DEAR SIR: In your editorial of 6 March, you deal with the matter of anti-parasitic veterinary medicines in animal production.
While the article serves to contribute to the conversation around the use of anti-parasitic medicines, the development of resistance and supply channels, unfortunately the article contains a number of inaccuracies.
Firstly, the introduction of new veterinary medicines regulations which will be brought into effect next January is not the reason for, nor the cause of the change in designation of anti-parasitic medicines as prescription only medicines (POM).
This is a critical point that some commentators overlook or fail to recognise.
The change in designation arises from a Health Product Regulatory Authority (HPRA) expert taskforce in 2019 concluding that the available scientific evidence shows that anti-parasitic veterinary medicines that are intended for use in food-producing species do not comply with the criteria for derogation from veterinary prescription specified in existing EU law and carried forward in Regulation 2019/6.
The report is freely available on the HPRA website and was subject to extensive stakeholder consultation. The scientific evidence that resistance is present in food-producing animals is compelling and stark.
The HPRA is the independent, competent authority for the authorisation of veterinary medicines in Ireland.
The new regulations to be introduced next January are simply coincidental in that they provide an opportunity to provide legal clarity regarding the derogation – this could equally be done immediately under existing regulations.
The new regulations, however, are critical in other areas relating to veterinary medicines in as much they focus on important issues such as targeted antibiotic usage, recording of usage, record keeping, etc.
These continue to be subject to extensive stakeholder consultation.
Secondly, the article asserts on two occasions that the removal of the derogation is “blaming farmers” for the development of resistance. From the Department’s perspective, I can categorically state that nothing could be further from the truth. The fact is that farmers and their animals are the ones that immediately lose out when resistance develops.
The policy objective of the Department is to put in place a regulatory system that best supports farmers in optimising herd health. This is supported by prudent and appropriate use of veterinary medicines, whenever they are necessary and how they are used.
In this regard, the Department has been engaging with all stakeholders through an Anti-parasitic Resistance Stakeholder Group. The group has a comprehensive work programme containing over 30 actions that aim to assist farmers, retailers, farm advisers, pharmacists and veterinarians in how we can manage parasite control as effectively as possible. Some actions will continue in the longer-term, while others are more focused and short-term, designed to assist the Department in strategic policy decisions.
Over the past number of months, while advancing these actions, the Department officials have been listening to the views and concerns of all these stakeholders and it is through engagement in this forum the Department will shortly conclude on certain strategic policy matters.