Memorandum submitted by the Animal Health
Distributors Association (UK) Ltd (Vet 35)
AHDA is responding to the invitation to make
a submission on the need to replace the Veterinary Surgeons Act
1966. AHDA represents businesses registered to sell and supply
POM-VPS and NFA-VPS medicines under the current Veterinary Medicines
Regulations to farmers and other animal owners. The sale of all
these medicines must be specifically authorised by an AMTRA (Animal
Medicines Training Regulatory Authority) SQP (Suitably Qualified
Person), and no business may be registered to handle POM-VPS and
NFA-VPS medicines unless the sale is supervised by an AMTRA qualified
SQP. You will undoubtedly hear from AMTRA concerning the massive
investment currently in hand to upgrade all SQPs to an elevated
training requirement supported by the taking and passing of an
exam recognised by the Secretary of State. This investment, costing
our businesses an estimated £1 million is to enable an SQP
to both prescribe, advise and supervise the sale of POM-VPS and
NFA-VPS medicines, whereas, up to 2005 only Veterinary Surgeons
could prescribe.
Bearing this in mind, and with the support of
the changes to the regulations currently in hand to be fully implemented
by VMD in September 2008, and that many medicines are undergoing
a re-classification review by VPC into POM-VPS and NFA-VPS, AHDA
submits the following representations:
1. Under the definition of "veterinary
surgery" it is not the exclusive right of only veterinary
surgeons to make a diagnosis on animals, under the existing act
farmers are permitted to perform a diagnosis on their animals,
this needs to remain in place.
2. Our businesses can only advise and prescribe
medicines by using SQPs for POM-VPS and NFA-VPS medicines. Hence
any changes to the Act need to retain the right of our staff to
advise and prescribe all medicines that are not registered as
POM-V.
3. The use of faecal egg counts to determine
the appropriate anthelmintics in the VPS category should not be
restricted solely to veterinary surgeons. Our SQPs are trained
and qualified to advise in the area which is heavily geared to
medicines in the POM-VPS and NFA-VPS areas. Interpretation of
results from an approved veterinary laboratory is normal practice
for SQPs
As regards the proposals from The Royal College
of Veterinary Surgeons outlined in the invitation for submissions
document, AHDA has nothing to add except to point out that under
the new DEFRA Code of Practice for SQPs issued under the Veterinary
Medicines Regulations, CPD (Continuous Professional Development)
is a legal requirement and that the AMTRA Code of Practice goes
further by insisting that SQPs must undertake CPD to remain on
the register on an annual basis.
AHDA requests to be kept fully informed of the
progress of this review and undertakes a willingness to assist
in clarification of any of our submissions.
September 2007
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