing veterinary practices around the country and clearly stated that it would not be making prescriptions available to its clients to purchase their products - and I think the words used were - "from the likes of you". It would be supplying the products itself.
The principle under which the NVPS was set up was that farmers would engage with a veterinary practitioner. The prescription would be issued online via the NVPS and the farmers could go wherever they wished. If that is the system the statutory instrument is providing for, then the idea that an individual can be refused a veterinary prescription is the same as going to the doctor and the doctor saying the patient cannot go to the chemist and giving the medication himself or herself. That would not be tolerated by pharmacies.
Danny Healy-Rae (Kerry, Independent)
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Where is this coming from? Who is initiating it?
Mr. Terence O'Shea:
The idea is not to point the finger of blame in any direction. This originated from the European regulation. The Department of agriculture and the Minister are ultimately responsible for drafting the statutory and signing it into law. That is the law of the land. They have more than adequate discretion to provide for everyone's concerns. It is our belief that they are not providing adequately for our concerns. If the Deputy asked me to describe the statutory instrument and I was a veterinary practitioner, I would say it was the goose that would lay the golden egg. That is the reality. That is where we are coming from.
Danny Healy-Rae (Kerry, Independent)
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I do not mind pointing the finger or being told who is the cause of it. I am all for fairness. I believe these people have provided a valuable service to small farmers throughout Kerry and beyond and I support their continuation and will continue to do so.
Eileen Lynch (Fine Gael)
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I thank the witnesses for being with us and for their informative presentation and notes on it.
My big concern is the effect this will have on farmers and the inconvenience it is causing them. A good example is the way the dry cow tubes have worked and the extra costs that is placing on farmers. Previously, they could go to their chemist or co-op and get dry cow tubes, whereas now they also have to pay a prescription fee on top of that. From farmers' point of view, the inconvenience and extra costs are indefensible.
I take the point that we are pretty much dealing with a crisis as regards antimicrobial resistance, AMR, in animals and cross-contamination and it is becoming a larger issue. However, we have to be practical about how we deal with that. From listening to the witnesses and from their submission, I have significant concerns about the anti-competitive nature of how the statutory instrument is being introduced and implemented. Mr. O'Shea spoke about it, but could the witnesses give a bit more clarity on why farmers will have difficulty in accessing medicines from merchants? In theory, my understanding is that they should be able to get their prescriptions and then decide who they want to purchase the medicines from. Are there any further comments on that or on how that element of the matter could be resolved?
Mr. Ray Doyle:
I will try to address all of those points. I could not agree more with the Senator about the inconvenience. It is the reason we need to stay in business and have maximum availability. It is in keeping with the regulation to maintain current supply routes.
On the extra cost, the problem is that the antiparasitic treatments were up-regulated by the Health Products Regulatory Authority, HPRA, to prescription-only medicines, POM, so they necessitated prescriptions. That ship has sailed and we understand that, so we have to deal with the cost of the prescription. We will have to take on board that cost if we want to sell the products, which is what we are trying to do with this statutory instrument. Unfortunately, that is now a cost all farmers will have to be burdened with.
A prescription was always required for dry cow tubes. We had a different prescribing regime in place. It started in 2007 but expired in 2019 when this new regulation came in. The new statutory instrument is endeavouring to fill that gap so that we can credibly engage with veterinary practitioners to legally write the prescriptions, which is what we want to do that, but there are too many hurdles in our way. In theory, we can access the NVPS to dispense a product but in practice, it will be dispensed before the NVPS has a chance to create this alleged free and competitive market for it because it simply will not be credible. The example is the dry cow tubes. We have legally been able to dispense them since 2022 with a prescription on the NVPS, but farmers do not come in with prescriptions because they have already been dispensed by veterinary practitioners and the alleged free market we are supposed to have simply does not exist. We want to engage the veterinary practitioners, pay them for their services and prescribing, and try to sell the product through that.
I will revert to the big figures I had. Veterinary medicines amount to €400 million in total. Already, €300 million of that is being dispensed through veterinary channels. All we are trying to do is to maintain what we have. We are faced with a falling market in antiparasitics. The Senator touched on AMR, but we are all agreed that antiparasitic resistance is a bigger problem.
Eileen Lynch (Fine Gael)
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Mr. Doyle touched on this, but having read the regulation that this statutory instrument implements, I wish to ask whether we are bordering on, or potentially in the field of, not being compliant with what the regulation sets out. I have a serious question as to whether the statutory instrument is properly implementing the EU regulation in terms of the spirit in which the regulation was drafted and what it was meant to do. It does not appear that the statutory instrument is doing what the regulation is meant to do.
Mr. Doyle mentioned that Merchants Alliance Ireland has been engaging with the Department of Agriculture, Food and the Marine, but perhaps not successfully. I appreciate that the Department says it is too late, but does Mr. Doyle think it is as simple as amending the statutory instrument? What is the best way to get this resolved?
Mr. Ray Doyle:
It actually is as simple as amending the statutory instrument. That will then comply with objectives 2 and 3 of the regulation to increase competitiveness. With the way the statutory instrument is written, vaccines have been excluded. Why is this? We all need to drive down antimicrobial and antiparasitic usage. The only tool to do that is the increased use of vaccines. We are allowed to dispense licensed merchant, LM, vaccines, but the Department has decided in its wisdom that it cannot allow us to dispense the POM vaccines even though we are dispensing POM antiparasitics now. We are good enough to dispense POM antiparasitics and the older vaccines, but we cannot be allowed to dispense the POM vaccines. That is not credible when we are faced with trying to decrease the usage of antimicrobials and antiparasitics and increase competition. How does it increase competition or even keep competition in place if 75% of the route to market is already controlled by the veterinary channel? How is it competitive to decrease that further?
Eileen Lynch (Fine Gael)
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The witnesses provided figures about the effect this will have on their businesses. Rural Ireland is the larger element. Their groups are feeling this on the ground already despite the fact that only part of it has been implemented at this point.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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I thank the witnesses for attending. I will hit them with a few quick questions. Did the Department bring in the responsible persons or make any effort to try to talk to or work with them?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Regarding this statutory instrument, have the responsible persons in the local places where we get medicines, a co-op or wherever else been contacted by the Department or was any system put together to try to work with them to upgrade them or the like so they could have the qualification to be the responsible persons with more letters after their names? I will put it that way.
Mr. Barry Larkin:
I will come in on that. It is just not that simple. In the grand scheme of things, the answer is "No". Looking through the detail of the statutory instrument, many of us are unsure of the role of the responsible person going forward. We have all these responsible persons in our businesses.
Ultimately, however, a vet will do the prescribing. The terms and conditions required to comply with the proper assessment protocol-----
Michael Fitzmaurice (Roscommon-Galway, Independent)
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I mean before now. I am not talking about now. When this was starting off, was there any engagement on resolving it?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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That is all I want to know. A happy medium needs to be found for the simple reason that we need vets. Farmers around the country need vets. In my part of the country, we get a good service, as do most places. We need the co-ops and the small operators like Colm Tully down my way to sell the dosing stuff. The pharmacies also do it. We need to strike a happy medium between all of them. I will be talking to the Department later.
There is a problem arising. If I had cattle and at the beginning of the year wanted to go in for the annual fluke and worms dose, it is not considered therapeutic. If I do a faecal sample, am I right in saying I have to have the prescription with it that the vet cannot give from afar? Is that the big problem?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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If you do a faecal sample-----
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Right. That is one of the major stumbling blocks and needs sorting. Do the witnesses agree?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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I put this to Mr. Doyle because he is on the co-op side of it. Co-ops have a tendency. There is a fear among farmers - I will be clear on this because I have to call it straight - that co-ops want a dairy man to buy the milk, fertiliser, meal and everything. Was there a danger that if co-ops got too much control, they would have everyone pushed into the one corner of buying everything off them and they could go nowhere else? How do we balance that?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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But how do you balance it? At the moment, you can buy a calf and you have to buy milk replacer and meal off them. You have to do everything right up along until that calf goes to wherever it is going. They are a totally different outfit from the small merchant down the country that you run into to get the dosing stuff, or a pharmacy. How do we balance that?
Mr. Ray Doyle:
I would contend my colleagues in the alliance are the balance to that. They are independent people actively competing with the co-ops and keeping them honest. I have no issue with the Deputy's proposition. It is balanced by the marketplace. One of our contentions is that amending the SI would allow the market to balance itself, not to keep it 75% skewed towards one operator. I have no issue with that at all.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Mr. O'Shea reckons there could be 500 to 600 outfits or individuals lost if this goes the route it is going at the moment.
Mr. Terence O'Shea:
The group I represent, the ILMA, articulates the difficulties and views of about 350 small merchants throughout the Twenty-six Counties, myself included. We have done a fairly substantial assessment. Did everybody buy into it? No, they did not, but from our feedback we could count 38 merchants we genuinely believed would remain in business if officials in the Department made the appropriate amendments to the SI and the prescribing protocol. In that alone, we are losing eight of every nine members we have.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Is that with the new legislation?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Even if it was changed.
William Aird (Laois, Fine Gael)
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I thank the witnesses for coming in. Michael Byrne is the person I deal with and have dealt with for over 40 years. Like other speakers, I want to say this is not a question of bashing farmers or vets. I use a vet very regularly and so does anybody involved in the business I am involved in.
On the dry cow tube one, I could do it for years without getting it. Now I get a veterinary certificate for it and I still buy them off Michael Byrne. I want to make that clear.
When you get up in the morning and have a sick animal, you make a call to the vet or whatever you do, but there is also the routine dosing and routine looking after cattle that we all do and are reared with. I do not need a vet to tell me how to do that. I remember the vet coming in several times to my late father and asking him, "Jimmy, what do you think is wrong with them?" Young vets starting off got their knowledge from farmers who knew what it was but did not have the stuff to give to the cow.
This is like the corner shop closing. This will close down another business and there is no need for it. These people give us a service we are used to. We do not have to rock up and change our clothes. We can drive in and they can come out. Before that they gave a service, as Deputy Healy-Rae said, at all the marts. I bought a load of cattle at marts and an old man would say to me, "By the way, you should dose that one." I could buy the dose and dose him straight away when I got home. That is all we want. There is nothing about ill-treatment or anything. This is just routine stuff we do to look after cattle, the same as people with small animals give them stuff for fleas or dose them. We looked after them and were used to the service we were getting. There was nothing wrong with the service. The service was not abused, either by the people dispensing the stuff or the people, like myself, buying it. There was no abuse in it. We understand a lot of the stuff needed is intramuscular. The vet will leave you a bottle of whatever. There is room for this. At the moment, we are talking about a €400 million industry which is €300 million at the veterinary end and €100 million for everybody else dispensing it. I got and continue to get a great service. I would like that service to continue.
As a practising farmer, I have never been forced into buying this or thought I had to buy that. I buy where I think I get the best product and then I argue on the value, the very same as everybody else. I will not be pushed into co-ops or anything like that. I will do the business I think best. Mostly, whether you are buying meal or anything else, you build a relationship with a person, trust the person and they give you the service you need. I would like somebody to tell me why they went down the road of changing something that was working. There was no abuse of it. This is like going into a supermarket and you will not be able to get Aspro, Anadin, shampoo or anything like that.
Danny Healy-Rae (Kerry, Independent)
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We do not mind about shampoo.
William Aird (Laois, Fine Gael)
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You will have to go to your chemist to get that. It is the very same. We look after our animals. What is all this about? Once a week, I have to sit down and put into my medical register everything I do and everything I have bought. There is a record. The corresponding number has to be put into it and it is inspected. What is wrong? There are no complaints about it. Obviously, it is a vested industry that wants to take these people out. It will be dearer for me. Will it be available to me? Will it be closed at 5 p.m.? I can ring Mick Byrne when I am at silage or during the calving period and am under pressure. I ask Mick would he mind dropping stuff in to me and it is done.
I had five questions. How does the veterinary medicines Act 2023 affect the responsibilities and compliance requirements of veterinary professionals and animal health practices? That is one question I had. I could ask the witnesses the five questions but I will not. I will give them my experience of it. I think it is wrong. We have to sit down and talk to the Minister. All we want is for common sense to prevail. We have heard everything the witnesses have to say. I was reading this for months on end. I do not want this taken out of the market.
I do not have any questions because I know it all. I just want to say I support the witnesses 100%. They can speak to me as a practising person who is dealing with them.
I have been dealing with Mick Byrne, as my father did before me, for 41 years. That is how long we have been dealing with him. He provides a great service and I do not want to see him go. His son is there now as well. He is a lovely fella. Why would we damage something that is working well? That is all I will say. If the witnesses want to answer, that is fair enough, but Merchants Alliance Ireland is not having any impact at the veterinary end, on the qualifications of a vet or anything like that, none whatsoever. I do not need a vet to tell me there are lice on my cattle. I can see them.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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In the brief moment that is left, the witnesses may respond.
Mr. Ray Doyle:
I could not agree more with everything the Deputy said. We are most definitely not undermining the veterinary profession. We are going to be another source of income to the veterinary profession - I need to state that again - because we have to pay for all the products that were once not prescription only medicine, POM, and now are. We will be recycling money back into the veterinary profession because we have to and we have no issue with that.
William Aird (Laois, Fine Gael)
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Can I say-----
Aindrias Moynihan (Cork North-West, Fianna Fail)
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The Deputy has four seconds.
William Aird (Laois, Fine Gael)
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Most of the vets I know do not want them anyway. That is all I can tell the Merchants Alliance Ireland.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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As the 50 minutes allocated for the first group have concluded, on behalf of the committee I thank Merchants Alliance Ireland for its contribution to the meeting today. I will suspend the meeting to allow the next group of witnesses to come in.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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I draw attention to a note on privilege. Witnesses giving evidence from within the parliamentary precincts are protected by absolute privilege in respect of the evidence they give to the committee. This means that witnesses have a full defence in any defamation action taken based on anything they say in the committee meeting. However, witnesses are expected not to abuse this privilege and may be directed to cease giving evidence on an issue at the Chair's discretion. Witnesses should follow the direction of the Chair in this regard. They are reminded of the long-standing parliamentary practice to the effect that, where reasonable, no adverse commentary should be made against an identifiable third person or entity. Witnesses giving evidence from outside the location of the parliamentary precincts are asked to note that they may not benefit from the same level of immunity from legal proceedings as witnesses giving evidence from within the parliamentary precincts and may consider it appropriate to take legal advice on this matter. Privilege against defamation does not apply to the publication by witnesses outside the proceedings held by the committee of any matters arising from proceedings.
The committee will now hear from officials from the Department of Agriculture, Food and the Marine. They are Dr. Maria Destefanis, agricultural inspector; Ms Caroline Garvan, senior superintending veterinary inspector; Ms Noreen Galvin, veterinary inspector; Ms Janice Whelan, assistant principal officer; and Mr. Bill Callanan, chief inspector.
Our time is limited. The statement has been circulated. I ask Ms Garvan to keep her contribution to two minutes and then we will move on to members for questions. Six minute slots will put us under pressure. Can we do five minute slots and in that way allow ten members to ask questions? In that way we will move through it as quickly as we can.
Ms Caroline Garvan:
Good afternoon. I thank the Cathaoirleach and the committee.
I appreciate that members have already read the statement so I will just pick out some key points. The Minster and Department are acutely aware of the impact this could potentially have on members of Merchants Alliance Ireland. We have worked steadfastly with all our stakeholders, and in particular with Merchants Alliance Ireland, to put in place mitigating actions. I will go through them and address some of the comments that were made by my colleagues previously.
We developed the national veterinary prescription system, NVPS, which is an electronic prescription system that facilitates ongoing competition in the supply chain. Farmers can access their prescriptions on that system and go wherever they wish to get them. The proper assessment protocol was mentioned. It is a niche protocol to support retailers in having an engagement and arrangement with vets to issue a prescription, but it is limited to certain circumstances. That is in the interest of animal health and welfare. Anti-parasitic resistance is a severe concern for the sustainability of the livestock sector in Ireland. Research has shown that compared with other member states - remember these are prescription only medicines in all other member states - we are losing €236 million to parasitic disease in this country. We are losing €8 million because of resistance so there is a need to regulate and the legislation requires it.
This protocol allows vets to have an arrangement with a licensed retailer to issue a prescription, thereby giving the retailer the ability to access the prescription. It has been commented that the protocol is onerous. I would suggest that prescribing anti-parasitic medicines properly is an onerous task. Quite an amount of information is needed. We have moved from the field where it used to be livestock was treated rigidly at five, eight and 13 weeks.
Now you have to have an adaptable parasite control programme which looks at all the factors that are in the protocol, all the information around the farm, the stocking density and what medicines are used. That protocol is necessarily detailed to optimise the outcomes for farmers, profitability and production.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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We need to move on to Senator Collins.
Joanne Collins (Sinn Fein)
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May I clarify just one or two things? The NVPS was set up to ensure that these animals would not be overloaded with antibiotics. Is that the reason everything was put on a system?
Ms Caroline Garvan:
No. The NVPS was set up because we have to submit usage data for antibiotics to Europe and we were not able to do so in 2023 and will not be able to do so in 2024. It is a regulatory requirement to submit that data but it also enhances our ability to access markets. It shows that we have good oversight. We have reduced our use of antimicrobials by 28% in the past four years, and that is the leadership and commitment of the farming sector. We have reduced critically important antimicrobials by 54%, which protects human health. That is why the NVPS was set up.
Joanne Collins (Sinn Fein)
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Has the Department been tracking the number of prescriptions uploaded to the NVPS?
Ms Caroline Garvan:
Yes, we have. We have 85,000 on the system at the moment. The first thing to say is that this system was introduced on 13 January, and we are fully cognisant that this was the start of a very busy spring season. As with any IT system, there were going to be challenges. We now have-----
Joanne Collins (Sinn Fein)
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Does Ms Garvan know what percentage of all prescriptions written up are on the system?
Ms Caroline Garvan:
I would not be able to tell the Deputy exactly what the percentage is, but what I can tell her is that 54% of vets are using it and 51% of practices are using it daily and weekly. Up to 80% of veterinary practices are engaged with the NVPS, so they are either using it or adapting their IT systems in order that they can use it. We are now at 80% usage, I would suggest, of NVPS. We have that other 20% to get to by 1 September. Our goal is to make sure that everyone is using it in order that we can support the prescriptions arriving to the retailers.
Joanne Collins (Sinn Fein)
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I am just asking about the competitive side of it. We listened to our previous group of speakers. I do not know whether it was said that 98% or 99% of all prescriptions are being dispensed by vets. Where is the competitiveness for the independent?
Ms Caroline Garvan:
If you consider the time of year when the system went live, the springtime, the vast majority of products will be dispensed by vets at the time of calving or at the side of the crush. The antiparasitics are not yet prescription only, so we have seen prescriptions dispensed by retailers and they tend to be milking cow tubes. The other thing is-----
Joanne Collins (Sinn Fein)
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Going past this season, Ms Garvan thinks it will even itself out?
Ms Caroline Garvan:
Yes, because when the products require prescription, the opportunity will be there for them to be on the system for retailers to access them. The other thing to say is that we have met with the retailers and responsible persons. We met with them in November. We are acutely aware of the stress and concern that this potential impact will cause, but they are not fully on board with the NVPS yet and are not fully using it. We have provided a free web app in order that they can use it through that. The main point is that the antiparasitics do not require prescriptions at the moment, so that is why they are not going up on the system.
Joanne Collins (Sinn Fein)
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Does the Department have a timeline as to when all these vets will be putting these prescriptions on the NVPS? Does the Department have a deadline for this to be 100%?
Joanne Collins (Sinn Fein)
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That is great. I thank Ms Garvan.
Paul Lawless (Mayo, Aontú)
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I welcome the Department representatives, the merchants and the members and representatives of veterinary associations. I have concerns for many of the stakeholders, the farmers, as regards the potential unavailability of vets. That is a major factor. The creation of a monopoly is a concern as well. Monopolies obviously do not end well for the consumer. I have concerns about the merchants, the loss of business and the role they play, particularly in rural Ireland. I have concerns as well for the pharmacist as regards the loss of business. This is at a time when, on the human side, we are increasing the role that pharmacists play yet on this side we are actually reducing their role, and indeed that of vets, in the animal welfare aspect. My understanding from speaking to a range of vets across Mayo is that the service in the west is run in many cases on overtime, and this will increase more workload on them.
I have just a few questions. Ms Garvan mentioned that an assessment was done by the Department. What was the outcome of the impact assessment as regards the consequences for the merchants? Ms Garvan also mentioned that mitigation factors were introduced. What were they? Specifically, what tangible measures can she say the Department has addressed to the merchants here today?
Paul Lawless (Mayo, Aontú)
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May I stop Ms Garvan there? She mentioned 85,000 prescriptions on the system. How many of those were purchased at the site of a merchant or a pharmacist, for example?
Paul Lawless (Mayo, Aontú)
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How many? Out of 85,000, how many were purchased from-----
Paul Lawless (Mayo, Aontú)
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That is 85 out of 85,000.
Paul Lawless (Mayo, Aontú)
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In terms of a mitigation factor, it is not a good start.
Ms Caroline Garvan:
As I tried to explain, however, the products that are currently being prescribed would not be supplied generally by a licensed retailer. As a result, so why would they get the prescription? That is my point. The products that are up there now are predominantly antibiotics, which are used to treat diseases during the spring. They are never supplied by a licensed retailer so they would not be dispensed by them.
Paul Lawless (Mayo, Aontú)
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Was any consideration given at Department level to potentially training merchants to prescribe any type of non-therapeutic medicine or to engage in any way possible such that they would have access to that system?
Ms Caroline Garvan:
The responsible persons can dispense on the system - there is no issue in that regard - but the only people who can prescribe in this jurisdiction are veterinary practitioners. This was the subject of a lengthy debate and went to the Attorney General. No other member state allows anyone except for a veterinary practitioner to prescribe veterinary medicines, so there is no provision for a responsible person to prescribe.
Paul Lawless (Mayo, Aontú)
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In terms of a happy medium when it comes to approach, was there any consideration at Department level as regards the targeted advisory service on animal health, the TASAH scheme whereby a vet could prescribe non-therapeutics at a particular point and then allow, for example, the farmer to purchase the medicines wherever he sees fit? Was that ever considered in this regard?
Ms Caroline Garvan:
Yes. The Department funded a TASAH in 2022-23 for parasite control, and this year the Minister announced €8.3 million to fund 30,000 biosecurity TASAHs. Under that, a parasite control programme can be developed, and, in the context of that programme, if there is a need, a vet can write a prescription.
I want to mention as well non-therapeutic use, and I fully accept the points made. It is very confusing, and the Department has developed guidance because it was used because the intention was that the vet has only information, no visit to the farm, and is prescribing for sub-clinical disease. If you have not been on a farm and an animal has a disease, you cannot prescribe responsibly, so we will define subtherapeutic use. The guidance will go out in the coming days. We will do what needs to be done to ensure that vets are clear what that means in order that they can prescribe any product that has been licensed for treatment or prevention, so there will not be a lack of clarity on what that means.
Paul Lawless (Mayo, Aontú)
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Going back to the points about the monopoly of the market, there are concerns here that the large players in the market, who I will not mention, could potentially monopolise this market in the sense that we could actually take the business away from the vets themselves and open the door for such a system to come into play.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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We need to move on to the next speaker. Deputy Newsome Drennan, le do thoil.
Natasha Newsome Drennan (Carlow-Kilkenny, Sinn Fein)
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On that, I ask Ms Garvan tell me a bit about the online prescription. I am a farmer, so I can go online and say I want wormers. Is that how it works? Do I still have to go through a vet? What kind of a system is Ms Garvan talking about?
Natasha Newsome Drennan (Carlow-Kilkenny, Sinn Fein)
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From whom?
Natasha Newsome Drennan (Carlow-Kilkenny, Sinn Fein)
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And that script can go wherever I choose.
Natasha Newsome Drennan (Carlow-Kilkenny, Sinn Fein)
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I still get charged for that script.
Prescriptions cost money. Who is going to pay for that?
Natasha Newsome Drennan (Carlow-Kilkenny, Sinn Fein)
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I do not need a vet to tell me that one of my animals needs a worm dose.
Natasha Newsome Drennan (Carlow-Kilkenny, Sinn Fein)
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Perhaps some people need more education on it. I have horses and cattle. We have been trained. I worked as a veterinary nurse. I know enough about what wormers my horses need. Is it the case that we are going to require dung samples before we are allowed to get a dose? How far are we going to take it?
Ms Caroline Garvan:
It is a question of whether we want best practice, and to be able to use the wormers we use now in ten years' time. If we do, we must factor in all the information that is required. We have to understand the life cycle of a parasite, for every species and seasonality. We must look at stocking density, the weather, whether refugia is being practised and grazing management. I suggest that veterinary expertise is needed to do all of that.
Natasha Newsome Drennan (Carlow-Kilkenny, Sinn Fein)
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I wonder. Most of my horses were quite fine as they were. Does Ms Garvan think this will push people to buy wormers in the North?
I go back to antibiotics, which were got through a vet. What data have been found to show that this is better for human health and animal health? What information has been collected in that regard?
Natasha Newsome Drennan (Carlow-Kilkenny, Sinn Fein)
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From antibiotics. Ms Garvan says there is a 28% reduction in antibiotic use. What difference has that made to our health and to animal health? Is it possible to say that? Every animal has a tag and a passport. On our farm, we are using the same amount of antibiotics that we always used in the event of animals being sick. I find it hard to see how there has been a reduction of 28%. Is there a pocket where that has come from?
Ms Caroline Garvan:
The reduction is based on data collected by the Health Products Regulatory Authority and submitted to Europe every year. That is the validation for the statement that a 28% reduction has been achieved.
It is important to understand that if a child toes into hospital today the family would like to know that the antibiotic they are given is effective. If we do not reduce the use in animal health, it will impact public health. It is in the top five global public health threats. Ireland is leading the way. We had a Commission audit two weeks ago and it complimented us on how much of a reduction we had achieved. Those figures have been validated and sent to Europe for confirmation. They are accurate.
Natasha Newsome Drennan (Carlow-Kilkenny, Sinn Fein)
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Most of the time when a child goes into hospital, they are given the wrong antibiotics to start with. It is about three days before the results of the blood tests come back, which show what the correct antibiotic should be.
If a vet comes to my yard and a calf or a horse is sick, the general response is to throw an antibiotic at them. These are vets. If the animal does not get better after a couple of days, we call the vet back and then they will do a blood test and we will go from there. That is generally how it works, except with the horses. Because I know my animals so well, I will ask for a blood test to be done there and then and to be sent away, just in case the antibiotic is not right.
Natasha Newsome Drennan (Carlow-Kilkenny, Sinn Fein)
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Merchants are at the heart of the community, especially in rural Ireland. Both the equine vet and the cattle vet are run off their feet. We ring them and they are racing. It could be all hours of the night and they are racing around. They are already run off their feet. It is madness.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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We must move on to Senator Brady.
Paraic Brady (Fine Gael)
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The witnesses are very welcome. I am delighted to see the relevant people from the Department and other bodies are here. We must be blunt. Whether we like it or not, there is a need for the competition authority to be called in at some stage, because this will affect the merchants.
A word has been bandied about by the Department of agriculture for the past eight or nine months, namely "simplification". We have heard it numerous times. The reality is that it is not getting any simpler for the farmer. There is more and more paperwork. These are the facts. The Department is now pegging more on top of us again. The reality is that the farmer knows his animals, if he is doing his job right and is qualified and in the Bord Bia scheme. He is taking faecal samples. As Deputy Aird said, he knows if the cattle in the shed have lice. One is either a farmer or one is not a farmer. When cattle in the shed have lice, the farmer will clip their backs and hope the lice do not cross and then the farmer will apply a lice powder. It is very simple. Farmers know about best practice.
This morning, I had a calf with a swollen navel. I know he needs Synulox. I cannot go into the veterinary practice to get it. I have to go to my local vet to get it. I understand that if a calf is dehydrated, we give it Lactaid. It is called simplification, but we are putting bands and rules on top of farmers. We decided that we were not going to do this, but now we are at it again. Do we not understand that when we go to the co-op we can give a herd number or a tag number? This is what Bord Bia is about. We have traceability in respect of everything. It is very simple. Why are we trying to complicate stuff? Does Ms Garvan not agree that if I went to the local co-op tomorrow morning and if it had a system, I could not give a tag number and get a delousing powder for the cattle in the shed?
Paraic Brady (Fine Gael)
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We all know the problem with sheep. There is a special dose that does not work any more because we have let it go. I accept that. If I test my flock of sheep by doing a faecal sample and I understand they need something in particular, am I not entitled to go to the co-op and buy that product? Why do I have to go to the vet? Why are we complicating it? If I have done the faecal sample and it is in my record for Bord Bia, why are we complicating it?
Paraic Brady (Fine Gael)
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We can still regulate it. I am not saying we cannot do that. What I am saying is that it can be put on the system that is sent off to Europe. There is no problem in doing that when I have taken a faecal sample. The proof is there.
Paraic Brady (Fine Gael)
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There is no discretion, so we are going to pile more paperwork in on top of the farmer again. That is basically what Ms Garvan is telling me here today.
Paraic Brady (Fine Gael)
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I can only speak for myself. Most farmers are not afraid to use computers now. Let us be honest and say that either a farmer must call out a vet or drive to him. They are not going to get on a laptop to upload prescriptions. That is not going to work. Let us be straight about it.
Paraic Brady (Fine Gael)
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Ms Garvan is after contradicting the whole lot. The vet can read my mind on the phone. Is that what she is telling me. He does not need to go to the shed to look because he is a qualified vet.
Ms Caroline Garvan:
My point is that he is Senator Brady's vet. He understands what the Senator has used in the past and what issues he has had. He has got the results of the faecal egg count. He knows how the Senator's animals graze the land, so he or she has the knowledge to give a prescription. The protocol, which we have devised to support the retailers, is for a vet that has never been on one's farm, never seen a farmer's sheep or the test results. That is the difference.
On simplification, the electronic prescribing system will stop farmers having to have paper prescriptions. They will get them all on a central portal on the agfood.ie portal. All the prescriptions will be there. Farmers will no longer need to have paper prescriptions, so that is simplification.
Paraic Brady (Fine Gael)
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Ms Garvan is not getting it. Many farmers-----
Aindrias Moynihan (Cork North-West, Fianna Fail)
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No, I do need to move on.
Paraic Brady (Fine Gael)
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My point is that many farmers are not IT-savvy.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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The floor is Deputy Cooney's.
Paraic Brady (Fine Gael)
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That is what my point is.
Joe Cooney (Clare, Fine Gael)
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I thank everyone for attending today. Having listened to the various statements, I would like to ask the Department officials about the possible use of the data available to them under the Act. Data is a highly valuable commodity, as they well know, and while it can be used in a proactive and positive way, it can also be used in a way that users may not have foreseen when the gathering system was set up. We are well aware of that. In this context, I have a few questions. Given the amount of data available to the Department under both the fertiliser database and national veterinary prescription system, and the granularity of the data down to individual vets, farmers, locations and even animals, is there capacity for the Department to use the system to regulate, limit or even prevent the sale or purchase of amounts or types of fertilisers to a farmer or the sale or purchase of prescription-only products to specific vets or farmers? Is there capacity under the Act for the Department to share the data from its database to any internal or external State agencies or commercial bodies? Finally, is there capacity for the information within the database to be referenced in investigations by State agencies or bodies into environmental or food-chain incidents?
Ms Caroline Garvan:
I thank the Deputy. I might answer on the NVPS question he raised. I thank him for raising the GDPR issue because it was raised at the start. We have gone to our own internal data protection unit and it has confirmed that there is no GDPR issue with the system. On the data, the Act limits who we can share it with, and there is no consideration currently being given to sharing any of it. We understand the importance of maintaining the integrity of the data.
There will not be a restriction on the sale of antimicrobials. What the regime will do is allow us to better implement official controls over oversight and prescribing. It goes back to AMR, so we can better direct our official controls to ensure the prudent prescribing and use of all medicines. That is where it stops.
Joe Cooney (Clare, Fine Gael)
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The Department is confident enough that the data will not be given to other public bodies.
Joe Cooney (Clare, Fine Gael)
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It is a concern that has been raised with me on several occasions. I can see why it would be raised.
Joe Cooney (Clare, Fine Gael)
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It is good to hear that. I hope that is the way it will be because there is serious concern that it may happen in certain cases.
Paul Daly (Fianna Fail)
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I welcome the witnesses from the Department. We have been here before. I was a member of the previous committee. In this business, you take on issues and try to have as much input and influence regarding them as you can, and then they are decided upon and you move on. That is what we did with this one, yet we are back dealing with it. To me, that implies the system is not working and changes will be needed.
I have a couple of points for the officials. It is all about antiparasitic and antimicrobial resistance. Where there is a POM vaccine and the vet has given the prescription, how is antimicrobial or antiparasitic resistance affected by not allowing a merchant to sell the product? If the vet gives the prescription, why is a monopoly being created regarding the sale of the product?
I cannot accept what was said about the 85,000 prescriptions and only 85 going to the merchants because of the time of the year. The merchants could have sold many or nearly all of the products. The officials must admit the system is not working and that is why the measure has not been enacted yet. Once the Department admits it is not working, a solution may be thrashed out. The Department referred in its statement to what is not appropriate at this time for the vaccines. Will it be appropriate sooner, and if so, how is that changing, altering or affecting antiparasitic resistance and the aim of eliminating parasites?
I get the point that the NVPS technology will take time but I cannot accept that one in a thousand prescriptions is going back to the merchants. You might as well let the merchants have the vaccines if it is going to be one in every thousand being sold. That is not going to do any harm to the bigger picture. I will let Ms Garvan answer those questions and then come back in.
Paul Daly (Fianna Fail)
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Not all vaccines.
Paul Daly (Fianna Fail)
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Why is the Department differentiating between vaccines?
Paul Daly (Fianna Fail)
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Does Ms Garvan not accept my point that if a prescription has been given, a vet will have sanctioned the administration of the vaccine? Given that point, why does it matter who dispenses? The problem here is the difference between prescribing and dispensing. Maybe we should have gone the whole hog and decoupled like other countries.
Ms Caroline Garvan:
We have no issue with prescription-only vaccines being supplied. We have allowed it since 2007. The vaccines the Senator is talking about are the POME vaccines, which do not require a prescription but are required to be supplied only by a vet or pharmacist. That was the determination made by the Health Products Regulatory Authority, the competent authority to decide the route of retail.
Paul Daly (Fianna Fail)
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It licenses the product.
Paul Daly (Fianna Fail)
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The Department decides who dispenses, not the HPRA.
Ms Caroline Garvan:
If we were to change the route, we would be interfering with the competent authority that determined on the basis of risk that the product should be dispensed only by a vet and pharmacist. We would be challenging and undermining its risk assessment. The Senator is correct that we can decide on the distribution channel but if we did the likelihood would be that the vaccines would then become prescription only, which would obviously put an additional burden on farmers and potentially a cost.
Paul Daly (Fianna Fail)
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Given the merit of the regulation, which refers to the stimulation of innovation and increasing the availability of veterinary medical products, the Department has failed.
Paul Daly (Fianna Fail)
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It does not appear like that. It is one in one thousand.
Ms Caroline Garvan:
It is important to state we do not have eyes on all the prescriptions that were issued this spring. It is highly likely that the retailers are still getting prescriptions but they are getting paper prescriptions because not all the vets are using the system. Therefore, we cannot say they are not still dispensing prescription products at retail level. The retailers would have to comment on that.
Paul Daly (Fianna Fail)
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There is plenty of room for error in the figure of 85 out of 85,000 but it is still a bad figure.
Paul Daly (Fianna Fail)
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The majority of them can be supplied by co-ops and merchants also.
Paul Daly (Fianna Fail)
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We have the dry cow numbers. Can Ms Garvan comment on them? We have the intramammary tube numbers. That is an example and Ms Garvan has just referred to it.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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I ask Ms Garvan to reply briefly as we need to move on.
Ms Caroline Garvan:
I absolutely accept the supply from the co-ops has dropped significantly, but the supply from the merchants has not and it is starting to increase again. It is fair to say that the figures show that the vets did not get all the supply the co-ops lost. We have moved to selective dry cow therapy and it is a real example of the progress on AMR.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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Go raibh maith agat. I need to move on to Deputy Cleere.
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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I thank the officials for attending this afternoon. I am very conscious that at the heart of everything here – involving the Department, merchants and veterinary side – is the farmer at home. I am thinking of the farmer at home, and that is where my questions are coming from. In all of this, was any thought at all given to the potential significant inconvenience for your normal, ordinary farmer in rural Ireland?
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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Yes.
Ms Caroline Garvan:
Okay. The important thing is that the TASAH programme in 2022 showed that in many cases farmers are using antiparasitics when they do not need to. Some 89% of the cattle herds in the TASAH programme had a faecal egg count below the threshold required for an antiparasitic and 75% of sheep herds were being given medicines that perhaps were not needed.
Many adult animals are also being treated. This regulation will focus on whether farmers need to buy these products in the first place which I suggest is a win. Antiparasitic resistance has significant impacts on production and profitability at farm level. Unless we address it appropriately through the prescribing methodology, farmers' security and society as a whole will lose out.
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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What is the Department's view on the notable shift in sales patterns among merchants due to this statutory instrument regulation and what is being implemented?
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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In previous exchanges, there was the possibility that hundreds or thousands of jobs in rural Ireland could be lost. What is the Department's view on that possibility?
Ms Caroline Garvan:
First, the Department certainly does not want to see job losses on that scale or any scale across rural Ireland. Rural Ireland is an integral part of our society. We have put in place these actions to support that. The reality is that we do not know what is going to happen on 1 September. We have put these actions in place to support the retailers but we do not know what will happen with the regulation.
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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Given that we do not know what will happen, how would the Department assess the potential financial burden of compliance with the veterinary medicine products regulations on small-scale farmers and merchants? What supports will be made available to mitigate these costs for all the different stakeholders?
Ms Caroline Garvan:
I mentioned the €8.2 million for the 30,000 TASAHs. This is a significant support whereby farmers will get free-of-cost consultation and advice with a vet. Addressing antiparasitic resistance is all about having a bespoke holistic approach at farm level and the TASAH facilitates that. Farmers will get advice, have a faecal egg count done and receive recommendations. I suggest the TASAH mechanism provides an invaluable tool for farmers to have more sustainable parasite control, which will support-----
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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Is there any support for merchants or the veterinary side of things?
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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I am conscious of time so I will move along. The NBPS is the new electronic prescription system developed by the Department. How much did it cost?
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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Is it fit for purpose? I note that it was said earlier that 54% are engaged. What is the story with the other 50%?
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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Are half of them using it?
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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Another 30% are aware it is there.
Ms Caroline Garvan:
No, they are working with their software providers to use it. There are four software companies that provide software for vet practices. They are small teams who must facilitate the 499 veterinary practices we need to be using this. We have 390 practices either using it or working towards using it. It is fit for purpose and operational.
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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Is the €11 million good value for money? The Department has spent €65 million in the past two years on IT systems that have not been successful in terms of efficiency and cutting out the red tape, as a Senator said earlier.
Ms Caroline Garvan:
It is good value for money. It will allow us to comply with our European requirements and have the information. It will allow us to access other markets abroad because we will show full oversight of the antibiotics, in particular, that are used in our animals. It will also allow us to protect human and animal health. It is good value for money.
Peter Cleere (Carlow-Kilkenny, Fianna Fail)
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Thank you.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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An Teachta Danny Healy-Rae is next.
Danny Healy-Rae (Kerry, Independent)
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I thank the Cathaoirleach. From all the interchanges there, I resent very much the assertion made by the Department official, Ms Garvan, which insinuated that farmers would not know the dose they should be giving to their animals. As a farmer for many years, I know what kind of dose the man would have wanted. In my case, I would go to the likes of Terence O'Shea for an animal dose or drench, and for minerals and different small things like that. To think that all of this would be taken away from them at the stroke of a pen because Europe directed it is a lot of nonsense to me. I feel the vets have enough to do and are doing their job very well. This will create a monopoly. The person who will pay the piper at the end of the day will be the farmer or the fellow who is buying the dose. That has to be realised by the Department. We need to have a bit of competition, but the little there is has been taken away completely.
The Department is saying that a farmer does not know when an animal needs a dose or some thing like that. He will know if he needs to get a vet. This is already happening. Every one of us here seems to be united in the fact this will create a monopoly. A scenario is being created that none of us asked for. Everything was going fine. The co-ops and distributors are all lovely people who have been doing well by the farmer. If they were not doing well by the farmer, they would not be there at all and would not be treating the farmers fairly. I will be very disappointed it happens to be the case in September that the merchant alliance and that crowd will lose whatever licence they had to do what they were doing. They were providing a great service at critical times for farmers, such as calving and lambing times, as well as what they put into the baths for sheep with foot rot or whatever. God almighty, it is only common sense if there is a lame lamb that a bath would be filled with this kind of a wash. Surely, the Department does not seriously think it will improve anything by having to get a prescription from the vet. It is being said that the vet will give out the prescription and the farmer can go where he likes with it, but that will not happen. The vet will give the prescription and the medicine himself. That rules out men like Terence O'Shea from Glengarriff who sells to the people of Kenmare and elsewhere in County Kerry and does so very well. There are several others - I do not know them all, but I know this man very well - who are providing this valuable service. I am absolutely disgusted to hear someone saying we might be better off going to the vet than getting the doses sent from a merchant who is doing it now. Maybe she has something to say about it. I am very disappointed with that remark.
Ms Caroline Garvan:
I thank Deputy Healy-Rae. He may have misunderstood that remark. I never said farmers would not know how to dose their animals. Farmers are the best judges of their animals. They are with them day in, day out. In 2022, the TASAH programme I referenced showed that animals were being treated that did not need to be treated. This was shown on the basis of evidence that products were being overused.
We have said from the start that we support competition. We want to see the likes of Terence O'Shea and his colleagues remaining in business. That is why we have put in all the actions I have tried to outline. Regarding the farmer feeling under pressure to buy directly from the vet standing in front of him or her, as I said earlier, farmers can request a prescription through an email to either their own vet or a vet that works for a co-op. Farmers do not have to go in and feel that personal pressure face to face. We have addressed it in this way.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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Thank you. Deputy Fitzmaurice is next.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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First, under the previous and current programmes for Government, every decision must be rural approved. Has this been rural approved?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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The consequences of this legislation.
Obviously not.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Okay. That is grand.
The Department said it looked at 85,000 prescriptions. A total of 84,915 have come in. Does that not give the Department an indication that it needs to wait until next January at least to see what the balance is and that it cannot jump in? At the moment, there are 84,915 to the vets, 85 to the merchants. Does that not worry the Department? Should it not wait another six months and watch this because what is happening could be a disaster?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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There are no consequences for the job.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Does the Department accept that it will be more expensive on farmers from now on?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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"Yes" or "No" is all I want.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Why not?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Except that farmers will be paying for a prescription.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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What are Ms Garvan's thoughts?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Okay. That is more money.
Has the Department engaged with the responsible person?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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When and where did it do that?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Why has the responsible person been accepted by the EU in Northern Ireland but not here in southern Ireland?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Yes.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Why are they allowed to in Northern Ireland? They are part of the EU as well.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Yes. They are part of the EU as well.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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I did not ask that question. I am asking about the responsible person.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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In the North they can.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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They were in the EU at the time. Is that not correct? They still are in the EU.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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No. It was in the UK because the UK had done something our Department did not do. Is there any possibility the Department will go back to Europe to ask if there is any upskilling, be it through veterinary nurses or the responsible person? Is there any hope the Department will talk to them about trying to resolve that issue? That needs doing.
Will there be a resolution - we have talked about the faecal egg count - where a farmer has to get the prescriptions and it cannot be done from a distance? Will there be a resolution to the therapeutic and non-therapeutic issue? This is what seems to be bogging the whole job down.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Even though they can do it in Northern Ireland this minute, and it is in the EU. They can do it if they are the responsible person, but we cannot.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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If I get a faecal egg count, I have to go to the local vet and do all that. If I go to the vet in January or February and ask for a dose for fluke or worms, I can get it from a distance. What is going to resolve that issue? That seems to be a major stumbling block at the moment.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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No, I am talking-----
Michael Fitzmaurice (Roscommon-Galway, Independent)
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----- about if I get a faecal egg count, it is called therapeutic. Is that right?
Michael Fitzmaurice (Roscommon-Galway, Independent)
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I am trying to get as many in as I can.
Michael Fitzmaurice (Roscommon-Galway, Independent)
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Is it not-----
Aindrias Moynihan (Cork North-West, Fianna Fail)
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Our time has concluded. Sin é. Go raibh maith agaibh. Gabhaim míle buíochas leis na hoifigigh. On behalf of the committee, I thank the officials for their contributions today.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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I draw witnesses' attention to the fact that witnesses giving evidence within the parliamentary precincts are protected by absolute privilege in respect of the evidence given to the committee. This means that witnesses have a full defence in any defamation action for anything said at a committee meeting. Witnesses are, however, expected not to abuse this privilege and may be directed to cease giving evidence on the Chair's direction. Witnesses should follow the direction of the Chair in this regard and are reminded of the long-standing parliamentary practice to the effect that, as is reasonable, no adverse comment should be made against an identifiable third person or entity. Witnesses giving evidence from a location outside the parliamentary precincts are asked to note that they may not benefit from the same level of immunity from legal proceedings as witnesses giving evidence from within the parliamentary precincts and may consider it appropriate to take legal advice on this matter. Privilege against defamation does not apply to the publication by witnesses, outside of the proceedings held by the committee, of any matters arising from the proceedings.
The committee will hear from officials from the Veterinary Council of Ireland and Veterinary Ireland. I ask the Veterinary Council of Ireland, followed by Veterinary Ireland, to introduce their officials.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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The witnesses circulated their statements earlier. I will allow two minutes for them to give a brief synopsis of their opening statements before we move to our questions and answers session. We will start with the Veterinary Council of Ireland.
Ms Niamh Muldoon:
As I referenced, we are the independent statutory body tasked with regulating the veterinary professions. We operate registers for 3,600 veterinary practitioners and 1,250 veterinary nurses, and oversee 775 veterinary practice premises. We act in the public interest and in the interests of animal health and welfare and public health.
Our main and most relevant purpose before the committee today is to deal with our code of conduct. It is a code of professional conduct that is binding on all vet nurses and vets, in particular, in the context of the privilege of prescribing veterinary medicines.
Mr. Finbarr Murphy:
Veterinary Ireland is the representative body for the veterinary profession in Ireland. Private veterinary practitioners, PVPs, are the gatekeepers of animal health and welfare and serve as a key pillar of support to the Irish agrifood industry. More pertinently, PVPs act as the gatekeepers in the supply of POMs. This is an important role in ensuring that medicines, and in particular antimicrobial medicines, get to the right animal with the right diagnosis and for the right duration. The prudent prescribing of antimicrobials is essential to ensure that the food we produce is safe and nutritious and that we achieve our goals and commitments to addressing the growing human health threat that is antimicrobial resistance. The threat of antiparasitic resistance was also acknowledged, as all vets have seen the outcomes on farms where this is an issue.
The client-patient practice relationship, CPPR, has been defined as the relationship between animal owners and their vet or veterinary practice of choice by the Veterinary Council of Ireland. The CPPR puts obligations on the vet and veterinary practice, which protects the level of service that is offered to the public. A CPPR is a very personal relationship built over years and, in many cases, generations. It is the cornerstone of the veterinary service to which our clients have become accustomed and value.
PVPs are obliged to provide 24-hour care to animals under their care. Irrespective of the animals' owners declaring they do not want such care, the obligation is there. The provision of 24-hour care is a significant burden on veterinary practices, as it is expensive to provide and loss making, interferes with the work-life balance of vets and their families, places vets in potential contravention of the working time directive, and makes recruitment and retention of vets in large animal practice more difficult.
There has been much debate about availability of vets to deliver services on farms and the need to train more vets. As detailed in our submission, the number of vets registered in Ireland is steadily rising while the number of veterinary practices delivering farm animal veterinary care is steadily decreasing.
Eileen Lynch (Fine Gael)
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I thank the representatives of Veterinary Ireland and the Veterinary Council of Ireland for being with us and for their comprehensive reports. As the witnesses are aware, we have heard from the Department and the merchants association. The arguments they put forward related to the monopoly in the provision of animal health services that has occurred as the result of the statutory instrument. They gave the good example of what had happened in respect of the provision of dry cow tubes. Some 2% are now provided by co-operatives and chemists as opposed to directly from vet practices. What is our witnesses' argument on that point? It seems to me that it is anti-competitive. I appreciate it should not be. On the figures, it appears that is how the situation has worked out up to now. There appear to be valid concerns.
Mr. Conor Geraghty:
I will answer that question. The prescribing of dry cow tubes by co-operatives was under a provision called Schedule 8, which was introduced in 2007. That Schedule was a last-minute intervention by the Minister at the time to allow co-operative vets to prescribe tubes that, if prescribed in the same manner by an ordinary vet, would be prosecutable. It was very anti-competitive against the ordinary practising vet. With the new regulation, there was a ban on prophylactic use. For years, dry cow tubes were prescribed and advised by all the people in the know for use in blanket dry cow therapy on all cows to reduce their cell counts. That was what we were told when we were in college and it was only later, with the ability to do individual SEC counts, milk recordings, etc., that we could get away with treating animals with an active infection. Since 2021, there has been an obligation. Rather than just writing a prescription for a herd like we once did, we have to identify each cow that requires an antibiotic and not prescribe for the ones that do not require one. That is a big change that requires a lot of veterinary input.
Animal Health Ireland, AHI, has come forward with a dry cow consult to aid farmers in this regard. The vet will be paid to go onto a farm and go through those data. By extension, what we have seen is that vets are on farms for two or two and a half hours doing these dry cow consults. They are prescribing the tubes that are required, usually for a percentage of the herd. Those prescriptions may then be filled by the vet or the merchants. The merchants did not lose their share. The co-operatives did not have the number of vets needed to provide the service we are talking about. They were just signing prescriptions and selling stuff over the counter. That is from a bygone time.
It did not surprise us that, when Schedule 8 ended, this situation ended. At the same time, though, there has been a reduction in the number of tubes being prescribed. Farmers are better off because they have bought fewer tubes.
Eileen Lynch (Fine Gael)
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May I come in there? In the time that this has changed, the use of these products has remained constant, has it not?
Eileen Lynch (Fine Gael)
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The whole point was that a farmer would have a vet on site on the farm saying that cows A, B and C required dry cow tubes. It was meant to reduce their use-----
Eileen Lynch (Fine Gael)
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-----because it would be more targeted.
Eileen Lynch (Fine Gael)
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Where are those statistics? Is that proven?
Mr. Conor Geraghty:
We have it here. Two different values are being bandied around. There has been a fair bit of oddball information today. There is value. The data company that collects this data will do so in two separate formats. It will collect the data by the list price that is charged by the wholesalers to whoever buys it. The company will also detail it by pack size or the number of packs. If we just use the list price version, there has been a serious amount of inflation in the cost of everything since 2021, as the Senator is aware. Inflation in respect of dry cow tubes has been at 6%, 8% and 14% in the past three years. If we factor all of that in, we are at -22% by value compared with 2021.
It is approximately the same with pack sizes; I think it is down by 19%. Therefore, there was a drop in 2022, a further drop in 2023 and last year it was a little bit more because selective dry-cow therapy has resulted in an anomaly whereby some of the old bacteria are beginning to make a comeback meaning that more cows needed to be treated in 2024.
Eileen Lynch (Fine Gael)
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Does Mr. Geraghty believe that the NVPS will realistically be able to work? I appreciate that it has only been mandatory since the start of the year. Given the volume it will need to deal with and the uptake up to this point, does he believe it is really viable from an efficiency point of view?
Mr. Conor Geraghty:
I hope it will work because we have spent a lot of money on it. Ultimately, we are using the system. The system is working and is collecting the data. We would have much preferred if the Department collected from the farmers as was designed in the regulation. It was foisted on us. There is considerable extra work involved in it. The NVPS allows for real time prescribing which we were using anyway before that, but it needed to be integrated into the Department's system.
William Aird (Laois, Fine Gael)
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How does the VMPMFFR Act 2023 affect the responsibilities and compliance requirements of veterinary professionals and animal health practitioners?
Mr. Conor Geraghty:
It affects us in a number of ways. First, we have more responsibility with prescribing dry-cow tubes. We will have more responsibility with prescribing antiparasitics when that comes in because they will no longer be available through licensed merchants and will need to be prescribed. Under the NVPS, we will have to collect the data and supply it.
William Aird (Laois, Fine Gael)
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The clock has gone down. Can you keep an eye on the clock. Is it on there? It is very hard to monitor it.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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Drive on.
William Aird (Laois, Fine Gael)
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What are the implications of the Act for farmers and agricultural production in terms of excess medicated feed?
William Aird (Laois, Fine Gael)
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Mr. Geraghty cannot answer it.
How does the regulation impact pharmaceutical companies and manufacturers of veterinary medical products and fertilisers?
William Aird (Laois, Fine Gael)
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There is no one to answer those questions; that is grand.
What safeguards or provisions are in place to protect public health, animal welfare and environmental sustainability under the new regulations?
William Aird (Laois, Fine Gael)
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What supports or transitional measures are provided for smaller stakeholders, for example small-scale farmers or feed producers, to adapt to the new regulatory requirements?
Mr. Conor Geraghty:
I do not know about feed producers. However, small farmers have access to the targeted advisory service on animal health, TASAH. They have access to three hours of veterinary advice to do with parasites in particular. From that, they can have a parasite-control plan for their farm which should sort out their issues and costs.
William Aird (Laois, Fine Gael)
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Will we have this advice on every farm by a veterinary surgeon?
William Aird (Laois, Fine Gael)
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How will the 30,000 be picked?
William Aird (Laois, Fine Gael)
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If it is oversubscribed, what happens?
William Aird (Laois, Fine Gael)
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If it is closed and the farmer is not in it, what happens? Will he ring the vet and the vet will tell him it will cost €200 to do that?
William Aird (Laois, Fine Gael)
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What does Mr. Geraghty mean by "with their own vet"? I have a vet who comes to my yard. I know all about the dry-cow tube thing. It is possible to get samples through Tirlán or whoever supplies them and we are able to have selected therapy. I know all that. We are doing all that. We do not need people like Mr. Geraghty coming in here to tell us that.
I am concerned about the ordinary tube for a cow that gets mastitis. Every time a cow gets mastitis, which I know all about bringing in the cows in the morning or the evening, do I need to ring my vet because I will only be given four tubes? I ask Mr. Geraghty to answer yes or no to those questions.
William Aird (Laois, Fine Gael)
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What is the allowance? Mr. Geraghty needs to be quick because my time is going and I have loads of questions.
William Aird (Laois, Fine Gael)
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The vet does not have to go to the farm every time.
William Aird (Laois, Fine Gael)
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All right.
The IBRs and Bovipast that I have been used to giving my calves will be gone. Who will have to determine that? Do I just ring the vet or do I do a dung sample and send it off and it will come back through Veterinary Ireland to tell me?
William Aird (Laois, Fine Gael)
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I can still get them from the place to where I always got them.
Mr. Conor Geraghty:
Bovipast is a particular licensed vaccine available in all outlets for sale over the counter. As IBR is POME, a farmer needs to buy that from a vet or a pharmacist. It is the same as it always was; it has not changed. Once the Minister decides, which is due to happen in September, the antiparasitics will require a prescription. That is new.
William Aird (Laois, Fine Gael)
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I ask Mr. Geraghty to give an example.
William Aird (Laois, Fine Gael)
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So, the Ivomecs of this world, the white doses and liquid doses all need them.
William Aird (Laois, Fine Gael)
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When we want that, we ring the vet. Can the vet then say he will provide the Ivomec? Does he need to come out and look at the animals or what is going on?
William Aird (Laois, Fine Gael)
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What does Mr. Geraghty and his colleagues want?
William Aird (Laois, Fine Gael)
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What is other proper-----
William Aird (Laois, Fine Gael)
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I am entitled to try to establish this. I am a member of the Oireachtas committee. At the moment, I can ring my vet and ask the question. If I ring my vet on this, will I be charged every time? Is there a call-out charge?
William Aird (Laois, Fine Gael)
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Listen to this one, everybody.
William Aird (Laois, Fine Gael)
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What is it?
William Aird (Laois, Fine Gael)
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What is Mr. Geraghty's lead on it? Will he be telling his veterinary union that they will need to charge?
William Aird (Laois, Fine Gael)
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I would feel embarrassed every time ringing my vet who is very busy asking what I would call funny questions about things where I know what to do. That is my last question to Mr. Geraghty.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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A vótáil has been called in the Dáil. I propose to ask a Senator to take the Chair so that the committee can continue.
Paul Lawless (Mayo, Aontú)
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May I return to the meeting in a few moments?
Aindrias Moynihan (Cork North-West, Fianna Fail)
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The Deputy may ask a few questions quickly.
Paul Lawless (Mayo, Aontú)
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Do we have time?
Aindrias Moynihan (Cork North-West, Fianna Fail)
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We do because the Senators will be able to continue.
Paul Lawless (Mayo, Aontú)
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I thank the representatives from the Veterinary Council of Ireland and Veterinary Ireland for appearing before the committee. They are probably getting a sense that there is a concern here. We need to ensure that we address the issues in terms of the spread and so on. However, a monopoly will potentially arise. I understand that Dr. Caroline Garvan earlier advised that there were 85,000 prescriptions and only 87 of them were ultimately sold by merchants, which is 0.1%. With this increased level of work, do vets, particularly in rural areas, have the capacity to administer this? If these trends are consistent, it will create a huge workload.
Ms Niamh Muldoon:
"Yes" is the short answer. We have capacity within the veterinary profession in the country. Every farm and every animal currently benefit from the superb service and expertise our veterinary profession provides. I fully understand the concern because this is a very significant change. On the reference to the levels of prescription on the NVPS, it is important to understand the context. The requirement for prescription for antiparasitic products does not become live until September. No antiparasitic products currently require a veterinary prescription. They are currently available over the counter from licensed merchants, from pharmacists and from veterinary practices.
That change will come in September, when SI 462 of 2024 becomes live.
Paul Lawless (Mayo, Aontú)
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I am sorry to interrupt Ms Muldoon. I appreciate her answer. Is there any possibility within the TASAH scheme whereby farmers could receive their prescriptions for non-therapeutic medicines? In this way, it may reduce the additional cost. This will bring a cost to farmers; there is no question about that. Is there a possibility? Is that being considered? It may be a question for the Department. Could it happen within those TASAH consultations that the prescription for non-therapeutic medicines could be provided at that stage?
Ms Niamh Muldoon:
The intention is that the TASAH will offer an holistic care piece with regard to antiparasitic programme planning for a course of six months. Yes, prescriptions will be available as part of that TASAH plan. That will minimise cost on the farmers and, arguably, save some costs in the longer term if there was inappropriate use previously.
Paul Daly (Fianna Fail)
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We have seen all the shenanigans going on while that was happening. There has been a vote called in the Dáil. It is actually a voting block. It will go on for a while, so we decided that, rather than the witnesses sitting around and waiting, given it is only Senator Brady and me left, we do not vote in that, and all the TDs have finished their questions, I would take the Chair, Senator Brady and I will ask a few questions, and then the witnesses can go home and not be hanging around until that is all over.
Paraic Brady (Fine Gael)
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We have a lot of time now to discuss.
Paul Daly (Fianna Fail)
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You will get me in trouble with everyone else. You get five minutes, same as everyone else.
Paraic Brady (Fine Gael)
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Two of the TDs gave me their time, so we have lots of time to go through this.
Paul Daly (Fianna Fail)
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Willie Aird will come back if I give you more than five minutes.
Paraic Brady (Fine Gael)
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As I said when the Department was here, we have bandied the word “simplification” around. When it comes to prescriptions and dealing with the farming groups, and I speak personally on this, every farmer knows they have overused prescriptions. I can and will accept that. I was probably one of them myself. The reality is most of us are doing faecal samples in our herds. Our vets are on call 24-7. In fairness to the vets in Longford, I have to compliment them. There is always a vet there when you need one. Whether it is your vet or a different one, there is always a vet, and that has to be acknowledged. I have to be clear. My point for this whole thing is there has been an overuse. I will admit to that. However, when we go back to faecal samples and what can be sold per licence or what cannot be sold for merchants or in the veterinary practice, will Mr. Geraghty not accept that the vet’s place is on the ground, treating animals? We are currently overburdened in the veterinary practice where we have a spike in TB. The vets are on-call 24-7. The vets in the sector are overburdened. It was said there are 3,600 vets in the whole of Ireland. It was admitted there is an intention for that to increase in time and that there is a shortfall. This is a question. We have seen that 54% of the practices are using the Department daily. The reality is the other 46% are not using it. Whether we like it or not, they are overburdened with work now – 73% or 74% was mentioned. Does Mr. Geraghty envisage that we will get to a point where up to 80% or 90% of veterinary practices will use the Department?
Mr. Conor Geraghty:
There are 3,600 vets on the register. Some 90% of the large animal work, according to the Department, is done by about 600 or 650 vets. The rest of those vets are in various other sectors. We have lost 22% of large animal practices already. As people are aware, practices come in and, the next thing is, farmers get letters saying those practices are not doing large animals anymore, that they have sold or whatever. This is an issue and it has been debated here. We have looked at new veterinary schools and all the rest of it. However, ten new veterinary schools will not solve the problem if only 9% to 11% of what comes out of those veterinary schools are attracted into farm animal veterinary because 9% to 11% retire anyway - or maybe more. That is the first thing.
The second question is a chicken and egg thing. If you give them less work to do, will you have more vets or fewer vets? We contend that, with what is currently happening, we will have less vets because, basically, we have been squeezed on all sides. It is a very seasonal thing in Ireland, not like the rest of Europe. We need a pile of vets at a certain time of the year, or maybe two peaks in the year. The rest of the year, vets are looking at us, wondering what they are going to do. Like it or not, we have an awful lot more lax regulation on medicines and vaccines in Ireland than in much of Europe. We talk about the separation of supply and prescription. In much of Europe, such as in Belgium, France and Holland - our major competitors - only a vet can give a vaccine to the animal. Our regulation is much more lax. That is probably because if you look at what is required on a vaccine, many things can go wrong, whether it is self-injection, mutations, adverse effects if you give it to an animal with a temperature, etc. Getting back to our current problem, we have a situation where there are approximately 499-odd practices, according to the Department, that want an NVPS. We looked at the Veterinary Council figures and thought it was around 434. If we are losing 22% of them, we are under pressure. We had to take on the NVPS, which is more or less done. There are four suppliers of IT software into veterinary practices. There are two main ones. Both of them have two software engineers each. They have to go to a veterinary practice and spend two or three days there setting it up. They are making their way around the country. They have done well in four months to get it up to 81%. I was listening in on the committee meeting two weeks ago on the ACRES IT system. To be fair, we think they have done very well, especially during the busiest time of the year, when no one wants to see software engineers in the middle of a veterinary practice.
Paul Daly (Fianna Fail)
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First, to put on the record, I am a client of Slieve Bloom Veterinary. It probably says a lot about the farmer-vet relationship that this is the first time I have met Mr. Lynch. While his staff, in fairness, have been superb on my partner's farm at home, he and I have not met. We are all talking about the farmer-vet relationship. It a different world we are in, how we are farming, and the practices and the number of staff they have. They provide a fantastic service. I cannot fault it.
From there, I will ask a hypothetical question of both parties. There is a stand-off, let us say, or not a stand-off as such but a problem with this statutory instrument. We heard the merchants. We have to be sympathetic. If half of what they are saying is true, they are gone. What do the witnesses' see as the middle-ground solution? One has to be happy with the way it is, but we all have to compromise in situations like this. Could they see a change to the statutory instrument that might leave everybody happy?
I feel I am obliged to say this. Mr. Geraghty made a statement about co-op vets prescribing. He said what they were doing was prosecutable.
Paul Daly (Fianna Fail)
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But that means it must be prosecutable if they were doing it.
Paul Daly (Fianna Fail)
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That is an accusation that they were doing it.
Paul Daly (Fianna Fail)
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Mr. Geraghty needs to explain that because I picked that up and I do not want-----
Mr. Conor Geraghty:
If a private veterinary practitioner prescribed antibiotics under the previous regulations from 2007 to 2022 without having visited the farm or having a relationship, it would be an offence. Vets were prosecuted and struck off from the Veterinary Council, one in the Cathaoirleach's neck of the woods, as far as I know.
Paul Daly (Fianna Fail)
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But they were prescribing it without visiting the farm. Is that what Mr. Geraghty is saying?
Paul Daly (Fianna Fail)
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It is important Mr. Geraghty clarifies what he said because it came across-----
Mr. Conor Geraghty:
It has been a bone of contention for private vets for a long time. Under Schedule 8, there was no requirement to visit the farm, and I am sure the Department can confirm that. Regarding PVP, at the time, it was not called client-patient-practice relationship. It was a bona fide vet relationship at the time in the legislation. The minimum requirement was a visit once a year to the farm.
That was the minimum. There needed to be a real and demonstrable relationship. There are cases where prosecutions were taken, suspended sentences were handed out and people were fined up to €40,000 and were struck off the Veterinary Council for doing what a co-op-led operation could do, which was legal under the Act because it had a special clause.
Ms Niamh Muldoon:
In 2025, in terms of the regulation of medicines, we are a world away from where we were in 2007. As of Regulation (EU) 2019/6 and reflected in the Veterinary Council code of conduct binding on every vet, there is a very strict requirement in terms of the obligations around prudence when it comes to prescribing anti-microbial medicines. This is because we know about the interconnectivity between animal, human and environmental health. There has been a 24% reduction in the use of anti-microbials across animal health in the past four years. In part, this is directly attributable to Regulation (EU) 2019/6 and the binding code of conduct of the Veterinary Council. There are very strict mandatory requirements when a vet comes to discharge the privilege of prescribing an anti-microbial. The world has changed a lot since 2007. It is a different world. There is a full appreciation of the importance of anti-microbial resistance and the detrimental impact of that across all health spheres. It is listed as one of the top ten challenges for the western world by the World Health Organization and there are very strict requirements under the Veterinary Council code of conduct regarding prescribing anti-microbials.
Paul Daly (Fianna Fail)
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Will the witnesses comment on the regulation of the statutory instrument?
Mr. Conor Geraghty:
Looking at the structure of veterinary practice, probably only one third or one quarter of veterinary practices actually retail this stuff. The rest of them are not doing it. There is every opportunity, using the national veterinary prescription system, NVPS, or this protocol, for merchants to develop a relationship with their local vet for farmers. My farmers are going in and out. When I go down to the merchants, my farmers are at the counter. They ask if that is what they need for their cattle. I talk them through it at the counter and they buy it off the merchant. There is no problem. My local merchant lives two doors down the road from me. This is the way local community-based businesses work. It is a matter of stopping all this rhetoric. It is down to local people getting on with local people in local communities and working it out.
Paul Daly (Fianna Fail)
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Will Mr. Geraghty comment on what was said about the 85 out of 85,000 prescriptions getting back to the merchant?
Mr. Conor Geraghty:
All the prescriptions that are up there are for what we use during the spring. They are all antibiotics. The Department said that. If I were to go out to the Acting Chair's farm at 12 a.m. and say the cow is X, give him a prescription that he could get the next day in the pharmacy and which he would inject the cow with for the next three days, he would not be impressed. That is not the way it works. When the products the farmers want to buy in the merchants become on prescription, then come back and tell us the percentages, but at the moment, this is stuff they expect to you to have injected into the vein and leave them to tomorrow or the next day.
Eileen Lynch (Fine Gael)
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My query was passed on to me by Deputy Newsome Drennan, who asked me to raise it on her behalf. We have been discussing the impact, both now and in the future, of the prescription of antiparasitic products. Is there a cap on the number of wormers one can have on a farm? Is there a proposal that it would be capped in terms of what is in the SI in that regard?
Mr. Conor Geraghty:
To my knowledge, there is no cap. You have to justify what you prescribe regardless of what the product is. Someone would have to justify it to either the Department or the Veterinary Council why they prescribed way in excess of what was needed at the time. The prescription length for antiparasitics is six months, so someone could prescribe what he or she believes is needed for six months and it can be filled at any time. It does not need to be filled in one go but can be filled as required if it is required. Perhaps the witnesses from the Veterinary Council would like to comment on the other questions because there is an element of justification and what justifies using and prescribing.
Ms Niamh Muldoon:
Our code of conduct carries very strict requirements on when a vet comes to discharge the privilege. Every prescription has to be justified and reasoned. If it is for more than an individual animal, all those clinical notes have to be recorded so that, at any stage, that independent discretion and objective decision-making being applied by the vet is reasoned and rationalised within his or her notes.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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I have a few questions. It seems as though 100% of vets are not using the online system. Why is this case?
Aindrias Moynihan (Cork North-West, Fianna Fail)
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This did not appear out of nowhere. This would have been a planned-----
Aindrias Moynihan (Cork North-West, Fianna Fail)
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When will we have 100% of people using the system?
Mr. Conor Geraghty:
The Department was encouraging people to use it up to now and will use the summer to make sure the rest of them are using it. It has set a date for September. We are happy enough that, by September, with the quiet time in the summer, it should be achievable, but as with anything, there are people who will have to be brought over the line instead being coaxed over it.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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Earlier witnesses referred to seasonality, how there is different demand for different types of medication at different times of the year and said they would have expected a lot more of the veterinary rather than the merchants at this point. At what point would Mr. Geraghty expect to see the medications the merchants would be using ramping up?
Aindrias Moynihan (Cork North-West, Fianna Fail)
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Will there be a dramatic increase from September? If there is seasonality to it-----
Mr. Conor Geraghty:
According to the merchants, and we met them last year, there are 100 veterinary practices out of that number that are actively selling antiparasitics. A lot of small practices do not bother with this. This is a lot of hassle for small practices as it involves carrying a range of products, keeping them in date, etc.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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When one sees that figure of 85 out of 85,000-----
Aindrias Moynihan (Cork North-West, Fianna Fail)
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-----it looks very unbalanced.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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At some point, you would expect to see a dramatic increase or a levelling out of that. Will Mr. Geraghty give us an indication of the timeline?
Mr. Conor Geraghty:
There will never be a levelling out because all the antibiotics are supplied and prescribed by vets. A person cannot go into a merchant, regardless of whether he or she has a prescription, and buy a bottle of injectable antibiotic. It is not allowed. Farmers can go to a pharmacy but farmers want their animal treated. They do not want to call you, pay you, get a prescription, get cleaned up, go into town to some pharmacy to get the medication, come back and start treatment. When they call the vet, they expect the vet to treat the animal if the animal is sick. Once antiparasitics become prescription, we envisage that farmers will need a prescription to fulfil it. All the IT systems are provided for farmers to fulfil that wherever they normally fill it. The Minister has provided a TASAH, which basically pays the vet to give the advice so they can get the prescription. There is not one for everyone in the audience, but if there is oversubscription, the Minister might provide more. Then we have the situation-----
Aindrias Moynihan (Cork North-West, Fianna Fail)
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Is it envisaged that there would be a nominal charge or any charge on prescribing? Have there been conversations on that?
Mr. Conor Geraghty:
The prescription is the outcome of this service that is provided where you have to gather the data and make a justification.
Whatever the service is, it is going to have to be paid for. If the farmer is not going to use TASAH to pay the vet, someone is going to have to pay the vet. We have to work this out. It will have to be worked out with merchants, vets and farmers and it will all be different. Obviously we cannot decide. Every vet will have his or her own local or individual arrangements with farmers and that is probably where this needs to move now. I cannot see any further loosening of the regulation. The protocol that the Minister put into it has loosened it up such that the CPPR basically only starts once the prescription is written.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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I have one final question. What is the expectation with regard to the September date?
Aindrias Moynihan (Cork North-West, Fianna Fail)
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If there was one important step to be taken between now and September, what would it be?
Aindrias Moynihan (Cork North-West, Fianna Fail)
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Would Mr. Geraghty agree that some people may feel that might be a bit anti-competitive?
Ms Niamh Muldoon:
Can I just make one comment? The Health Products Regulatory Authority, HPRA, initially issued a report recommending that these products would require a veterinary prescription in December 2019, which is a significant period of time. Ultimately, it is important for animal and human health and for everyone's benefit that this increased regulation takes place.
Aindrias Moynihan (Cork North-West, Fianna Fail)
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Ar son an choiste, ba mhaith liom mo bhuíochas a ghabháil libh go léir. On behalf of the committee I thank the witnesses for their contributions.