From Dr R. R. Dawson
SIR,-I refer to the letter from Brian Spencer (PJ, July 1, p13), in which he refers to earlier published letters from David Evans and Andrew Cairns. I note that Brian Spencer complains that neither the National Office for Animal Health nor a manufacturer responded to those letters.
Although not NOAH or a manufacturer, I did respond indirectly, since it was Andrew Cairns's letter in your journal that caused me to make a comment in a column in my own members' circular.
Part of the circular discussed the current European Union review of animal medicine legislation, known as Review 2000. I then went on:
"In the above discussion of the EU review the preferred classification has been referred to as a 3-tier system. Throughout the last decade of intense representations on this issue, the argument has been about whether the EU goes for a 2-tier system as in Germany and many other member states - POM and GSL in UK terms - or whether it goes for a 3-tier system - POM, PML and GSL in UK terms.
"We have been justified in referring to the UK system as a 3-tier system, because there are so few P products as to make them largely irrelevant to the central argument. What AHDA has sought is a middle tier of animal medicines whose distribution is controlled, which are supplied from registered premises and authorised by qualified persons. As far as AHDA is concerned, PML medicines - pharmacy and merchants list medicines - can be supplied by registered agricultural merchants and pharmacies alike (although relatively few are supplied from pharmacies since most pharmacists involved in animal medicine distribution do so from registered agricultural merchants premises, not pharmacies), and all agricultural merchants permitted to sell PML medicines are registered with and inspected by the Royal Pharmaceutical Society. As they are termed pharmacy and merchants list medicines, and form the middle tier there is no need for a separate Pharmacy or P category of animal medicines. We are having enough trouble trying to persuade the EU to adopt three tiers - we would never succeed in persuading them to adopt four tiers!
"Therefore, it is of concern that the Veterinary Pharmacists Group (the old Agricultural and Veterinary Pharmacists Group) of pharmacists is calling publicly (PJ, May 20, p770) for more animal medicines to be classified P on the back of the government's review into the dispensing of veterinary medicines by veterinarians. It appears that this review is seen as an opportunity to try to increase the number and type of animal medicines available to be supplied by the pharmacy - but not the registered agricultural merchant.
"In my view, calls for more P medicines are counter-productive to the interests of both agricultural merchants and pharmacies who wish to continue to have a viable middle tier of controlled non-prescription animal medicines to sell to animal owners. Those who would rather see just two tiers, as in Germany, will be delighted at this attempt to fragment the middle tier, and may well use it to undermine what should be the common objective of AMTRA-qualified agricultural merchants and pharmacists - to secure the continued availability of a wide (and expanding) range of non-prescription animal medicines. This will not be achieved if the united representations of the last dozen years to promote the PML sector and see those medicines which need not be POM become PML, is fragmented by calls for some to become P instead. Let us reunite behind a three-tier structure; united we are strong; if we are divided we all will suffer."
Roger R. Dawson
Secretary General, Animal Health Distributors Association (UK) Ltd, Woodbridge, Suffolk