Relevant Matter
Legislation
Public Policy Area
Agriculture
Period
1 Jan, 2023 to 30 Apr, 2023
Specific Details
Veterinary Medicinal Products, Medicated Feed and Fertilisers Regulation Bill 2023
Intended results
IFA highlight the detail of the IFA Submission on Veterinary Medicinal Products, Medicated Feed and Fertilisers Regulation Bill 2023
IFA identified key areas of concern for Irish farmers throughout the drafting stages of the EU Veterinary Medicine Regulation, which included in particular the prescribing process and categorisation of veterinary medicinal products. The changes sought by IFA were not provided by the Department of Agriculture in the final draft of the EU Regulation and as a result these issues must now be addressed in this Bill.
The substantive point raised related to the categorisation of Antiparasitic Products and as result brought into focus the prescribing process for these products. The current draft of the Bill facilitates only registered veterinary practitioners in prescribing antiparasitic products.
- This approach removes competition from the supply chain for farmers and critically removes a significant stakeholder from proactively supporting National efforts to promote better and more targeted usage of antiparasitic products. The demise of licensed merchant stores and veterinary pharmacies that will occur as a result will have an even more profound impact on the rural communities and the farmer's they serve due to the loss of economic activity in these regions.
There will be a two-tier system created by this Bill in its current format on the island of Ireland in relation to sourcing antiparasitic products, placing Irish farmers at a competitive disadvantage while creating strong incentives for illegal trade in these products.
The Bill must facilitate prescribing for antiparasitic products by Qualified Persons. This can be achieved by recognising the procedures currently in place where Responsible Persons have fulfilled this function in National Law since 2007 under accreditation from the Department of Agriculture which meets the criteria set out in the EU Veterinary Medicines Regulation.
- The opportunity to provide this is also attainable under the context of uniformity of approach on the island of Ireland for animal health and welfare measures.
The proposal for all veterinary medicine prescriptions to be issued on line through the NVPS raises significant farmer concerns in relation to the level and type of data that will be stored relating to each individual farm and the accessibility of that data by DAFM and others.
- This information is private farmer data and the Bill cannot seek to compile and use this information in a format that provides ease of access to individual identifiable farmer medicine usage information in a more detailed or comprehensive way than is already available. This has the potential to be used by DAFM and industry to categorise farms and/or animals for potential inspections and/or price penalties on animals or produce from farms.
The sanctions for non-compliance with measures in this Bill must be proportionate and farmers cannot be accountable for or sanctioned where prescribers or suppliers of veterinary medicines have failed to comply with their obligations in this area.
Farmers are end users and dependant on prescribers and suppliers to meet their obligations, as farmers we do not have oversight of these service providers, this is the responsibility of DAFM and therefore we cannot be liable for their failures to comply with their legal obligations.
The power provided to those charged with implementing this Bill must not extend to farmers. Farmers can only access veterinary medicines when they are prescribed by a licensed qualified person and supplied by a DAFM approved outlet. Entry by force onto farms is not acceptable and must be removed from the Bill. Entry to farms under this Bill must require a warrant and be by arrangement with the herdowner. Farms are also family homes.
Name of person primarily responsible for lobbying on this activity
TJ Maher IFA Animal Health Chair, Tomas Bourke IFA Senior Policy Executive, Anna Daly IFA Policy Executive
Did any Designated Public Official(DPO) or former Designated Public Official(DPO) carry out lobbying activities on your behalf in relation to this return? You must include yourself, and answer Yes, if you are a current DPO or a DPO at any time in the past. (What is a Designated Public Official?)
No
Did you manage or direct a grassroots campaign?
No
Was this lobbying done on behalf of a client?
No
Lobbying activity
The following activities occurred for this specific Subject Matter Area.
Informal communication (2-5)
Designated public officials lobbied
The following DPOs were lobbied during this return period on this specific Subject Matter Area. These DPOs were involved in at least one of the Lobbying Activities listed above, but not necessarily all of them.
As returns are specific to a Subject Matter Area the above Lobbying Activities may be associated with multiple returns.
Brian Leddin
TD (Dáil Éireann, the Oireachtas)
Denis O'Donovan
Senator (Seanad)
Jackie Cahill
TD (Dáil Éireann, the Oireachtas)
Joe Flaherty
TD (Dáil Éireann, the Oireachtas)
Lynn Boylan
Senator (Seanad)
Martin Browne
TD (Dáil Éireann, the Oireachtas)
Matt Carthy
TD (Dáil Éireann, the Oireachtas)
Michael Collins
TD (Dáil Éireann, the Oireachtas)
Michael Fitzmaurice
TD (Dáil Éireann, the Oireachtas)
Michael Ring
TD (Dáil Éireann, the Oireachtas)
Paul Daly
Senator (Seanad)
Paul Kehoe
TD (Dáil Éireann, the Oireachtas)
Tim Lombard
Senator (Seanad)
Victor Boyhan
Senator (Seanad)